SFUND RECORDS CTR 2072529 - US Environmental … 648,000 in direct extramural costs to mitigate threats to human health and the ... following day to perform field chemistry ... waste

SFUND RECORDS CTR

2072529

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION IX

75 Hawthorne StreetSan Francisco, CA 94105

MEMORANDUM

DATE: JUL 2005

SUBJECT: Request for a Time-Critical Removal Action at Industrial Zinc Plating, Inc.,Long Beach, Los Angeles County, California

Craig Benson, On-Scene CoordinatorEmergency Response

Daniel Meer,Response, Planning

FROM:

TO:

THROUGH: Peter Guria, ChiefEmergency Respon;

I. PURPOSE

The purpose of this Action Memorandum is to obtain approval to spend up to$ 648,000 in direct extramural costs to mitigate threats to human health and theenvironment posed by uncontrolled hazardous substances (cyanide, arsenic, zinc, acidsand corrosive liquids and solids) in bulk and non-bulk containers, soils, and buildingmaterials associated with the abandoned metal plating facility operated by the IndustrialZinc Platers, Inc. (the Site). The Site is located at 3200 E. 29th Street in the City ofLong Beach, County of Los Angeles, California (90806). The proposed removal ofhazardous substances would be taken pursuant to Section 104(a)(1) of theComprehensive Environmental Response, Compensation and Liability Act (CERCLA),42 U.S.C. § 9604(a)(1), and Section 300.415 of the National Oil and HazardousSubstances Pollution Contingency Plan (NCP), 40 C.F.R. § 300.415.

On June 21, 2005, the United States Environmental Protection Agency (EPA)initiated an emergency response action to mitigate the threats posed by abandoned platingwastes. Authority to expend up to $200,000 to initiate emergency characterization,stabilization and re-containerization of hazardous substances was granted under the On-Scene Coordinator's (OSC) delegated warrant authority to mitigate the threats posed at theSite. The actions proposed in this document provide the transition from emergencystabilization activities to fulfillment of identified time-critical removal needs. These time-critical actions include the off-site transfer and disposal of secured and re-containerized

hazardous wastes and the continuing identification and removal of contaminated soils,building materials and debris presenting a release and direct contact exposure threat.

II. SITE CONDITIONS AND BACKGROUND

Site Status: Non-NPLCategory of Removal: Time-CriticalCERCLISID: CAD981388101SITE ID: 09NB

A. Site Description

1. Physical location

The Site is located at 3200 E. 29th Street in Long Beach, Los Angeles County,California. The coordinates of the Site are N 33° 48' 24.8", W 118° 09' 12.2".

2. Site characteristics

The Site is located on an approximate two acre parcel of land in anindustrial/commercial area of Long Beach, California. The Site lies immediately south ofthe San Diego (405) Freeway and under one-quarter of a mile south of the Long BeachMunicipal Airport. The Site consists of one 19,200 square foot building with an addressof 3200 E. 29th Street (north building) and one 9,600 square foot building withaddresses 3202-3208 E. 29th Street (south building). The two site buildings aresurrounded by asphalt and concrete paved driveways with parking lots along 29th Streetand between the two site buildings ( Figure 1).

Industrial Zinc Platers, Inc. (IZP) operated its plating lines exclusively at 3200 E.29th Street until approximately 1997, when an expanded plating facility at 3100 E. 29th

Street was completed on the adjoining parcel. Former IZP business owner, RaymondBall, sold the at 3200 E. 29th Street property to the current property owner, BrianGooldy, around November 2003. Mr. Ball did, however, continue to conduct platingoperations at both locations until approximately October 2004. All chemicals andequipment associated with the 3100 E. 29th Street operation were reportedly addressedin a separate cleanup action. Information to support this is currently being investigated.The actions addressed in this document are specific to the Site as defined above.

Records indicate that IZP conducted electroplating, plating, polishing, anodizingand coloring operations. The company's focus appears to have been zinc cyanideelectroplating on iron substrates.

3. Removal site evaluation

The Site was referred to EPA by the Los Angeles County Sanitation Districts(LACSD). On June 20, 2005, OSC C. Benson participated in a walk-through inspectionwith LACSD Industrial Waste Inspector Neil Tran. Also present were personnel fromthe Superfund Technical Assistance and Response Team (START) contractor and Mr.Gooldy. The walk-through revealed a large quantity of liquid and solid hazardouswastestreams including plating solutions, sludges and untreated industrial wastewaters.Materials were located in several distinct areas on-site including a tank farm along theeastern side of the south building, the former wastewater treatment area in the parkinglot separating the two buildings, and large decayed and partially buried steel andreinforced concrete vats in the eastern half of the north building (Figure 1).

Site conditions prompted OSC Benson to give a general notice of CERCLAliability to Mr. Gooldy. Mr. Gooldy represented that he did not have the resources toconduct any stabilization or cleanup work associated with the former plating operation.OSC Benson and START made arrangements to implement a sampling plan on thefollowing day to perform field chemistry confirmation on suspected corrosive andcyanide bearing waststreams and to provide samples for off-site laboratory analysis.Arrangements were also made for Civil Investigator J. Jaros to meet with Mr. Gooldy thefollowing morning to further discuss his potential liability and options. Mr. Gooldydeclined split samples for any EPA sampling event and provided keys to the fence andwarehouse locks for future access.

On June 21, 2005, START implemented an approved Emergency ResponseQuality Assurance Sampling Plan (QASP). Over 25 samples were collected fromplating vat solutions, above-ground storage tanks, 55-gallon drums and salvage drums.Field chemistry verified the presence of corrosive and cyanide bearing solutions andsludges in unsecured, decayed and compromised bulk containers. Six samples fromthe field analytical set were submitted to an approved off-site laboratory for rush EPAapproved analysis of heavy metals and total and amenable cyanide.

The main zinc plating line in the north building is represented by eleven tanks,each surrounded by about eight inches of reinforced concrete. Tank capacities rangefrom 3,600 to 8,425 gallons in size. Approximately 20,000 gallons of solutions andsludges are contained within these vats. Another approximate 20,000 gallons ofsolutions and sludges are estimated to be contained in above-ground storage tanks, 55-gallon drums and salvage drums across the property. An undetermined volume ofcontaminated containment concrete, building materials, debris and soils also exist at theSite. A START Container Inventory listing preliminary container descriptions, volumesand field chemistry results is contained in Appendix 1.

Investigator Jaros met with Mr. Gooldy and EPA's Office of Regional Counselcontacted the attorney for the former owner (R. Ball). In each case, the party denied

responsibility and/or the financial ability to perform necessary emergency stabilizationmeasures was denied. The lack of immediate potentially responsible party (PRP)response, coupled with the field confirmation of large quantities of corrosive andcyanide bearing wastestreams in unsecured areas, accessible to tenants and the public,resulted in OSC Benson initiating an emergency stabilization and cleanup action underdelegated warrant authority. Emergency activities commenced on June 22, 2005, withthe mobilization of an Emergency and Rapid Response (ERRS) contract cleanup crew.

4. Release or threatened release into the environment of a hazardoussubstance, or pollutant or contaminant

The objective of the June 21, 2005, EPA/START sampling event was to obtainan analytical data set meeting EPA Quality System guidelines that is representative ofcurrent Site conditions and that could be used to identify key hazardous substances ofinterest for project health and safety needs and future waste profiling purposes. APreliminary Laboratory Results Summary Table is contained in Appendix 2. Fieldtesting and preliminary laboratory analytical data confirmed the presence of largequantities of corrosive solutions, high concentration cyanide solutions and numerousheavy metal contaminated wastestreams associated with former electroplating andindustrial wastewater treatment processes.

Analytical data indicate the presence of Resource Conservation and RecoveryAct (RCRA) listed wastes "F007" and "F008" (associated with electroplating operationswhere cyanides are in used in the process), wastes exhibiting the RCRA hazardouswaste characteristic of corrosivity under 40 CFR 261.22, and zinc and copperconcentrations in plating waste in excess of California Total Threshold LimitConcentrations (TTLC) waste determining values.

Maximum concentrations recorded were 147,000 rng/l total cyanide, 242,000mg/kg zinc and 11,500 mg/kg copper. Liquid sample "IZP-V7-L1" exceeded the RCRAToxicity Characteristic Leaching Procedure (TCLP) waste threshold of 5 mg/L arsenic ata concentration of 10.1 mg/L. The remaining liquid samples could not be digested formetals analysis due to the extremely high concentrations of cyanides present. Inaddition, total chromium and cadmium concentrations in sludge and residue samplesare at concentrations that would be expected to fail their corresponding TCLP wastedetermining thresholds.

RCRA listed and characteristic wastes and chromium, copper, cadmium, arsenicand zinc are hazardous substances as defined by Section 101 (14) of CERCLA. Otherhazardous substances or pollutants and contaminants not discovered to date or notspecifically identified herein may exist at the Site. These substances may also pose athreat to human health and the environment.

There is limited security at the Site and the hazardous contents of the tank farmand wastewater treatment area are accessible by co-tenants and neighboring

businesses. The potential for fire, vandalism and continuing deterioration of containersat the unmanaged Site may result in the combustion, physical exposure or comminglingof incompatible hazardous substances resulting in harm to the public health or welfareor the environment. Considering the proximity of nearby businesses and publichighways, the Site represents a significant threat of release affecting nearby populationsand direct contact exposure to Site workers.

5. National Priorities List ("NPL") status

The Site is not currently on or proposed for inclusion on the NPL.

B. Other Actions to Date

On June 20-21, 2005, the EPA Emergency Response Program conducted aremoval site assessment. Based on the findings of this assessment, OSC Bensondetermined that the conditions at the Site presented an imminent and substantialendangerment to human health and the environment. Authority to expend up to$200,000 to initiate emergency characterization, stabilization and re-containerization ofhazardous substances was granted under the On-Scene Coordinator's (OSC)delegated warrant authority to mitigate the threats posed at the Site.

C. State and Local Authorities' Roles

1. State and local actions to date

The LACSD provided OSC Benson with an Enforcement Summary packagewhich documents numerous violation notices dating back to 1989 that were issued toIZP for occurrences of "discharge of wastewater containing pollutant concentration inexcess of Federal EPA pretreatment standards". On December 30, 2004, LACSDvoided IZP's permit to discharge industrial wastewater to the sewer. The apparentabandonment of accumulated untreated industrial wastewaters on-site, dischargepermit revocation, and attempts at wastewater management by the new property owner(Gooldy) led to the LACSD referral to EPA.

Through his attorney, Mr. Gooldy provided OSC Benson with a report entitled"Subsurface Investigations Report of Findings, Industrial Zinc Plating Company," datedJanuary 27, 2003. The report was prepared by The Leu Group Team for the law firmTrutanich-Michel (council for Raymond ball and IZP). The report documents anextensive subsurface soil, groundwater, and soil gas sampling investigation in 2002(see Appendix 1, Figure 5). The report concludes that contamination found across thissite demonstrates a complex history of unrelated impacts from multiple sourcesincluding:

• Shallow soil and potential groundwater impacts from the previous platingoperations.

• Direct evidence of high methane gas concentrations present in the soil thatappears to be related to the regional Long Beach Oil Field.

• Evidence of releases of methyl ethyl ketone (MEK) and acetone possibly fromformer plastics manufacturing activity on-site or former underground storagetanks (USTs) that held paints and solvents.

• Petroleum hydrocarbon contamination in the soil and groundwater from off-sitesources.

• Soil impacts from a historic landfill.

In October 2004, the City of Long Beach, Department of Health and HumanServices (LBDHHS) received the above mentioned report from Mr. Gooldy's attorney,along with a request that LBDHHS provide oversight for a site investigation/remediationeffort. Based on the conclusions of the report and impacts to groundwater, theLBDHHS referred the project to the Regional Water Quality Control Board - LA Region(RWQCB). OSC Benson confirmed with the RWQCB that the extent of their effort hasbeen limited to scoping of oversight needs and costs.

No evidence has been uncovered to date which substantiates that any agency atthe local, State or Federal level has been actively engaged in any cleanup oversightactivities (either at 3100 E. 29th Street or the Site), or that there have been any othernotifications of the results of historical environmental assessments at the Site.

2. Potential for Continued State/Local Response

Neither state nor local agencies have the resources to undertake the requiredcleanup action at this time.

OSC Benson has discussed the nature of the on-going emergency responseaction with LBDHHS and RWQCB personnel. A RWQCB manager has agreed to meetwith the OSC and work to ensure a smooth transition from EPA emergency and time-critical response actions to possible RWQCB long term remediation efforts.

Representatives from State and local response organizations may be requestedto assist and coordinate with the OSC in various tasks including data review, planningand community relations. EPA recognizes, however, that their financial ability tocontribute to the response will be limited.

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

Conditions at the Site represent a release, and potential threat of release, of aCERCLA hazardous substance threatening to public health, or welfare, or theenvironment based on the factors set forth in the National Oil and HazardousSubstances Pollution Contingency Plan ("NCP"), 40 CFR § 300.415(b)(2). Thesefactors include:

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1. Actual or potential exposure to nearby populations, animals or the foodchain from hazardous substances or pollutants or contaminants

There is an actual or potential exposure to nearby populations from hazardoussubstances at the Site, including the now unmananged and unsecured heavy metalsolutions, sludges and debris containing chromium, copper, cadmium, arsenic and zinc.These hazardous substances exist in liquid and solid wastes deposited throughout thefacility and in Site soils and building materials. There are also large quantities of acidicand strong caustic cyanide laden plating solutions and wastes in open and degradedvats.

Although the Site property is fenced, pedestrian access is relatively unimpeded.The facility remains a human health risk to any vandals or trespassers, including youngchildren, who might enter the premises. Direct contact, inhalation or ingestion of thehazardous substances at the Site poses an acute health threat to these individuals.Toxic fumes and smoke may reach populations outside the Site in the event of a facilityfire or the mixture of incompatible chemicals, such as hydrogen chloride and cyanide.The threat of release and subsequent exposure is high. Toxic threats from specificmaterials at the Site are discussed below.

Chromium is an ecotoxic heavy metal that is an inhalation, ingestion, and dermalexposure risk. Chromium bioaccumulates and targets the liver, kidneys, reproductiveorgans, circulatory system, and gastrointestinal system. Acute exposure to chromiumcan cause harmful effects to the gastrointestinal system. Chronic exposure can causeharmful effects to the skin, lungs, mucous membranes, and possibly cancer.

Arsenic is toxic and is commonly used as a poison to control pests. Arsenicaffects the skin, the respiratory system, the kidneys, the liver, the central nervoussystem, the gastro-intestinal tract, the reproductive system and is a possible teratogen.

Cyanide is readily absorbed through the skin, mucous membrane, and byinhalation. Symptoms of cyanide poisoning include anxiety, confusion, vertigo, nausea,convulsions, paralysis, coma, cardiac arrhythmia, and transient respiratory stimulationfollowed by respiratory failure or death.

Nitric acid is a corrosive material that can burn the skin, eyes, and respiratorytract on direct contact or inhalation of vapors. It can cause acute pulmonary edema orchronic pulmonary diseases from inhalation. When heated or reacted with water, itproduces toxic and corrosive fumes.

Hydrochloric acid is a strong corrosive that can burn the skin, eyes and mucousmembranes on dermal contact. It also is moderately irritating to the respiratory tractwhen inhaled. Hydrochloric acid produces toxic and corrosive fumes when exposed towater.

Sodium hydroxide is a strongly alkaline material (pH levels greater than 7.0).Sodium hydroxide is corrosive and has an irritating effect on all body tissue, causingburns and deep ulcerations. Inhalation can cause damage to the upper respiratorytissue and lung tissue, with effects ranging from mucous membrane irritation to severepneumonitis.

Other hazardous substances or pollutants and contaminants not discovered todate or not specifically identified herein may exist at the Site. These substances mayalso pose a threat to human health and the environment.

2. Actual or potential contamination of drinking water supplies

The RWQCB has made a preliminary determination that existing data suggeststhat a release of chemicals has degraded the groundwater quality and beneficial uses ofthe State's waters. No specific contamination of a drinking water supply has beenidentified to date. As stated above, the RWQCB will retain oversight and control overpotential impacts to the groundwater resources.

3. Hazardous substances or pollutants or contaminants in drums, barrels,tanks, or other bulk storage containers, that may pose a threat ofrelease.

A preliminary inventory of containers (Appendix 2) includes over 45 various sizeddrums, tanks, clarifiers and vats. Nearly all the containers were in very poor condition.Drums and salvage drums were improperly utilized, marked and labeled. Tanks werefound to be leaking and plating bath residues and wastewater treatment sludges werefound spilled outside of their containment.

A complete inventory of bulk and non-bulk containers and their contents will onlybe possible during removal actions activities with the necessary health and safetyprogram elements.

4. High levels of hazardous substances or pollutants or contaminants insoils largely at or near the surface, that may migrate

Shallow soil impacts revealing contaminants such as lead, cyanide, and zincfrom the previous plating operations have been reported in previous sampling at thesite. As detailed below, a key goal of this proposed action is to further delineate andremove contaminated shallow soils from potential source areas.

5. Weather conditions that may cause hazardous substances or pollutantsor contaminants to migrate or be released

Exterior waste containment areas are exposed to rainfall and the north buildingroof is deteriorated in areas which may allow rainfall leaks directly over the abandonedplating line. Surface water runoff contaminated with cyanide and other heavy metalscould migrate off-Site and enter into surface water pathways which could pose a humanhealth risk to neighboring communities. Further, weathering of structural debris andwaste containment areas by wind, sun and rain can cause the deterioration of remainingmaterials and will result in an ongoing release of heavy metals and cyanide locatedwithin those materials.

6. Threat of fire or explosion

Waste containment areas are not fully secure and have not been completelyassessed. The potential presence of oxidizing materials, exposed electrical wiring,unknown conditions and vandalism could affect fire safety or result in a release if thechemicals are allowed to mix and react together.

7. Availability of other appropriate federal or state response mechanismsto respond to the release

No other appropriate federal, local or state public funding source has beenidentified. The proposed action exceeds the financial capability of the California StateEmergency Reserve Account.

IV. ENDANGERMENT DETERMINATION

Actual or threatened releases of hazardous substances from this Site, if notaddressed by implementing the response action selected in this Action Memorandum,may present an imminent and substantial endangerment to public health, or welfare, orthe environment.

V. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed Actions

1. Proposed action description

EPA proposes to inventory, characterize, segregate, bulk, re-containerize andremove for disposal all abandoned hazardous substances and contaminated materialsleft in containers, tanks and process vats at the Site. All wastes will be characterizedusing EPA approved methodologies and delivered to approved receiving facilities.

EPA further proposes to continue the evaluation of contaminated soils, asphalt,concrete and structures associated with the former electroplating operations andremove for disposal, as necessary, all exposed materials posing an imminent threat ofendangerment. The U.S. EPA will not investigate or respond to deep soil orgroundwater contamination at the Site.

All activities will be performed in conformance with prescribed health and safetyprocedures. Sampling and analysis activities will conform to EPA approvedmethodologies and mandatory specifications for quality assurance and quality controlactivities.

2. Contribution to remedial performance

EPA does not anticipate a long term remedial action at this Site. This removalaction should remove all immediate threats posed by uncontrolled hazardoussubstances at the Site.

The long-term cleanup plan for the Site: Final reporting of this removal action willbe provided to the RWQCB, the LBDHHS, and the LACSD for consideration in anyfurther activities under state, county, and city programs.

Threats that will require attention prior to the start of a long-term cleanup:

There is no EPA long-term cleanup planned for this Site. The immediate threatsthat have been identified in the Action Memorandum will be addressed by the proposedremoval action.

The extent to which the removal will ensure that threats are adequately abated:

The removal of abandoned, above ground hazardous substances andcontaminated soils is expected to abate the immediate threats from the Site.

Consistency with the long-term remedy:

As stated above, removal activities undertaken in this action will be consideredand incorporated into state, county, and city facility closure proceedings.

Post Removal Site Control

The OSC has begun planning for the provision of post-removal site control,consistent with the provisions of § 300.415(k) of the NCP. The nature of the removal,elimination of all threats, is, however, expected to eliminate or minimize the need forpost-removal site control.

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3. Description of alternative technologies

Alternative technologies are not considered for the proposed response action.

4. Applicable or relevant and appropriate requirements (ARARs)

Section 300.415(j) of the NCP provides that removal actions must attain ARARsto the extent practicable, considering the exigencies of the situation.

Section 300.5 of the NCP defines applicable requirements as cleanup standards,standards of control, and other substantive environmental protection requirements,criteria or limitations promulgated under Federal environmental or State environmentalor facility siting laws that specifically address a hazardous substance, pollutant,contaminant, remedial action, location or other circumstances at a CERCLA site.

Section 300.5 of the NCP defines relevant and appropriate requirements ascleanup standards, standards of control and other substantive requirements, criteria, orlimitations promulgated under Federal environmental or State environmental or facilitysiting laws that, while not "applicable" to a hazardous substance, pollutant, orcontaminant, remedial action, location, or other circumstances at a CERCLA site,address problems or situations sufficiently similar to those encountered at the CERCLAsite and are well-suited to the particular Site.

Because CERCLA on-site response actions do not require permitting, onlysubstantive requirements are considered as possible ARARs. Administrativerequirements such as approval of, or consultation with administrative bodies, issuanceof permits, documentation, reporting, record keeping, and enforcement are not ARARsfor the CERCLA response actions confined to the Site.

The following ARARs have been identified for the proposed response action. Allcan be attained.

Federal ARARs: Potential Federal ARARs are the RCRA Land DisposalRestrictions, 40 C.F.R. § 268.40 Subpart D; the CERCLA Off-Site Disposal Restrictions,and the U.S. Department of Transportation of Hazardous Materials Regulations, 49C.F.R. Part 171,172 and 173.

State ARARs: Potential State ARARs are Characteristics of Hazardous Wasteimplemented through the California Health and Safety Code, Title 22, § 66261.20,§ 66261.21, § 66261.22, § 66261.23, § 66261.24.

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5. Project schedule

Emergency removal activities were initiated on June 21, 2005. Removalactivities will require approximately two months to complete

B. Estimated Costs

Regional Removal Allowance Costs

Cleanup Contractor $ 510,000

Extramural Costs Not Funded from the Regional Allowance

START Contractor $ 30,000

Extramural Subtotal $540,000

Extramural Contingency (20%) $108.000

TOTAL, Removal Action Project Ceiling $648,000

VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED ORNOT TAKEN

Given the Site conditions, the nature of the hazardous substances documentedon-Site and the potential exposure pathways to nearby populations described inSections Ml and IV above, actual or threatened releases of hazardous substances fromthe Site, if not addressed by implementing the response actions selected in this ActionMemorandum, present an imminent and substantial endangerment to public health, orwelfare, or the environment.

VII. OUTSTANDING POLICY ISSUES

There are no outstanding policy issues with the Site identified at this time.

VIII. ENFORCEMENT

Please see the attached Confidential Enforcement Addendum for a discussionregarding PRPs and enforcement. In addition to the extramural costs estimated for theproposed action, a cost recovery enforcement action also may recover the followingintramural costs:

12

Intramural Costs1

U.S. EPA Direct Costs $ 30,000

U.S. EPA Indirect Costs(35.28% of $ 648,000 + $ 30,000) $239.198

TOTAL Intramural Costs $ 269,198

The total EPA extramural and intramural costs for this removal action, based on full-costaccounting practices that will be eligible for cost recovery, are estimated to be$917,198. Of this, an estimated $ 510,000 comes from the Regional removalallowance.

IX. RECOMMENDATION

This decision document represents the selected removal action for the IndustrialZinc Platers, Inc., Site at 3200 E. 29th Street in Long Beach, California, as developed inaccordance with CERCLA and not inconsistent with the NCP. This decision is based onthe Administrative Record for the Site.

Because conditions at the Site meet the NCP criteria for a time-critical removal, Irecommend that you concur on the determination of imminent and substantialendangerment and the removal action proposed in this Action Memorandum. The totalremoval action project ceiling if approved will be $ 648,000, of which an estimated$510,000 comes from th§^egi©n§{.iemoxal allowance. You may indicate your decisionby signing below.

Approve: _Date

Response, Planning and Assessment Branch

Disapprove:Daniel Meer, Chief DateResponse, Planning and Assessment Branch

1 Direct costs include direct extramural costs and direct intramural costs. Indirect costs are calculatedbased on an estimated indirect cost rate expressed as a percentage of site-specific direct costs,consistent with the full cost accounting methodology effective October 2, 2000. These estimates do notinclude pre-judgment interest, do not take into account other enforcement costs, including Department ofJustice costs, and may be adjusted during the course of a removal action. The estimates are forillustrative purposes only and their use is not intended to create any rights for responsible parties. Neitherthe lack of a total cost estimate nor deviation of actual costs from this estimate will affect the UnitedStates' right to cost recovery

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Enforcement Addendum

Index to the Administrative Record

Figures

Figure 1 Site Layout Map

Appendices

1. START Container Inventory, June 21, 2005

2. Preliminary Laboratory Results Summary Table, June 21, 2005

cc: Sherry Fielding, USEPA, OEM, HQDirector, California Department of Toxic Substances ControlDepartment of the Interior

Director, Los Angeles Regional Water Quality Control Board

14

bcc: Site FileJohn Jaros, SFD-9-4Craig Benson, SFD-9-2Elizabeth Cox, ORC-3

Celeste Temple, SFD-9-4

15

Index to the Administrative Record

• START Container Inventory, June 21, 2005

• Preliminary Laboratory Results Summary Table, June 21, 2005

• County Sanitation Districts of Los Angeles County, referral, file: 03/05-4764,June 10, 2005.

• City of Long Beach, Department of Health and Human Services, letter to BrianGooldy, October 20, 2004

• City of Long Beach, Department of Health and Human Services, letter referral tothe Site Cleanup Group, California Regional Water Quality Control Board-LosAngeles Region, October 20, 2004

• California Regional Water Quality Control Board-Los Angeles Region, letter toBrian Gooldy, October 15, 2004.

• Earth Tech, preliminary scoping memorandum to Brian Gooldy, February 11,2005

• County Sanitation Districts of Los Angeles County, Enforcement SummaryPackage, 1989-2004

• The Leu Group Team, "Subsurface Investigations Report of Findings, IndustrialZinc Plating Company", January 27, 2003

20

Figure 1

Site Layout Map

21

Figure 1Industrial Zinc Plating

June 2005

SCALE 1"~50'

29th STREET

SIDEWALK

B

LEGEND

18 Clarifier

Eg] Plating Line

O CPT LocationsA Son Gas Survey

Locations+ SoilBorfng

Locations

• Monitoring WellLocations

X GeoProbe Boring Locations

CPT-8Q OROST-8

0C>T-5

IW-3

T-4

ST-4

EXISTING BUILDING

*, JR. I—

fB-7 GP-7

9605 Arrow Route, Suite TRancho Cucamonga, CA

Site Layout MapIndustrial Zinc Plating Corporation

3200 East 29th Street, Long Beach, CA

FIGURE

APPENDIX 1

SUPERFUND TECHNICAL ASSISTANCE and RESPONSE TEAMCONTAINER INVENTORY

June 21, 2005

23

Container InventoryIndustrial Zinc Plating

3200 E. 29th Street, Signal Hill, California

State ManifestNo.

2442839 I/24428392pending

pending

pending

pending

24428391/24428392

pending

pending

24428392pending

24428392

pending

24428392

24428392

24428392

24428392

24428392

24428392

24428391

24428393

ROB*

NA1-20-422

1-20-422

1-20-422

1-20-422

NA

1-20-422

1-20-422

NA1-20-567

NA

1-422/1-20-

NA

NA

NA

NA

NA

NA

NA

NA

NA

ERRSColorCode

White

White

White

White

green

red

blue

none

none

White

White

White

White

White

White

green

red

red

START ID

1AIB

2A

3A

4A

SA

SB

6A

7A7B

8A

8B

9A

10A10B

1IA11B

I2AI2B

13A13B14A14B

ISAI5B

20A

20B

21A

22A

Location/ Add'l Info

Inside north building, vat on south end of plating line

Inside north building, plating line vatlabeled as "Bright Dip (1% HNO3) on 1986 drawing

Inside north building, plating line vatlabeled as "Bright Dip (1% HNO3) on 1986 drawing

Inside north building, plating line vatlabeled as "cold water rinse" on 1986 drawing

Inside north building, plating line vatlabeled as "zinc plating (cyanide)" on 1986 drawing

Inside north building, plating line vatlabeled "cold water nnse" on 19S6 drawing

Inside north building, plating line vatlabeled as "caustic cleaner" on 1986 drawing

Inside north building, plating line vatlabeled as "cold water nnse" on 1986 drawing

Inside north building, plating line vatlabeled as "15% HCI" and "5% HCI"

Inside north building, small sump at northeast corner of plating line

Inside north building, small sump between vats 7 and 8 of plating line

Inside north building, south end of drainage near plating line

Inside north building, small sump at west side of vats 1 and 2

Inside north building, southwest corner of plating shop area

Inside north building, along western edge of plating shop across fromvat 6

Outside in secondary containment area east of south building



Description of Contents

iquidx)ttom solids

TOttom solids, no liquid, marked "1% nitric acid"

bottom solids, no liquid, marked "1% nitric acid"

jottom solids, no liquid, marked "nnse water"

iquid and debris; marked "zinc solution"

Bottom solids

xrttom solids, no liquid, marked "nnse water"

liquid and debrisbottom solids

oottom solids, marked rinse water

liquid

bottom solids, no liquid

liquid in small sumpsolids



liquid in small sumpsolidsliquid in small sumpsolids


contents are reddish colored liquid similar tothat observed in vat 5 at plating line, marked"wastewater overflow"

solids/ sludge

contents are yellow liquid, marked "munatic acid"

contents are yellow liquid, marked "munauc acid"

EstimatedVolume (gallons)

450

unknown

unknown

unknown

600

<lyd 3

450

< l y d 5

unknown

45

45

45

45

45

45

2000

1700

2000

Total Capacity

7200 gal

3600 gal

3600 gal

3,600 gal

7225

3600

8,425 gal

4,800 gal

9600 gal

Field Test Results

?H = 7, brownish-blackiquid

pH = 7, grayish-white solid



pH=14; Cyanide present;reddish brown liquid

no sample

pH=12; brown sludgeSee also sample #9.

no sample

composite solid samplescrapped from sides of vats7 and 9; pH=12

pH=7, tan/ light brown liquid

pH=7, brownish red liquid

pH=7, brown liquid

pH=7, colorless liquid

pH=10, reddish brown liquid

pH=7, colorless liquid

pH=12; cyanide present;brown liquid with sediments

pH=2, dark brown liquid


Lab Results

CN = 147,000 mg/L

CN = 0.976 mg/LAs =10.1 mg/LZn = 126 mg/L

CN = 5.95 mg/kgZn, Cu > TTLC

CN = 4140 mg/kg

Page 1 of 3



State ManifestNo.

24428393

24428393

2-20-208

24428393

24428391

24428391

pending

24428391

24428391

24428391

24428391

24428391

24428391

24428391

24428391

pending

pending

24428391

pending

pending

pending

pending

ROB*

N/A

1-20-422

1-20-422

1-20-422

2-20-208

2-20-208

2-20-208

1-20-422

ERRSColorCode

red

red

White

blue

red

White

blue

White

White

White

White

white

White

White

blue

White

White

blue

No code

No code

No code

START ID

23A

24A

25A

25B

26A

27A

27B

28

29A

29B

30

31

32

33

34A

35

36

37A

37B

38

39

40A

40B

41

42

43



Outside m secondary containment area east of south building




Outside m secondary containment area east of south building


55-gallon black, pory, bung-top dram, outdoor containment area

55-gallon black, pory, bung-top drum, outdoor containment area

55-gallon black, poly, bung-top drum, outdoor containment area





75-gallon yellow salvage drum, outdoor containment area




75-gatlon yellow salvage drum, outdoor containment area




contents are yellow liquid, marked "muriatic acid"

contents are yellow sludge; marked "muriaticacid"

contents not visible, marked "caustic, sulfunc,lypochlonte"

solids/ sludge

solid, blue/copper colored sludge; no marking

colorless liquid m small rusty vat, appears to bewater that has leaked from Tank 26

solids/ sludge

drum marked "Mill Zinc Bnte P"

Overpack drum liquid

solids

light reddish orange liquid

Eight yellow liquid






clear liquid with green tint

brown sludge

fine dark brownish gray ashy solid, no liquidsheterogeneous, blue-green chips between fine and~ 2mm diameter, no liquids

very dark brown liquid, oily

grey sludge, contains small black, grey, and whiteparticles

light brownish grey with white particles, powderysolid

light brown, fine grain powdery solid

grey and brown, mostly fine powdery solid withsome larger particles mixed


2000

1600

1500

500

30

55

65

40

50

50

50

65

50

50

20

unknown

Total Capacity

55-gallon

5S-gallon

55-gallon

55-gallon

55-gallon

55-gallon

55-gallon

75-gallon

75-gallon

75-gallon

75-gallon

75-gallon

75-gallon

75-gallon

Field Test Results


pH=2; dark brown liquid

pH=7, brown liquid

>H=7; blue and coppercolored marshmallow-likesolid

pH=2, light brown liquid

pH=7, light brown liquid)H=ll,gray liquid withsediments

pH=7

pH=7

pH=7

pH=7

pH=7

pH=7

pH=7

pH=7

pH=7

p H = l l

pH = 5

pH=l 1, negative for CN, butreactive with additionalsulfuric acid

p H = l l

pH=ll

p H = l l

pH=5

Lab Results

CN = 3,290mg/L

CN = 6.74 mg/kgZn > TTLC

Pag«2of3



State ManifestNo.

24428391

24428391

pending

pending

pending

24428392

ROB#

2-20-208

1-20-422

1-20-422

ERRSColorCode

White

blue

blue

blue

No code

1

1

START ID

44

45A

45B

46A

46B

47A

47B

48A

48B

49A

49B





75-gallon yellow salvage drum, inside

3,000 gallon poly tank in former hazardous waste treatment area,outdoors

clarifier near plating line, inside



reddish brown liquid

grayish brown, mostly fine solid with larger (~1in.) diameter pieces mixed

yellow oily-hke liquid (-6 inches deep)

oily sludge; brown with black specks

thick, colorless liquid

light grayish white, flaky solid

brown liquid

colorless liquid


Total Capacity

55-gallon

75-gallon

75-gallon

75-gallon

3,000

Field Test Results

pH = 7

pH=l l ;maybeCNcontaining; Hazcat test forCN turned teal not dark blueas it should if CN is present

pH=10

pH = 1 1 ; negative for CN, buthighly reactive withadditional sulfuric acid

pH=12; negative for CN, buthighly reactive withadditional sulfuric acid

PH=13

pH=12; negative for CN, buthighly reactive withadditional sulfuric acid

pH-7

Lab Results

Color Cole Guide:Blue -causticGreen « contains cyanideWhite -pH neutralRed B acidichighlight ™ need to verify dram Id and contents

2005 ecology & environment, me

Page 3 of 3

APPENDIX 2

PRELIMINARY LABORATORY RESULTS SUMMARY TABLEJune 21, 2005

24

i

Contaminant

AntimonyArsenicBariumBerylliumCadmiumChromiumCobaltCopperLeadMolybdenumNickelSeleniumSilverThalliumVanadiumZincTotal Cyanide

Amenable Cyanide

t Industrial Zinc Plating if I I I I , - .-A^,-* •' ' ^ ','r -'*"'* i

SamIZP-V5-L1 IZP-T21C-L1

(mg/L) (mg/L)

CN too high to run metals bis required during digestior

create toxic levels c

147,000 3,290

IZP-T20-L1(mg/kg)

/c acidificationi, which would>fHCN

4,140

CN too high to run amenables b/cchlorination used during analysis will

cause high HCN

Notes

N/A Not Applicable

TTLC Total Threshold Limit Concentration

TCLP Toxicity Characteristic Leaching Procedure

mg/kg milligram per kilogram

mg/L' milligram per liter

pie IDIZP-V7-L1

(mg/L)21510.1

0.191<0.05

0.00989 J0.395<0.0517.71.149.19

0.08770.147

0 0208J<0050.415126

0.976

IZP-V7/9-S1(mg/kg)

25< 1.41

69<1 4134.11,29021.6

11,50039915

44.9<1.416.26437136

169,0005.95

IZP-T26-SL1<mg/kg)

264< 1.91

13< 1.9151.8

2,31048.16654.63

<9.5481.9

<1 91< 1.9169.5

0963 J

242,0006.74

expected Monday 6/27/05

TTLC(mg/L)

500500

10,000075100

2,5008,0002,5001,0003,5002,000100500700

2,4005,000N/A

N/A

TCLP(mg/L)

N/A5

100N/A15

N/AN/A5

N/AN/A15

N/AN/AN/AN/A

N/A

2005 ecology & environment, me

Documents

SFUND RECORDS CTR 2072529 - US Environmental … 648,000 in direct extramural costs to mitigate threats to human health and the ... following day to perform field chemistry ... waste