1.1.1 Incident Category

 Time critical removal action.

1.1.2 Site Description

The Spencer Drum Site is an approximately 17,000 square foot warehouse located in a mixed residential and commercial area in Spencer, Marathon County, WI. The building contains two rooms, a larger room to the north and a much smaller room to the south. The larger room was operated as a mechanic shop from 2012 until December 2014 when the owner suddenly passed away.  Prior to 2012, the entire warehouse housed a liquidation company and retail shop, Don Smith Sales.

The smaller of the two rooms in the warehouse contains approximately 90 drums that are in extremely poor condition. Many of the drums are leaking and some are bulging. The drums were reportedly acquired in the 1970s by the liquidation company.  Almost all of the drums are unlabeled and there are no records available regarding the contents of the drums.  A Wisconsin Department of Natural Resources (WDNR) Warden interviewed representatives from Don Smith Sales, but was unable to gather any credible information about the origin or contents of the drums.

WDNR received an anonymous notification of the drums on June 23, 2015. Shortly thereafter, WDNR requested assistance from the EPA Emergency Response Branch.

1.1.2.1 Location

The Site is located at 408 E. Willow Drive, Spencer, Marathon County, WI 54479 (Parcels 181-2602-082-9915 and 181-2602-082-9906) in a mixed residential and commercial area.  The geographic coordinates for the Site are Latitude: 44.752219, Longitude: -90.296194. Commercial properties neighbor the Site to the north and the east.  The Spencer Area Fire Department station borders the Site to the South. A residential neighborhood borders the Site to the west.  The closest residence is located approximately 200 feet to the west of the property. A municipal water tower is approximately 100 feet to the northwest of the warehouse. 

1.1.2.2 Description of Threat

Approximately 90 drums of unknown contents are being stored improperly at the Site. Many of the drums are failing and are already leaking their contents onto the floor. It is possible that the spilled material has migrated beyond the concrete floor into the sub-slab and/or under the foundation.  In addition to leaking drums, there are also bulging drums at the Site. Hazardous characteristics of stored materials was confirmed by EPA and local fire officials.  These materials are defined as hazardous substances in 40 CFR §302.4 and hazardous waste in 40 CFR §261.24.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

On July 21, 2015, EPA OSC Kathy Halbur conducted a reconnaissance visit with WDNR Regional Spills Coordinator Tom Kendzierski. On August 27, 2015, the Marathon County Hazardous Materials Team, Spencer Fire, Wausau Fire, Marathon County Emergency Management, Wisconsin Emergency Management (WEM), WDNR, and EPA conducted an exercise at the Site. Approximately one third of the drums stored at the Site were screened with a Multi-Rae Pro for volatile organic compounds (VOCs), gamma radiation, lower explosive limit, oxygen level, carbon monoxide, and hydrogen sulfide levels.  The temperature of the selected drums was also screened with a Fluke Infrared Thermometer and the condition of the selected drums was assessed.  Elevated VOC concentrations were detected from every drum screened; levels ranged from 224 to 99,000 parts per billion (ppb). Temperatures were relatively consistent, ranging from 62-67^oF. 

Twelve drums were sampled for additional screening and limited hazcatting.  Almost all of the samples collected were multi-phase; the materials are so old that they are solidifying. Types of additional screening conducted included general appearance, pH, flammability (pass/fail), water solubility, density, “Spilfyter” strips, Hazmat ID, and Ahura First Defender.  Corrosivity and flammability of some of the materials being stored in the warehouse was confirmed using the Spilfyter strips. Many of the drums’ contents have leaked onto the floor.  Contents from the leaking drums has comingled on the floor of the warehouse. Kitty litter had been previously spread to contain spilled material. The drums are stored very close together. Bulging drums were observed, but not assessed during the exercise due to safety concerns. 

2.1.1 Response Actions to Date

During this reporting period (11/30/15-12/3/15), the following activities occurred:

• Mobilized ERRS, START, and EPA crew and equipment to Site;

• Established support and exclusion zones;

• Sampled all waste drums and containers (Level B PPE);

• Conducted hazard characterization analysis for all sampled waste;

• Combined waste streams with similar characteristics into test batches;

• Collected waste disposal samples for laboratory analysis;

• Repackaged liquid waste for shipment;

• Labeled and segregated hazardous waste;

• Conducted air monitoring in accordance with the Air Monitoring Plan;

• Demobilized crew and equipment.

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

EPA sent General Notice of Liability letters to the property owner and Don Smith.  Neither PRP was able to conduct the necessary removal action. 

2.1.3 Progress Metrics

2.2.1 Planned Response Activities & Next Steps

The following activities are planned for the next reporting period:  

• Obtain and review laboratory analysis of disposal samples;

• Obtain bids for disposal and select CERCLA approved disposal facilities;

• Remobilize ERRS, START, and EPA personnel to Site;

• Prepare solid wastes for shipment;

• Transport waste for off-site disposal;

• Clean and assess floor; and

• Conduct air monitoring.

2.2.2 Issues

Increasingly cold temperatures are making working conditions difficult and causing the liquid wastes to freeze.

ERRS: Environmental Quality Management (and Veolia)

START: Tetra Tech

* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.

2.5.1 Safety Officer

No safety incidents during this reporting period.  Drum sampling was conducted in Level B PPE.

2.5.2 Liaison Officer

EPA OSC Halbur is the Liaison Officer for this removal action. The Spencer Fire Chief, representatives from WDNR, and the property owner visited the Site during this reporting period.

2.5.3 Information Officer

EPA OSC Halbur is the Information Officer for this removal action.

3.1 Cooperating Agencies

Spencer Fire Department

Wisconsin Department of Natural Resources

Wisconsin Emergency Management

EPA: 1

ERRS: 6

START: 1

CERCLA: Comprehensive Environmental Response, Compensation, and Liability Act of 1980

EPA: Environmental Protection Agency

ERRS: Emergency and Rapid Response Services

OSC: On-Scene Coordinator

PPE: Personal Protective Equipment

PRP: Potentially Responsible Party

START: Superfund Technical Assessment and Response Team

TBD: To be determined

VOC: Volatile Organic Compound

WDNR: Wisconsin Department of Natural Resources

WEM: Wisconsin Emergency Management

6.1 Internet location of additional information/report

The Administrative Record is available at the Spencer Village Hall, 105 Park St., Spencer, WI 54479.

Additional information about the removal is available at www.epaosc.org/spencerdrum.

6.2 Reporting Schedule