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Ashtabula Iron and Metal Site

All POL/SITREP's for this site Ashtabula Iron and Metal Site
Ashtabula, OH - EPA Region V
POLREP #1
Initial
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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Ashtabula Iron and Metal Site - Removal Polrep
Initial Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V

Subject: POLREP #1
Initial
Ashtabula Iron and Metal Site
C5R2
Ashtabula, OH
Latitude: 41.8739139 Longitude: -80.7985901


To:
From: Elizabeth Nightingale, OSC
Date: 12/9/2013
Reporting Period: 12/3/13-12/6/13

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:      Completion Date:  
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
This site currently is an abandoned industrial property in a mixed residential/industrial area in Ashtabula, Ohio. The site is approximately 22 acres in size and contains approximately 53,000 square feet of buildings and numerous outdoor storage areas that contain large piles of various solid wastes. Much of the surface soil in between the piles is mixed with or covered by fine scrap metal shavings and debris. Surface soil is stained in several areas on site. 

EPA, Ohio EPA and other agency investigations have found numerous threats to human health and the environment associated with the site. The primary threat is the presence of hundreds of unsecured containers of known or suspected toxic hazardous substances. Access to the site is unrestricted and evidence of vandalism and trespassing is present in the facility. If the containers are compromised, characteristically toxic hazardous wastes and listed hazardous substances will be released to the environment. 

Additional threats present on site include: 
• asbestos containing materials; 
• containers of characteristically toxic hazardous wastes / CERCLA listed hazardous substances including benzene, selenium, 1,2-dichloroethane and lead; 
• metal turnings piles that have spontaneously combusted; 
• a radium source;
• a lab with hundreds of containers labeled as various acids or unlabeled; and 
• other hazards. 

A time critical removal action was initiated on 12/3/13 to address these threats. 


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

As described above, numerous unsecured containers of hazardous substances and characteristically ignitable and toxic wastes are present on site.   Many of these containers are degrading and are located outside, presenting a significant threat of release.  As detailed above, assessment verified that the containers contain a variety of hazardous substances, as designated under Section 102 of CERCLA, including lead, 1,2-dichloroethane, benzene, and selenium.  

The content of the majority of the containers onsite is unknown, as most were unlabeled and have not been characterized.  The known and suspected hazardous substances located on site have the potential to be released through container degradation or vandalism, and migrate off-site and into ground and surface waters.  These chemicals could be ingested by children and pets; tracked off-site by visitors and trespassers; and spread throughout the area, into residential homes, and businesses.  Release of these chemicals could impact the Ashtabula River, and the aquatic life within it. There is a potential for direct contact with the hazardous substances because the site is bordered by residential neighborhoods and located within a city.  Access to the site is not restricted.

In addition to the threats posed by the containers, radium, a substance that is on the CERCLA priority list of hazardous substances because it poses a significant potential threat to human health due to its known or suspected toxicity and potential for human exposure, is present on site.  Asbestos is also present on site in waste materials.  Asbestos is defined as a hazardous substance as defined by 40 C.F.R. § 302.4.  

These hazardous substances are not organized, secured, or maintained in a manner necessary to prevent exposure and/or release.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
Assessment results are briefly summarized above. Detailed results are available in the EPA Site Assessment Report, available upon request. 

2. Current Activities
  2.1 Operations Section
    2.1.1 Narrative

Hazardous substances and materials have been previously documented (or discovered upon arrival for the removal) 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 are located outside throughout the site. Several torn bags labeled asbestos have been identified in one central waste pile. The radium source, and one extensive pile of metal shavings with a history of spontaneous combustion will also be addressed. 


2.1.2 Response Actions to Date

Week's Activities Overview

Over the week beginning December 2nd, 2013 the following activities were completed:

- Mobilized to site and conducted orientation activities
- Drafted and revised Emergency Contingency, Health and Safety and Air Monitoring Plans
- Delivered Emergency Contingency Plans to Hospital, Fire and Police Departments, and verified hospital route
- Established waste staging area in maintenance building 
- Gathered, staged and secured containers from main office building, former railroad roundhouse, wooden outbuilding, and outdoor areas near maintenance building
- Removed 6 small pole mounted transformer from site (via First Energy)
- Conducted mercury and radiation monitoring in the aluminum outbuilding per tip from former employee, but did not detect excessive levels of mercury or radiation within the building (both at ground and breathing zone levels)

Additionally, the Ohio Department of Health (ODH) was on site on Friday to inspect the room inside the former railroad roundhouse with contains the radiation source.  ODH screened the room with a Ludlum Micro R meter.  Background inside the room was 6 Micro R/hr.  Levels reached 18 Micro R/hr near the lead container containing the radiation source. Wipe samples were collected on the sides and top of the bucket.  Samples were screened with a pancake probe.  Screenings did not exceed background levels.  The radiation source is properly contained and the crew is able to enter the room and retrieve small containers/drums without exposure to dangerous levels of radiation. 


Update by geographic area:

Below is an update on the status of action for each of the focus areas on site.

- Main Office Building - Cleared. Containers have been removed from building, and secured and staged at staging area
- Maintenance Building - Not cleared. This building is being used as the chemical staging area
- Former Railroad Roundhouse - Partially Cleared. Most containers have been removed from building, and secured and staged at staging area. Radium source remains in building (secured in lead based container) - EPA Health Physicist is handling disposal of this source
- Wooden Outbuilding - Cleared. Containers have been removed from building, and secured and staged at staging area
- Aluminium Outbuilding - Monitored for mercury and radiation on 12/5/13
- Auxillary Office Building / Lab Area - Not cleared. Chemist will address this building due to presence of approximately 200 containers of potent acids and unlabeled containers of liquid
- Bags labeled asbestos - not yet addressed
- Metal shavings pile complex - not yet addressed
- Containers and drums outside throughout site - collection of small containers has been initiated


Air Monitoring and Sampling:
Air monitoring began on 12/2/13, and will be conducted every day work is ongoing on site. During the week of  12/2/13, no exceedances of any site action levels were detected.



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 2012. Investigation is ongoing.


2.1.4 Progress Metrics

Waste Stream Medium Quantity Manifest # Treatment Disposal
           
           
           


  2.2 Planning Section
    2.2.1 Anticipated Activities

Planned removal activities on-site include:

 

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 site activities may include 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
Next week, work will continue to gather, stage and secure containers from throughout the site. Work to hazcat containers is scheduled to begin.

2.2.2 Issues
None.

  2.3 Logistics Section
    ERRS is managing logistics.

  2.4 Finance Section
    No information available at this time.

  2.5 Other Command Staff
    2.5.1 Safety Officer
OSC is serving in this role.

2.5.2 Liaison Officer
OSC is serving in this role.

2.5.3 Information Officer
OSC is serving 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
  12/3/13
EPA: 1
ERRS: 4
START: 2
OEPA: 2
Ashtabula Fire Department: 5
First Energy: 1
Liberty (OEPA Tire Removal Contractor): 1

12/4/13
EPA: 1
ERRS: 4
START: 1
OEPA: 0
Ashtabula Fire Department: 1
First Energy: 5
Liberty (OEPA Tire Removal Contractor): 1

12/5/13
EPA: 1
ERRS: 4
START: 2
OEPA: 0
First Energy: 0
Liberty (OEPA Tire Removal Contractor): 0

12/6/13
EPA: 1
ERRS: 4
START: 1
OEPA: 1
ODH: 1
First Energy: 0
Liberty (OEPA Tire Removal Contractor): 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
POLREPs will be issued weekly during weeks when onsite activities occur.

7. Situational Reference Materials
  n/a