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SFUND RECORDS CTR
88224768 SFUND RECORDS CTR
5104-00006
ecology and environment, inc. 11 GOLDEN SHORE, LONG BEACH, CALIFORNIA 90802, TEL. (310) 435-6188
International Specialists in the Environment
December 17, 1996
U.S. Environmental Protection Agency Ref. No.: Ti91296-005 Planning and Assessment Section (H-8-1) TDD No.: 099611-003 75 Hawthorne Street PAN No.: 0112-WCSF-XX San Francisco, California 94105
Attention: Matt Mitguard, Project Officer
Subject: West Coast Plating Site Assessment, South El Monte, California
This report describes initial U.S. Environmental Protection Agency (EPA) and Superfund Technical Assessment and Response Team (START) site investigative and assessment activities at West Coast Plating (WCP), 1734 South Tyler Avenue in South El Monte, Los Angeles County, California. WCP is a defunct metal finishing and plating facility which has recently been purchased by a Chinese national, who plans to raze the property in order to build a bookbinding facility.
In October 1992, EPA and the Technical Assistance Team conducted a preliminary assessment at the site (Technical Direction Document [TDD] No. 099210-031), which was then called Anchor Plating. The assessment was conducted in order to determine whether the site deserved EPA emergency response attention due to potential problems with the facility's hazardous waste management practices. At that time, it was determined that the site could remain under local agency jurisdiction.
In 1996, the WCP property was sold to the new owner in an "as is" condition, with all plating equipment, materials, and wastes left on site. EPA became involved with the site in November 1996, after the Los Angeles County Fire Department's Hazardous Materials Division notified EPA that the facility was in poor condition and could present a danger to public health and/or the environment. The WCP structure had broken skylights in the roof, and recent rains had led to the potential for vats of hazardous wastes to overflow onto the ground, producing an additional potential for dangerous and reactive mixes of chemicals to form and escape the property. The site is located in an industrial area, but children from a near-by residential area walk past WCP twice daily on their way to and from school. ,
' k' V
On November 6, 1996, START and EPA On-Scene Coordinator (OSC) Bill Lewis conducted a site inspection at WCP. During the inspection, the WCP plating facility was found to be in disarray. Many vats and containers had been removed from the property, but numerous drums of apparent vat solutions had been left behind. Other plating vats were still extant and full of unknown liquids, some of which were in a position to overflow. Standing liquids with an appearance indicative of metals contamination were on the floor, and, outside the southern side of the WCP building, large tanks and surface sumps were full of unknown liquids, and exposed to rain. An on-site laboratory area still contained numerous chemicals which appeared to be very old. The rear part of the main building, and a separate, smaller building behind the main building, were being used for bullet making operations at the time of the site visit.
recycled paper-
Ref. No. T191296-005 Matt Mitguard Page 2
Based on the initial site inspection, OSC Lewis immediately tasked START to conduct preliminary hazard categorization activities at the site, while he met with Mr. Lin, the brother of the new property owner, who is also the probable operator of the intended bookbinding operation. OSC Lewis directed Mr. Lin to provide 24-hour security; to hire a contractor by November 12 in order to initiate site stabilization activities, and to complete the site stabilization activities by November 15, 1996. These stabilization activities mandated by OSC Lewis included repair of the WCP roof, the removal or stabilization of exterior tanks/vats exposed to rain, and the provision of secondary containment for vats and containers which were in poor condition.
During OSC Lewis' meeting with Mr. Lin, START sampled 62 major containers on the property, and tested the samples for corrosivity (pH) and cyanide. Many of the sampled containers were found to contain highly corrosive liquids, and four of the sampled containers were found to contain cyanide (see START hazard categorization results, Attachment 1). As a result of these field tests, OSC Lewis directed START to collect samples for definitive laboratory analysis.
On November 7, 1996, START collected five samples at WCP. Two of the samples were collected from the front and back floor of the WCP building, and three others were collected from tanks/vats which had exhibited high corrosivity and/or cyanide in the field tests. The samples were analyzed for pH, total and amenable cyanide, reactive cyanide, 17 California total metals, and/or hexavalent chromium. Sample collection was conducted using standard techniques for proper quality control, and were placed under chain-of-custody. START also collected a duplicate set of samples for Mr. Lin (at his request), and left them at the WCP property.
A summary of the results obtained, along with California and EPA hazardous waste criteria, is provided in Table 1. The results indicate that certain of the on-site wastes meet the criteria for RCRA hazardous waste per 40 CFR §261.22 (corrosivity) and §261.23 (reactivity). In addition, high concentrations (percent range) of cyanide were detected, and samples collected from the floor of the warehouse indicate concentrations of certain metals which exceed California Total Threshold Limit Concentrations. Based on the total concentrations of metals detected, some metals would most likely exceed the EPA Toxicity Characteristic Leaching Procedure criterion.
By November 14, 1996, Mr. Lin had hired Cal-Ace Environmental Engineering Company (Cal-Ace) to conduct the initial site stabilization activities mandated by OSC Lewis. On November 15, 1996, START met OSC Lewis at WCP in order to oversee Cal-Ace activities. By the.time of START'S arrival, Cal-Ace had repaired the roof and had filled one vacuum truck of "neutral liquids," pumped from exterior sumps and tanks. Prior to transport off-site, the vacuum truck, owned by Cal-Ace's contracted transporter, AM Environmental (AM), was discovered (by AM personnel) to contain corrosive liquid in the pH range of 0-1. This liquid had been pumped from exterior sumps and from Tank 49, which were field tested by START to have a pH of 7; and from Tank 50, which START had determined to contain a high-pH liquid, both by field pH test and by off-site laboratory analysis.
The low pH discovered in the vacuum truck, and the neutral- to high-pH of the pumped sumps and tanks, indicated a possible stratification of pH in one or more of the pumped-out containers. START'S field test of liquid at the top of Tank 50, indicating a pH of 12, and a subsequent laboratory test of liquid from deeper in the tank (collected by drum thief), indicating a pH of 9.75, are indicative of such stratification. In addition, once the Tank 50 liquids had been removed to the vacuum truck, Tank 50 residue indicated a pH of 0-1.
Ref. No. T191296-005 Matt Mitguard Page 3
Table 1 Sampling Results at West Coast Plating
November 7, 1996
Analyte Floor #1
Floor #2
Tank #3 Tank #9
Tank #50
EPA Hazardous
Waste Criterion
EPA TCLP
Criterion California
TTLC
PH 9.77 1.83 10.4 <1 9.75 <2; >12.5 NA NA
Reactive Cyanide (mg/Kg) NA NA. 2,840 NA NA 250* NA NA
Total Cyanide (mg/Kg) 262,000 NA 226,000 NA NA . NA NA NA
Amenable Cyanide (mg/Kg) 260,000 NA 224,000 NA NA NA NA NA
Hexavalent Chromium (mg/Kg) <1 <1 NA NA NA NA 5.0 500
Antimony (mg/Kg) 9.6 14.9 NA NA NA NA NA 500
Arsenic (mg/Kg) <0.5 7.4 NA NA NA NA 5 500
Barium (mg/Kg) 152 42.7 NA NA NA NA 100 10,000
Cadmium (mg/Kg) 3,260 136 NA NA NA NA 1.0 100
Chromium (mg/Kg) 1,740 4,320 NA NA NA NA 5.0 2,500
Cobalt (mg/Kg) 1.2 13.8 NA NA NA NA NA 8,000
Copper (mg/Kg) 18,500 16,900 NA NA NA NA NA 2,500
Lead (mg/Kg) 1,970 2,860 NA NA NA NA 5.0 1,000
Molybdenum (mg/Kg) 1.4 3.8 NA NA NA NA NA 3,500
Mercury (mg/Kg) <1 <1 NA NA NA NA 0.2 20
Nickel (mg/Kg) 873 13,300 NA NA NA NA NA 2,000
Selenium (mg/Kg) <0.5 <0.5 NA . NA NA NA NA 100
Silver (mg/Kg) 4.7 15.6 NA NA NA NA 5.0 500
Thallium (mg/Kg) <2.5 4.8 NA NA NA NA NA 700
Vanadium (mg/Kg) 9.6 10.1 NA NA NA NA NA 2,400
Zinc (mg/Kg) 3,510 867 NA NA NA NA NA 5,000
* current EPA guidance level
Ref. No. T191296-005 Matt Mitguard Page 4
AM's vacuum truck was made of iron and was not rated to carry acids. In addition, a test of the atmosphere in the headspace of the vacuum truck indicated the presence of hydrogen cyanide at a concentration of 50 parts per million, a concentration equal to HCN's IDLH value. Upon hearing of the HCN in the vacuum truck, Cal-Ace's president, Mr. Jeff Lee, abandoned the site, leaving his subcontracted transporter (AM) to deal with the vacuum truck issue.
Because the vacuum truck could not continue to hold, and could not legally transport the acidic liquid, OSC Lewis determined that the best course of action would be to bring several large, portable polyethylene tanks on site to temporarily store this liquid. Due to the need for immediate action, and because Mr. Lin had no means to rent such tanks at short notice, EPA's Emergency Removal Services contractor, CET, was contacted and requested to acquire the tanks on an emergency basis. The tanks were delivered in the late afternoon of the same day, November 15.
Prior to pumping the vacuum truck liquid into the portable tanks, START re-checked the pH and headspace using Level B personal protection. At that time, the pH of the liquid was found to be 10-11, and the vacuum truck's headspace tested negative for HCN. Pumping of the liquid was subsequently accomplished, using a caustic soda solution as an off-gassing scrubber, without incident. Only one of the two 4,900-gallon tanks was used, and was filled to approximately two-thirds of its capacity.
As a result of Cal-Ace s abandonment of the site, OSC Lewis directed Mr. Lin to acquire a new contractor to complete the initial site stabilization activities. On November 18, AM was hired by Mr. Lin to complete these activities. AM's stabilization activities at WCP will be described in a future report under a pending TDD.
Photographs of the initial conditions found at WCP are presented in Attachment 2. If you have any questions or comments regarding this report, please do not hesitate to contact this office.
Sincerely,
Michael Schwennesen START Member
attachments
cc: OSC B. Lewis • file
ATTACHMENT 1
START HAZARD CATEGORIZATION RESULTS
WEST COAST PLATING
Co»JT/lWt4
PHAS CONTTYP
A001
A002
A003
A004
A005
A006
A007
A008
A009
A010
A011
A012
A013
A014 . A
A015
A016
A017
A018
A019
A020
A021
A022
v
V
V
V
c
V
V
V
V
V
V
V
c
c
c
V
D
D
0
C
0
c
SIZE
500
500
500
500
40
500
600
500
500
500
500
100
50
20
20
600
55
55
55
150
55
55
AMOUNT MATCON CLAS MATRIX PH CYANIDE
0 s •
1 s
0.75 S
0.01 S
0.5 P
0 S
0 S
1 S
1 S
1 s
1 s
0.05 S
0 S
0 s
0 s
s
p
p
p
s
p
p
0.0
NS
CNL L
CNL L
NCS S
CNL L
NS
NS
AL L
AL L
CNL L
BL L
NS
NS
NS
NS
NCL L
AL L
AL L
NCL L
NS
AL L
AL L
7
11
10
7
12
1
1
10
13
7
7
11
1
1
6
No
Yes
Yes
No
Yes
No
No
No
No
Yes
No
No
No
No
No
No
No
No
No
No
No
No
Monday, November 18,1996
LABEL
•CYANIDE COPPER RINSE"
"COPPER STRIKE"
"CADMIUM CYANIDE"
"ALK. RINSE"
"BRIGHT TIN"
"SOLUTION COPPER"
"ALK CLEANER"
"ALK CLEANER"
"50% NITRIC"
"50% NITRIC"
"WATER RINSE TANK*
"WOODS NICKEL STRIKE"
"NITRIC"
C0MMENT VOLUME
DIMENSIONS 2W X 8L X 4H o
PH AND CYANIDE TESTS ONLY 500
PH AND CYANIDE TESTS CONDUCTED. ONLY 375
CYANIDE TEST ONLY ' 5
PH AND CYANIDE TESTS ONLY 20
NOT SAMPLED 0
NOT SAMPLED-EMPTY 0
PH TEST ONLY 500
PH TEST. ONLY 500
PH AND CYANIDE TESTS ONLY 500
TWO SEPARATE CONTAINERS: PH AND CN 500
SOLID RESIDUE. NOT SAMPLED 5
EMPTY. NOT SAMPLED 0
EMPTY. NOT SAMPLED 0
EMPTY. NOT SAMPLED 0
PH AND CYANIDE TESTS ONLY 600
PH TEST. ONLY 55
PH TEST ONLY • " • 55
PH TEST ONLY 55
SOME SLUDGE: NOT SAMPLED 1.5
PH TEST ONLY 55
PH TEST ONLY 55
Page 1
WEST COAST PLATING
PHAS CONTTYP SIZE AMOUNT MATCON CIAS MATRIX PH CYANIDE
A023
A024
A025
A026
A027
A028
A029
A030
A031
A032
A033
A034
A035
A036
A037
A038
A039
A040
A041
A042
A043
A044
D
C
C
V
D
C
C
C
D
D
D
C
V
D
D
D
D
D
D
D
D
D
55
2
40
600
55
100
40
40
55
55
55
50
60
55
55
55
55
55
55
55
55
55
0.5 P
0 P
1 P
1 S
0.01 P
0.5 P
1 P
0.5 P
1 P
1 P
1 P
0.5 P
0.75 P
0 P
0 P
1 P
0.33 P
0.75 P
0 P
0.01 P
0.5 P
0 P
AL L
NS
AL L
NCL L
NS
NS
NCL
BL
AL
AL
AL .
BL
AL
NS .
NS
AL
AL
AL
NS
NS
AL
NS
12
1
1
1
12
1
7
7
1
2
2
7
7
1
7
No
No
No
No
No
No
No
No
No
No
No
No-
No
No
No
No
No
No
No
No
No
No
LABEL COMMENT VOLUME
"DANGER. ACID" PH TEST ONLY 27.5
NOT SAMPLED 0
PH TEST ONLY 40
2 SUB-CONTAINERS. PH TEST ONLY 600
-6" SLUDGE. NOT SAMPLED ( 0.55
NOT SAMPLED 50
PH AND CYANIDE TESTS ONLY 40
PH AND CYANIDE TESTS ONLY 20
ACID RINSE PH TEST ONLY 55
ACID RINSE PH TEST ONLY 55
ACID RINSE PH TEST ONLY • 55
PH AND CYANIDE TESTS ONLY 25
"WATER RINSE TANK" PH TEST ONLY ' 45
SOME SLUDGE: NOT SAMPLED 0
SOME SLUDGE. NOT SAMPLED 0
• PH TEST ONLY 55
PH TEST ONLY 18.15
PH TEST ONLY 41 25
EMPTY 0
NOT SAMPLED 0.55
"H2S04 DIP" PH TEST ONLY 27.5
SMALL AMOUNT OF RESIDUE. NOT SAMPLED 0
Page 2
WEST COAST PLATING
PHAS CONTTYP SIZE AMOUNT MATCON CLAS MATRIX PH CYANIDE
A045
A046
A047
A048
A 049
A050
A051
A052
A0S3
A054
A055
A056
A057
A058
A059
A060
A061
A062
D
C
D
V
C
C
C
C
C
D
D
D
C
C
D
D
C
C
55
15
55
2000
1000
500
1000
500
500
55
55
50
15
55
55
55
20
350
0 P
0.5 P
0 P
0.67 S
0.8 P
0.8 S
0.5 P
0.7 P
0.5 P
0.01 P
0 P
1 P
1 P
0 P
0 P
0.01 P
1 P
0.01 P
NS
AL
' NS
NCL
NCL
BL
AL
BL
AL
NS
NS
AL
AL
NS
NS
NS
AL
NS
12
1
12
1
7
7
1
1
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
NcT
No
No
Monday, November 18.1996
LABEL COMMENT VOLUME
•CAUTION. CHROMIC
•ACID"
•HCL DIP-
SMALL AMOUNT OF RESIDUE. NOT SAMPLED
PH TEST ONLY
NOT SAMPLED
PH AND CYANIDE TESTS. ONLY
PH TEST ONLY
PH AND CYANIDE TESTS. ONLY
PH TEST ONLY
PH AND CYANIDE TESTS ONLY
PH TEST ONLY
SLUDGE ON BOTTOM: NOT SAMPLED
SLUDGE ON BOTTOM: NOT SAMPLED
PH TEST ONLY
PH TEST ONLY
1" SLUDGE. NOT SAMPLED
EMPTY
1" SLUDGE: NOT SAMPLED
PH TEST ONLY
1'SLUDGE. NOT SAMPLED
7.5
0
1340
800
400
500
350
250
0.55
0
50
15
0
0
0.55
20
3.5
Page 3
Page No. 1 11/18/96
Class Code Hazard Class Description
AL Acid Liquid AOL Acid Oxidizing Liquid AOS Acid Oxidizing Solid AS Acid Solid BL Base Liquid BOL Base Oxidizing.Liquid BOS Base Oxidizing Solid BS Base Solid CLG Chlorinated Gas CLL Chlorinated Liquid CNG Cyanide Gas CNL Cyanide Liquid CNS Cyanide Solid FG Flammable Gas FL Flammable Liquid FS Flammable Solid NCG Non Characteristic Gas NCL Non Characteristic Liquid NCS Non Characteristic Solid NFL Non-Flammable Liquid/Oil NS No Sample Taken OG Oxidizing Gas OL Oxidizing Liquid OS Oxidizing Solid SG Sulfide Gas SL Sulfide Liquid SS Sulfide Solid
HAZARD CLASS & DATA GLOSSARY
Data Glossary
PHASE : A = All the material T = Top portion B = Bottom portion
CONTAINER TYPE : V = Vat D = Drum C = Container less than 55 gall.
SIZE : Size of container in gallons AMOUNT : 1.00 = Full
0.75 = 3/4 Full 0.00 = Empty
CONTAINER MAT.: S = Steel (material that G = Glass the container P = Poly is made of) F = Fiber CONTAINER COND. P = Poor
F = Fair G = Good
CONTAINER TOP : O = Open B = Bung
MATRIX : S = Solid L = Liquid G = Gas
SOLUBLE : Y = Soluble in water L = Floats in water G = Heavier than water
PH : 0 - 14, 7 = neutral. LOCATION: Area on site where container is located. DRUM NO.: Number identifying container -
(sometimes different than sample ID f) SORT CLASS: Optional entry to allow a user-specified
classification and sorting of the records.
ATTACHMENT 2
PHOT ODOCUMENT ATION
PHOTODOCUMENTATION
West Coast Plating facility. Photograph taken from across Tyler Avenue, looking east Photographed by: R. Wise November 6, 1996
Interior view of West Coast Plating facility, looking east. Photographed by: R. Wise November 6, 1996
PHOTODOCUMENTATION
Tanks outside the south side of West Coast Plating building. Photograph looking west Photographed by: R. Wise November 6, 1996
Photographed by: Interior view of West Coast Plating facility, looking south.
R. Wise November 6, 1996
