The Herron Avenue Drum Site consists of approximately 4 acres of land that has been developed for residential housing in Hamilton County, Cincinnati, Ohio. The Site consists of twenty parcels located along the southern portion of Herron Avenue, and is bordered to the east by the West Fork of Mill Creek, to the west by Cass Avenue, and to the south by Dreman Avenue. The Herron Avenue Site is surrounded by an area of residential properties of the north, west, and south perimeters. The West Fork of Mill Creek and a public playground is located along the eastern perimeter.
Based on interviews and aerial photos (1932-2001), the northern portion of the Site was utilized for residential and agricultural purposes from the late 1880s to the 1960s. From at least 1869 to 1905, the Site was owned by private individuals and utilized for residential and agricultural use. The southern portion of the Site was utilized for residential and light industrial purposes, as well as a junkyard.
Numerous environmental investigations were performed at the Site between 1995-2003. In the Report of Phase I Environmental Site Assessment by H.C. Nutting Company (HCN) dated October 31, 1995, the following potential environmental concerns were noted:
• Surface staining, apparently associated with petroleum products, in the northern portion of the property, and
• Hazardous substances or wastes associated with the former presence of a cabinet shop and enamel spraying shop on-site, and two 55-gallon drums observed on the property.
A limited Subsurface Investigation was performed by HCN at the Site in December 1995, and summarized in the Report of Limited Subsurface Investigation dated January 11, 1996. The HCN report concluded that localized hydrocarbon impact was present, and that the detected hydrocarbons did not appear to be those of environmental concern (i.e. attributable to the presence of gasoline, diesel fuel, or fuel oil).
In December 1999, Environmental Enterprises, Inc. (EEI), completed the Report of Phase I Environmental Site Assessment that identified the following areas of environmental concern:
• Four unlabeled 55-gallon drums were noted exposed in a hillside on Site. One of the drums appeared to contain asphalt; the other three drums were sealed and partially buried. The report recommended characterization of the drums prior to removal and disposal from the Site.
• Debris consisting of furniture, tires, bottles, and automotive parts were observed throughout the Site.
In a Phase II Investigation and Sample Results report dated May 18, 2000, EEI noted that samples were collected from the drums and laboratory analyzed for RCRA metals. Analytical results indicated the presence of lead in the drums (maximum concentration of 55 ppm) and recommended that the drums be dispose of properly as “lead contaminated”.
In November 2002, South Cumminsville Community for Better Housing, Inc., purchased the Site for the purpose of developing 20 residential lots. The City of Cincinnati received an easement to install public storm sewers at the Site on October 24, 2002. Two 55-gallon drums with unknown contents (liquid/sludge) were encountered during excavation activities associated with the Herron Avenue sanitary sewer construction project on March 18, 2003. Variable fill materials consisting predominantly of foundry sands were encountered during sewer installation up to that date, as the sanitary line had already been installed north and south of the subsurface drum area (middle of the Site). Construction activities were halted with approximately 75 feet of sewer line remaining to be laid to finish the project.
In a report dated July 2, 2003, ATC Associates, Inc., summarized a geophysical survey that was performed by subcontractor Mundell & Associates, Inc. (Mundell). The purpose of the survey was to investigate the extent of potential buried 55-gallon drums of waste at the Site, given the discovery of such materials within sewer installation area. The report summarized that metallic anomalies at depth suggest the potential presence of significant buried drum repositories. Three distinct anomalies along the northern half of the right-of way area may represent repositories of over 100 drums each. Other irregularly shaped anomalies are less likely to, but could represent significant drum accumulations.
In a letter dated July 11, 2003, the City of Cincinnati requested U.S. EPA assistance in conducting a potential time-critical removal action at the Herron Avenue Drum Site. The City of Cincinnati noted drums in various stages of deterioration were found along with what appeared to be paint, petroleum, solvent, and foundry sand waste
On July 1, 2003, U.S. EPA, TTEMI START, City of Cincinnati, and ATC (City of Cincinnati contractor) performed test trenching at four locations on the City of Cincinnati right-of-way portion of the Site. ATC identified the test trench locations based on the anomalies of the Mundell geophysical survey. Three of four test trenching locations identified subsurface drums as the anomalies, the fourth location revealed tires as the anomaly. Foundry sand was encountered at all U.S. EPA test trench locations to a depth of 10-15' below ground surface. Subsurface drums were noted to be in a deteriorated condition with contents leaking to the surrounding soil and sand. Drum waste contents were noted as liquid solvent, paint, black tar, and debris.
U.S. EPA sample results of the foundry sand encountered in the test trenches indicated the presence of total lead at concentrations of up to 446 ppm. Two drum had flashpoints low enough to be considered ignitable waste streams. Drum sample D-7 contained acetone (14,000 ppm), ethylbenzene (21,000 ppm), methyl ethyl ketone (16,000 ppm), toluene (120,000 ppm), and xylenes (73,000 ppm). The concentration of methyl ethyl ketone (16,000 ppm) exceeded the TCLP regulatory limit of 200 ppm.
In September, 2003 an Action Memo was signed authorizing U.S. EPA removal activities at the Herron Avenue site. On July 6, 2004, U.S. EPA and their contractors will mobilize to site in order to begin set-up for removal activities.
As of October 21, 2004, 3,350 drums/containers have been excavated from the Herron Avenue site.
