Site Remediation Program

Frequently Asked Questions: Cleanups at Metal Finishing Shops

If you are a metal finishing operator planning to shut down, this document provides basic information on cleaning up your operations and explains where you can get more information. This document, however, is not intended to be comprehensive nor is it intended to replace, interpret, or modify laws, rules, and regulations.

Why should I clean up my operations?

A metal finishing operation can contaminate soil or groundwater with hazardous chemicals used or produced in the manufacturing process. This situation can create a danger to the environment and public health. Some of the reasons to clean up these hazardous chemicals in a timely manner are:

• State and Federal Hazardous Waste Regulations: You are required by the Resource Conservation and Recovery Act (RCRA) to clean up areas where hazardous waste was stored.

• Real Estate Transactions: You may find it difficult to borrow money or sell your property if it is contaminated.

• Potential Liability: You may be faced with private party lawsuits seeking compensation or cleanup if the site is contaminated or has contaminated neighboring properties.

• Potential Enforcement Action: You may be ordered by a court to clean up your site and may be subject to monetary penalties. In addition, you may be responsible for costs and damages incurred by the Illinois EPA in cleaning up or controlling the contamination.

Cleanup without Illinois EPA Oversight

What steps should I take to clean up areas where hazardous waste was stored?

The following steps are recommended to properly clean up those areas at your operation:

1. Ensure compliance with all applicable RCRA labeling, marking, record keeping and reporting requirements (e.g., manifest records, inspection schedules and logs, waste analysis, written contingency plan, annual reporting, etc.).
2. Develop a cleanup plan. The plan should describe how all waste residues, contaminated containment systems (liners, etc.), contaminated soil, and structures and equipment contaminated with waste and leachate will be removed or decontaminated. Cleanup activities may involve steam cleaning and triple rinsing of all structures and equipment. Areas where spills may have migrated to the soil (e.g., cracked concrete, stained or discolored surfaces) should be sampled to determine if contamination is present.
3. When metal finishing processes cease, remove any hazardous products or raw materials (e.g., unused solvents, unused plating solutions, etc.) from your shop within 90 days; otherwise, you will be required to manage them as hazardous wastes and be subject to additional regulations. You must manage all hazardous waste properly (e.g., perform analyses of the waste, package and label waste for transportation, track the shipment and receipt of the waste, meet record keeping and reporting requirements, etc.)
4. Implement your cleanup plan.
5. Document that all the hazardous materials and hazardous wastes have been shipped off-site and you have cleaned the areas where hazardous waste was stored.
6. When you no longer generate hazardous waste (including hazardous waste resulting from cleanup activities), you should obtain a a Notification of Regulated Waste Activity form (USEPA Form 8700-12) and mail the completed form to the Illinois EPA's Annual Reports and Manifest Group at the address at the end of this document.

What is the Site Remediation Program and how can it help me?

The Site Remediation Program (SRP) is a cooperative, voluntary program that offers a standard systematic procedure for environmental property assessment and cleanup. Upon successful completion of program requirements, the Illinois EPA will issue a No Further Remediation (NFR) Letter for the site. The NFR Letter states that the site does not represent a threat to human health and the environment. Often banks will not lend money on equity, and buyers will not accept a property, unless an NFR Letter has been issued.

Under the SRP, participants are required to pay for Illinois EPA review and evaluation services at site cleanups.

The cost of cleaning up a metal finishing site depends on a variety of site-specific factors that include, but are not limited to:

• Materials and wastes managed at the site
• Extent of the no further remediation determination (i.e., focused or comprehensive NFR Letter) which the remediation applicant is seeking from the Illinois EPA
• Future land use classification (residential, industrial/commercial, conservation, or agricultural)
• The scope of the investigation conducted to develop remediation objectives for soil and groundwater
• Community interest
• Housekeeping practices conducted during the operation of the site
• Remediation technology and time frame

Since cleanup standards are risk-based, the cleanup costs may be lower than anticipated.

Do I have to obtain the services of a Licensed Professional Engineer?

Yes. All SRP site activities and report preparation must be conducted by, or under the general supervision of a person licensed in Illinois to practice as a professional engineer (LPE).

Some things to consider in selecting a LPE:

• Professional reputation
• References
• Experience in dealing with your particular problem and successful completion of similar projects in Illinois

For assistance in selecting an LPE, you can contact the Illinois EPA's Office of Small Business at 1-888-372-1996.

What are the steps to successful participation in the SRP?

Upon enrollment into the SRP, the following steps are required by the remediation applicant for successful participation:

• Conduct a site investigation;
• Develop cleanup levels;
• Plan the cleanup (if necessary); and
• Perform and document the cleanup (if necessary).

Site Remediation Program Cleanup Process

Conduct a Site Investigation - Where and what should I check at my operation?

Typical areas where hazardous chemicals may be present at a metal finishing operation include, but are not limited to:

• Areas around cleaning, plating and rinse tanks
• Dumpsters, utility lines
• Cracks in the floor, entryways
• Piping, floor drains, sump areas, trenches
• Sewage line to the main storm or sewer lines
• Areas below vapor collection exhaust systems
• Loading docks
• Known or suspected spill areas (e.g., discolored or stained areas, stressed or dead vegetation, etc.)

Types of hazardous wastes typically generated by metal finishing operations include, but are not limited to:

• Dirty rags
• Filter wastes
• Metal fines and cuttings
• Worn polishing materials
• Spent solvents used in degreasing
• Wastewater treatment sludges
• Spent plating bath solutions
• Plating bath residues
• Spent stripping and cleaning bath solutions
• Quenching bath residues
• Quenching waste water treatment sludges
• Used containers

Typical hazardous chemicals found at metal finishing operations, include but are not limited to:

• Cadmium
• Chromium
• Copper
• Cyanide
• Nickel
• Trichloroethylene (TCE)
• 1,1,1-Trichloroethane (TCA)
• Tetrachloroethylene (PCE)
• cis-1,2-Dichloroethane (DCE)
• 1,1-Dichloroethane (DCA)
• Nitric Acid
• Hydrochloric Acid
• Sulfuric Acid

The site investigation should be designed to collect information to determine the extent and concentration of hazardous chemicals in the soil and groundwater. Site investigation activities include, but are not limited to: records review (e.g., review of historical sources to determine past uses of the site and surrounding area); topographic work (e.g., site base map and legal description); and field work (e.g., soil and groundwater sampling, field and laboratory analyses, etc.).

Develop Cleanup Levels - How do I know if my site is contaminated?

The Tiered Approach to Corrective Action Objectives (TACO) is the methodology used by the SRP to develop site-specific, risk-based remediation objectives (i.e., cleanup levels). TACO takes into account the extent and concentration of hazardous chemicals, the possibility of people inhaling or ingesting the hazardous chemicals, and current and future use of the site. TACO offers multiple approaches (e.g., look-up tables, calculation of cleanup levels, risk assessment, area background, exclusion of exposure pathways, etc.) and measures (e.g., engineered barriers, institutional controls, etc.) to develop site-specific remediation objectives. Each approach differs on the type of site-related and risk-based information that can be used to develop less stringent, but still protective, site-specific remediation objectives.

Plan the Cleanup - What remedial actions should I take?

After remediation objectives are established using the TACO procedures, you may:

• Reduce hazardous chemical concentrations to meet established objectives through active remediation (e.g., removal of contaminated soil, soil-vapor extraction system, etc.);
• Restrict exposure to contaminated soil or groundwater or both by using engineered barriers or institutional controls;
• Take no action, if hazardous chemical concentrations are not above the remediation objectives; or
• Use a combination of the options above.
• Perform and Document the Cleanup 

Common cleanup activities at metal finishing operations:

• Remove or decontaminate tanks
• Triple-rinse all surfaces that have come in contact with hazardous waste
• Powerwash floors and manage wastewater properly
• Conduct hazardous waste determinations
• Remediate all contaminated soil and groundwater to meet the requirements of TACO
• Send all waste to a treatment, storage, and disposal facility permitted to handle your waste (i.e., no drums should remain on-site).

Upon successful completion of the SRP requirements, the Illinois EPA will issue a NFR Letter. To be effective, the NFR Letter must be recorded with the Office of the Recorder in the county in which the site is located.

Summary of Cleanup Methods

The table below summarizes the two methods described in this document to ensure that hazardous materials and hazardous wastes are removed and properly shipped off-site after shut down.

For more information on: Hazardous Waste Management Regulations:

RCRA Hotline
1-800-424-9346 or TDD 1-800-533-7672
or Visit the USEPA Web Site

Site Remediation Program/TACO:

Voluntary Site Remediation Unit
Remediation Project Management Section
217/782-6761 

Notification of Regulated Waste Activity

Illinois EPA
Division of Land Pollution Control
Waste Reduction and Compliance Section
1021 North Grand Avenue East, P.O. Box 19276
Springfield, Illinois 62794-9276
217/785-8452