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.

In July 2010, U.S. EPA conducted further site characterization in order to define areas of contamination, determine the number and volume of waste streams and conduct treatability tests on the wastes at the Site.  Sampling results identified 18 grids that contained PCBs above 50 part per million and/or above the TCLP Cadmium and Lead regulatory limits of 1 mg/L and 5 mg/L, respectively.  Results also identified that at least 50% of the site exhibited concentrations of multiple heavy metals above the residential direct contact criteria in Ohio.  These metals included antimony, arsenic, cadmium, lead, mercury and zinc.  Additionally, contaminated areas were also identified on the neighboring property directly west of the Site as well as in the creek that is the southern border of the Site.

Baseline air sampling for heavy metals, asbestos and PCBs was conducted in November 2010.  Analysis did not detect any heavy metals or asbestos in the air samples and only low levels of PCBs.  The results were reviewed by ATSDR and found to not pose any health risks.

An Action Memorandum documenting these results and requesting funding to conduct the Time-Critical Removal was approved and signed on September 21, 2011.  However, again 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 May 6, 2010, United States District Court Magistrate Judge William H. Baughman Jr. signed a second Administrative Warrant (Civil Docket Case No. 1:11 MJ 9092) granting U.S. EPA access for 210 days to the response actions necessary to mitigate any threats to human health and the environment posed by conditions at the Site.

2.1.2 Response Actions to Date
During the period of June 6-17, 2011, U.S.EPA along with START and ERRS contractors mobilized to the Site and began Site setup in preparation for removal action.  Activities included:

• Setup of trailers and connection or utilities (phone, electric)
• Establishment and demarcation of Exclusion Zone and Contamination Reduction
• Setup of Decontamination Line
• Conduct limited excavation of grid I-1 to allow construction of haul road
• Construction of road to be used for trucks transporting wastes off-site
• Install fence to secure property
• Receive and stage equipment
• Conduct perimeter air monitoring for particulates
• Establishing Site security

A reporter for Gazette Newspapers, Inc. visited the Site for an interview and to take photographs.  Heavy rains and severe weather restricted work on several days.  During the period of June 20-24, 2011, removal activities began.  Site activities during this time period included:

• Disconnected electrical lines from house
• Dust suppression using water truck
• Begin consolidation of non-hazardous debris for transportation and disposal
• Demolished house and pole barn
• Construct staging area for drums and compressed gas cylinders
• Consolidated drums and compressed gas cylinders in staging area
• Excavated grids B-2 & B-3 for staging area of asbestos panels and PCB capacitors
• Began consolidating asbestos panels, capacitors and mercury rectifiers
• Demarcated TSCA regulated waste areas
• Segregated tires and recyclable materials in non-hazardous debris
• Conducted site survey with Lumex Mercury Vapor Analyzer and Ludlum Model 192 for gamma radiation
• START conducted a Health and Safety Inspection of Site setup and operations
• Continued perimeter air monitoring for particulates

Heavy rains and severe weather restricted work several days during this time period.  Ashtabula County and New Lyme Township was contacted and notified of the beginning of the removal activities.

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

Removal action will include the following:

• Removal of non-hazardous debris (recycled when possible) in order to access contaminated area
• Excavation and disposal of TSCA wastes
• Excavation, treatment and disposal of RCRA (TCLP cadmium and lead) wastes
• Excavation of soils exhibiting concentrations of heavy metals, asbestos and PCBs above OEPA's residential direct contact criterion
• Consolidation and disposal of asbestos panels, PCB containing capacitors and mercury rectifiers
• Consolidation, characterization and disposal of drums and compressed gas cylinders

2.2.1.2 Next Steps

• Begin perimeter air sampling for asbestos, PCBs and heavy metals with the commencement of removal activities
• Collect ground water samples from three wells in close proximity to the Site
• Complete assessment of creek and property immediately to the west of the Site
• Conduct confirmation sampling 

2.2.2 Issues
None at this time.