UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION »

25 RINS1ON HOAIlKANSAS I.IIY. KANSAo i j

April 13, 1993

MEMORANDUM

SUBJECT: Request for a Removal Action at the Emory Plating Site,Des Moines, Polk County, Iowa

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FROM: Wood H. Ramsey, OSCfjl|f'FIRE/EP&R/ENSV ' CV

TO: William W. RiceActing Regional Administrator

/ .$£W Billy J.T Directo

THRU: tf Billy J. Fairless, Ph.D.Director, ENSV

CERCLIS ID#: IAD005293469SITE ID/: KD

I. PURPOSE

The purpose of this Action Memorandum is to request anddocument the approval of the proposed removal action describedherein for the Emory Plating site, 3929 East 14th Street,Des Moines, Polk County, Iowa. It is requested action be takenconcerning the site, due to the presence of uncontained wasteand residues that have high cyanide concentrations (greater than10,000 ing/Kg) .

II. SITE CONDITIONS AND BACKGROUND

A. Site Description

1. Removal Site Evaluation

The Emory Plating site is a former electroplatingfacility located at 3929 East 14th Street, Des Moines, Polk County,Iowa. The facility consisted of a single building and surroundingproperty as depicted in the attached photographs and sketch. Thefacility was acquired by the Emory Plating Company in 1976. Thebusiness and property were sold to Musser Enterprises under a salescontract for deed in 1985. Musser Enterprises, Inc., operated anelectroplating business at the site until abandoning the facility.

Musser Enterprises, Inc., failed to file an annual report with theIowa Secretary of State's office and was rendered inactive as acorporation on September 6, 1991.

The Region VII Environmental Protection Agency (EPA) conducteda Resource Conservation and Recovery Act (RCRA) inspection at thefacility in May 1990. During that inspection, a violation wasissued for failing to make a hazardous waste determination forsandblasting waste generated at the facility. In addition tothe RCRA inspection, a site reconnaissance was performed by theEmergency Planning and Response (EP&R) Branch on June 25, 1992.

During the site reconnaissance, the air quality in thebuilding was monitored using colorimetric indicator tubes forhydrogen cyanide (HCN). The first measurement was taken before thebuilding was ventilated and resulted in approximately 2 milligramsof HCN per cubic meter of air. The threshold limit value as atime-weighted average (as published by the American Conference ofGovernmental Industrial Hygienists) is 11 milligrams per cubicmeter of air. The building was then ventilated by opening twooverhead doors and subsequent measurements for HCN resulted inno detection. Additional air monitoring was performed using aradiation meter, a combustible gas indicator/oxygen meter and aflame ionization detector for total organic vapors. No significantconcentrations were found with those instruments. Following theair monitoring, a general survey of the building was made. Thebuilding had been vandalized and trash and debris were widespread.Approximately nine plating vats were observed (one with threecompartments) and several were of questionable integrity. One vatwas empty, turned on its side and appeared to be badly corroded.Several drums, mainly fiber drums (later found to be containingsolid cyanide compounds), were in poor condition. Once the surveywas complete, the site was secured by replacing the boards on thedoors and windows.

On July 13, 1992, a removal assessment was conducted atthe Emory Plating site. The initial work consisted of clearingdebris and solid waste from areas where the vats were located.Containers of what appeared to be hazardous substances weremoved and segregated in a room in the northeast corner of thebuilding (room #3). The plating vats were sampled once the areahad been cleared of debris. In addition, pH measurements andoxidation/reduction potential (ORP) measurements were made.Samples were collected for total metals and for total and amenablecyanides. Samples were also collected from the soil on all foursides of the building, from metal dust/fibers on the east side ofthe building and from uncontained materials found on the buildingfloor. After the samples were collected, most of the materials onthe floor were placed in containers along with the metal

dusts/fibers from the east side of the building. Approximately15 containers were sampled and field characterized. The fieldcharacterization tests were conducted using a pH meter andindicator paper for cyanide, oxidizers and peroxides. Three of thecontainers gave positive results for cyanide and one was labelledas zinc cyanide. Test results from other sampled containersindicated the presence of corrosive substances with pH valuesexceeding 12 or less than 3. Banner guard was fixed to theexterior of the building on three sides prior to leaving thesite to warn the public of the hazards inside the building.

Based on the site reconnaissance and available records,the problems associated with the site include open plating vatscontaining acidic solutions, open vats containing basic solutionswith cyanide, drums of solid cyanide, containers of acid solution,numerous containers of unknown materials and corrosive and cyanidebearing residues on the floor.

2. Physical Location

The facility is located in a commercial/residentialarea in north Des Moines, Iowa. The City of Des Moines has apopulation of approximately 190,000 people. Adjacent to EmoryPlating are commercial properties with at least one of theseproperties approximately 100 feet from residential property. Thereis also considerable pedestrian traffic on the site property along14th Street. At the request of the Des Moines Health Department,the Department of Public Works boarded the site to discouragetrespassing inside the building. The coordinates for the site areLatitude 41° 37' 57" North, Longitude 93° 35' 06" West.

3. Site Characteristics

The facility is no longer in operation. It wasabandoned in August 1990. The site is privately owned. Therecords at the Polk County Recorder of Deeds office listed theproperty owner as Emory Plating.

4. Release or Threatened Release Into the Environmentof a Hazardous Substance, or Pollutant orContaminant

The materials present at the Emory Plating site canbe placed in three groups; plating solutions, uncontained materialsand materials in closed containers. A complete site inventory isincluded as Attachment A.

The vats store plating solutions that are either acidicor basic. The pH of the acid solutions are as low as 0.0 usinga portable pH meter. The basic solutions were found to have apH as high as 13.4 based on meter readings in the field.

Laboratory analyses indicate high concentrations of cyanide(over 10,000 mg/L). The vats are summarized as follows:

Vat

V-l

V-2

V-3

V-4

V-5

V-6

V-7

V-8

V-9a

V-9b

V-9c

Dimension(WXLXD)

30"x60"x42"

48"x24"x36"

D=30", diam.=16"

32"x72"x42"

18"x48"x36"

35"x54"x36"

13"x20"x32"

17"x36"x30"

14"X35"X17"

14"x35"xl7"

14"x35"xl7"

Volume ofSolution200 gallons

100 gallons

10 gallons

190 gallons

90 gallons

25 gallons

20 gallons

53 gallons

40 gallons

40 gallons

40 gallons

Type of Solution

acid (chromic)

basic

acidic

basic

basicbasicacid

basic

basic

basic

basic

Results for samples collected from the vats and othermaterials present in the building are summarized as follows:

Concentration

310,000 mg/L

10.2

18.4 mg/L219 mg/L171 mg/L0.0

>10,000 mg/Kg>10,000 mg/Kg

~122,630 mg/L

SampleLocation

V-l

V-2

V-3

V-4

V-5

Media

Liquid

Liquid

Liquid

Solid

Liquid

Compound

Chromium

PH

ChromiumNickelZincPH

Cyanide (total)Cyanide (free)

P»Zinc

Sample Media Compound ConcentrationLocation

V-6 Liquid pH 2Zinc 591 mg/LCadmium 255 mg/L

V-7 Liquid Zinc 1,040 mg/LpH 0.0

V-8 Liquid pH 13.4Silver 17 mg/LAntimony 153 mg/LCyanide *

V-9a/b/c Solid pH 13Cyanide (total) 46.9 mg/LCyanide (free) 42.3 mg/L

* Actual laboratory data is not available due to an uncontrolledreaction during which the sample was lost.

Composite samples were collected from surface soil ata depth of zero to two inches, surrounding all four sides ofthe building. The results are summarized as follows:

Location Lead Concentration

North of building 912 mg/KgEast side of building 544 mg/KgSouth side of building 1750 mg/KgWest side of building 249 mg/Kg

In addition to the vats and soil, samples were collected fromuncontained materials on the floor and floor residues. The resultsgave cyanide concentrations over 10,000 mg/Kg.

Other materials present at the site include three drumscontaining solid forms of cyanide, presumably used for preparingplating solutions, several drums of corrosive solids and severaldrums of flammable liquid.

5. NPL Status

The site is not on, or proposed for, the NationalPriority List.

6. Maps, Pictures and Other Graphic Representations

Photographs and a site location map are attached.

B. Other Actions to Date

1. Previous Actions

The EPA Region VII Environmental Monitoring andCompliance Branch conducted a RCRA inspection of the facility onMay 4, 1990. During that inspection, the facility was given anotice of violation for failure to make a hazardous wastedetermination for sandblasting waste. The waste was spent shotfrom sandblasting paint and was suspected of containing lead.A site reconnaissance was also conducted on June 25, 1992, byEPA/EP&R and Technical Assistance Team (TAT) personnel.

2. Current Actions

There are no current actions at the site.

C. State and Local Authorities' Role

1. State and Local Actions to Date

The Des Moines Fire Department (DMFD) becameinvolved with Emory Plating during the course of severalinspections at the facility concerning improper storage of cyanide.At least six inspections were made from February 1987 to July 1990.After operations ceased at the site, DMFD referred the site to theIowa Department of Natural Resources (IDNR) for the removal of thematerials at the site. IDNR then referred the site to Region VIIEPA Superfund Branch.

2. Potential for Continued State/Local Response

The City of Des Moines, specifically the Health andFire Departments, have secured the building by boarding the windowsand doors. The overhead doors were secured from inside thebuilding. The city indicated repair or replacement of the boardswill be performed as needed. At EPA' s request, the Health and FireDepartments have volunteered to drive by the site. Those actionswill be performed until the removal action is started.

III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENTAND STATUTORY AND REGULATORY AUTHORITIES

The substances at the Emory Plating facility p r e s e n t asignificant threat to the public due to the open vats of thevarious plating solutions. The solutions consist of cyanide,chromium, possibly lead and corrosive liquids. The greatest threatis the presence of cyanide as uncontained waste materials and asfloor residues.

Specific information concerning exposures to some of thesubstances present at the site was obtained from DangerousProperties of Industrial Materials, N.I. Sax. 7th Edition.

Cyanide; Cyanide is extremely poisonous by all routes ofexposure. Exposure to concentrated cyanide can lead to death,although less severe symptoms are observed from chronic exposures.For the most part, death is caused by respiratory failure. Othersymptoms include salivation, nausea without vomiting, confusion,vertigo, convulsions, paralysis and cardiac arrhythmias. Cyanideis stable in basic solutions, but will generate HCN gas if the pHdrops below 7. However, carbon dioxide in air is acidic enough torelease HCN gas from cyanide solutions. Cyanide is reactive withnitrates, fluorine, magnesium and is a flammable gas as HCN.

Chromium; Chromium is a human poison by ingestion and asuspected carcinogen.

Lead; Lead is a poison by ingestion. It is also a suspectedcarcinogen of the lungs and kidneys. Systemic effects include lossof appetite, anemia, headache, irritability, muscle and jointpains, tremors, hallucinations and liver changes. Low levels oflead can impair neurotransmission and depress the immune system.Acute exposure can lead to reversible kidney damage. Chronicexposure can cause irreversible vascular sclerosis, tubular cellatrophy, interstitial fibrosis and glomular sclerosis. Highconcentrations can result in sterility, abortion and neonatalmortality and morbidity. Absorption of high levels of lead may beindicated by a dark line on gum margins referred to as the "leadline."

Acids: Hydrochloric acid is a human poison. It is mildlytoxic by inhalation, moderately toxic by ingestion and a corrosiveirritant to the skin, eyes and mucous membranes. Nitric acid isalso considered a human poison and is corrosive to eyes, skin,teeth and mucous membranes. It is also a very strong oxidizer andpresents a significant threat due to its reactive nature with awide variety of compounds, primarily in combinations with acetone.

Bases; Sodium hydroxide presents a threat due to its toxicityand reactivity. As with the acids, it is toxic by ingestion and iscorrosive to skin and mucous membranes. However, its effect onskin tissue is much more destructive than that of acids. Directcontact with sodium hydroxide can cause burns, deep ulcerations anddestroys tissue by saponification. Inhalation may lead to damageof the upper respiratory tract. It can also react violently witha wide variety of substances and is a dangerous material to handle.

The substances present at the site are hazardous substances asdefined by the Comprehensive Environmental Response, Compensationand Liability Act (CERCLA) and are RCRA hazardous wastes. Theassociated RCRA waste numbers would include: cyanide, P030;corrosivity by characteristic, D002; reactive by characteristic,D003; electroplating baths by process, F007, F008.

The site qualifies for a removal action based on the NationalOil and Hazardous Substances Pollution Contingency Plan, found inTitle 40, Code of Federal Regulations, Part 300. The facilitymeets the criteria found in 40 CFR 300.415(b)(2), due to potentialexposure to nearby human populations of the hazardous substances,hazardous substances present in bulk containers that pose a threatof release and reactive substances in close proximity toincompatible materials (the combination of which could produce heatand toxic gas).

IV. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed Actions

1. Proposed Action Description

The following tasks will be performed to remove thethreat presented by the hazardous substances at the Emory Platingsite:

a. Removal of debris and/or residual matter fromthe floor and placing it in containers. Each container will becharacterized to determine disposal status.

b. Containerize plating solutions, bulking them ifpractical. Some solutions may be treated on-site to reduceor remove cyanides and metals. The solutions will be sampledfollowing treatment to determine disposal status.

c. Disposal of contained waste. Once confirmed ashazardous, contained wastes will be disposed off-site at a RCRAauthorized disposal facility.

It is possible the trailers are on lead-contaminated soil.If the trailers are not contaminated (according to the actionlevels), the undersides will be rinsed with water and they willbe moved to a clean portion of the site while the soil at theirformer location is removed (if necessary) and backfilling iscompleted.

2. Contribution to Remedial Performance

At this time, remedial action is not contemplatedfor the Emory Plating site. All site problems/contaminationshould be addressed by the proposed removal action which wouldbe consistent with any future remedial action.

3. Description of Alternative Technologies

For the most part, cyanide laden waste is eitherchemically or thermally destroyed. Metals can be eitherrecovered or stabilized and landfilled. Alternative technologiesexist for metals, such as soil washing, but would not be costeffective for small quantities as is the case at Emory Plating.

4. Engineering Evaluation/Cost Assessment

Since this removal is time-critical, anEngineering Evaluation/Cost Assessment has not been prepared.

5. Applicable or Relevant and AppropriateRequirements (ARARs)

The following is a list of ARARS that areapplicable to the proposed action:

• Title 40, Code of Federal Regulations, Part 261-268,concerning the disposal of hazardous waste, specifically:

Part 261: Identification of Hazardous Waste;

Part 262: Standards Applicable to Generators of HazardousWaste;

Part 268: Land Disposal Restrictions.

• Title 29, Code of Federal Regulations, Part 1910.120,Hazardous Waste Operations and Emergencies;

• Title 49, Code of Federal Regulations, Parts 171-173, 177,Transportation of Hazardous Waste.

A letter has been sent to IDNR requesting state ARARs thatshould be considered for the proposed actions.

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6. Project Schedule

Cleanup activities will be initiated at the siteas soon as possible following the approval of this memorandum.

B. Estimated Costs

Extramural Costs

Regional Allowance Costs $242,000TAT Costs 55,000Contingency 45,000

Extramural Subtotal 342,000

Intramural Costs

EPA Direct 20,000EPA Indirect 32,000

Intramural Subtotal 52,000

PROJECT TOTAL $394,000

V. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BEDELAYED OR NOT TAKEN

There are several possibilities that could occur if actionis delayed or not taken. Someone could come in direct contactwith the plating solutions and/or the solutions could be combinedwith the result producing hydrogen cyanide gas. Anotherpossibility is the containers (vats) leak which could contaminatethe building and the soil around the site. Also, there is apotential for contact with lead contaminated soil.

VI. OUTSTANDING POLICY ISSUES

There are no outstanding policy issues concerning the siteor the work proposed in this Action Memorandum.

VII. ENFORCEMENT

A. Site Information

According to the Polk County Recorder of Deeds, theowner of the property is Emory Plating Company. The property isvalued at $48,300. Based on information from the Iowa Secretaryof State's office, the Emory Plating Company was incorporatedon December 28, 1967, and listed as administratively inactive onNovember 24, 1986, for failure to file an annual report. The

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officers for the corporation were listed as Kent Easterday,Richard Hansen and Gary Akes. A name change occurred on June 25,1985, with the new name being Emory Liquidation, Inc., and theregistered agent was Richard Hansen. Prior to conducting theremoval assessment, Mr. Hansen was contacted for access approval.He said the property was abandoned and the county claimed it fortaxes.

In 1985, Emory Plating Company sold the business andproperty under a sale contract for deed to Musser Enterprises,Inc., but apparently the site was never deeded over as a resultof Musser Enterprises, Inc., failure to make payment on amountsowed under the sales contract. Musser Enterprises, Inc.,operated an electroplating operation at the site until August1990 when it abandoned the operation. Musser Enterprises, Inc.,failed to file an annual report with the Iowa Secretary ofState's office and was rendered inactive as a corporation onSeptember 6, 1992.

The sales contract entitled "Purchase Offer and Agreement"under which Musser Enterprises, Inc., was to purchase thebusiness and site of Emory Plating Company, was executed bythe officers of the corporations and individually byRichard W. Hansen, Kent E. Easterday and Gary L. Akes.

B. Potentially Responsible Parties

Requests for Information pursuant to Section 104 ofCERCLA have been sent to Richard W. Hansen, Kent E. Easterday,Gary L. Akes and Douglas W. Musser and all responses were due onor before November 30, 1992. Responses were received from theabove parties.

C. Enforcement Strategy

Notice Letters were sent to the above individuals, aswell as to Musser Enterprises, Inc. and Emory Liquidation, Inc.,with a description of the anticipated removal action and an offerto the potentially responsible parties (PRPs) to perform thework. In the event the PRP(s) does (do) not agree to conduct theremoval, Environmental Services Division will perform thisresponse action as a fund lead cleanup, and EPA will thereafterseek to recover its costs from the PRP(s) pursuant to Section 107of CERCLA.

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VIII.Recommendation

This decision document represents the selected removalaction for the Emory Plating site, in Des Moines, Iowa, developedin accordance with CERCLA as amended, and not inconsistent withthe National Contingency Plan (NCP). This decision is based onthe administrative record for the site.

Conditions at the site meet the NCP Section 300.415(b)(2)criteria for a removal and I recommend your approval of theproposed removal action. The total project ceiling, if approved,will be $394,000. Of this, an estimated $242,000 comes from theRegional removal allowance.

Attachments

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