\\m)UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGIONS77 WEST JACKSON BOULEVARD

CHICAGO, IL 60604-3590 EpA Regjon , Records ctr.

MEMORANDUM

DATE:

259397

REPLY TO THE ATTENTION OF

SE-5J

SUBJECT: ACTION MEMORANDUM - Request for Approval of Funding In The Amountof $791,796 for a Time Critical Removal Action at the Northwestern PlatingWorks Site. Chicago. Cook County, Illinois

FROM:

TO:

ris, On-^pene CoordinatorErrteJ-gerfcy Response SecticjiU^ , n

Emergency; Response Section 3

Richard Karl, DirectorSuperfund Division

: \

THRU: Linda Nachowicz. Branch Cruef {]\ i \ j ,__/

Emergency Response Branch V/v -y t^Cr^ /N .Site ID#: B5DP H [}

I. PURPOSE

The purpose of this memorandum is to request approval to expend up to $791,796 to abate animminent and substantial threat to public health and the environment present at the NorthwesternPlating Works Site. Chicago, Cook County. Illinois (Site) (latitude 41 °50' 11.1481" north andlongitude -87°43' 58.3321" west). This action is necessary to mitigate the immediate threat topublic health and the environment posed by the presence of uncontrolled hazardous substancesfrom metal-plating waste, which include barium, cadmium, chromium, lead, cyanide andcorrosive and caustic liquids. On April 3. 2006. Branch Chief Linda Nachowicz authorized$50.000 to perform emergency stabilization at the Site.

The response action proposed herein wil l mitigate Site conditions by removal and off-sitedisposal of the contaminants of concern. The high levels of heavy metals, cyanides, corrosi veand caustic l iquids at concentrations considered hazardous, and the Site's proximity to residentialand business properties require that this action be classified as a time critical removal. Theproject w i l l require an estimated 90 working days to complete.

There are no nationally significant or precedent setting issues associated with the NorthwesternPlating Works Site. The Northwestern Plating Works Site is not on the National Priorities List(NPU

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 50% Recycled Paper (20% Postconsumer)

II. SITE CONDITIONS AND BACKGROUND

CERCLIS ID # LLN005 10086

A. Site Description

1. Site history

A limited amount of history is known about the Northwestern Plating Works (NPW) Site.According to the Chicago Department of Environment (CDOE), operations ceased at this facilityin August 2005. However, Mr. David Jacobs, the principal of the corporation which is thecurrent owner of the facili ty, was unresponsive in providing CDOE with a closure plan. Basedon inspections by CDOE, large amounts of plating chemicals and waste from plating operationswere stored at the facili ty in an unsafe manner. CDOE was concerned about the potential healthhazards from chemicals and wastes at this Site posed to nearby residents and other receptors, andthe potential for the facility to dispose of the plating materials illegally. After apparentvandalism at the facility on March 6, 2006, CDOE referred the Site to the U.S. EPA on March 9,2006.

When a voluntary access agreement was not forthcoming from Mr. Jacobs, on March 31, 2006,Region V enforcement counsel, assisted by the U.S. Attorney's Office in the Northern District ofIl l inois , sought and obtained an ex-parte civil administrative warrant that allowed U.S. EPA'sentry, inspection and the taking of samples and copying of records. The samples taken pursuantto this warrant became the basis of the Site assessment report.

2. Physical location

The NPW Site is located at 3114 South Kolin Avenue, Chicago, Cook County, Illinois. TheNPW Site occupies approximately 0.5 acre in a mixed commercial and residential area. Thegeographic coordinates for the NPW Site are latitude 41 ° 50' 11.1481" north and longitude -87°43' 58.3321" west. The plating facility is one block west of Pioprowski Park, one of the parks inthe Chicago Park District system, located at 4247 West 31st Street, and one block east of LittleVil lage High School, which is located at 3120 South Kostner Avenue.

According to the Region 5 Superfund Environmental Justice Analysis, the population within aone mile radius of the Site is 40,264. Of these 40,264 persons, 95% are classified as minority.Approximately 46% of the families residing in this block group have an income of less than theestablished state low income level. To meet the Environmental Justice (EJ) concern criteria inI l l i n o i s , the area wi th in 1 mile of the Site must have a population that is at least 54% low-incomeand/or 64% minority. Therefore, the demographic conditions indicate an environmental justicepriority for the community around this Site.

3. Removal Site evaluation

On April 3, 2006. U.S. EPA On-Scene Coordinator (OSC) Michael Hams, OSC Jim Mitchell,and Superfund Technical Assessment and Response Team (START) members Dave Franc and LizLehnertz arrived at the site to conduct assessment activities, including documentation of siteconditions, collection of samples tor threat analysis, and inventory of the materials stored at theNPW Site. Other personnel present on the Site included representatives from CDOE and theU.S. EPA's National Enforcement Investigations Center (NEIC).

U.S.EPA and START conducted initial air monitoring operations in Level C PPE. Airmonitoring equipment used at the NPW Site consisted of MultiRAE and Multiwarn multiple gasmonitors which monitored for carbon monoxide, hydrogen sulfide, hydrogen cyanide, lowerexplosive limits, and volatile organic vapors. In addition, hydrogen cyanide levels were alsomonitored with the use of a Drager PAC HI hydrogen cyanide monitor. Air monitoring resultsidentified slightly elevated readings of hydrogen cyanide at a maximum sustained level of 0.8part per million (ppm). The NIOSH exposure limit for hydrogen cyanide is 4.7 ppm. Therefore,it was determined that any work that included sampling and site stabilization inside the buildingwas to be performed in Level C PPE. Other work, which included Site Recon, was performed inLevel D PPE. Air monitoring was performed during all site activities, but no sustained hydrogencyanide levels above 0.8 ppm were noted. After conducting initial air monitoring, STARTdocumented the site layout and general building conditions and U.S. EPA and STARTformulated a sampling plan based on observations.

The NPW Site consists of a building, an attached shed, and an open space area used for storage.The building was in fair condition, but a number of holes in the roof and several broken windowswere observed. The interior of the building consisted of an office area, warehouse area,maintenance area, boiler room, a pickle and clean room, and two shipping and receiving docks.

The warehouse portion of the building is where plating operations occurred. NPW baseoperations consisted of plating brass, zinc, copper and cadmium to other solid surfaces. Sevenrows of vats supported the plating of these metals. Each vat contained 30-40 gallons of variousliquids. These liquids solutions were labeled, "cleaner," "rinse." "acid," "zinc," "cadmium""copper," "dip," and "nickel." The majority of these vats were observed to be overflowing ontothe floor. Leaking and staining of the concrete floor was observed near Plating Line 4, the zincplating line. During the site assessment, it was raining and water was entering the warehousethrough holes in the roof. Water was hitting the vats and pooling on the floor. Standing waterfrom the floor on the southwest portion of the warehouse measured a ph of 10. Unidentifiedsolid materials were on the floor in several areas of the warehouse. Four large above groundstorage (AST) tanks were observed in the warehouse. These tanks are believed to supportcyanide and heavy metal treatment operations. The AST included a 1,200 gallon cyanidereduction tank, a 3.000 gallon ph adjust tank, a 6,000 gallon clarifier tank, and a 5,000 gallonset t l ing tank. The warehouse also contained a cyanide fil ter press, numerous unidentified drums.

and seven 1 cubic yard bags of solid waste with a Department of Transportation (DOT) label of3077 ( RCRA hazardous waste) was noted on the bag.

The interior of the office area contained gun shell casings, ammunition powder, a 9 foot by 9 footfloor tile potentially composed of asbestos, and various small receptacles of chemicals, includingcyanides and bleach. The interior of the maintenance area contained several compressed air gascylinders and other unidentified buckets with liquids as well as tools. The boiler room held aboiler, pipe insulation potentially containing asbestos, and a vent and fi l l pipe, indicating thepossible presence of an underground storage tank (UST). The areas in the loading dock includedtwo rows of pallets with drums stacked three rows high. Some of these drums contain solidwaste; others are labeled "cyanide standard." Also within the loading dock area is an 8 foot by 8foot pressurized oven that is believed to have been used for thermal treatment of concentratedcyanide waste such as spent plating or stripping solutions.

The interior of the shed, which is adjacent to the loading dock, contained several drums,numerous unidentified vessels, and an unknown material on the floor. The outside storage areaheld numerous drums and receptacles, two empty 4,000-gallon ASTs, several propane tanks, anda UST containing unknown material.

Approximately 179 drums and various containers were noted at the NPW Site, the majority ofwhose contents are unidentified. The condition of the drums ranged from fair to unopened, andseveral of the drums did not have lids.

On April 4, 2006, U.S. EPA OSCs Michael Hams and Jim Mitchell, and START members DaveFranc and Liz Lehnertz returned to the site to complete site assessment activities. Otherpersonnel present at the site included representatives from CDOE, EPA Criminal InvestigationDivision (CID), EPA National Enforcement Investigations Center (NEIC), IllinoisEnvironmental Protection Agency (EEPA), ERRS, and at the request of CID, the Naperville FireDepartment.

On April 3 and 4. 2006. START collected a composite floor sample and samples from solidplating waste materials, solid waste from the floor of the building, three open vats, and one ASTto evaluate whether the NPW Site poses a threat to human health or the environment.Specifically, START secured one solid waste sample from a 1 cubic yard bag, one solid wastesample of material on the floor, and three liquid waste vat samples on April 3, 2006. STARTcollected one liquid waste sample from an AST and one composite floor sample on April 4,2006. START acquired the samples under the direction of U.S. EPA OSCs Michael Hams andJim Mitchell. Samples that were collected were determined based on visual observations andfield pH screening of the contents in some drums and containers. Sampling activities arediscussed below. The samples were submitted to STAT Analysis Corporation (STAT) inChicago. I l l inois , for various analyses including Target Analyte List (TAL) metals, toxicitycharacteristic leaching procedure (TCLP) metals, pH, total cyanide, reactive cyanide, andhexavalent chromium.

Vat sample W-01 was a l iquid waste sample collected from an open vat labeled "Zinc Die CastAcid Tank" on Plating Line 1. Field pH screening indicated that this liquid was highly corrosivewi th a pH between 1 and 2.

The results for waste sample W-01 contained low concentrations of the following TCLP metals:arsenic, cadmium, chromium, lead, and selenium. The sample included detectableconcentrations of the following TAL metals: aluminum, antimony, barium, cadmium, calcium,chromium, copper, iron, lead, magnesium, manganese, nickel, potassium, silver, and zinc. Inaddition, the sample contained a detectable concentration of total cyanide (0.027 milligram perliter [mg/L]). The pH of the liquid waste sample was determined to be 1.2, indicating thepresence of a highly corrosive liquid.

Vat sample W-02 was a liquid waste sample collected from an open vat labeled "Cyanide CopperPlating Tank" located on Plating Line 1. Field pH screening indicated that this liquid had a pHof 10.

The results for waste sample W-02 included low concentrations of the following TCLP metals:arsenic, chromium, lead, and selenium. The sample was composed of detectable concentrationsof the following TAL metals: antimony, arsenic, barium, calcium, chromium, cobalt, copper,iron, lead, magnesium, manganese, nickel, potassium, selenium, vanadium, and hexavalentchromium. In addition, the sample contained detectable concentrations of total cyanide (1.9mg/L) and reactive cyanide (1.2 mg/L). The pH of this sample was 10.1, indicating the presenceof a basic liquid.

Vat sample W-03 was a liquid waste sample collected from a ful l , open vat labeled "NickelPlating Tank" located on Plating Line 6.

The results for waste sample W-03 contained low concentrations of the following TCLP metals:barium, chromium, and lead. The sample was composed of detectable concentrations of thefollowing TAL metals: barium, beryllium, calcium, chromium, cobalt, copper, iron, lead,magnesium, manganese, nickel, potassium, and zinc. In addition, the sample containeddetectable concentrations of total cyanide (0.2 mg/L) and reactive cyanide (0.24 mg/L). The pHof this sample was 4.70.

Sample W-04 was a solid waste sample collected from the floor. The sample was a whitecrystall ine solid.

The results for waste sample W-04 and its duplicate, W-04D. contained a concentration of TCLPtotal chromium at 12 mg/L and 24 mg/L exceeding the 5 mg/L threshold for "MaximumConcentration of Contaminants for the Toxicity Characteristic" as reported in 40 CFR Subpart C261.24. This indicates that the sample is a RCRA hazardous waste. The sample includeddetectable concentrations of the following TAL metals: chromium, copper, iron, sodium, zincand hexavalent chromium. In addition, the samples contained detectable concentrations of total

cyanide (45,000 milligrams per kilogram [mg/kg] in sample W-04 and 63,000 mg/kg in sampleW-04D) and reactive cyanide (17 mg/kg in sample W-04 and 32 mg/kg in sample W-04D). ThepH of this sample was 11.0, indicating the presence of a basic solid.

Sample W-05 was a solid waste sample collected from a full bag of plating waste material. Thebag was labeled as being 1,000-kilograms in weight and F006 RCRA hazardous plating waste; aU.S. Department of Transportation (DOT) label of 3077 (hazardous waste) was noted on the bag.

The results for waste sample W-05 contained low concentrations of the following TCLP metals:chromium, silver, and mercury. The sample was composed of detectable concentrations of thefollowing TAL metals: aluminum, antimony, arsenic, barium, cadmium, calcium, chromium,cobalt, copper, iron, lead, magnesium, manganese, nickel, potassium, silver, sodium, zinc, andmercury. In addition, the sample contained a detectable concentration of total cyanide (1,400mg/kg). The pH of this sample was 8.5, indicating the presence of a neutral solid.

Sample W-06 was a liquid waste sample collected from a full AST in the northeast portion of thebuilding.

The results for waste sample W-06 included a low concentration of the TCLP metal arsenic. Thesample was composed of detectable concentrations of the following TAL metals: aluminum,arsenic, banum, cadmium, calcium, chromium, copper, iron, lead, magnesium, manganese,nickel, potassium, silver, sodium, and zinc. In addition, the sample contained a detectableconcentration of total cyanide (1.9 mg/L). The pH of this sample was 8.6, indicating thepresence of a neutral liquid.

Sample W-07 was a composite floor sample collected from three areas—two areas near theplating lines in the warehouse portion of the building and one area in the shed.

The results for waste sample W-07 contained a concentration of cadmium at 4.2 mg/L exceedingthe TCLP regulatory constituent level of 1.0 mg/L, again indicating a RCRA hazardous waste.The sample also was composed of low concentrations of the following additional TCLP metals:banum, chromium, silver, and mercury. The sample contained detectable concentrations of thefollowing TAL metals: aluminum, antimony, arsenic, barium, cadmium, calcium, chromium,cobalt, copper, iron, lead, magnesium, manganese, nickel, potassium, selenium, silver, sodium,zinc, mercury, and hexavalent chromium. In addition, the sample included concentrations oftotal cyanide (30,000 mg/kg) and reactive cyanide (3.6 mg/kg). The pH of this sample was 8.6,indicating the presence of a neutral solid.

B. State and Local Authorities' Role

1. State and Local actions to date

On March 8, 2006, CDOE requested that the U.S. EPA Region 5 Emergency Response Branchconduct a time critical removal assessment and possible removal action at NPW Site Works Site.Based on recent inspections by CDOE, the facil i ty is storing large amounts of plating waste in anunsafe manner. The facility building is not completely secured; vats and receptacles in thebuilding contain waste to overflow. In addition, the Metropolitan Water Reclamation Districthas observed color and pH changes in effluent from the facility. CDOE is concerned about thepotential health hazards from plating wastes at this Site to nearby residents and other receptors,and the potential for the facil i ty 's principals to dispose of the material illegally.

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

The conditions at the NPW present an imminent and substantial threat to the public health, orwelfare, and the environment and meet the criteria for a removal action provided forin the National Contingency Plan (NCP), Section 300.415, Paragraph (b)(2). 40 C.F.R.§ 300.415(b)(2)(I), ( i i i) and (v), respectively, specifically allows removal actions for:

1. Actual or potential exposure to nearby human populations, animals, or thefood chain front hazardous substances or pollutants or contaminants;

According to the Agency for Toxic Substances and Disease Registry (ATSDR), cadmium andnickel may reasonably be anticipated to be human carcinogens, and hexavalent chromium is ahuman carcinogen. When ingested, zinc can cause stomach cramps, nausea, and vomiting.Taken longer, it can cause anemia and decrease levels of good cholesterol. Exposure to highlevels of cyanide for a short time harms the brain and heart and can even cause coma and death.

An elevated level of reactive cyanide was detected in the vat sample W-02: an elevated level ofnickel was detected in vat sample W-03; elevated levels of chromium, zinc, hexavalentchromium, and total and reactive cyanide were detected in solid waste sample W-04; elevatedlevels of cadmium, chromium, nickel, zinc, and mercury were detected in the solid waste platingsample W-05: and elevated levels of cadmium, chromium, zinc, and total and reactive cyanidewere detected in the composite floor sample W-07. Cyanide salts are readily absorbed throughingestion, inhalation, and skin contact. Particular cyanide salts such as potassium cyanide arecorrosive to the skin and can enhance the absorption through the skin. Interaction of cyanidesalts wi th acids can generate hydrogen cyanide gas, which is highly toxic. While cyanide saltsare not combustible, exposure to fire can liberate hydrogen cyanide gas and nitrogen oxides. Themolten cyanide salts remain a direct contact hazard. In addition, concentrations exceeded theregulatory constituent levels for TCLP chromium (sample W-04) and TCLP cadmium (sampleW-07), making these samples illegally stored hazardous waste. As discussed above, each of

these constituents are a hazardous substance and present a threat to nearby human populations.The pH of vat sample W-01 was 1.2, which suggests the l iquid is h ighly corrosive. Theaccessibility of the building to humans and animals is evidenced by the reported recent vandalismthat occurred and the holes in the building roof.

2. Hazardous substances or pollutants or contaminants in drums, barrels, tanks, orother bulk storage containers that pose a threat of release;

START documented the presence of multiple full 55-galIon drums and other various sizedcontainers at the site, the contents of which are unknown. In addition, START observed liquidson the floor around many of the vats, suggesting that several of the vats may be leaking. Asdiscussed above, analytical results indicate the presence of hazardous, caustic and corrosivesubstances inside the building.

The building has reportedly been the target of vandalism. It is possible the building could bevandalized again, which could result in spills of unknown or hazardous and possiblyincompatible substances onto the surrounding floors: furthermore, such spills could migrate toother areas of the site and possibly off site. Spills of corrosive materials in the vicinity of cyanidewastes could cause the release of cyanide gas. Such a release could endanger students at theLittle Village High School, which is located one block west of the Site, or participants inprograms at Pioprowski Park, one block east of the Site.

3. Weather conditions that may cause hazardous substances or pollutants orcontaminants to migrate or be released;

Cook County receives approximately 33.8 inches of rain each year. Analytical results indicatethe presence of hazardous substances inside the building, including cyanides, heavy metals, andcorrosive liquids. Holes were observed in the building roof, allowing rain and snow to enter.The rain and snow could cause the open-top containers to overflow onto the surrounding floorsand then migrate to other areas of the site and possibly off site.

4 Threat of fire or explosion;

According to the CDOE, the site has been vandalized, and during U.S. EPA's removal siteevaluation, staff from the City of Chicago's Graffiti Removal Program was removing graffitifrom the roof. It is possible that the site building could be vandalized again, which presents apossible threat of fire or explosion.

5. The availability of other appropriate federal or state response mechanisms torespond to the release;

On March 8, 2006, the Chicago Department of Environment asked the U.S. EPA - Region V,ERB to proceed with a time-critical removal action at the NPW Site. Neither the City of Chicagonor the State of I l l ino i s have the funds to undertake removal of the metal-plating waste materialfound at this Site.

IV. ENDANGERMENT DETERMINATION

Given the conditions at the NPW Site, the nature of the hazardous substances on-site, and thepotential exposure pathways described in Sections n and HI above, actual or threatened releasesof hazardous substances from this Site, if not addressed by implementing the response actionsselected in this Action Memorandum, present an imminent and substantial endangerment topublic health, or welfare, or the environment.

V. PROPOSED ACTIONS AND ESTIMATED COSTS

The OSC proposes to undertake the following actions to mitigate threats posed by the presence ofhazardous wastes at the Northwestern Plating Works Site:

1) Develop and implement a Site Health and Safety Plan, including an air monitoring planand Site contingency plan;

2) Develop and implement a Site Security Plan:

3) Drums, smaller containers, vats, floor sweepings, unknown materials, facility contents,debris, and tanks will be sampled, analyzed, categorized and staged for disposal.Compatible waste streams wil l be bulked/re-containerized, and appropriately prepared fordisposal at off-site disposal facilities.

4) Emptied tanks, piping, debris, drums and other containers wil l be cleaned as necessary,cut to size and disposed of at off-site disposal facilities.

5) Floors, walls, ceilings, building components and contents wi l l be cleaned and/or disposedof as soon as reasonably possible to remove contaminated dust and material to preventcontaminant migration or cross contamination of cleaned areas.

6) Characterize, remove and properly dispose of hazardous substance and wastes located atthe Site in accordance with U.S. EPA's Off-Site Rule (40 CFR 300.440);

10

The OSC has initiated planning for provision of" post-removal Site control consistent with theprovisions of Section 300.415(1) of the NCP. The nature of this removal action, as well as thecomplete removal of all hazardous wastes from the Site, wi l l el iminate the need for any postremoval Site control.

The estimated costs to complete the above activities are summarized below. These activities wi l lrequire an estimated 90 working days to complete.

EXTRAMURAL COSTS;

Regional Removal Allowance Costs: $599,830Total Clean-up Contractor Costs

Other Extramural Costs Not Funded from the Regional Allowance:Total START, including multiplier costs $ 60,000

Subtotal, Extramural Costs $659,830

Extramural Costs Contingency $131.966(20% of Subtotal, Extramural Costs)

TOTAL, REMOVAL ACTION PROJECT CEILING $791,796

The response actions described in this memorandum directly address the actual or threatenedrelease at the Site of a hazardous substance, or of a pollutant, or of a contaminant which maypose an imminent and substantial endangerment to public health or welfare or to theenvironment. These response actions do not impose a burden on affected propertydisproportionate to the extent to which that property contributes to the conditions beingaddressed.

Applicable or Relevant and Appropriate Requirements

All applicable, relevant, and appropriate requirements (ARARs) will be complied with to theextent practical. A letter has been sent to Bruce Everetts of the Illinois EPA on July 6, 2006requesting that the Illinois EPA identify State ARARs. Any State or Federal ARARs identifiedin a t imely manner for this removal action will be complied with to the extent practical.

VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYEDOR NOT TAKEN

Continued risk to public health and the environment wi l l result if no action or delayed actionensues.

11

VII. OUTSTANDING POLICY ISSUES

None.

VIII. ENFORCEMENT

For administrative purposes, information concerning the enforcement strategy for this Site iscontained in an Enforcement Confidential Addendum (see Attachment B).

The total EPA costs for this removal action based on full-cost accounting practices that will beeligible for cost recovery are estimated to be $1,275,016.50 '

($791,796 + 30,000) + (55.15% x $821,796) = $1,275,016.50

IX. RECOMMENDATION

This decision document represents the selected removal action for the Northwestern PlatingWorks Site, Chicago, Cook County, Illinois, developed in accordance with CERCLA asamended, and is not inconsistent with the NCP. This decision is based on the AdministrativeRecord for the Site (see Attachment C). Conditions at the Site meet the criteria of the NCP, 40C.F.R. § 300.415 (b) (2) for a removal action and I recommend your approval of the proposedremoval action. The total estimated project ceiling, if approved, will be $791,796. Of this, anestimated $599,830 may be used for cleanup contractor costs. You may indicate your decisionby signing below:

APPROVE: DATE:Superfund Division Director

DISAPPROVE: DATE:Superfund Division Director

Direct Costs include direct extramural costs and direct intramural costs. Indirect costs are calculated based on anest imated ind i rec t cost rate expressed as a percentage of site-specific direct costs, consistent with the ful l cost accountingmethodology effective October 2. 2000. These estimates do not include pre-judgment interest, do not take into account otherenforcement costs, inc luding Department of Justice costs, and may be adjusted dur ing the course of a removal action. Theestimates arc tor i l lus t ra t ive purposes only and their use is not intended to create any rights for responsible parties. Neither thelack of a to ta l cost estimate nor deviation of actual total costs from this estimate w i l l affect the United States' right to costrecovers

REMOVAL PROGRAMACTION MEMORANDUM

ROUTING SLIP

(Site Name)

1)

2)

3)

4)

5)

6)

7)

8)

9)

Don't forget to sign the yellow!

ON-SCENE COORDINATOR (MC SE-5J or(Assures thai Enforcement Confidential Addendum from the Enforcthe Adminis t ra t ive Record (AR) Documents are avai lable and the dr

ADMINISTRATIVE RECORDS COORDINATOR (MC(Jan Pfundheller: Assures that the AR is complete and the "Officialdav turnaround) '

^^ ® 'nt Specialist is included;

Index is included)

SECRETARY, RS I/II/III (MC SE-5J or SE-GI)(RS-I Secretary (Grosse Isle) will mail AM to RS-III Secretary for tracking purposes .. 1-dayturnaround)

OFFICE OF REGIONAL COUNSEL: (C-14J)^STAFF ATTORNEY (*>herru t5teS ) ^> * l \ OGORC SUPERVISOR(3-day turnaround on this document per the ORC-WMD Memorandum of

Understanding)

CHIEF, RS/I/II/III (MC SE-5J or SE-Gl(3-day turnaround)

CHIEF, ERB (MC SE-5J) (Linda Nachowicz)(3-day turnaround)

ERB SECRETARY (LOG-OUT) (MC SE-5J)(1-day turnaround)

DIRECTOR, SUPERFUND DIVISION (Rick Karl(MC S-6J)

FINAL PROCESSING: MC SE-5JTO RS II SECRETARY (For RS-II Action Memos)TO RS III SECRETARY (For RS-I and RS-III Action Memos)

(Original Action Memo, yellow copy, and this sheet are filed in ERB Site File.Photocopies of signed original go to OSC and to D.O. File (with D.O. and P.R.); bee'sare distributed.)

Attachments:A. Detailed Cleanup Contractor EstimateB. Enforcement Confidential AddendumC. Administrative Record IndexD. Environmental Justice Analysis

cc: D. Chung, U.S. EPA HQ,M. Chezik, U.S. Department of Interior, w/o Enf. AddendumB. Everetts, IL EPA, w/o Enf. AddendumS. Davis, IL DNR, w/o Enf. Addendum

13

Attachment A

DETAILED CLEANUP CONTRACTOR ESTIMATENORTHWESTERN PLATING WORKS SITE

CHICAGO, COOK COUNTY, ILLINOISMAY 2006

The estimated cleanup contractor costs necessary to complete the removal action at theNorthwestern Plating Works Site are as follows:

Personnel and Equipment $238,260Materials and Misc $105,480Transportation and Disposal $156,119

SUBTOTAL $499,85920% CONTINGENCY $ 99,971

TOTAL $599,830

14

ATTACHMENT B

ENFORCEMENT CONFIDENTIAL ADDENDUM

NORTHWESTERN PLATING WORKS SITECHICAGO, COOK COUNTY, ILLINOIS

JUNE 2006

(REDACTED 1 PAGE)

ENFORCEMENT CONFIDENTIALNOT SUBJECT TO DISCOVERY

ATTACHMENT C

U.S. ENVIRONMENTAL PROTECTION AGENCYREMOVAL ACTION

NO.

1

DATE

03/00/06

03/31/06

ADMINISTRATIVE RECORDFOR

NORTHWESTERN PLATING WORKS SITECHICAGO, COOK COUNTY, ILLINOIS

ORIGINALJUNE 14, 2006

AUTHOR

Schnoes, K.,ChicagoDept. ofEnvironment

RECIPIENT

Del Rosario, R.,U.S. EPA

Fitzgerald, P.,U.S. Attorney &K. Lindlanci,AssistantU.S. Attorney,U.S. DistrictCourt, NorthernDistrict ofIllinois, EasternDivision

Respondent

Brown, G.,u.5. MagistrateJudge, U.S.District Court,Northern

Illinois,EasternDivision

Tetra TechEM Inc.

Resoondent

TITLE/DESCRIPTION PAGES

Letter re: Chicago Dept. 1of Environment Requeststhe U.S. EPA to Conducta Time Critical RemovalAssessment at the North-western Plating Works Site

Application for Ex Parte 36Administrative Warrant forEntry, Inspection andSampling w/Attached Exhibits:1. Declaration of TerrenceSheehan, Chicago Dept. ofEnvironment2. Declaration of MichaelHarris, OSC, U.S. EPA3. Declaration of JosephKawecki, Civil InvestigatorU.S. EPA4. Declaration of Sherry L.Estes, Associate RegionalCouncil, U.S. EPA5. Deed from NWP Enterprises,Inc. to David J. Jacobs, Inc.

Administrative Warrant for 5Entry, Inspection, Sampling,Taking Photographs, andReviewing and CopyingRecords

Site Assessment Reportfor the NorthwesternPlating Works Site

65

NO. DATE

00/00/00

AUTHOR

Harris, M.,& J. Mitchell,U.S. EPA

RECIPIENT

Karl, R.,U.S. EPA

Northwester Plating WorksOriginal AR

Page 2

TITLE/DESCRIPTION PAGES

Action Memorandum:Request for Approval ofFunding in the Amount of$791,796 for a TimeCritical Removal Actionat the NorthwesternPlating Works Site(PENDING)

Attachment DEnvironmental Justice Analysis

Region 5 Superfund EJ AnalysisNorthwest Plating Site Chicago, IL

Norlhwesl Plating SiteCook Counly . ILOne mile radiusPopulation 10.264Minority 95%Low Income 46%

State of Illinois averages.Minority 32%

Low Income. 27%

US. EPA Region 5Environmental Justice Case Criteria

for State of Illinois

Minority 64% or greater

Low Income 54%orgreaer

0.2 0.4 0.6 0.3 1 1.2 1.4 Miles