Time Critical Removal Action – Abandoned Plating Operation


An abandoned plating facility located in the Midwest was purchased at a sheriff’s auction by a regional bank. The facility contained nearly 600 drums, barrels, bulk storage containers, glass carboys, and open vats of a variety of plating chemicals and wastes including: low pH (pH=0) and high pH (pH>13) liquids of unknown composition, chlorinated solvents, chromate, cyanide, nickel pentrate, acid mixtures, hydrogen peroxide, sodium hydroxide, and liquid caustic soda. Most containers were in poor condition resulting in release to the site’s floor, drains, and soil. The site had been vandalized and posed an imminent threat to human health and the environment. In addition, the site was situated directly adjacent to a group of residences, further increasing the threat to human health and the risk of property damage due to the possibility for fire or explosion. Cox-Colvin & Associates was retained by the bank to inventory the hazardous materials, and assess the potential cost to eliminate the hazards so that the site could be redeveloped.


Based on the amount of material, the extreme toxicity of much of it, and the imminent threat posed by the site, Cox-Colvin approached US EPA and successfully demonstrated the need for a Time-Critical Removal Action. Cox-Colvin & Associates assisted the US EPA and Ohio EPA in the gathering of evidence for a potential criminal investigation, supervised the removal of approximately 250,000 pounds of solid and liquid hazardous waste materials, and coordinated the post-removal and decontamination inspections by US EPA and Ohio EPA. The Time-Critical Removal Action was completed, and returned to a condition ready for resale within nine months of the initial walk through.