SFUND RECORDS CTR

2104204

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION IX

75 Hawthorne StreetSan Francisco, CA 94105

MEMORANDUM

SUBJECT Request for a Time-Critical Removal Action at Graybill Metal Polishing,Inc , Los Angeles County, California

FROM Craig Benson, On-Scene CoordinatorEmergency Response Section (SFD-9-2)

TO Daniel Meer, ChiefResponse, Planning & Assessment Branch (SFD-9)

THROUGH Peter Guna, ChiefEmergency Response Section (SFD-9-2)

I PURPOSE

The purpose of this Action Memorandum is to obtain approval to spend up to$ 464,400 in direct extramural costs to mitigate threats to human health and theenvironment posed by uncontrolled hazardous substances (cyanide, chromium,hexavalent chromium, copper, cadmium, lead, nickel, zinc, acids and caustic liquids andsolids) in bulk and non-bulk containers, sludges, soils, and building materials associatedwith the unmanaged metal plating and polishing facility known as Graybill MetalPolishing, Inc (the Site) The Site is located at 1245 East Florence Avenue, LosAngeles, County of Los Angeles, California (90001) 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 May 9, 2006, the United States Environmental Protection Agency (EPA) initiatedan emergency response action to mitigate the threats posed by abandoned plating andmetal polishing and buffing wastes EPA's On-Scene Coordinator (OSC) utilized hisdelegated authority to spend up to $200,000 to initiate emergency characterization,stabilization and re-contamenzation of hazardous substances

The actions proposed in this document would transition from the OSC's emergencystabilization activities and complete the time-critical removal of the threat from hazardoussubstances remaining at the Site These time-critical actions include the off-Site transfer

and disposal of secured and re-containerized hazardous wastes and hazardoussubstances and the continuing identification and removal of contaminated sludges, soils,building materials and debris that pose threats to the public and the environment Specificthreats are described below

The Administrative Record for this action includes the California Department of ToxicSubstances Control (DTSC) Compliance Inspection Report for an inspection DTSCconducted on October 18, 2005 (DTSC Inspection Report) and EPA's observations duringa joint DTSC/EPA Site assessment conducted on May 9, 2006, as described herein

II SITE CONDITIONS AND BACKGROUND

Site Status Non-NPLCategory of Removal Time-CriticalCERCLISID CAN000908399SITE ID 09NZ

A Site Description

1 Physical location

The Site is located at 1245 East Florence Avenue, in the unincorporated of LosAngeles County area generally known as the Florence-Firestone area, near the City ofLos Angeles, California (90001) The Site occupies two adjacent parcels comprisingone lot in a mixed commercial/residential neighborhood The coordinates of the Site areN 33° 58'30 9", W 118° 15'08 8"

2 Site characteristics

The Site is located on an approximate 11,000 ft2 lot in a commercial/residentialarea, less than one-quarter mile east of the City of Los Angeles boundary The Siteconsists of one approximate 8,000 ft2 building divided into a polishing and buffing area(east) and plating area (west) The asphalt paved back lot (north side of parcel) housesan additional chrome and nickel strip line and a separate storage shed, and is generallycongested with empty tanks, containers, used equipment, automobiles and other debrisThe back lot is surrounded by a fence that is bordered on the north by residences,including individual homes and apartments, and on the east by a convenience storeparking lot The facility structure is abutted to the west by a business operating a metalanodizing facility (See Figure 1)

Graybill Metal Polishing Inc (Graybill) conducted copper cyanide, nickel andchrome plating and metal polishing and buffing operations for automobile parts andhardware According to the DTSC Inspection Report, Steven Graybill began operatingthe facility in 1964 after purchasing an interest in American Electro-Plating, Co , Inc(operated by Forrest Graybill III, presumably Steven Graybill's relative), which had

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operated a plating facility on the property since approximately 1932 American Electro-Plating, Co , Inc is a defunct corporation Steven Graybill's son, Jonathan Graybill, isthe current facility manager The property is owned by the Van Bergen Family Trust(Ralph Van Bergen Jr, trustee)

3 Removal site evaluation

DTSC's Emergency Response Branch referred the Site to EPA, providing awritten Request for Federal Action on May 10, 2006 On May 9, 2006, OSCs CraigBenson and Jason Musante conducted a walkthrough inspection and removal siteassessment with DTSC State Regulatory Programs Division representative RobertBrushia, Ph D , and DTSC Emergency Response Unit representatives DavidRasmussen and George Baker Also present were personnel from the SuperfundTechnical Assessment and Response Team (START) contractor, Jonathan Graybill,and Dick Howes and Rik Vollaerts of the Heger Realty Corporation Heger Realty isretained by the Van Bergen Family Trust to sell the property EPA received signedaccess agreements from Jonathan Graybill and Dick Howes OSC Benson alsoreceived verbal consent to access the Site in a telephone conversation with Ralph VanBergen Jr None of the parties have conditioned their grant of access, and all of theparties declined an interest in split samples

During the assessment, EPA observed a large quantity of liquid and solidhazardous waste streams that included caustic, acidic, cyanide bearing and metalbearing plating process solutions in unsecured plating vats, containers marked toinclude hazardous wastes, and waste treatment sumps and clanfiers Metal polishingand buffing dust, containing hazardous concentrations of cyanide, chromium, coppernickel, lead, selenium and zinc (per DTSC analysis) also were scattered throughout thefacility and on the ground outside the facility Accumulated chemical waste was evidentthroughout the plating and collection sump and clanfier areas and covered thecontainment flooring, wooden walkways, and vats Numerous drums marked to containhazardous wastes (but without a notation of the accumulation start date) and containersof process chemicals were present inside the building and back lot area

The building, chemical storage areas and plating lines were found in extremelypoor condition Gaps in the perimeter fencing, shattered window glass, torn metalsiding and holes in the roofs of the mam building and storage shed allowed for directaccess and contaminant migration to the exterior

DTSC analytical results from the October 18, 2005 DTSC Compliance Inspectionwere available for review during the assessment Dr Brushia stated that facilityconditions appeared unchanged from the date of DTSC's previous inspection Theanalytical results from several vat, sludge, and grinding dust samples documentedelevated and hazardous waste determining concentrations of cyanide and numerousmetals including, chromium, hexavalent chromium, cadmium, copper, nickel, lead, zinc,and selenium (DTSC Inspection Report) In many cases, the significant concentrations

of cyanide, zinc, copper, nickel or chromium were detected in the uncontained sludgesand buffing and polishing dust A summary table of the DISC analytical results iscontained in Appendix 1

The START conducted field chemistry analysis on accessible larger tanks andcontainers, and confirmed the presence of oxidizing solutions, cyanide solutions andacidic and corrosive solutions both inside the building and in the back lot JonathanGraybill provided confirmation of the content of various plating vats and tanks during aportion of the inspection START prepared a preliminary inventory listing largercontainer descriptions, volumes and field chemistry results, included with thismemorandum as Appendix 2 There are dozens more chemical containers and anundetermined volume of contaminated debris, sludges, building material, soils,concrete, and sump and clanfier system materials awaiting full inventory andcharacterization Based on the apparent characterization, EPA observed incompatiblematerials stored in close proximity, which creates an additional risk of chemical reactionresulting in combustion, explosion or toxic vapor

Jonathon Graybill represented to EPA that Graybill had abandoned the Site,leaving the hazardous materials in the unsecured building (During most of theinspection, Jonathon Graybill was, in fact, packing his computer, some furniture andother personal effects ) Based on the Site conditions, OSC Benson gave a generalnotice of CERCLA liability to Ralph Van Bergen Jr (by telephone) and to JonathanGraybill Ralph Van Bergen Jr represented that he would continue to work with HegerRealty Corp and Dick Howes in the hopes of finding a buyer or cleanup firm willing toassume work within the current constraints Jonathan Graybill represented that Graybillhad no plans for cleanup nor cleanup funds, and subsequently left a set of keys to thefacility and departed the premises

Based on the observed Site conditions, the unsecured and unmanaged nature ofthe facility, and field confirmation results, on May 9, 2006, OSC Benson initiated animmediate stabilization and removal action in accordance with his delegated responseauthority

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

Field testing and DTSC laboratory analytical data have confirmed the presenceof large quantities of corrosive solutions, high concentration cyanide solutions andnumerous heavy metal contaminated waste streams associated with the former metalplating and buffing and polishing 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 chrome, hexavalent

chrome, copper, lead, nickel, zinc, and selenium in Site wastes in excess of theCalifornia Total Threshold Limit Concentration and the California Soluble ThresholdLimit Concentration waste determining threshold concentrations (See Appendix 1)

RCRA characteristic and listed wastes, including chromium, hexavalentchromium, copper, lead, nickel, zinc and selenium, are hazardous substances asdefined by Section 101 (14) of CERCLA Other hazardous substances or pollutants andcontaminants not discovered to date or not specifically identified herein may exist at theSite These substances also may pose a threat to human health and the environment

There is no security at the Site and the hazardous contents of the wastes andsubstances are accessible by adjacent residences, neighboring businesses, andvagrants The potential for fire, vandalism and continuing deterioration of the Sitestructures and containers at the unmanaged Site may result in the combustion, physicalexposure or commingling of incompatible hazardous substances resulting in harm to thepublic health or welfare or the environment Considering the proximity of nearbybusinesses and public highways, the Site represents a significant threat of releaseaffecting nearby populations

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 May 9, 2006, the EPA Emergency Response Program conducted a removalassessment of the Site Based on the findings of this assessment, OSC Bensondetermined that emergency conditions existed at the Site, he utilized his delegatedauthority to expend up to $200,000 to initiate emergency characterization, stabilizationand re-contamerization of hazardous substances to mitigate the threats posed at theSite

C State and Local Authorities' Roles

1 State and local actions to date

According to the DTSC Inspection Report documenting a joint DTSC and localCertified Unified Program Agency (CUPA - Los Angeles County Fire Department)compliance inspection conducted on October 18, 2005, the facility has been the subjectof numerous past inspections, notices of violation, and enforcement orders issued byDTSC, the CUPA and the Los Angeles County Sanitation District (LACSD) State andlocal agencies have documented numerous violations of state hazardous waste controllaws and LACSD discharge restrictions In April 2006, the California Attorney General'sOffice delivered a Unilateral Cleanup Order to the Graybill business operators and the

property owner However, DTSC requested EPA's assistance because the parties werenot complying with the clean up order and the Site conditions continued to deteriorate

2 Potential for Continued State/Local Response

Each of the state and local agencies have asserted a lack of resourcesnecessary to undertake the required cleanup action at this time Accordingly, DTSCrequested EPA's assistance

OSC Benson has discussed the nature of the on-going emergency responseaction with DTSC and the LACSD A DTSC Project Manager has agreed to coordinatewith the OSC and work to ensure a smooth transition from EPA emergency and time-critical response actions to possible DTSC and/or Los Angeles Regional Water QualityControl Board (RWQCB) long term remediation efforts DTSC or the RWQCB will besolicited for input into the design of any future subsurface evaluation that may takeplace at the Site

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 Assistance from the organizations likely will be limited totechnical support and services, rather than direct financial contribution to the response

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, ofCERCLA hazardous substances that threaten the public health or welfare, or theenvironment, based on the factors set forth in the National Oil and HazardousSubstances Pollution Contingency Plan ("NCP"), 40 C F R § 300 415(b)(2) Thesefactors include

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 unmanaged and unsecured heavy metalsolutions, sludges and debris containing chromium, hexavalent chromium, copper, lead,nickel, zinc and selenium These hazardous substances exist in liquid and solid wastesdeposited throughout the facility and in Site debris and building materials There alsoare large quantities of acidic and strong caustic cyanide laden plating solutions andwastes in open and degraded vats The proximity of incompatible acidic solutions andcyanide bearing solutions in severely degraded containers poses a threat of mixing andcreating toxic hydrogen cyanide gas

Buffing and polishing dust accumulated on the facility floor and on the groundand exterior surfaces of the facility contains hazardous concentrations of chromium,copper, nickel, zinc, selenium, lead and cyanide EPA's observation that this dust is onthe ground outside the facility and has escaped the facility through open windows anddoors suggests that the dust may have migrated off-site There are residences,including private homes and an apartment complex bordering the facility to the northand east, and these residences may have been, or are being, impacted by releases ofthe hazardous buffing and polishing dust

Although the Site property is fenced, gaps in the fence leave pedestrian accessrelatively unimpeded The facility remains a human health risk to any vandals ortrespassers, including young children, who might enter the premises Direct contact,inhalation or mgestion of the hazardous substances at the Site poses an acute healththreat to these individuals Toxic fumes and smoke may reach populations outside theSite in the event of a facility fire or the mixture of incompatible chemicals The threat ofrelease and subsequent exposure "s high Threats from specific materials at the Siteare discussed below

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

Chromium is an eco-toxic heavy metal that is an inhalation, mgestion, 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

Hexavalent chromium can cause irritation to the nose, such as runny nose,nosebleeds, and ulcers and holes in the nasal septum Ingesting large amounts ofhexavalent chromium can cause stomach upsets and ulcers, convulsions, kidney andliver damage and death Skin contact with certain chromium compounds can causeskin ulcers The World Health Organization has determined that hexavalent chromium isa human carcinogen The Department of Health and Human Services has determinedthat certain hexavalent chromium compounds are known to cause cancer in humansThe EPA has determined that hexavalent chromium in air is a human carcinogen

Lead is a heavy metal that bio-accumulates in human tissues Short-termexposure to large amounts of lead can cause harmful effects on the nervous system,gastrointestinal system, kidneys, and circulatory system Long-term exposure to lowlevels, such as those that occur in the work place, can cause damage to the centralnervous system, kidneys, blood, gastrointestinal tract, and gmgival tissues

The large quantity of solutions exhibiting the hazardous waste characteristic of

corrosivity presents a direct contact and inhalation threat that could cause severe burnsof the skins and lung tissue Corrosive solutions at the Site are attributed to

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

No specific contamination of a drinking water supply has been identified to date

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

Over 5,000 gallons of caustic, acidic, cyanide bearing and metal bearing platingprocess solutions, held in severely degraded and unsecured plating vats, product andwaste containers, waste treatment sumps and clanfiers have been identified throughoutthe Site Other drums and containers at the Site are improperly utilized, marked orlabeled EPA observed leaking tanks of unidentified material, and releases outside ofcontainment of plating bath residues and sludges In addition, numerous RCRAmarked drums of hazardous waste and unmarked containers of process chemicals,wastes and debris were present inside the building and back lot area These drums donot state an accumulation start date There remains at the Site an undeterminedvolume of contaminated debris, sludges, building material, soils, concrete, and sumpand clanfier system materials awaiting full inventory and characterization

Off-Site laboratory analytical results for the purposes of waste profiling andacceptance at an approved disposal facility is pending A complete inventory of all

8

containers and their contents will only be possible during subsequent response activitieswith the necessary health and safety program elements

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

Contamination of the soils underlying the plating process lines and chemicalstorage areas will be investigated In a statement to DISC, Jonathan Graybill statedthat at one time in the facility's history (time unknown) the facility had a dirt floor andthey were plating over a dirt floor, so "we know there are hazardous chemicals in the dirtunder the shop"

As detailed below, a key goal of this proposed response action is to furtherdelineate and remove 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 building roof isdeteriorated in areas in a manner that will allow rainfall to enter the facility directly overthe abandoned plating line Surface water runoff contaminated with cyanide and otherheavy metals could migrate off-Site, which could pose a human health risk toneighboring communities Further, weathering of structural debris and wastecontainment areas by wind, sun and ram can cause the deterioration of remainingmaterials and will result in an ongoing release of heavy metals and cyanidecontaminated materials

6 Threat of fire or explosion

Waste and chemical containment areas are not fully secure and have not beencompletely assessed The documented presence of oxidizing materials, exposedelectrical wiring, unknown conditions and vandalism could affect fire safety or result in arelease if the chemicals 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 plating and polishing and buffingoperations and remove for disposal, as necessary, all exposed materials posing animminent threat of endangerment The U S EPA will not investigate or respond to deepsoil or groundwater 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 DTSC and the LACSD for consideration in any further activities understate or county 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 this 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

10

Consistency with the long-term remedy

As stated above, removal activities undertaken in this action will be consideredand incorporated into state and county 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 NCR The nature of the removal,elimination of all threats, is, however, expected to eliminate or minimize the need forpost-removal site control

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 415Q) 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

11

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, 49CFR 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

5 Project schedule

Emergency removal activities were initiated on May 9, 2006 Removal activitieswill require approximately two months to complete

B Estimated Costs

Regional Removal Allowance Costs

Cleanup Contractor $ 357,000

Extramural Costs Not Funded from the Regional Allowance

START Contractor $ 30,000

Extramural Subtotal $387,000

Extramural Contingency (20%) $77,400

TOTAL, Removal Action Project Ceiling $464,400

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 III and IV above, actual or threatened releases of hazardous substances fromthe Site, if not addressed by implementing the response actions selected in this ActionMemorandum, will continue to present an imminent and substantial endangerment topublic health or welfare, or the environment

VII OUTSTANDING POLICY ISSUES

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

VIII ENFORCEMENT

12

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

Intramural Costs'

US EPA Direct Costs $30,000

U S EPA Indirect Costs(35 28% of $464,400 + $ 30,000) $ 174.424

TOTAL Intramural Costs $ 204,424

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$668,824 Of this, an estimated $357,000 comes from the Regional removal allowance

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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IX RECOMMENDATION

This decision document represents an appropriate removal action for the GraybillMetal Polishing Inc , Site, at 1245 East Florence Avenue, near Los Angeles, California,as developed in accordance with CERCLA and not inconsistent with the NCR Thisdecision is based on the Administrative Record for the Site

Because conditions at the Site meet the NCR 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 $464,400, of which an estimated$357,000 comes from the Regional removal allowance You may indicate yourdecision by signing below

Approve _, Daniel Meer, Chief Date /

I ^ Response, Planning and Assessment Branch

DisapproveDaniel Meer, Chief DateResponse, Planning and Assessment Branch

14

Enforcement Addendum

Index to the Administrative Record

Figures

Figure 1 Site Layout Map

Appendices

1 Summary Table of DISC Analytical Results

2 Preliminary Large Container Inventory and Field Chemistry Results

cc Sherry Fielding, USEPA, OEM, HQDirector, California Department of Toxic Substances Control

bcc Site FileJohn Jaros, SFD-9-4Craig Benson, SFD-9-2Andrew Helmlmger, ORC-3Celeste Temple, SFD-9-4

15

Index to the Administrative Record

California Department of Toxic Substances Control (DISC), Compliance InspectionReport (undated) for an inspection conducted on October 18, 2005, w/outattachments

START Removal Assessment Report - pending

17

Figure 1

Site Layout Map

18

RESIDENTIAL AREA

I I

STA BRITEANNODIZING

DEBRIS

DEBRIS

PLATINGAREA

BREAK.ROOM

330

DEBRIS

RIB:

KJJI1

10

OFFICE

SHED DEBRIS

DRAIN LINE

II

METALPOLISHINGAREA

RB4

24Polishing

Dust

RB -

R B I .

|22|

Clainfier

RB2.

RECEPTION

23lairift

CONVIENENCESTORE ANDAPARTMENTS

2 Tank ID Number

.. .;•> USEPA Sample Location

RB3 DISC Sample Location

GRAYBILL METAL POLISHING1245 EAST FLORENCE AVENUE

LOS ANGELES CA

FIGURE 1SITE LAYOUT AND

SAMPLE LOCATIONS

APPENDIX 1

Summary Table of DTSC Analytical Results

19

Summary of D1SC Analytical Results

(Samples collected October 18 2005)

RISC >ff DTSC , >'DtSC,j. IO/J8/J005 \UVlM005

Ji I ' iDTSCJ/ -,.1. ^

Location Summa

. ^Suuip lutiier In~ tpufflng rbtmi outii^clwfirt' f -ifrofti floor

10I8D5RBII?-' .JI01805RB2», ,IQtro5ltB3jl&t°ita5ltB4:, ', lOliOStt&ttr

Antimony (Sb)

Ch omi rn(Cr>

Molybdenum (M i)

Antimony (SbJ

(Bi)

Cuppc (Co)

MolybdenunnMo)

Cyanide (mg/L)

Ditx only includes elevated cuiutituenu rcpurted in Ihc DTSC Inspection Rcpon without iltachnKnti

APPENDIX 2

Preliminary Large Container Inventory and Field Chemistry Results

20

Preliminary START InventoryLarge Containers

May 9 2006

,' i. , „. <^ „ ' , . - "< ,* UI A") <AV"l4W«;C ln%liM»ntbifr >.>,', ,^^,w^,,v'4i\^^AC^% it^&^^1 jt!^Jiii'&<1!Lf-.' ' <. > .">>- u- .', r*f l „ i t , . / r Com9/ners»hiroMatloh. 4*'S£'&i!} •i'bb.&j >L* !, V^WSfcf?i,i > A-i

rID ,12

34567

89101112

1314151617

1819202122

2324

' X-' _(',. _ , /./ X

,. Location1 ' ! '•'j ,Inside plating lineInside plating lineInside plating lineInside plating line

Inside ott plating lineInside plating lineInside plating lineInside platingjmeInside plating lineInside plating lineInside plating lineInside plating lineInside plating line

Outside in striper areaOutside in striper areaOutside in striper areaOutside in striper areaOutside in striper areaOutside in striper area

Outside NE cornerSump Inside near tank 10Clanfier Polishing room

Clanfier Outside east wallThroughout site

V' , fj '. Slze^aljt

6804207001100700

50050015015015015015055450275100505015

300NANA

NA

Varies

^ ,,? ,#£'^Volume <ga|h'

340MT

525363

1/2 solid250

250MT

150100MT1004035027550351515

275NA

NANA

Unknown

Process Step/Label;& 'iH4in$n&fy>r$ m.Bright nickel bathPreliminary cleanerCopper cyanideBright nickel bathUnknownBright nickel bathChromium TrioxideChrome dragoutChrome dragoutChrome dragoutChrome dragoutNickel StrikeZincateNickel StripNickel StripNickel StripNickel StripNickel StnpNickel StripZincateDischarge to dander1st clarifier 3 staqge2nd clarifierPolishing

V*"' -'Cbritefvf'De^cflptkn^ ii)Green clear liquid 8 sludgeBlack skudge 2Clear/yellow liquid 6 sludgeGreen clear liquid 4 green sludgeWhite solud materialGreen clear liquidDark brown liquidBlack sludge 2Dark brownClear liquidDebrisDark green liquidGreen/yellow liquidClear yellow liquidMint green liquid 1 sludgeClear brown liquidClear green liquidClear green liquidClear green liquidOpague brown liquidGreen/yellow liquidDark grey Cloudy sludge approx 3Clear liquidPolishing Dust covers entire site

^•to/CMfrtfW* i

3&6

11

6116

3

37

4

14141

1111

1

1111

83

763

*»'Vjf s?*'Oxldizer

NNNNNN

NN

NNNN

NNY

NNYYN

1P4SyanlrJiNNYNNNNNNNNNNNNNNNNN

•$m<^n,,,,,;

NNNNN

NNNN

NNN

NNN

NNN

NN

N

.lf$&I?$J*i f" *""£'S«^4HiB'/, ^Mfev.",r, ~' % J,,,* A -,, c\,; i:tbrres1,ondlngBa-rnPle3

GB01

GB03 101805RB5 GB CN

GB 07 GB CR

GB 14 GB NiSGB 15 GB NiS

GB Sump101805RB1101805RB2 _,

101805RB3 101805RB4

':•! ' • -tWaste Group;

NeutralNACaustic/cyanideNeutralCausticNeutralAcidNAAcidNeutralNANeutralCausticCausticOxidizerCausticAcidOxidizerOxidizerCausticCausticNA

NotesGB x USEPA sample

101805RBX DTSC sampleTable represents only a partial inventory of the largest accessible containers on site at the time of the removal assessment Complete inventory of all bulk and non bulk containers to follow

ERRS 2 ContractsEQM Labor and Equipment Rate Comparison

Site Name

Option Year 4/Contract Year 5

CLIN 0001

A PERSONNELDESCRIPTION

Response ManagerForemanEquipment OperatorPASCleanup TechChemistIH / Health & SalelyT&D CoordinatorSubcontract Manager

PERSONNELDESCRIPTION (OT)

Response ManagerForemanEquipment OperatorPASCleanup TechChemistIH / Health & SafetyT&D CoordinatorSubcontract Manager

DO Number 02-016-9074

ifcijMax LHitW

160

120160480

16040

Totals

'-4"$C~~.asB* *&3a

-> _, EQj Ij.'" $t

LFHH;*Vi&£

$$$

643341 924091

$ 31 41$ 2895$$$$

3947428262597333

^*^y^v*$3s?$*£: RPE&^^^ tSf -kV-

$ 1029280$$$$

4 909 205 025 60

1389600$$$$$

1001440293320

47 071 20

132

88132160

132

TotalsTotal Labor

6433628861 37471243433947428262597333

8 491 56

5 400 566219846 948 80

8 261 88

35 322 6482,393 84

B EQUIPMENT CLASSIFICATIONS

RCMS EQUIPMENT DESCRIPTION

1 01 10 Truck Boom1 03 20 Truck Box 2 Ton1 09 10 Truck Passenger Car1 15 30 Dump Truck Euclid1 36 10 Truck Pickup1 36 20 Truck 4 Wheel Drive1 42 10 Truck Road Tractor1 45 10 Truck Stakebed 1 Ton1 45 20 Truck Stakebed 2 Ton (with lift gate)1 51 18 Truck Vacuum 1800 gal1 51 35 Truck Vacuum 3500 gal2 20 20 Personnel Decon trailer 8 x25 approx2 25 40 Trailer Equipment 8 x40 Personnel

Decontamination enclosed self containedwith HVAC and emergency shower

25515 Office Trailer with steps small(less than 40 ft)

2 55 40 Office Trailer with steps large(more than 40 ft)

2 70 10 Trailer Storage less than 40 f2 70 20 Trailer Storage 40 ft or greater301 10 Backhoe Case 580 Jdeere410C

JCB 1400B or equivalent3 10 20 Dozer Cat D4 with 6 way blade

or equivalent3 10 40 Dozer Cat D6 with 6 way blade

or equivalent3 10 80 Dozer Cat D10 with 6 way blade

or equivalent

f<*4 **V ^ ^c ••>»''<• •"*£''*,DAYS/^?-'V&rV OS"*"

21

21

v: sKAbs-SPRi^x^^r^^csji^.'UNIT.~-°WPRICE-C-S&.

$$$$

22868114374871

60838$ 5042$$$$$$$

64943030810824135305628770359121 73

$ 17861

$ 2706

$$$

378810821624

$ 17319

$ 31392

$ 48711

$ 1 894 28

ESTIMATED^^SS^'AMOUNT J&r^g&f

$$$ 1 022 91$$$ 1 363 74$$$$$$

$

$

$$$

$

$

$

$

ERRS 2 Contracts3 15 20 Compactor Roller (Vibratory)3 20 20 Crane 20 ton3 30 40 Excavator CAT 205L or Case 688

or equivalent3 30 45 Attachment articulating Bucket 1 2 3 yards33055 Excavator CAT 215/315 or equivalent3 30 65 Excavator CAT 225/229/325 or equivalent3 35 10 Fork Lift Small (2 tons or less)3 35 12 Fork Lift Large (over 2 tons)3 40 10 Road Grader3 45 31 360 Degree rotation Hydraulic Drum Grappler3 55 20 Front end loader crawler

CAT 933/935 or equivalent3 55 30 Front end loader crawler

CAT 943/935 or equivalent3 55 40 Front end loader crawler

CAT 943 or equivalent3 60 40 Front end loader/wheeled

CAT 936E Case 721 or equivalent3 60 60 Front end loader/wheeled

CAT 988B Dresser 560B or equivalent3 60 70 Front end loader/wheeled

CAT 988B Dresser 560B or equivalent3 65 20 Heavy Duty Scraper3 95 10 Uni Loader w/ Bucket3 95 35 Uni Loader Barrel Grappler Attachment4 06 30 Flash Point Analyzer5 01 05 Air Monitoring Detection Pump5 01 20 Photoionization Detector5 01 25 Flame lomzation Detection

Monitor (OVA), 5 01 35 Radiation Detector5 05 15 Cascade/Airline System

with 5 mm SCBA escape5 15 10 Hand Held Radio7 1520 Boat 14/167 15 42 Boat Motor 10 to 50 h p721 10 Compressor Air 185 CFM7 23 20 Computer Portable PC (IBM

compatible) with printer7 35 10 Copy Machine (plain paper copier)7 45 10 Facsimile Machine (plain paper copier)7 51 05 Generator 5 kw7 51 20 Generator 10 kw7 51 40 Generator 50 kw75310 Portable Heating Capabilities

Space Heaters7 67 30 Emergency lighting (light plant)7 96 30 Water Laser Meduim Pressure

Multigun (2500 5000 psi)8 12 20 Pump Centnfugal 2 inch8 18 30 Pump Double Diaphragm 3 inch8 21 10 Pump Diesel 2 inch8 54 15 Pump Trash 3 inch9 05 05 Oil Harbor boom 6m 12m skirt 50 ft length

10

10

10

10

10

Total

$$

191 5930850

$$$$$$$$

238 141190640592448 131082490923788611906

$ 27062

$ 311 75

$ 33556

$ 351 81

$$

$ 2 381 40$$$$ 1 082 40$$$

$

$

$

$

$ 51958

$$$$$$$

9742178477111 496494259820574736

$

$$$$$$$

$$

75783788

$$

3247812

$ 1840$$

22756494

$$

10822706

$ 1624$$$

270654 1212448

$$

12987036

$$$$$$

71 44378837884546422281 18

$$

$ 32470$$$$

$$$$$$

$$ 70360

$$$ 37880$$$$ 7,257 55

SubtotalTravelMiscAnalyticalT&DSubtotalG&AG&A SubsContmgncyGrand Total

82%27%

1000%

$$$$$$$$$S

89 651 397 000 00

18000002 000 00

200 000 00316651 39

2 050 0005 454 000

32415539356,570 93