1.1.1 Incident Category
CERCLA Incident Category:  Inactive Recycling Facility

1.1.2 Site Description

1.1.2.1 Location

See Initial Polrep.

1.1.2.2 Description of Threat
A Site Assessment conducted on February 18, 2010 documented the uncontained presence of hazardous wastes and substances in surface soils and sediments as well as the presence of numerous drums, containers and cylinders of unknown contents spread across the Site.  The Site is located in a residential/agricultural area where private wells are the primary source of water.

See Initial Polrep for additional information.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
Primary contaminants of concern identified during the Site Assessment included: heavy metals (antimony, arsenic, cadmium, lead, mercury), asbestos (chrysotile) and polychlorinated biphenyls (Aroclor 1242 and 1254).

See Initial Polrep for additional information.

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 U.S.EPA by the Ohio Environmental Protection Agency (OEPA) based on complaints of strong mineral odors and the presence of drums and capacitors spread across the Site.

An Action Memorandum documenting the threats and requesting funding to further characterize the site and begin a Time-Critical Removal was approved and signed on May 20, 2010.  However, U.S.EPA was unable to obtain verbal or written permission to access the Site.  The matter was referred to the Department of Justice U.S. District Attorney's Office for assistance in obtaining an Administrative Warrant for access to the Site.  On June 29, 2010, United States District Court Magistrate Judge James Gallas signed an Administrative Warrant (Civil Docket No. 1:10 MJ 5074) granting U.S. EPA access for 30 days to take initial response actions at the Site.

2.1.2 Response Actions to Date
During the period of July 12-16, 2010, U.S.EPA along with START and ERRS contractors mobilized to the Site to collect samples to delineate and characterize the type and volume of wastes present on the Site.  The Site was divided into 20' by 20' grids and samples were collected from the center of each grid at three foot intervals until native soils were encountered.  A total of 141 samples of surface and subsurface soil/fill/waste were collected and analyzed for PCBs and TCLP Metals.  Additional volume was collected for use in treatability studies if needed.  In addition, all the 0-3 foot samples were screened for total metals using a Innov-X XRF .  Many of the samples exceeded Ohio's Generic Direct Contact Standards for several total metals, including: arsenic, cadmium, lead and mercury. 

Three sediment samples were collected from the intermittent stream that borders the Site downstream of the fill area.  Results from the Site Assessment indicated the possibility of off-site migration and additional samples were collected to determine if off-site migration of any contaminants has occurred. 

Following discussions with a neighboring resident, a visual inspection was conducted of the property located directly west of the Site.  More piles of debris, waste, drums and cylinders were observed adjacent to similar areas across the fenceline of the Site.  Review of aerial photographs and discussions with the resident revealed that operations at the Site often extended onto the adjacent property.  XRF screening was conducted in these waste areas and similar elevated concentrations of lead and cadmium were identified.  Three surface soils samples were collected from these waste areas outside the Site boundary.

Four wipe samples for PCBs were also collected.  Two were collected from concrete areas inside the Pole Barn and two confirmation wipe samples were collected from the excavator following decontamination.

During the period of July 19-23, 2010, all decontaminated equipment was demobilized and the on Site well was located, inspected and evaluated for potential use during the removal action 

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
EPA continues its efforts in determining viable potentially responsible parties. 

2.1.4 Progress Metrics

Not applicable.

2.2.1 Anticipated Activities

2.2.1.1 Planned Response Activities

After all analytical results are evaluated, a Action Memorandum Amendment will be prepared to request funding for the removal and disposal of all the wastes present on and off Site.  Specific actions will be detailed in the Action Memorandum.
 

2.2.1.2 Next Steps

Review analytical results and prepare cost estimate for continued removal action.  Coordinate continued response actions with State and Local representatives. 

2.2.2 Issues
U.S.EPA continues to be unable to obtain permission to access the Site and will continue to coordinate with the Department of Justice U.S. Attorney's Office to prepare and obtain an Administrative Warrant for access to complete the removal action.

Due to the size of the site and the extant of contamination on the Site, U.S.EPA is working with the New Lyme Township Trustee's to locate nearby areas to stage trailers for the duration of the removal action.