1.1.1 Incident Category
CERCLA Incident Category:  Inactive Recycling Facility

1.1.2 Site Description

1.1.2.1 Location

The New Lyme Metals Site is located at 618 State Route 6 in Jefferson, New Lyme Township, Ashtabula County, Ohio, 44047.  The geographical coordinates for the Site are Latitude 41.604995° North and Longitude 80.764439° West.  The Site is comprised of three parcels, totaling approximately 1 acre in size, and contains a dilapidated house and garage.  The Site is located in a rural area of New Lyme Township.  Approximately 150 people live within 1 mile of the Site.  Residences are located approximately 200 feet from the north and west property boundaries.

1.1.2.2 Description of Threat
During a Site Visit on December 9, 2009 and Site Assessment on February 18, 2010, U.S. EPA On-Scene Coordinators (OSC) documented uncontained waste across the Site including electronics components, circuit boards, capacitors, tires, gas cylinders, and numerous drums.   Approximately 20 55-gallon drums containing unknown contents were documented inside the garage.  Multiple 55-gallon drums were observed in a partially buried bus on the southwest corner of the Site and in the basement of the on-site residential house.  The OSCs also observed heavily stained soil and evidence of burning.  The Site is currently vacant.  However, the OSCs documented evidence of trespassing, including graffiti inside the garage and fresh footprints in the snow.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
The Site Assessment involved sampling surface soil, contents in drums and suspected asbestos containing material on the Site, and sampling sediment from the creek that runs next to the Site.  Analytical results from the Site Assessment indicated the presence of elevated concentrations of hazardous substances, as defined by section 101(14) of CERCLA.

Soil samples collected contained PCBs and metals including arsenic, lead, cadmium, antimony, mercury at concentrations exceeding the Ohio Administrative Code (OAC) 3745-300-08 Residential Land Use Category Generic Direct Contact Standard for the Single Chemical criteria.  Four bulk samples contained more than 1 percent asbestos, which is the regulatory limit defined at 40 CFR 61.141.  The above are hazardous substances, as defined by section 101(14) of CERCLA.   One surface soil sample contained cadmium exceeding the TCLP regulatory limit outlined at 40 CFR 261.24.  Additionally, the arsenic concentrations in the downstream sediment sample from the adjoining stream may indicate that arsenic is migrating from the Site. 

2.1.1 Narrative

The site is an abandoned electronics scrapping facility, located in a rural township of New Lyme, Ohio. The Site was referred to EPA by the Ohio Environmental Protection Agency (OEPA) based on a strong mineral odor, drums, and capacitors. 

2.1.2 Response Actions to Date
The OSCs conducted a Site Visit and Site Assessment to document the threat of a release at the Site.  During the Site Assessment, the OSCs documented evidence of recent trespassing.  In March 2010, EPA installed a gate and fence to prevent trespassing. 

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
EPA is still in the process of locating and determining viable potentially responsible parties. 

2.1.4 Progress Metrics

Not applicable.

2.2.1 Anticipated Activities

2.2.1.1 Planned Response Activities

The OSCs propose to undertake the following response actions to mitigate threats posed by the presence of hazardous substances at the Site:

1.      Develop and implement a Site-specific Health and Safety Plan, including an Air Monitoring Plan, and a Site Emergency Contingency Plan;

2.      Conduct characterization sampling to determine if wastes can be segregated to minimize the volume of mixed waste transported off-site for disposal at a hazardous waste landfill.  The OSCs and Emergency and Rapid Response Services (ERRS) contractor will dig test trenches across the Site and collect samples from various depths within each test trench;

3.      Conduct a treatability study to determine if leachable metals can be treated prior to off-site disposal;

4.      Inventory and perform hazard characterization on substances contained in cylinders and drums;

5.      Consolidate and package hazardous substances, pollutants and contaminants contained in cylinders and drums for transportation and off-site disposal to a RCRA/CERCLA-approved disposal facility in accordance with U.S. EPA’s Off-Site Rule (40 CFR § 300.440);

6.      Transport and dispose off-site any hazardous substances, pollutants and contaminants at a RCRA/CERCLA-approved disposal facility in accordance with U.S. EPA’s Off-Site Rule (40 CFR § 300.440);

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

2.2.1.2 Next Steps

If the Action Memorandum is approved and written access to the Site is obtained, EPA will mobilize to the Site and begin removal activities as described in Section 2.2.1.1.

2.2.2 Issues
During the week of January 18, 2010, a Site owner verbally granted access to the Site for the Site Assessment.  However, EPA has not been able to obtain a written access agreement, despite repeated attempts.  The enforcement team is planning to pursue a court-issued warrant or order for access for removal actions.