Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

Removal Site and Date Region Description Summary

Country Home Furnishings, 

November 2009

Gardner, MA - EPA Region I Building with drums and containers containing flammable 

liquids.

Former Athol Rod and Gun Club, 

August 2009

Athol, MA - EPA Region I Outdoor shooting range; presence of high levels of antimony, 

arsenic, lead, and Polycyclic Aromatic Hydrocarbons (PAHs) in 

surface soils. Currently budgeted at $2.76M for removal actions.

The Former Bendix Property Site, 

July 2010

Greenfield, MA - EPA Region I Approximately 380 discarded metal and/or plastic 55 gallon 

drums, and other various sizes containers, exist throughout the 

entire (interior/exterior) grounds of the Site. The PA/SI revealed 

friable asbestos and asbestos containing material, metals 

(chromium), and volatile organic compounds.

Former Ibadex Research 

Company Emergency Response, 

August 2010

Danvers, MA - EPA Region I Evicted renter of property indicated that he could not recall all 

the materials he had, but they were in small quantities and 

included: hydrochloric acid, hydrofloric acid, nitric acid, sulfuric 

acid, boron tri-flouride, mercury, arsenic, solvents, gases, and 

laser capacitors with PCBs.

Nova Dye & Print Corporation, 

March 2008

Waterbury, CT - EPA Region I The PA/SI consisted of collecting drum samples for volatile 

organic compounds (VOCs), semivolatile organic compounds 

(SVOCs), polychlorinated biphenyls (PCBs), metals, flashpoint, and 

pH analyses; surface soil samples for VOCs, SVOCs, PCBs, and 

metals analyses; and suspected asbestos containing materials 

(ACMs) for asbestos analysis. On October 15, 2009, an Action 

Memorandum was signed approving a total project ceiling of 

$1,200,000.00 to address the site.

VET Printing, May 2010 Casco, ME - EPA Region I The Site is an abandoned, privately operated printing facility that 

went out of business in the fall of 2009. During a site visit on 4 

May 2010, personnel from MEDEP found the company had 

ceased operations and laborers were on-site cutting up the metal 

machinery for scrap. They proceeded to inspect the facility for any 

possible remaining containers of hazardous wastes, and found a 

previously unknown room that had been boarded up and hidden 

behind a row of file cabinets. The room was full of overflowing 

and leaking containers. An inventory of the hidden room included 

five 55-gallon drums, three 30-gallon drums and eighty to one 

hundred 5-gallon drums. In addition, there were multiple printing 

and photochemical containers of various sizes throughout the 

building and two 55-gallon drums with “hazardous waste” labels.
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

Walton & Lonsbury Site, August 

2010

Attleboro, MA - EPA Region I 13,500 square-foot chromium plating facility. In 2007, when W&L 

closed its operations, there were four active plating tanks (out of 

six that were in operation when the dry scrubber air handling 

systems were installed in 1997). These tanks have capacities of 

740 gallons, 680 gallons, 1,440 gallons and 1,210 gallons. 

Chemical usage at the Site has included trichloroethylene (TCE), 

1,1,1-trichloroethane (TCA), chromic oxide, hydrochloric acid, 

sulfuric acid, phosphoric acid, cyanide, paint thinner, aluminum 

oxide, sodium hydroxide, sodium bisulfate, sodium hydrosulfate, 

and lead sulfate. Wastes generated at the Site include 

hydrochloric acid, chromium hydroxide sludge, chromic acid 

wastewater, chromic acid contaminated solids, TCE, TCA, 

aluminum oxide dust, and cyanide plating bath solution.

During the August 2010 PA/SI chromic acid and significant 

quantities of chromic acid sludge were found to still be in the 

tanks.

61-77 Sherer Street Site, 

November 2010

Rochester, NY - EPA Region II Former bronze and aluminum foundry that ceased operations 

and was believed to have been abandoned within the last two 

years (e.g., 2008). The building is a one-story brick and cinder 

block structure covering approximately 23,000 square feet. The 

yard contains several rusted, dilapidated sheds; several 

abandoned drums.

Concord Chemical, August 2010 Camden, NJ - EPA Region II A former manufacturer of various liquid and powder cleaners and 

detergents. On August 23, 2010, On-Scene Coordinators (“OSC’s”) 

from the Removal Action Branch (“RAB”) and representatives 

from NJDEP and the City of Camden conducted a Site visit as part 

of the removal assessment. They found over 100, 55-gallon drums 

were observed including at least 20 hazardous waste (based on 

labeling) salvage or overpacked drums in the loading dock area. 

Waste identified on labels included caustics, corrosives and 

flammable materials. The second floor contains a large laboratory 

that has over 1,000 small containers of chemicals, reagents and 

unknown chemical mixtures. Container labels indicated the 

presence of acetone, tetrachloroethylene (“PCE”), carbon 

tetrachloride, 1,1,2,2-tetrachloroethene, chloroform, pyridine, 

toluene, hydrochloric acid, acetic acid, sulfuric acid, nitric acid, 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

acetic anhydride, butyl alcohol, kerosene, and ammonia in the 

lab. The second floor contains over 100, 55-gallon drums with 

labels indicating that contents included sulfonic acid, styrene, 

isopropyl alcohol, sodium methylate, monoethanol amine, 

propylene glycol, ethylene glycol, sodium hydroxide, cresylic acid, 

and ammonia. Some of the containers have open tops and/or 

material on the drum top that has spilled out of the container.

Former Western Publishing Site, 

September 2010

Poughkeepsie, NY - EPA 

Region II

A former printing facility, EPA conducted entries into the Site 

building in September 2010 as part of a removal assessment. 

Approximately 70 unlabeled drums with unknown contents are 

located within the Site building. Results of EPA's September 2010 

analytical sampling of several of the drums indicated that some 

contain CERCLA-designated hazardous substances. One drum 

contains elevated levels of vinyl chloride, cadmium and 1,2-

dichloroethane, and another contains a material considered to be 

a characteristic ignitable waste under RCRA.

R.N.Hitchcock Electroplating 

Facility, December 2005

Port Byron, NY - EPA Region II The Site was a former electroplating and metal-finishing facility 

which was operated by various owners from 1946 until 2003.

During their investigations in 2005, NYSDEC identified unknown 

chemicals remaining in drums, open vats, tanks and small 

containers and an underground settling tank located on the east 

side of the site. The results of the Site assessment/RSE confirmed 

that there were approximately seventeen open-top vats 

containing corrosive plating solutions and various chemical 

containers including 55-gallon drums, 5-gallon pails and an 

assortment of 40 and 50 pound bags of dry chemical. Many of the 

drums and other containers held acids, basic solutions, cyanide 

solutions, chromate solutions, flammable liquids, oxidizers and 

other hazardous materials. Many of the chemicals were 

improperly stored and in containers of poor integrity. 

Sampling of various containers confirmed the presence of 

flammable liquids, acids, cyanides, and heavy metals. Heavy 

metals detected include cadmium, chromium, copper, lead, nickel

and zinc. 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

Kenco, April 2010 Glenville, NY - EPA Region II The Kenco Site is the former location of the Kenco Chemical 

Company which operated at the Site as a commercial chemical 

repackaging and distributor beginning in 1955. In a letter dated 

April 6, 2010, the New York State Department of Environmental 

Conservation (NYSDEC) requested that EPA evaluate drums and 

containers stored at the Kenco property for removal action 

eligibility and address any offsite impacts of the PCE ground water 

plume emanating from 107 Freeman’s Bridge Rd. On April 23, 

2010, EPA completed an assessment of the containers at the 

Site. In a revised referral dated April 6, 2010, NYSDEC requested 

assistance from EPA to address offsite impacts of the dissolved 

phase PCE plume, evaluate drums and containers stored inside 

the Kenco warehouse for removal eligibility and to further 

evaluate the onsite PCE source for removal eligibility.

On April 23, 2010, EPA completed an inventory of the containers 

at the Site. Approximately 50, 55 gallon drums were identified 

along with more than 200 containers less than five gallons in 

size. Many of the containers inventoried were found to be 

empty. Hazardous substances were identified in the inventory 

which included ignitable and caustic liquids. Following the 

assessment of the containers, a removal action was not initiated 

due to the fact that the owner of the warehouse was continuing 

to secure and maintain the warehouse where the containers 

were stored. 

On December 14, 2010, EPA mobilized to the Site to dispose of 

drums and containers abandoned at the Kenco Site. See Site 

Profile for list of removed hazardous wastes.

ERRS contractors returned to the Site on February 14, 

2011 performing snow removal in preparation for load-out of the 

remaining waste at the Site. ERRS contractors returned to the Site 

on February 14, 2011 performing snow removal in preparation for 

load-out of the remaining waste at the Site.
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

An additional $30,000 of funding was authorized by the 

Emergency Response and Remedial Division Director on January 

26, 2011 to complete disposal at the Site. This brings the total 

ceiling authorized for this project to $90,000.

NanoChemonics, April 2011 Pulaski, VA - EPA Region III This Site is the location of the former NanoChemonics'

nanoparticle manufacturing facility. The Company ceased 

operations in July 2010. The Site contains a variety of potential 

threats of release of hazardous substances stemming from acid 

and caustic chemicals remaining within the manufacturing facility 

along with drums, totes, bags, and other containers of chemical 

substances; including, several laboratories. The response action 

was initiated during the week including April 8, 2011 and includes 

removal of residual chemical contamination, treatment and 

discharge of waters in the lagoon system, and closure of the 

lagoons on the Site.

Pipers Gap Acid Trailers, October 

2009

Lambsburg, VA - EPA Region III The Pipers Gap Acid Trailers Site is located in a rural residential 

area near Lambsburg, Carroll County, Virginia. On October 1, 

2009, the Virginia Department of Emergency Management (VADEM) notified the On-Scene Coordinator (OSC) of a situation 

involving the reported release of hazardous substances (i.e., 

hydrochloric acid). The release was reported to have occurred as 

a result of processes involving the removal of precious metals 

(gold) from computer components. Available information 

indicated that acid chemicals were being dumped and buried 

upon the property and that drums of acid were now located in 

and leaking from trailers located on the property. 

Throughout the night of October 1, 2009, local authorities opened 

and assessed the contents of the trailers. The following 

information was determined. There are 6 box trailers. The trailers 

were not locked and could be easily opened. The trailers 

exhibited evidence of leakage based upon odors and staining 

upon and alongside the trailers. The contents of the trailers 

include approximately 300 drums of unknown materials, dozens 

of buckets, bags of sodium metabisulfite, jugs of hydrochloric 

acid, at least one vat, crucibles, computer components, and other 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

miscellaneous materials. Some of the drums were found to

contain and to be leaking a reddish unknown oily material. Some 

of the drums were found to contain and to be leaking a strong 

acid (pH of approximately 1). Most of the drums did not have lids 

(sawed tops) and were covered only by a sheet of plastic and duct 

tape. Some of the drums were closed and were observed to be 

under some pressure (bulged); these drums emitted chlorine 

when opened. The detection of chlorine is consistent with a 

mixture of nitric acid and hydrochloric acid (known as aqua-regia) 

which is used in the etching of gold. Local authorities passed the 

above information to the OSC throughout the night of October 1, 

2009. 

EPA will arrange for disposal of wastes classified as RCRA 

hazardous wastes if disposal cannot be accomplished within a few 

weeks time. 

Stoney Creek Technologies, April 

2007

Trainer, PA - EPA Region III The Site is located in a mixed industrial and residential area of 

Trainer, Delaware County, Pennsylvania. The Site includes a 

chemical manufacturing facility consisting of about 200 tanks, 

several buildings, a laboratory, a wastewater treatment facility, 

and many processing vessels, equipment items, systems, and 

pipelines which are used in or are related to the chemical 

manufacturing processes. Chemicals at the facility include oleum, 

methanol, heptane, mineral spirits, sulfuric acid, and others 

including many mixtures. Stoney Creek Technologies primarily 

manufactures base products to be used in corrosion inhibitors, 

motor oil additives, and grease feed compounds. 

On April 12, 2007, the OSC was notified by EPA Region III staff 

that the facility was in bankruptcy court and that chemical 

substances remained at the facility which may pose a threat.

CERCLA funding not to exceed $250 K was authorized on April 

17, 2007 to assure that the chemicals at the facility are 

safeguarded in the absence of the Company's ability to do so. 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

On July 27, 2007, EPA Region III approved additional funding and 

exemptions from statutory limits for removal actions to allow for 

actions relating to the removal of chemical inventory from the 

Site should Stoney Creek Technologies be unable to do so. EPA 

also issued Orders to Stoney Creek Technologies and other 

companies to remove the inventory at the Site in order to reduce 

the potential threats. The Respondents to these orders were 

allowed to use the facility as a means to reduce the inventory 

(e.g., produce to reduce). 

The facility contains flammable, combustible and/or corrosive 

chemicals in dozens of tanks, many of which would pose a fire risk 

if improperly handled. Other chemical materials are also present 

in drums, open and closed containers of varying sizes, water 

treatment vessels, fuel vessels, trenches, drains, and other places. 

In October 2008, EPA initiated activities relating to the removal of 

the chemical inventory from the Site since Stoney Creek 

Technologies and 2 other companies which received orders from 

EPA have failed to remove the inventory from the Site. EPA 

completed the disposal of bulk liquid chemicals posing flammable 

threat in January 2010. EPA completed the removal of bulk acid 

chemicals in June 2010.

American Screw and Rivet, June 

2011

Anderson, SC - EPA Region IV On November 2010 SCDHEC received information that the facility 

had stopped operations and declared bankruptcy. In May 2011 

SCDHEC conducted an inspection of the facility and documented 

leaking holding tanks and overflowing sumps. SCDHEC also 

documented the presence of approximately 80 poly totes some of 

which were labeled hazardous waste, drums, as well as other 

containers such as pails, small plastic drums and cardboard 

containers. Initial assessments from the facility revealed 44 poly 

totes exposed to the elements. Some totes exhibited cage 

corrosion and an advanced state of degradation. After entering 

the facility’s building the OSC observed overflowing sludge filled 

sumps, water ponds in multiple areas, totes labeled with 

hazardous waste stickers and pH 2 annotations, cardboard 

containers in advanced state of degradation some of which had 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

spilled their contents, drums and multiple other containers.

ASR American Way, June 2011 Anderson, SC - EPA Region IV While USEPA was conducting a removal action at the American 

Screw and Rivet (ASR) Site, DHEC referred another property to 

Emergency Response and Removal Branch (ERRB) located at One 

American Way in Anderson, SC. The Site was affiliated with the 

ASR Site but under different corporate ownership. 

On June 14, 2011 OSC Crowley initiated an emergency response 

at the ASR American Way site to mitigate the threats posed from 

approx 30 drums of corrosive and caustic materials that are 

located behind a warehouse exposed to the environment and 

unsecured.

James E Music Company, January 

2003

Apopka, FL - EPA Region IV The James E. Music Company Site has been owned and operated 

by the family of James E. Music since it was purchased in 1980. 

The facility housed J.E. Music Company, a commercial entity 

which generated, stored and distributed a variety of customized 

cleaning chemicals and supplies as well as a variety of pesticides. 

Following an anonymous tip in January 2003, the Florida 

Department of Environmental Protection. 

(FDEP) conducted a series of inspections and identified multiple 

30 to 55-gallon drums with varying contents stored in the building 

at the Jemco site. FDEP found numerous drums, buckets, and 

bottles of potentially hazardous chemicals with evidence of 

potential release to the wood floor planking and soil beneath the 

building. The estate of James E. Music subcontracted a waste 

disposal contractor to profile, manifest, transport, and dispose of 

the chemicals and containers. Inventoried wastes included: 

petroleum 

distillates, sodium arsenate, heptachlor, pyretherins, lindane, pdichlorobenzene, ammonia, mineral spirits, sodium hydroxide, 

hydrochloric acid, xylene, various soaps and surfactants.

Karolina Polymers, January 2010 Hickory, NC - EPA Region IV Hickory FD contacted EPA OSC Raleigh Outpost, Ken Rhame, with 

a report that an abandoned building, previously Karolina 

Polymers, had flooded due to a ruptured sprinkler system. The 

building contains several drums, tanks, vats, and may also contain 

a potential radiation source. There is evidence that vandals and 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

trespassers have been inside the building. The property owner 

has not been identified, the last person to pay taxes has been 

contacted and granted EPA access to the extent that she has 

authority. Hickory FD and NCDENR requested EPA assistance 

during entry and assessment. The facility location is only several 

hundred yards from an un-related oil spill that OSC Rhame was 

working on. Additional START contractor (Tetra Tech) resources 

were mobilized to provide monitoring and hazard categorization 

capabilities for assessment. The total Site ceiling for this 

emergency action is $250,000. 

KM Ventures, August 2009 Lowell, NC - EPA Region IV On August 27 EPA NC OSC received a request from NC DENR 

Hazardous Waste to conduct a joint site visit at KM Ventures 

Property located at 1602 North Main Street in Lowell, Gaston 

County NC . DENR informed EPA that they had issued a NOV and 

Order to KM Ventures to comply with various RCRA Regulations. 

EPA and DENR Hazardous Waste conducted the site visit on 

August 28t.

The KM Venture Site has several thousand gallons of hazardous 

substances and oils that have been abandoned by the previous 

operator (Yorkshire America). These substances are currently 

being contained with containers that are in poor condition. The 

Catawba River borders the property on one side, there has been 

documented trespassers on site. 

October 6th Update: The RP, KM Ventures has agreed to an 

Administrative Order with EPA Reg 4. Clean up efforts will 

continue to be overseen by EPA through December 2009.

Robinson Foundry, June 2009 Alexander City, AL - EPA Region IV The Belcher/Robinson Foundry, located in Alexander City, is an 

abandoned ductile iron/grey iron foundry. EPA ERRB responded 

to a request from ADEM to address releases emanating from 

leaking drums and tanks on site. Initial reports from ADEM 

indicate the presence of an AST containing oil, several dozen 

drums containing hydraulic oil and sulfuric acid, plastic totes of 

various sizes, and paint cans.

Anchor Metal Finishing, January 

2008

Schiller Park, IL - EPA Region V Anchor Metal Finishing, Inc. was a black oxide finisher that used 

chemical 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

conversion on steel, a process that did not involve electroplating. 

Before Anchor Metal Finishing, Inc., Royal Metal Finishers 

conducted finishing operations at the Site. Royal Metal Finishers 

conducted two primary on-site operations: zinc plating on carbon 

steel and black oxidizing of steel. Royal Metal Finishers also 

conducted smaller operations for black oxidizing of stainless steel 

and copper plating on carbon steel. 

Process wastes generated by Royal Metal Finishers included filter 

press wastes, zinc bath sludge, iron oxide sludge, copper bath 

sludge, and zinc plating cleaner sludge. Royal Metal Finishers 

ceased operations at the Site in the late 1980s, around the time 

when Anchor Metal Finishing began renting space in the Site 

building. Anchor Metal Finishing, Inc operated at the Site from the 

late 1980s until January 2008. The Elite Sewer Company is 

presently operating as a business on the property. Elite Sewer 

uses the building for storage and occupies the building office. Elite 

Sewer also utilizes the property parking lot.

The Illinois Environmental Protection Agency (lEPA) on January 8, 

2008, responded to a complaint that Anchor Metal Finishing, Inc. 

was relocating to another location and moving drums in the 

middle of the night. lEPA inspectors completed an inventory of 

processed waste with the Anchor Metal Finishing, Inc., foreman, 

Daniel Wozniak. The lEPA inspectors advised Mr. Wozniak to 

develop and submit a formal written inventory of all the 

chemicals and materials at the Site. Because of the large number 

of drums, their poor condition, and uncontrolled Site conditions 

related to waste storage, lEPA requested U.S. EPA's assistance.

The total U.S. EPA costs for this removal action based on fullcost accounting practices will be eligible for cost recovery 

are estimated to be $ 628,657.

Chilton Plating, June 2011 Chilton, WI - EPA Region V On June 6, 2011, the on-scene coordinator for ERRS 

(Environmental Quality Management), and START (Weston) 

initiated a time-critical removal action at the former Chilton 

Plating Site in Chilton, WI. The Site contains a former plating 

company that operated from 1961 until 2007. The owner of the 

company is bankrupt and is not able to properly dispose of the 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

hazardous waste and unused products remaining at the Site. 

There are approximately 160 drums and numerous vats of 

hazardous waste and materials at the Site, including sodium 

cyanide, flammable materials, corrosive materials, and materials 

containing high concentrations of metals (such as chromium, 

nickel, and copper). Incompatible materials are stored together 

and some of the drums are leaking. The removal is expected to 

take approximately six weeks to complete.

An Action Memorandum approved up to $532,301 to conduct a 

time-critical removal action at this site.

Columbia City Testworth 

Laboratories, February 2011

Columbia City, IN - EPA Region V Testworth Laboratories, Inc. was established in 1941 and used the 

Site to manufacture the following types of products: special liquid 

adhesives; coating compounds of natural latex, natural rubber, 

and synthetic rubber; synthetic resins; chemical dispersions; 

emulsions for latex compounding; custom compounding sealants; 

and water- or solvent-based adhesives. 

Testworth ceased site operations in early 2010 after facility's 

closure by order of the Indiana State Fire Marshall. Indiana 

Department of Environmental Management (IDEM) requested 

that the U.S. EPA investigate potential environmental threats at 

the Site. In April 2010, U.S. EPA conducted a site assessment. The 

results of this assessment indicated that corrosive and flammable 

hazardous wastes remained onsite in drums, totes and other 

containers. 

Emergency Response and Rapid Services (ERRS) and Superfund 

Technical Assistance and Response Team (START) contractors 

were mobilized to the site on February 28, 2011 to remove and 

dispose of hazardous materials from the site.

Crown Laundry, April 2011 Indianapolis, IN - EPA Region V The Crown Laundry Site is a former industrial rug cleaner, which 

operated from 1910 to 1975. The United States Environmental 

Protection Agency (EPA) conducted a site assessment on October 

11, 2010. During the assessment, EPA documented approximately 

20 drums and hundreds of smaller containers 5 gallons or less. 

Field hazard categorization documented that many of the drums 

and containers contain characteristic hazardous waste including 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

ignitable and corrosive materials. EPA conducted emergency 

stablization and removal of the drums and other containers on 

October 12-22, 2010. 

EPA started time-critical removal activities on April 4, 2011. These 

activities will include: removing underground storage tanks 

(USTs), including dry cleaning solvents; mitigating soil 

contamination; and assessing nearby residential properties for 

potential vapor intrusion issues.

On December 17, 2010, EPA approved expenditures up to 

$1,991,732 to conduct emergency and time-critical removal 

actions at this site.

Custom Chrome Plating Site, 

March 2010

Dayton, OH - EPA Region V On March 4, 2010, the Ohio EPA requested assistance from US 

EPA Region 5 at the Custom Chrome Plating (CCP) Site in Dayton, 

OH. The site is the location of a former chrome plating facility. 

Abandoned wastes include chrome sludge, acids, chromic acid 

bath solutions and flammable liquids. 

On March 10, 2010, U.S. EPA conducted a site assessment at the 

CCP Site and observed approximately 25 chrome plating vats and 

tanks and 100 55-gallon drums and other waste containers within 

the facility. During the site assessment, U.S. EPA collected 9 liquid 

waste samples and 2 solid waste samples from drums, plating vats 

and containers. Analytical results indicated seven liquid waste 

samples having a pH value of less than 2.0 standard units and 

therefore meet the criterion for hazardous waste by virtue of

corrosivity as defined in 40 CFR 261.22. Analytical results 

indicated that five investigative samples have TCLP chromium 

concentrations greater than 5.0 mg/L, with a maximum TCLP 

chromium concentration of 11,900 mg/L, and therefore meet the 

criterion for hazardous waste by virtue of toxicity as defined in 40 

CFR 261.24. Analytical results indicated that two investigative 

liquid waste samples have flash points of less than 140 oF and 

therefore meet the criterion for hazardous waste by virtue of the 

characteristic of ignitability as defined in 40 CFR 261.21. 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

Hazardous wastes identified at the Site exhibit the following 

characteristics: 

• Corrosivity 

• Toxicity 

• Ignitability 

Butte La Rose Abandoned 

Containers

Louisiana, Region 6 On 5/14/2011, EPA discover an abandoned site that 

approximately 25 containers containing potentially hazardous 

substances. The site is located in Butte La Rose, LA inside the 

Atchafalaya River basin. Locals indicated that the owner died and 

the building on the property burned. The containers are 

unsecured and in the inundation zone according to the USACE. 

The USACE opened the Morganza Spillway on 5/14/2011. The Site 

is located within the USCG AOR as described by the USCG/EPA 

Response MOU. EPA contacted USCG and the COPT Morgan City 

granted EPA permission to conduct an emergency removal action. 

EPA is prepared to remove the containers and move them to a 

staging area will the containers will be sampled and disposed of. 

EPA activities have also been coordinated with LDEQ.

Cusol Company Inc Houston, TX - EPA Region VI The Cusol Company, Inc. (Cusol) site was referred to EPA Region 

VI Superfund Prevention and Response Branch on 10/19/09 by 

Harris County Public Health & Environmental Services (HCPHES). 

Cusol operated as an adhesives manufacturer until abandoned in 

2005. HCPHES inspected the site and found approximately 600 

55-gallon drums with and without labels, three 7,000-gallon ASTs, 

hundreds of smaller containers, evidence of spills/release, and 

limited security of the site. 

Cusol is located in a residential neighborhood. Eyewitness 

accounts, and physical evidence, support acts of trespass, 

vandalism, and thievary on-site.

La Union Drum La Union, NM - EPA Region VI On August 24, 2010 EPA’s Region 6 emergency response team 

was notified of an 18-wheeler box trailer located in La Union, NM 

filled with suspected hazardous waste. It is reported that the 

trailer and cargo has been setting in the same location for at least 

5 years. EPA mobilized to the site on August 26, 2010 to initiate 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

an emergency removal assessment. Objectives of the assessment 

were to: remove the containers from the trailer, inventory the 

containers, categorize the material and obtain disposal profile 

samples.

Maxwell Creek Drums Murphy, TX - EPA Region VI OSC Adams and START3 contractors were activated to respond to 

an NRC Report #956732 reporting abandoned and leaking drums 

in a ditch along South Maxwell Creek Road in Murphy, Texas.

North Fort Worth Plating Fort Worth, TX - EPA Region VI The North Fort Worth Plating Company site is located at 3105 

North Hays Street in Fort Worth, Tarrant County Texas. The 

facility consists of a 3,400-square-foot building constructed in 

1976. 

The site is an abandoned plating facility where chromium, nickel, 

copper, and gold plating for miscellaneous light commercial and 

residential applications was conducted. Plating operations began 

in the 1970s and ceased in some time around December 2003. 

Prior to closure and abandonment, machining and plating 

equipment, supplies, and chemicals were not removed. Based on 

a review of records obtained from TCEQ, little effort was made 

prior to or after closure/abandonment to remove on-site chrome 

plating wastes or equipment. These wastes were presumed to 

have been generated and accumulated during facility operations 

prior to its closure/abandonment in December 2003. As such, a 

quantity of solid and liquid waste remained on-site in 27 plating 

vats, an undetermined number of steel and poly 55-gallon drums, 

and more than 100 smaller containers at the time of 

closure/abandonment.

Scrub-A-Dubb Barrel Co. Lubbock, TX - EPA Region VI The Scrub-A-Dubb Site (Site) is an inactive drum refurbisher. The 

owner/operator began the business in the mid 1970s. Scrub-ADubb (SAD) would take drums from a variety of companies and 

sources, then clean, repair, and repaint the drums. SAD would 

then sell the drums. Drums that were in too poor of a condition to 

be refurbished or when the supply exceeded the demand, were 

stacked on the Site. It is evident that not all drums were empty or 

even RCRA-empty (40 CFR §261.7) were brought to the Site. It is 

estimated that more than 2,000 drums with significant quantities 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

of hazardous waste are on the Site. Some drums are completely 

full of liquid waste. It is estimated that between 40,000 and 

60,000 drums remain onsite. At this time, is not possible to assess 

the number and condition of other drums that may be 

underneath the piles of drums. 

The refurbishing process employed by SAD included rinsing the 

interior and washing the exterior of the drums with water. That 

water and contents of the drums was drained into a waste water 

treatment system comprised of several settling vats. The vats 

have discarded hoses, tanks, and other material dumped in them. 

The vats have been the source of previous releases that have 

gone offsite.

Chemco Industries Topeka, KS - EPA Region VII On June 19, 1995, the Kansas Department of Health and 

Environment (KDHE) Resource Conservation and Recovery Act 

(RCRA) program requested the U.S. Environmental Protection 

Agency (EPA) Region VII Emergency Response and Removal 

Program (ERRP) conduct a removal site evaluation at the Chemco 

Industries, Inc., site located at Building #638, Forbes Field, 

Topeka, Kansas. Chemco Industries, Inc. (Chemco) was a small 

business owned and operated by Kenneth H. Halbert. Mr. Halbert 

engaged in the purchase and resale of used laboratory-grade 

chemical reagents. On November 27-29, 1995, as part of the ERRP 

removal site evaluation, a thorough inventory of all laboratorygrade chemical reagents and chemical wastes at the facility was 

performed. The inventory documented approximately 2,454 

containers ranging in size from 1 ounce to 55 gallons that 

contained either a CERCLA hazardous substance or a flammable, 

corrosive, toxic, irritating, or oxidizing chemical. A large 

percentage (93%) of Chemco’s inventory appeared to be in good 

condition (i.e., labeled and non-leaking). However, several 

problems noted by ERRP’s inventory team included incompatible 

chemicals, staged in close proximity to one another, that were 

either rusting, leaking, bulging, or had collapsed resulting in the 

release of their contents within the facility. 

Subsequently, as a result of the removal site evaluation, EPA 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

Region VII conducted a time-critical removal action at Chemco 

from June 24, 1996, to July 8, 1996, during which time 

approximately 2,454 containers of laboratory-grade chemical 

reagents, ranging in size from 1-ounce to 55-gallons, were 

consolidated and transported off-site for disposal. 

According to KDHE, the former owner and operator of Chemco, 

Mr. Halbert had passed away in February 2006. From a review of 

the previous 1995 and 1996 removal inventory information, it 

appears most of the current inventory was present during the 

previous removal but was likely determined by Mr. Halbert to be 

usable or resalable product. With Mr. Halbert’s death and the 

dissolution of Chemco, all of the remaining material appears to be 

abandoned waste. 

Since no other federal or state response mechanisms was 

identified available to respond to the release, EPA is currently 

preparing to undertake a fund-lead time-critical removal action to 

stabilize conditions at the site. 

Hill Plating Inc. Springfield, MO - EPA Region VII The Hill Plating Inc., company operated as a plating facility from 

1987 to 2004. In 2005, the Missouri Department of Natural 

Resources (MDNR) responded to a call from the City of Springfield 

police department regarding trespassing violations at the facility. 

Subsequent MDNR investigations documented approximately 

2,655 gallons (22,157 pounds or 10,050 kilograms) of waste 

material present on the site, and approximately 2,211 gallons 

(18,450 pounds or 8,369 kilograms) of that waste was determined 

to be characteristically hazardous for corrosivity and/or 

ignitability. 

Based on the presence and volume of characteristically hazardous 

waste on the site, a history of vandalism, and the proximity of 

residences and businesses near the site, the risk posed by the site 

through the direct exposure pathway is relatively high. On August 

4, 2008, MDNR referred the site to the U.S. Environmental 

Protection Agency (USEPA) and recommended that a time-critical 

removal action be preformed to remove on-site wastes. MDNR 

intends to continue (phase II) of their site investigation activities 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

after the proposed USEPA removal action is completed. 

A fund-lead removal action was initiated by USEPA on November 

2, 2009.

Plating, Inc. Great Bend, KS - EPA Region VII The site formerly operated as a metal finishing facility that began 

chromium plating operations in Great Bend, Kansas, in 1968. Zinc 

plating processes were added at the facility in 1975. The plating 

lines used solutions containing chromium and zinc. In addition, 

highly caustic and acidic solutions were also used in the 

electroplating process. 

Operations at the facility ceased on November 4, 2005. Since the 

closure of the facility, little work has been performed to mitigate 

the hazards present and several sources of hazardous substances 

remain on the site and present a continued threat of release. A 

large number of open vats still contain electroplating solution. 

Wastes produced from the treatment of waste-caustic cleaner 

and electroplating waste are also onsite in open vats and 

containers. One drum of muriatic acid is bulging and leaking into 

the tank in which it was placed for secondary containment. 

During an inspection by state officials in January 2007, chromeplating wastes were identified onsite as well as other hazardous 

and non-hazardous wastes. Wastes currently onsite include 

approximately five tanks containing 6,400 gallons of chromic acid, 

three tanks and ten drums containing 2,100 gallons of muriatic 

acid, one tank containing 1,500 gallons of chrome contaminated 

alkaline cleaner, one tank containing 150 gallons of sodium 

hydroxide, and one tank containing 100 gallons of sodium 

bisulfite, as well as several tanks, 55-gallon drums and 5-gallon 

buckets of sulfuric acid, nitric acid, used oil, zinc plating sludge, 

dried alkaline cleaner sludge, and various plating additives. 

On July 26, 2006, yhe Kansas Department of Health and 

Environment (KDHE) referred the site to the Environmental 

Protection Agency (EPA) for completion of the Hazard Ranking 

System (HRS) evaluation for eventual listing on the National 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

Priorities List (NPL) consistent with the National Oil and 

Hazardous Substances Pollution Contingency Plan (NCP). 

On January 24, 2007, KDHE referred the site to EPA with a 

recommendation that a time-critical removal action be conducted 

at the site consistent with Section 300.415 of the NCP. 

Nome Street Trailer Site Denver, CO - EPA Region VIII This removal action involved the assessment, cleanup, and 

disposal of abandoned containers of toxic, corrosive, and 

combustible wastes. The containers of wastes including 

perchloroethylene, corrosive detergents and other wastes, 

appear to have originated from a dry cleaner supplier and retailer 

and were placed inside an unlocked semi-trailer abandoned on a 

city street.

Wallace Road Drums Salt Lake City, UT - EPA Region VIII The Wallace Road Drums site consists of two abandoned truck 

trailers on the side of the road in front of an industrial area. Inside 

the trailers are more than 60 50-gallon drums with substances 

that appear to be plating wastes; one of the drums was leaking 

material out of the trailer door and onto the ground. The trailers 

were unsecured and located in an industrial area with residences 

located nearby.

Borwick Ave. Waste Site South Gate, CA - EPA Region IX On 4/13/11, EPA was notified of a warehouse with abandoned 

waste in the City of South Gate, Los Angeles County, CA. The 

abandoned wastes are associated with a defunct waste 

transportation/brokerage concern also responsible for 

abandoned wastes at the Santa Fe Springs Drums Site. The Santa 

Fe Springs Drum Site was the subject of an EPA led removal action 

which concluded in March 2011. 

This second, distinct location, contained wastes similar to the 

Santa Fe Springs Drum Site. Avaialble RCRA Mark information 

suggests that abandoned wastes at the Borwick Ave Waste Site 

location originate from many of the same generators 

encountered at the Santa Fe Springs Drum Site location. 

EPA conducted a removal assessment including inventory, field 

testing and laboratory sample analysis. OSC Benson coordinated 

activities with the State Department of Toxics Substances Control 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

(DTSC), Los Angeles County Health HazMat and EPA's CID. A 

generator recall (voluntary PRP removal) was successfully 

concluded in early May. Bulk and non-bulk wastes which could 

not be attributed to identified generators were handled by DTSC's 

Emergency Reserve Account. This final phase orphaned waste 

removal was concluded by DTSC on May 16, 2011.

Foster Plating Oakland, CA - EPA Region IX The Site is an inactive plating shop in a mixed residential and 

commercial neighborhood in West Oakland. Deteriorated vats of 

plating solutions, including strong acids and caustics as well as 

cyanide solutions, are present at the Site. The plating shop is 

located in a large garage directly adjacent to an occupied 

residence.

Indalex Aluminum Solutions Modesto, CA - EPA Region IX Indalex Aluminum Solutions (Indalex) was an aluminum extrusion 

company that performed custom extrusion, anodizing, and 

painting at their Modesto facility until operations ceased in the 

Spring of 2009. Presently, Indalex is in bankruptcy and the facility 

has been abandoned. Access to the 9-acre site was not secure and 

as a result there has been widespread vandalism throughout. 

There are over one-hundred (100) 55-gallon drums, contents 

unknown, some labeled as “Hazardous waste” on site. There six 

(6) 10,000-gallon above ground storage tanks labeled as 

containing acids and bases. There are two (2) 5,000-gallon tanks 

and one (1) 8,000-gallon tank containing unknown liquids. There 

is visible liquid within the secondary containment around all of 

these tanks. Waste oil was released from two (2) 2,000-gallon 

tanks into the secondary containment. According to State and 

Local officials, within the facility there are several dip tanks 

associated with the plant processes that still contain liquids. 

On September 7, 2010 the California Department of Toxic 

Substances Control (DTSC) requested assistance to conduct a 

removal action at this facility.

Riverside Chrome Plating Riverside, CA - EPA Region IX On July 22, 2010, OSC Rob Wise and the StART provided technical 

assistance to Riverside Co. DA's Office in a search warrant at 

Riverside Chrome Plating, a defunct plating shop. During the 

search warrant and after determining that the cleanup would be 

beyond their financial capability, Riverside Co. Environmental 

Health referred the site to EPA for a removal action. 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

Throughout the day on the July 22 and into July 23, OSC Wise and 

the START conducted a removal assessment of the property after 

securing property access from the building owner and the plating 

shop owners. The assessment documented the presence of large 

quantities of acid liquids, base liquids, oxidizers, cyanide and 

heavy metals. 

OSC Wise issued a CERCLA General Notice to all parties.

Santa Fe Springs Drums Santa Fe Springs, CA, CA - EPA Region 

IX

The California Department of Toxic Substance Control (DTSC) 

referred the site of an abandoned hazardous waste 

transportation company to EPA Region 9 for removal. The 

trucking company SWHAT Trucking went out of business and 

abandoned a large quantity of hazardous waste in 5 gallon 

buckets, drums, 500 gallon totes, small storage tanks and 3-2000 

gallon vacuum trucks. The wastes include RCRA listed and 

characteristic wastes, chlorinated and nonchlorinated solvents, 

flammable liquids, waste oils, acids and paint related materials. 

On October 1, 2010, OSC Robert Wise and the START contractor 

began removal assessment operations and are on-going. OSC 

Wise issued CERCLA General Notice to the land owner and the 

business owner. Both indicated they are incapable of completing 

the cleanup.

All American Metal Finishing Kent, WA - EPA Region X All American Metal Finishing is a zinc electroplating shop 

specializing in rack and barrel plating. All American Metal 

Finishing was previously located at 1819 Central Avenue South, 

also in Kent. The current facility was in operation from 2007-2009. 

They have not shipped any waste since December 2008 leaving all 

process chemicals and waste on site. 

Due to the green river flooding concerns, the Washington 

Department of Ecology (Ecology) requested the assistance of the 

US Environmental Protection Agency (EPA) in the cleanup of All 

American Metal Finishing. On November 3, 3009, EPA performed 

a removal assessment to visually inspect and evaluate the Site to 

determine if the Site warrants cleanup. EPA observed the 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

following: 

Due to the green river flooding concerns, the Washington 

Department of Ecology (Ecology) requested the assistance of the 

US Environmental Protection Agency (EPA) in the cleanup of All 

American Metal Finishing. On November 3, 3009, EPA performed 

a removal assessment to visually inspect and evaluate the Site to 

determine if the Site warrants cleanup. EPA observed the 

following: 

· 32 Process Tanks (approximately 20,220 gallons of liquid) 

- 3000 gallons of Zinc Plating Solution 

- 320 gallons of Zinc Generation 

- 1400 gallons of Zinc Plating Rinse 

- 700 gallons of Nitric Acid Pre-Dip Solution 

- 700 gallons of TRI V 121(Chrome III) 3% Solution 

- 1400 gallons of TRI V 121(Chrome III) Rinse 

- 2800 gallons of TRI V 121(Chrome III) Yellow Converter Rinse 

- 800 gallons of Zinc Chrome Shield 

- 600 gallons of 30% Muriatic Acid 

- 2,000 gallons of Muriatic Acid Rinse 

- 1400 gallons of 9% Sodium Metasilicate 

- 1400 gallons of 9% Sodium Hydroxide 

- 2100 gallons of Metal Cleaner Rinse 

- 1500 gallons of 13% Muriatic Acid Rinse 

- 100 gallons Rinse Water 

Rexburg Drum Rexburg, ID - EPA Region X On July 8, 2010, EPA was asked by Idaho DEQ and Madison 

County to respond to a private residence on about 1⁄4 acre of land 

outside of Rexburg, Idaho. The site had what appeared to be 

thousands of paint-related containers that were in poor 

condition. 

EPA mobilized to the Site on July 10, 2010, having obtained access 

via an administrative warrant from US District Court. From July 10 

through July 16, EPA and START identified approximately 3,200 
Table X.

Examples of Removal Actions Involving Hazardous Waste Generators

Source: http://www.epaosc.org/site/regionmap.aspx

containers at the Site, which were segregated and staged, and a 

representative portion were sampled and hazard categorized. 

Leaking or unstable containers with hazardous substances were 

temporarily stabilized pending cleanup. Flammable, oxidizing and 

corrosive hazardous substances at the Site were identified. Access 

to the Site is unrestricted. The Site is adjacent to a heavily 

trafficked thoroughfare (W 2000 South). 

Star Bright Plating Mulino, OR - EPA Region X Star Bright is a plating shop that has been in operation for 

approximately 20 years, and which is in now in foreclosure. 

Chemicals used in the operation remain on site in a variety of 

containers, including open vats containing: ~700 gallons copper 

cyanide solution, ~1100 gallons of Acid Copper (H2SO4) solution, 

~2500 pounds of cyanide bearing sludge,~1100 gallons of 

contaminated rinse water, ~550 gallons of nickel plating solution 

and~1350 gallons of chrome solutions. Because of the largely 

uncontrolled chemical hazards at the site, local fire agencies have 

determined that they will not attempt to extinguish a fire at the 

facility. In the event of such a fire, a potentially toxic smoke plume 

could extend into nearby populated areas and endanger local 

health. Local fire and the state DEQ requested the assistance of 

US EPA in ensuring an expeditious and effective amelioration of 

hazards at the site.