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Colorado Precision Plating. Presented by Craig Myers, OSC. CO Precision Plating. This used to be Colorado Precision Plating, a small niche market plating facility that serviced the aerospace industry near Boulder, Colorado. CO Precision Plating. Fire at a plating shop, early morning 12/12/11

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colorado precision plating

Colorado Precision Plating

Presented by Craig Myers, OSC

co precision plating
CO Precision Plating

This used to be Colorado Precision Plating, a small niche market plating facility that serviced the aerospace industry near Boulder, Colorado.

co precision plating1
CO Precision Plating
  • Fire at a plating shop, early morning 12/12/11
  • Local Volunteer Fire Dept on scene
  • Regional HazMat team arrives, sees water run off, asks IC to stop fire suppression effort
  • First in unit has bunker gear with a residual pH of ~3
  • Local VFD requestes EPA’s assistance
    • Emergency decon, tyvek suits, disposed of bunker gear
    • new gear overnighted to staff their house the next day…
epa s role
EPA’s Role
  • VFD has insufficient resources to remain overnight…wants to put the fire out.
  • Fire Chief wants our advice
co precision plating2
CO Precision Plating
  • EPA is asked to assess the run off
    • Is it just fire fighting water, or is it more?
    • Reservoir ¼ mile away, water supply for Longmont
    • Only instant test is pH and visual (chrome, anodizing dies, etc)
  • However…
co precision plating3
Co Precision Plating
  • Business is a tenant on the property, leased the structure.
  • Property owner and spouse went to the hospital
    • 80+ years old
    • Treated and released; not answering cell phone.
  • Business owner died in October, business in probate, the widow is not answering either…
  • Access should be granted by both, as they both have 4th and 5th Amendment rights on the property.
emergency phase
Emergency Phase
  • Citing protection of the public good:
    • I had START enter the property to
      • Conduct in situ pH tests
      • Take limited samples of the runoff water
      • and document visual observations
    • Nothing that could be construed as “enforcement related” was done.
      • Actions were to support the VFD’s needs
      • And to make immediate decision about the protection of a water supply
    • No product samples
      • Building still too hot, structurally unsafe
      • Could not articulate immediate protection of the public interest to justify the takings
removal phase
Removal Phase
  • Access granted 12/13/11
  • Building is unstable, waste cannot be assessed safely until building is dismantled and/or demolished.
complications
Complications
  • Arson investigation
    • Can’t happen until haz-waste removed
  • Haz Waste Removal
    • Can’t happen until building is demolished
  • Building Demolition
    • Will destroy any evidence for arson investigation
  • BCSO and Hygiene Fire decide to forego the arson investigation and turn the property over to the property owners/EPA
current state 12 13 11
Current State 12/13/11
  • Unstable building
  • Unknown amount of incompatible Haz-waste
    • Acids, bases, metal laden solutions
    • All in compromised containers
    • Assumed to be around 5,000 gallons
  • Building was built before 1980
    • Does it contain Asbestos Containing Building Materials (ACBM)? Almost certainly.
    • Asbestos assessment cannot be performed…
a recurring issue
A Recurring Issue
  • NESHAPS
    • Colorado has Reg. 8, other states have similar regulations governing asbestos removal
    • Has “emergency exemptions”
      • Still take time to gain state approval of the exemption
      • Require PE to determine building structure unsound.
    • Implemented at the state level by Air Programs, not Haz Waste
      • Thus staff not familiar with CERCLA/ARARs
arars
ARARs
  • Applicable or Relevant and Appropriate Regulations
    • CERCLA actions must comply with substantive provisions, to the extent practical.
    • Cost and Project delay are both factors to consider when determining practicality. (see 1990 NCP Preamble)
unsafe for occupancy
Unsafe for Occupancy
  • Signed by local building official
    • Unsafe ≠ Structurally Unsound…
    • May or may not be a Professional Engineer
      • Required for emergency exemption under NESHAPS
did epa comply with neshaps
Did EPA comply with NESHAPS?
  • Very cold ~ 10° F
  • Wet demo, to the extent practicable
  • Assumed all fire debris contained ACM.
  • Used ARAR authorities in 400(g) and 415(j).
  • Disposed in NESHAPS cell
waste characterization
Waste Characterization
  • Unique numbers
  • Samples HazClassed
    • Major DOT hazard classes and RCRA characteristic waste codes
    • Allows waste to be bulked prior to disposal.
site assessment
Site Assessment
  • Surface water sampling of all fire fighting water and surface expressions
    • Low level detections in the creek during fire fighting operations
  • Soil sampling where fire fighting water had pooled and at French drain outfall.
    • French drain outfall very high
  • Soil borings via GeoProbe near leachfield, French drain outfall, and other locations.
    • Ubiquitous low level contamination
questions

Questions?

Craig Myers

Myers.craig@epa.gov

(303) 312-7067