U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Ashtabula Iron and Metal Site - Removal Polrep
Final Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
Subject: POLREP #7
Final
Ashtabula Iron and Metal Site
C5R2
Ashtabula, OH
Latitude: 41.8739139 Longitude: -80.7985901

To:
From: Elizabeth Nightingale, OSC
Date: 4/14/2014
Reporting Period: 4/7/14-4/11/14

1. Introduction
  1.1 Background
   
Site Number: C5R2    Contract Number:  
D.O. Number:      Action Memo Date: 9/25/2013
Response Authority: CERCLA    Response Type: Time-Critical
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 12/2/2013    Start Date: 12/3/2013
Demob Date: 4/11/2014    Completion Date: 4/11/2014
CERCLIS ID: OHN000510892    RCRIS ID: OHR000042911
ERNS No.:    State Notification: Yes
FPN#:    Reimbursable Account #:

1.1.1 Incident Category
Time critical removal action.

1.1.2 Site Description
Please see initial POLREP.

1.1.2.1 Location
The site is located at 1015 West 30th Street, Ashtabula, Ashtabula County, Ohio. The location coordinates are latitude 41.874396 ° and longitude - 80.798477 °.  The site is bounded by mixed industrial and residential neighborhoods in all directions.
1.1.2.2 Description of Threat
Please see initial POLREP.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
Please see initial POLREP.
2. Current Activities
  2.1 Operations Section
    2.1.1 Narrative

Hazardous substances and materials had been previously documented (or were discovered during the removal action) in and around the following locations on site:

- Main Office Building
- Maintenance Building
- Former Railroad Roundhouse
- Wooden Outbuilding
- Aluminium Outbuilding
- Wooden Office Building / Lab Area

Additionally, numerous containers were located outside throughout the site. Several torn bags labeled asbestos were identified in one central waste pile. The radium source; one extensive pile of metal shavings that contained hazardous substances and had a history of spontaneous combustion; waste oil contaminated soils and a leaking underground storage tank that contained unknown oily waste were also addressed through this action. 


2.1.2 Response Actions to Date

Week's Activities Overview

Over the week beginning April 7th, 2014 the following activities were completed:

- Completed excavation and disposal of contaminated soil that was below metal shavings piles along the western property boundary removed through this action. Soil was contaminated with waste oil and had a strong odor. Area was backfilled with clean fill and seeded.
- Completed excavation and disposal of contaminated soil that surrounded underground storage tank. Tank had leaked into surrounding soil. Tank was destroyed to prevent reuse and left in place. Area was backfilled with clean fill and seeded.



Update by geographic area:

Below is an update on the status of action for each of the focus areas on site. A map with building names and locations is available in the documents section of the website. A map depicting the outdoor areas addressed through this action will be available in the final project report (currently in development).

Uncleared buildings:
None

Fully Cleared Buildings (all containers of hazardous substances have been removed from these buildings): 
- Main Office Building 
- Wooden Outbuilding 
- Aluminium Outbuilding 
- Wooden Office Building / Lab Area 
- Utility Building on southern property
- Former Railroad Roundhouse 
- Maintenance Building


Outside Areas Addressed: 
- Bags labeled asbestos - Removed the week of 3/3/14.
- Metal shavings pile complex - Completed shipping of metal shavings piles that contained hazardous substances and had a history of spontaneous combustion offsite for proper disposal on 3/4/14.
- Small containers and drums outside throughout site - shipped for disposal during the week of 3/3/14.
- Rolloff with hazardous constituents - emptied into shippable rolloffs. Shipped offsite for disposal on 3/3/14 and 3/5/14.
- Large ground transformer - removed by First Energy
- Pole mounted transformers - removed by First Energy
- Contaminated soil below area where metal shavings were removed. 
- Area surrounding buried underground storage tank next to the wooden outbuilding. 


Air Monitoring and Sampling:
Air monitoring began on 12/2/13, and was conducted every day work was ongoing on site (conditions permitting).

During the week of 4/7/14, rainy conditions did not permit deployment of datarams. A MultiRae was used to monitor volatile organic carbon levels while pumping out the underground storage tank and excavating the soil around it. There were no exceedances of action levels within the breathing zone.   


2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
General notice and 104(e) letters were issued to multiple potentially responsible parties in September 2013. Investigation is ongoing.


2.1.4 Progress Metrics

Waste Stream Medium Quantity Manifest # Disposal Reuse
Aerosols Flammable Gas 3600 pounds 12735476 JJK  x  
Asbestos containing material Solid 1 ton 204663SB x  
Broken Glass, Non Hazardous Solid 450 pounds 12735475 JJK x  
Contaminated Water (UST) Liquid 698 gallons 296697 x  
Formic Acid Liquid 25 pounds 12735476 JJK  x  
Hazardous Debris Solid 1 - 20 cyd roll off  12735410 JJK x  
Hazardous Debris Solid 1 - 20 cyd roll off  12735411 JJK x  
Hazardous Waste Liquid Liquid 4050 pounds 12735475 JJK x  
Hazardous Waste Liquid Liquid 5400 pounds 12735476 JJK  x  
Hazardous Waste Solid (Mercury Contaminated Glass) Solid 450 pounds 12735475 JJK x  
Hydrochloric Acid Liquid 400 pounds 12735476 JJK  x  
Large Ground Transformer Liquid  1   x  
Liquid Labpack, Non Hazardous Liquid 7200 pounds 12735475 JJK x  
Metal and waste oil contaminated soil Solid 20 tons 001 x  
Metal and waste oil contaminated soil Solid 20 tons 002 x  
Metal and waste oil contaminated soil Solid 20 tons 003 x  
Metal and waste oil contaminated soil Solid 20 tons 004 x  
Metal and waste oil contaminated soil Solid 20 tons 005 x  
Metal and waste oil contaminated soil Solid 20 tons 006 x  
Metal and waste oil contaminated soil Solid 20 tons 007 x  
Metal and waste oil contaminated soil Solid 20 tons 008 x  
Metal and waste oil contaminated soil Solid 20 tons 009 x  
Metal and waste oil contaminated soil Solid 20 tons 010 x  
Metal and waste oil contaminated soil Solid 20 tons 011 x  
Metal and waste oil contaminated soil Solid 20 tons 012 x  
Metal and waste oil contaminated soil Solid 20 tons 013 x  
Metal and waste oil contaminated soil Solid 20 tons 014 x  
Metal and waste oil contaminated soil Solid 20 tons 015 x  
Metal and waste oil contaminated soil Solid 20 tons 016 x  
Metal and waste oil contaminated soil Solid 20 tons 017 x  
Metal and waste oil contaminated soil Solid 20 tons 018 x  
Metal and waste oil contaminated soil Solid 20 tons 019 x  
Metal and waste oil contaminated soil Solid 20 tons 020 x  
Metal and waste oil contaminated soil Solid 20 tons 021 x  
Metal and waste oil contaminated soil Solid 20 tons 022 x  
Metal and waste oil contaminated soil Solid 20 tons 023 x  
Metal and waste oil contaminated soil Solid 20 tons 024 x  
Metal and waste oil contaminated soil Solid 20 tons 025 x  
Metal and waste oil contaminated soil Solid 20 tons 026 x  
Metal and waste oil contaminated soil Solid 22 tons  027 x  
Metal and waste oil contaminated soil Solid 22 tons  028 x  
Metal and waste oil contaminated soil Solid 22 tons  029 x  
Metal and waste oil contaminated soil Solid 22 tons  030 x  
Metal and waste oil contaminated soil Solid 22 tons  031 x  
Metal and waste oil contaminated soil Solid 22 tons  032 x  
Metal and waste oil contaminated soil Solid 22 tons  033 x  
Metal and waste oil contaminated soil Solid 22 tons  034 x  
Metal and waste oil contaminated soil Solid 22 tons  035 x  
Metal and waste oil contaminated soil Solid 22 tons  036 x  
Metal and waste oil contaminated soil Solid 22 tons  037 x  
Metal and waste oil contaminated soil Solid 22 tons  038 x  
Metal and waste oil contaminated soil Solid 22 tons  039 x  
Metal and waste oil contaminated soil Solid 22 tons  040 x  
Metal and waste oil contaminated soil Solid 22 tons  041 x  
Metal and waste oil contaminated soil Solid 22 tons  042 x  
Metal and waste oil contaminated soil Solid 22 tons  043 x  
Metal and waste oil contaminated soil Solid 22 tons 044 x  
Metal and waste oil contaminated soil Solid 22 tons 045 x  
Metal and waste oil contaminated soil Solid 22 tons 046 x  
Metal and waste oil contaminated soil Solid 22 tons 047 x  
Metal and waste oil contaminated soil Solid 22 tons 048 x  
Metal and waste oil contaminated soil Solid 22 tons 049 x  
Metal and waste oil contaminated soil Solid 22 tons 050 x  
Metal and waste oil contaminated soil Solid 22 tons 051 x  
Metal and waste oil contaminated soil Solid 22 tons 052 x  
Metal and waste oil contaminated soil Solid 22 tons 053 x  
Metal and waste oil contaminated soil Solid 22 tons 054 x  
Metal and waste oil contaminated soil Solid 22 tons 055 x  
Metal and waste oil contaminated soil Solid 22 tons 056 x  
Metal and waste oil contaminated soil Solid 22 tons 057 x  
Metal and waste oil contaminated soil Solid 22 tons 058 x  
Metal and waste oil contaminated soil Solid 22 tons 059 x  
Metal and waste oil contaminated soil Solid 22 tons 060 x  
Metal and waste oil contaminated soil Solid 22 tons 061 x  
Metal and waste oil contaminated soil Solid 22 tons 062 x  
Metal and waste oil contaminated soil Solid 22 tons 063 x  
Metal and waste oil contaminated soil Solid 22 tons 064 x  
Metal and waste oil contaminated soil Solid 22 tons 065 x  
Metal and waste oil contaminated soil Solid 22 tons 066 x  
Metal and waste oil contaminated soil Solid 22 tons 067 x  
Metal containing waste Solid 20 tons  319002 x  
Metal containing waste Solid 20 tons 319003 x  
Metal containing waste Solid 20 tons 319004 x  
Metal containing waste Solid 20 tons 319005 x  
Metal containing waste Solid 20 tons 319006 x  
Metal containing waste Solid 20 tons 319007 x  
Metal containing waste Solid 20 tons 319008 x  
Metal containing waste Solid 20 tons 319009 x  
Metal containing waste Solid 20 tons 319010 x  
Metal containing waste Solid 20 tons 319011 x  
Metal containing waste Solid 20 tons 319012 x  
Metal containing waste Solid 20 tons 319013 x  
Metal containing waste Solid 20 tons 319014 x  
Metal containing waste Solid 20 tons 319015 x  
Non Hazardous Debris Solid 20 tons 319027 x  
Non Hazardous Debris Solid 20 tons 319028 x  
Non Hazardous Debris Solid 20 tons 319029 x  
Non Hazardous Debris Solid 20 tons 319033 x  
Non Hazardous Debris Solid 1 roll off (1 ton est) 319034 x  
Paint Related Material Liquid 4050 pounds 12735476 JJK  x  
Pole Mounted Transformers  Liquid  6   x  
Radium 226 Solid 1 coin   x  
Recyclables  Solid  4 large boxes full     x
Waste Acetic Acid Liquid 25 pounds 12735476 JJK  x  
Waste Corrosive Liquid, Acidic, Inorganic (Chromic Acid) Liquid 450 pounds 12735476 JJK  x  
Waste Flammable Liquid (Gasoline) Liquid 2250 pounds 12735475 JJK x  
Waste Flammable Liquid (Methanol) Liquid 450 pounds 12735476 JJK  x  
Waste Flammable Liquids (Wood Stain) Liquid 25 pounds 12735476 JJK  x  
Waste Grease, Non Hazardous Liquid 450 pounds 12735475 JJK x  
Waste Hydrofluoric Acid Liquid 25 pounds 12735476 JJK  x  
Waste Inorganic Liquid, Non Hazardous Liquid 2250 pounds 12735476 JJK  x  
Waste Inorganic Solid, Non Hazardous Solid 900 pounds 12735475 JJK x  
Waste Latex Paint, Non Hazardous Liquid 450 pounds 12735476 JJK  x  
Waste Nitric Acid Liquid 50 pounds 12735476 JJK  x  
Waste Oil Contaminated Soil (UST) Solid 22 tons 100 x  
Waste Oil, Non Hazardous Liquid 9450 pounds 12735475 JJK x  
Waste Organic Liquid, Non Hazardous Liquid 450 pounds 12735475 JJK x  
Waste Solid Labpack, Non Hazardous Solid 900 pounds 12735476 JJK  x  


Regional Metrics

This is an Integrated River Assessment.  The numbers should overlap.

Miles of river systems cleaned and/or restored

 0

Cubic yards of contaminated sediments removed and/or capped

 0

Gallons of oil/water recovered

 698 gallons

Acres of soil/sediment cleaned up in floodplains and riverbanks

 0

Stand Alone Assessment

Number of contaminated residential yards cleaned up

 0

Number of workers on site

 7

Contaminant(s) of Concern

various acids, corrosives, flammable liquids and solids, leachable lead containing waste, radium, metal containing waste, waste oil, and others

Oil response Tracking

Estimated volume 

Initial amount released

 N/A

Final amount collected

N/A

CANAPS Info

FPN Ceiling Amount

N/A

FPN Number

N/A

Body of Water affected

N/A

Administrative and Logistical Factors (Check X where applicable)

 Precedent-Setting HQ Consultations (e.g., fracking, asbestos)

 Community challenges or high involvement

x Radiological

x More than one PRP

Endangered Species Act  / Essential Fish Habitat issues

 Explosives

 AOC

 Historic preservation issues

 Residential impacts

 UAO

 NPL site

 Relocation

 DOJ involved

 Remote location

 Drinking water impacted

 Criminal Investigation Division involved

 Extreme weather or abnormal field season

 Environmental justice

 Tribal consultation or coordination or other issues

Congressional involvement

 High media interest

 Statutory Exemption for $2 Million

 Statutory Exemption for 1 Year

 Active fire present

x Hazmat Entry Conducted – Level A, B or C

 Incident or Unified Command established

 Actual air release (not threatened)









x  


  2.2 Planning Section
    2.2.1 Anticipated Activities

Planned removal activities on-site included:

 

a)      Developing and implementing a site-specific Health and Safety Plan, including an Air Monitoring Plan, and a site Emergency Contingency Plan;
 

b)      Developing and implementing a Site Work Plan that includes a Site Security Plan;

 

c)      Securing, characterizing, and sampling known and suspected hazardous substances, contained or uncontained, at the site;

 

d)     Consolidating and packaging hazardous substances, pollutants and contaminants for transportation and off-site disposal;

 

e)      Decontaminating contaminated structures as necessary;

 

f)       Transporting and disposing of all characterized or identified hazardous substances, pollutants, wastes, or contaminants that pose a substantial threat of release (except NORM) at a Resource Conservation and Recovery Act/CERCLA-approved disposal facility in accordance with  EPA’s Off-site Rule (40 C.F.R. § 300.440), as applicable;

 

g)      Removing and reusing or disposing of NORM in accordance with CERCLA and with all applicable state regulations; and

 

h)      Taking any other response actions to address any release or threatened release of a hazardous substance, pollutant and contaminant that the U.S. EPA OSC determines may pose an imminent and substantial endangerment to the public health or the environment.   

 

Additional planned site activities, if needed, included security, perimeter air monitoring, and decontamination on the site, as needed to complete the removal action. 


2.2.1.1 Planned Response Activities
Please see above.

2.2.1.2 Next Steps
Our last day on site was April 11, 2014.

Over the course of  the removal action at this facility, we obtained additional information about site history and subsurface site conditions that led us to believe that there may be a layer of contaminated soil below the site surface. As described previously, when we removed a pile of metal shavings along the western site boundary we uncovered waste oil contaminated soil. While we were excavating in the center of the site to remove asbestos containing material, we also uncovered waste oil contaminated soil with a strong odor about 2 feel below surface. A former employee stopped by and stated that metal shavings processing was the primary focus of the business on site for many decades, and oily metal shavings piles covered the entire site. A historical aerial photo that we found shows many piles of metal shavings across the site. This available information leads us to believe that waste oil from oily metal shavings piles may have migrated into the ground, and may exist subsurface across the site. Therefore, at the completion of the EPA time critical removal action, EPA will refer the site back to the Ohio EPA for further consideration.  

2.2.2 Issues
Please see above.
  2.3 Logistics Section
    ERRS managed logistics.
  2.4 Finance Section
    No information available at this time.
  2.5 Other Command Staff
    2.5.1 Safety Officer
OSC served in this role.

2.5.2 Liaison Officer
OSC served in this role.

2.5.3 Information Officer
OSC served in this role.
3. Participating Entities
  3.1 Unified Command
n/a

3.2 Cooperating Agencies
OEPA
ODH
Ashtabula Fire Department
First Energy
4. Personnel On Site
  4/7/14
EPA: 1
ERRS: 5
START: 1

4/8/14
EPA: 1
ERRS: 5
START: 1

4/9/14
EPA: 1
ERRS: 5
START: 1

4/10/14
EPA: 1
ERRS: 5
START: 1

4/11/14
EPA: 0
ERRS: 5
START: 0
5. Definition of Terms
 
ATSDR   Agency for Toxic Substances and Disease Registry
 BZ  Breathing Zone
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CERCLIS   Comprehensive Environmental Response, Compensation, and Liability Information System
DNR   Department of Natural Resources
EPA   Environmental Protection Agency
ERNS   Emergency Response Notification System
ERRS   Emergency and Rapid Response Service
NG/M^3  nanograms per cubic meter
NCP   National Oil and Hazardous Substance Pollution Contingency Plan
NOAA   National Oceanic and Atmospheric Administration 
NPL   National Priorities List
NRC   National Response Center
OEPA  Ohio Environmental Protection Agency
ODH  Ohio Department of Health
OSC   On Scene Coordinator
PPE  Personal Protective Equipment
PPM  Parts per million
RCRIS   Resource Conservation and Recovery Act Information System
RP   Responsible Party
RRT   Regional Response Team
START   Superfund Technical Assessment and Response Team
US FWS   United States Fish and Wildlife Service
USCG   United States Coast Guard


6. Additional sources of information
  6.1 Internet location of additional information/report
epaosc.org/aim

6.2 Reporting Schedule
Reporting is complete for this action.
7. Situational Reference Materials
  n/a