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Narrative:
Week's Activities Overview
Over the week beginning the September 16th, 2013 work focused primarily on the following activities:
- Finalizing the site health and safety plan
- Finalizing the site air monitoring plan
- Continued clearing of the land surrounding the battery pile, rear asbestos pile, mercury knob and 1.5 acre where cover will be installed.
- Continuing to improve of access paths to hillside waste piles
- Completion of excavation of the battery pile and rear asbestos pile, and staging of waste for treatment. Approx 868 tons of clean fill were received and used for backfilling this week, as of 9/19/13.
- Initiated installation of once section of the 1.5 acre cover
Soil Monitoring:
Throughout the site, after excavation of predesignated waste piles, remaining soil will be screened with the XRF to determine the amount of lead, copper, and arsenic remaining in the soil, if any. If levels of metals in remaining soil exceeds the residential direct contact criteria (RDCC), soil will be demarkated before backfilling.
This week, the XRF was used to screen the battery pile area during excavation to delineate the area that needed to be excavated and help determine the depth of contamination. After excavation, screening showed that lead in remaining soil in battery pile area (in the hole) was below the residential direct contact criterion of 400 parts per million (ppm).
Air Monitoring and Sampling:
Every day that cover installation and excavation and loading of contaminated soils will be ongoing air monitoring will be conducted to ensure public and worker safety. This work (and therefore air monitoring and sampling) began on 9/16/13.
Chemical hazards due to fugitive emissions from removal activities are anticipated to be low since the crew will employ administrative and engineering controls (i.e.; barricades, warning signs, and suppression measures) to minimize fugitive emissions and particulates (dust) that migrate off-site.
Meteorological data will be obtained daily from the NWS website that provides current weather conditions at the Houghton County Airport (Airport Code: KCMX) and documented in the site logbook.
Perimeter Air Monitoring:
Datarams are deployed along three of the perimeter boundaries where off-site receptors are most at risk to exposure from fugitive emissions. The smelter facilities were built into the northwest facing hillside, therefore monitors have been placed along the north, east, and west site boundaries. Real-time particulate data will be transmitted back to the site command post where it will be monitored continuously.
A website has been established to view the current and past perimeter air monitoring data for the site. To view the data go to the web address: viper.ert.org. You have to create a login on your first visit to the site. Once you have logged in, go to the R05 Michigan Smelter Deployment to view site data.
The perimeter action level for particulate has been set at 500 micrograms per cubic meter (μg/m3). Should a DR4 unit detect sustained particulate concentrations greater than 500 μg/m3, administrative and/or engineering controls will be initiated to reduce the particulate emissions.
During the week of September 16, 2013, no exceedances of 500 ug/m3 were detected.
Exclusion Zone Air Monitoring and Sampling:
Personal DR (PDR) particulate air monitors are deployed in the exclusion zone during active excavation and capping activities. The particulate monitors data-log instantaneous and time weighted average (TWA) particulate concentrations during active excavation/loading operations. The data logging averaging period is set to log at 60-second intervals. Data logs will be downloaded and stored on a daily basis.
The concentrations of contaminants identified in the removal assessment analytical results were used to establish a site-specific action level of 95 μg/m3 for total particulates for the exclusion zone. The crew will implement appropriate engineering control measures if an exceedance of the established action level is sustained for more than 60 seconds. Action level exceedances will be managed by setting the monitor to alarm at the established action level to notify on-site personnel.
During the week of September 16, 2013, no exceedances of 95 ug/m3 were detected.
Integrated air sampling for personnel exposure characterization was performed by ERRS for inorganic contaminants and asbestos in the breathing zone. ERRS collected samples from personnel with the greatest potential for exposure within the exclusion zone for each job classification over for a full shift (minimum of seven hours) over the first three days of intrusive activities. If the exposure assessment reveals employee exposures to be below the action level, further exposure determination will be discontinued. If there is a change of equipment, process, control, or a new task has been initiated that may potentially result in an employee being exposed at or above the action level, additional air monitoring shall be conducted. Should the sample results indicate exposures over the OSHA permissible exposure limits and site-specific action levels, engineering controls will be adjusted and an additional three days of air sampling will be conducted.
These samples were collected over the first three days of intrusive work during the week of September 16, 2013.
Results that have been received back to date show no detections of lead or arsenic.
Specific activities completed each day are described in further detail below.
Activities on 9/16/13
- Continued clearing and grubbing the land surrounding the battery pile, the rear asbestos pile, the mercury knob waste pile and the area to be capped.
- Installed erosion and sedimentation controls adjacent to Coles Creek, to prevent erosion from battery pile excavation and restoration into the water body.
- Initiated excavation of the battery pile in level C PPE, and staged waste for treatment/disposal
- Initiated a detailed asbestos survey of the site
- Continued to develop/improve access to the hillside waste piles.
- Implemented dust control measures
- Exclusion zone particulate
air monitors deployed in the vicinity of the work measured particulate
concentrations ranging from 0.03 µg/m3
to 53.87 µg/m3. Exceedances
of site action levels were not recorded.
- Perimeter air monitoring was initiated
along the north and east site boundaries. Exceedances of site action levels
along the site perimeter were not recorded.
Activities on 9/17/13
- Continued clearing and grubbing the land surrounding the battery pile, the rear asbestos pile, the mercury knob waste pile and the area to be capped.
- Continued excavation of the battery pile - approx 90% complete at days end, and staged waste for treatment. Excavation work was conducted in Level C personal protective equipment.
- Begun excavation of rear asbestos pile next to battery pile, and staged waste for disposal
- Completed the detailed asbestos survey of the site
- Continued to develop/improve access to the hillside waste piles.
- Implemented dust control measures
- Exclusion zone particulate air monitors deployed in the vicinity of the work measured particulate concentrations ranging from 0.16 µg/m3 to 47.6 µg/m3.
- Particulate air monitors along the site perimeter did not record any exceedances of Site action levels.
Activities on 9/18/13
-Completed excavation of the battery pile and begun backfilling with clean soil. The excavation averaged approximately one foot in depth and covered an area of approximately 6,000 square feet. Stockpiled contaminated soil has been covered with plastic sheeting while treatment, transportation and disposal arrangements are coordinated.
- Completed excavation of rear asbestos pile next to battery pile and begun backfilling with clean soil. This area is adjacent to the battery pile area and is included in size calculations listed above for battery pile area.
- Completed the detailed asbestos survey of the site. 21 samples of material that could contain asbestos were submitted for analysis. The materials include fire brick, asphaltic roofing material, mortar, and weathered fibrous deposits.
- Implemented dust control measures
- Exclusion zone particulate air monitors deployed in the vicinity of the work
measured particulate concentrations ranging from 0.09 µg/m3 to 59.64 µg/m3.
- Particulate air monitors along the site
perimeter did not record any exceedances of Site action levels.
Activities on 9/19/13
- Continued backfilling the battery pile and rear asbestos pile areas with clean soil
- Additional debris piles of suspect asbestos containing materials, possible transite siding, were identified approximately 10 feet north of the haul road, east of the Battery Debris Area. The crew excavated the suspect building debris and underlying soil and transferred the waste to the staging area. Material is covered in plastic.
- Initiated installation of a portion of the 1.5 acre cover by installing sand backfill along the haul road up to the Battery Debris Area
- Implemented dust control measures
- Exclusion zone particulate air monitors deployed in the
vicinity of the work measured particulate concentrations ranging from 0.02 µg/m3 to 39.2 µg/m3.
- Particulate air
monitors along the site perimeter did not record any exceedances of Site action
levels.
Activities on 9/20/13
- Begun installing topsoil and establishing final grade over backfill in battery pile area, rear asbestos pile area and haul road cover area for final restoration
- Implemented dust control measures
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
A general notice letter was issued to the Copper Range Company on November 5, 2012. A response was received from indicating that they were unsure about their liability and do not have the financial resources to conduct the removal action at the site. Investigation is ongoing.
2.1.4 Progress Metrics
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2.2.1 Anticipated Activities
The following activities have been planned for this removal action:
- Developing and implementing a site-specific Health and Safety Plan, including an Air Monitoring Plan, and a site Emergency Contingency Plan;
- Developing and implementing a site Work Plan that includes a Site Security Plan;
- Removing the mercury knob waste pile, 2 hillside waste piles, and the battery debris pile;
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Posting boundaries of terraces that contain contamination, and which cannot safely and practically be accessed for cleanup, with signage regarding the presence of contamination;
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Delineating subsurface contamination and installing an approximately 6-inch thick cover over metal-contaminated soil within an approximately 1.5-acre area;
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Removing piles of asbestos-containing materials for off-site disposal;
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Consolidating and packaging all materials containing hazardous substances, pollutants and contaminants for transportation and off-site disposal;
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Backfilling and restoring excavated and disturbed areas;
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Transporting and disposing of all characterized or identified hazardous substances, pollutants, wastes, or contaminants that pose a substantial threat of release at a Resource Conservation and Recovery Act/CERCLA-approved disposal facility in accordance with EPA’s Off-site Rule (40 C.F.R. § 300.440); and
- Addressing releases from other contaminated media in accordance with applicable, appropriate, and relevant requirements to the extent practicable.
The response action proposed will mitigate the threats at the site by properly identifying, consolidating, and packaging hazardous materials, pollutants, and contaminants on-site. The consolidated materials will be removed and ultimately disposed of off-site. Additional site activities may include security, perimeter air monitoring, and decontamination on the site, as needed to complete the removal action. This response action will be conducted in accordance with Section 104(a)(1) of CERCLA, 42 U.S.C. § 9604(a)(1) and Section 300.415 of the NCP, 40 C.F.R. § 300.415, to abate or eliminate the immediate threat posed to public health and/or the environment by the presence of the hazardous substances. Direct contact threats with hazardous substances are expected to be minimized at the site once the removal action is completed.
2.2.1.1 Planned Response Activities
2.2.1.2 Next Steps
Next week, primary tasks planned are excavation and backfilling of the mercury knob area, and other waste piles, time permitting .
2.2.2 Issues
None.
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