1.1.1 Incident Category
Time Critical - Removal Action
1.1.2 Site Description

Phase II Assessment - January 2013 

A Phase II Property Assessment (Phase 2) of the Site was completed in January 2013. The Phase 2 was funded by an EPA Brownfields Assessment Grant for hazardous substances previously awarded to the City of Sidney, Ohio. The approximately 5.74-acre property consists of two platted, unused alleys, and 27 platted lots. The 160,000 square foot industrial building consists of a series of interconnected buildings. For the Phase I, the buildings were referenced by a number (Buildings 1 through 16). The buildings are slab on grade with no basements except for a crawl space beneath Building 2 and vary from one to three stories in height; the majority of the buildings are one story in height. According to the Phase 2, portions of the building roofs and walls failed, multiple windows were broken, and the buildings were exposed to the elements. The Site was historically used for iron and aluminum cookware manufacturing and contained foundries dedicated to both types of activities. The Site was first developed for this use in the late 1890s and cookware manufacturing continued until 1997. Limited portions of the property were then used for polishing and grinding work between approximately 2002 and 2008. Soil and waste sampling conducted during the Phase 2 documented Aroclor 1260 as the only polychlorinated biphenyl (PCB) detected at the Site. Elevated levels of metals including arsenic, antimony, chromium, mercury, and nickel, were detected throughout the Site. 

Ohio EPA Emergency Response - August 2015

On August 5, 2015, Ohio EPA Emergency Response responded to a citizen complaint that described transformer oil dumped on-site. Ohio EPA responded to the complaint and found 5 large PCB transformers at the abandoned Wagner Manufacturing facility. Four of the five transformers had the lids removed.

On August 11, 2015, Ohio EPA investigated the facility with US EPA. In addition to the 5 PCB transformers, numerous vats of corrosive (pH range from 1 to 5) liquid were observed. The vats of acidic liquid contained variable amounts of liquid but the total acidic liquid quantity was estimated at 10,000-15,000 gallons. Foundry sand and metallic dust and debris were observed throughout the abandoned facility.

On August 20, 2015, The Ohio EPA's Division of Environmental Response and Revitalization requested EPA's assistance to conduct an assessment and a potential emergency removal action at the former Wagner Manufacturing facility. The Ohio EPA noted that the facility is in very poor condition; roofs are collapsed in several buildings; many windows are missing, broken or boarded; and there is evidence of break-in and vandalism. This Site is in a residential neighborhood, the facility is compromised, and the amount of chemicals made this facility an immediate threat to the environment. 

EPA Site Assessment - August 2015

On August 27, 2015, US EPA, EPA's Superfund Technical Assessment and Response Team (START) contractor, Ohio EPA, and Sidney Fire Department (SFD) conducted an investigation of the Site.  During the Site investigation, EPA observed approximately 40 55-gallon drums and 80 containers (having a volume of 5 gallons or less) on Site. Analytical results from numerous Site building waste piles documented low levels of arsenic, barium, lead, thorium, and radium. EPA also documented abandoned chemical waste, including containers holding ignitable and corrosive hazardous waste at the Site. The vats of acidic liquid contained variable amounts of liquid but the total acidic liquid quantity was estimated at 15,000 gallons. Foundry sand and metallic dust and debris were observed throughout the abandoned facility.

1.1.2.1 Location
The WW Site is located at 440 Fair Road, and is situated in a mixed residential and commercial area of Sidney, Shelby County, Ohio 45365. The geographical coordinates for the Site are 40.2807830° North latitude and -84.1622330 West longitude. The Site is bordered to the north by a residential area on Culvert Street, to the south and east by a residential area on Fair Road, and to the west by a residential area on South Wilkinson Avenue. Residential areas are located within 100 feet north and west of the Site.

1.1.2.2 Description of Threat
EPA confirmed the presence of a threat of release of hazardous substances, pollutants, or contaminants at the Site as defined by Section 101(14) of CERCLA, including the presence of corrosives (acids and caustics) and ignitable hazardous waste in drums, vats, and containers. Additionally, elevated levels of metals were documented in waste piles that are open to the environment. EPA documented that approximately 120 drums, 15,000 gallons of corrosive liquid, 200 cubic yards of metals contaminated foundry sand and five leaking transformers are on Site. The Site buildings are in very poor condition; roofs are collapsed in several buildings; many windows are missing, broken or boarded; and there is evidence of break-in and vandalism.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
EPA performed a Site investigation on August 27, 2015 and documented that approximately 120 drums and containers, 10,000 gallons of corrosive liquid, five leaking transformers, and 200 cubic yards of metals contaminated foundry sand are on Site. Drums and containers were noted to be rusted and deteriorated, with contents spilled on the floor. Additionally, transformers have been vandalized and are leaking contents to the surrounding soil. Analytical results from numerous Site building waste piles documented low levels of Arsenic, Barium, Lead, Thorium, and Radium.

Based on the analytical results and Site conditions observed during the site assessment, the Site meets the criteria for a removal action pursuant to 40 CFR 300.415(b)(2) and poses an imminent and substantial threat to the public health or welfare of the United States or the environment.

2.1.1 Narrative
On August 8, 2016, EPA initiated a time-critical removal action at the Site. The removal action is anticipated to last 90 working days and include removal and off-site disposal of hazardous waste. Hazards include acid filled vats, corroded drums, foundry sand, and other miscellaneous chemical containers spread throughout the site.
2.1.2 Response Actions to Date

June 28, 2016- EPA START initiated an emergency contingency plan (ECP) and air monitoring plan for the removal action.

June 29, 2016- EPA and START meet with local officials (City of Sidney, Sidney FD, Sidney PD) to discuss the EPA removal action scope of work, and the emergency contingency plan. 

July 7, 2016- Site Emergency Contingency Plan distributed by US EPA to local agencies following incorporation of comments.

July 25, 2016- EPA OSC Renninger updated the Sidney City Council on the pending removal action. The presentation included information about the removal scope of work, Site Investigation results, and Site Contingency Plan. 

August 3, 2016- EPA was given access to the property adjacent to the Wagner Ware site to be used for the command post during the removal activities.

August 8, 2016- EPA, START, and ERRS on-site to perform a site walk-through and begin planning site activities for each building. ERRS recommended having an Asbestos Survey performed before site activities begin. Support Zone area identified at eastern end of Culvert Street.

August 11, 2016- EPA, START, and ERRS on-site for the Asbestos Survey. Samples were taken throughout the site and sent in for analysis. Results of the survey showed various portions of the building have non-friable asbestos containing material (ACM), and these areas will be delineated and avoided for work. 

Week of August 22, 2016- ERRS mobilized trailers to the site, connected the power, and developed a site health and safety plan (HASP) for the removal action.

August 29, 2016- ERRS crew mobilized and initial site safety briefing completed.  HASP signed by crew.  Off-shift site security initiated.  EPA START initiated hot zone and perimeter air monitoring.  Support Zone established at eastern end of Culvert Street. 

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

EPA is currently investigating PRPs at the site.

2.1.4 Progress Metrics

2.2.1 Anticipated Activities

See section 2.2.1.1 below

2.2.1.1 Planned Response Activities

1. Develop and implement a Site-specific Health and Safety Plan, including an Air Monitoring Plan, and a Site Emergency Contingency Plan;
2. Develop and implement a Site Security Plan;
3. Characterize, remove, transport and dispose of all characterized or identified hazardous waste and associated debris located at the Site;
4. Recycle non-hazardous waste;
5. Decontaminate floors of Site building;
6. Remove transformers and contaminated soil from transformer area.

2.2.1.2 Next Steps

1. Starting on August 29, 2016, ERRS to segregate hazardous and non-hazardous waste streams, staging hazardous materials inside the building (Exclusion Zone) and non-hazardous materials in roll-off boxes in the Contamination Reduction Zone;
2. Starting on August 29, 2016, START will conduct air monitoring in the Exclusion Zone and Contamination Reduction Zone.

2.2.2 Issues

1. There is frequent trespassing onto the site during off-working hours. Trespassers are vandalizing the building and its contents, which includes hazardous materials with associated deteriorating containers in uncontrolled storage areas.
2. Continue site security at the Support Zone during non-working hours (evenings/weekends).

Front gate to access the Support Zone is closed/locked during non-working hours.

Temporary upper parking lot closure is in effect for Wagner Ware during the removal action.

EPA Security Guard on-site (Support Zone) during non-working hours (evenings/weekends).

* 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.

3.1 Unified Command
N/A
3.2 Cooperating Agencies
Ohio EPA

Sidney Fire Department

Sidney Police Department

City of Sidney

Shelby County EMA

US EPA - 1

START - 1

ERRS - 5

ERRS: Emergency and Rapid Response Services contractor

OSC: On-Scene Coordinator

POLREP: Pollution Report

START: Superfund Technical Assessment and Response Team contractor

US EPA: United States Environmental Protection Agency