1.1.1 Incident Category
Removal action under an Action Memorandum.
1.1.2 Site Description
Former electroplating facility essentially abandoned in place
1.1.2.1 Location
4000 - 4008 E. Monument Street

Baltimore, MD 21205
1.1.2.2 Description of Threat
Potential release of plating acids and other materials into the environment
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

 After site visits on May 3, 2016 and May 18, 2016, the OSC issued a special bulletin on May 19, 2016 and initiated a cleanup at the site.  This was amended on May 27, 2016 to increase the project ceiling.  On June 2, 2016, an Action Memorandum was signed authorizing a removal action at this site.  See the documents section of this website for the Special Bulletins and Action Memorandum.

2.1.1 Narrative
Cleanup continues.
2.1.2 Response Actions to Date

Due to the poor condition of the building (leaking roof, etc.) water builds up in the sumps and on the floors after heavy rains.  This sump water continues to be pumped from the building into a holding tank onsite awaiting offsite disposal. A shipment of sump water, totaling 2,700 gallons was shipped offsite for proper disposal on 7/8/16.   All disposal facilities are checked for compliance status to ensure that they meet all environmental regulations before wastes are shipped.  Water samples are being collected from all sumps in the building to determine which are most contaminated, and whether some of the sump water can be discharged to the City sanitary system if it meets the discharge criteria.

 Waste materials in the building are being marked and staged with compatible wastes for bulking prior to disposal. Bulking operations continue, with the following wastes having been bulked in 250 gallon containers in preparation for offsite shipment and proper disposal: caustics 2,750 gallons; Flammables 500 gallons; Cyanide wastes (from electroplating vats) 1,000 gallons.  Because of the volume of neutral liquids, they are being bulked into a frac tank.  As of 7/15/16, approximately 7,000 gallons have been collected.  Most of the containers/vats in the yard out back have now been emptied, and the containers turned over so no more rainwater can collect in these containers/vats.  Others that still contain waste liquids have been covered to prevent additional accumulation of rainwater.

On 7/8/16 the lab pack subcontractor completed segregating and packaging lab chemicals.  The following containers were filled with various segregated wastes:  1 one gallon container, 13 five gallon containers,  2 fifteen gallon containers, 2 twenty gallon containers, 4 thirty gallon containers, 14 fifty-five gallon drums, and 5 cubic yard boxes.  These materials will be shipped offsite as soon as approvals are in place and transportation can be arranged. 

Air monitoring throughout the building is conducted on an ongoing basis.  Five air monitoring units are set up while work is ongoing: three inside the building and two outside.  Volatile organic compounds, oxygen, lower explosive limit, carbon monoxide, hydrogen cyanide, and chlorine are monitored on a continuous basis, and any alarms are sent out to the OSC and contractors monitoring the system.  In addition, air samples were collected and analyzed, and compared to relevant worker exposure standards.  No excessive levels of contamination were identified in the building.  However, all work in the building continues to be conducted with the use of respiratory protection (respirators or supplied air, depending on the nature of the work).

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Research on PRPs is ongoing.
2.1.4 Progress Metrics

2.2.1 Anticipated Activities
Categorization, staging, and disposal of hazardous substances will continue.  Shipment of hazardous and non-hazardous wastes will continue throughout the project.  Shipment of the cyanide salts is scheduled for 7/25/16.  Overpacking and/or bulking compatible waste streams in preparation for offsite disposal will continue.  The remaining wastes include ammonia caustics, neutral liquids, acids, peroxides, oxidizers, sludges from electroplating vats, and other miscellaneous wastes.

2.2.2 Issues

The building is in poor condition. There is no electricity in the building.  Electricity is being provided through the use of generators with extension cords and lighting strings throughout the building.  Heavy rains slow work in the building due to leaks in the roof and water flowing in from the yard. 

3.1 Unified Command
The EPA took the lead for the site on Thursday, June 2, 2016.  Baltimore City Fire, Police, and Housing Departments and Office of Emergency Management, Maryland Department of the Environment, and EPA are continuing to coordinate on the response.

OSC - 1

START - 2

ERRS - 9