U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Tecumseh Heus - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
Subject: POLREP #2
Progress
Tecumseh Heus
B5XP
New Holstein, WI
Latitude: 43.9517523 Longitude: -88.0859015

To: Al Nass, WDNR
Jason Smith, Tecumseh Products Company
From: Kathy Halbur, OSC
Date: 5/11/2011
Reporting Period: 4/8/2011-5/11/2011

1. Introduction
  1.1 Background
   
Site Number: B5XP    Contract Number:  
D.O. Number:      Action Memo Date: 12/22/2010
Response Authority: CERCLA/OPA    Response Type: PRP Oversight
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 11/19/2010    Start Date: 11/18/2010
Demob Date: 4/26/2011    Completion Date:  
CERCLIS ID: WID006116529    RCRIS ID:
ERNS No.:    State Notification:
FPN#:    Reimbursable Account #:


1.1.1 Incident Category

This Site is a PRP oversight time critical voluntary clean-up.

1.1.2 Site Description

Thia Site is an abandoned manufacturing facility privately owned by Mr. Edward Jones.  Mr. Jones operated a contract machining facility, Heus Manufacturing, at the Site from 2007-2009.  Mr. Jones abandoned the building, including the waste remaining from operations at the facility, in 2010. 

Heus Acquisitions purchased the property from Tecumseh Power in June, 2007.  The Tecumseh Products Company acquired the Site in 1956.  Tecumseh Products transferred the facility to its subsidiary Tecumseh Power Company in 2003.  Tecumseh ceased manufacturing operations at the facility in 2007.  In November 2007, Snowstorm Acquisition Corporation purchased the Tecumseh Power Company from Tecumseh Products and changed the business name to TecumsehPower Company.  Heus leased 350,000 square feet of the facility to Tecumseh for limited operations at the Site related to their business closure.  Heus terminated the lease and ordered TecumsehPower to vacate the building in May 2009. 

In May, 2010, the City of New Holstein and WDNR conducted an inspection of the Site.  Significant quantities of abandoned waste and evidence of trespassing were discovered at the facility.  The whereabouts of Mr. Jones were unknown to City and State officials. There are numerous liens on the property, including liens for delinquent taxes. The City took measures to secure the facility, including repairing and locking the perimeter fence.  In June, 2010, WDNR requested that U.S. EPA conduct a time critical removal action to mitigate the immediate threat posed by the abandoned waste at the Site.

1.1.2.1 Location

The Site is located at 1604 Michigan Avenue, New Holstein, Calumet County, Wisconsin.  The 38.7 acres property contains a 910,000 square foot building complex.  The Site is located in a mixed industrial, commercial, residential, agricultural land use area near the downtown of the City of New Holstein. Residences are located within 70 feet to the east and south and 300 feet to the west of the Site.  The nearest surface water body is Jordan Creek, located approximately 1,500 feet east of the property.  Records indicate that groundwater is present on Site at depths ranging from 8-12 feet below ground surface.  Three public water supplies are located within 0.25 miles of the Site.

1.1.2.2 Description of Threat

The waste abandoned at the facility poses a direct contact risk and the threat of release to soils and surface water.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

In August 2010, U.S. EPA conducted a site assessment at the facility to quantify and characterize the abandoned waste.  The building was in generally good condition, however significant pooling of water on the floor was observed from numerous leaks in the roof.  The majority of the material is waste oil, some containing PCBs.  Limited quantities of corrosive materials were also identified.  Some of the older drums abandoned at the facility were under pressure.  Oil had been spilled on the floor in many areas of the building, resulting in very slippery conditions.  Numerous open pits filled with liquid waste were observed throughout the facility.  There is no power to the building and sources of natural light are very limited.  Other than the perimeter fence, the building is unsecured.  Conditions in the facility present a significant safety hazard for anyone in the building.  Evidence of recent trespassing includes graffiti and empty soda and beer cans. 




2. Current Activities
  2.1 Operations Section
    2.1.1 Response Actions to Date

In September, 2010, U.S. EPA initiated negotiations with the PRPs to clean-up the abandoned waste at the facility.  Due to concerns related to winter weather conditions, Tecumseh Products and TecumsehPower (owners/operators of the facility prior to Heus Manufacturing) ceased AOC negotiations in November, 2010 and commenced a voluntary clean-up at the Site.  Chief Industrial Services was retained to conduct the clean-up.  The clean-up was conducted consistent with the National Contingency Plan, with U.S. EPA overseeing the removal.  See Initial POLREP for additional information.

A small amount of the work agreed upon could not be completed due to the onset of freezing temperatures in December.  On April 8, 2011, OSC Halbur and the WDNR Project Manager returned to the Site to check on Site conditions prior to Tecumseh and Chief returning to the Site.  Heavy snow caused a portion of the deteriorating roof to collapse during the winter.  Storm water is beginning to re-enter the facility thru the opening in the roof.  One previously cleaned pit has refilled with water.

Tecumseh and Chief returned to the Site on April 26, 2011 to complete the remaining removal work.  The chromium pit was emptied and cleaned; 3,750 gallons of D007 liquid waste was shipped to Envirite of Illinois.  Chief also removed 9,450 gallons of non-hazardous liquid waste from the wastewater treatment tanks.  Chief attempted to clean the wastewater tanks, but the residual oil did not release well from the still cold concrete.  It was determined that the wastewater tanks could not be effectively steam cleaned until the facility was warmer.  Another attempt to clean the tanks will be made in June, 2011. 

2.1.2 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

The facility is owned by Edward Jones.  Mr. Jones has been non-responsive to U.S. EPA's General Notice Letter and Demand Letter. Tecumseh Products and TecumsehPower (owners/operators of the facility prior to Mr. Jones' operation of Heus Manufacturing at the Site) are conducting a voluntary clean-up.

2.1.3 Progress Metrics

Waste Stream Medium Quantity Manifest # Treatment Disposal
Chromium Wastewater (D007)      Liquid  3,750 gallons   006319247JJK  LDR submitted Envirite of Illinois
 Non-haz Wastewater   Liquid  9,450 gallons  14081 & 14092  NA  Chief
           



  2.2 Planning Section
   

2.2.1 Anticipated Activities

Tecumseh and Chief will return to the Site in June, 2011 to complete the cleaning of the wastewater treatment tanks.

2.2.1.1 Planned Response Activities

U.S. EPA will conduct oversight of the remaining clean-up activities.  In the event the PRPs do not return to the Site, U.S. EPA will mobilize ERRS to complete the removal action.

2.2.2 Issues

Heavy snow caused a portion of the deteriorating roof to collapse during the winter.  Storm water is beginning to re-enter the facility thru the opening in the roof.
  2.3 Logistics Section
    Cold temperatures continue to limit the PRPs' ability to complete the clean-up.

  2.4 Finance Section
    No information available at this time.
  2.5 Other Command Staff
    2.5.1 Safety Officer
There were no safety incidents during the reporting period.

2.6 Liaison Officer
Not Applicable

2.7 Information Officer
Tecumseh notified the City of New Holstein, Calumet County, WDNR and U.S. EPA of thier plans to resume their work at the Site prior to remobilizing.

3. Participating Entities
  3.1 Unified Command
Not applicable.

3.2 Cooperating Agencies
The City of New Holstein, Calumet County Emergency Management, WDNR, and U.S. EPA are all monitoring the clean-up.

4. Personnel On Site
  OSC Kathy Halbur conducted oversight of the voluntary time critical clean-up action, pursuant to the NCP.

5. Definition of Terms
  No information available at this time.
6. Additional sources of information
  6.1 Internet location of additional information/report
For additional information, visit www.epaosc.org/Heus

6.2 Reporting Schedule
Final POLREP expected in the Summer, upon the completion of the remaining work.

7. Situational Reference Materials
  Not applicable