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
The presence of heavy metals, PCBs, asbestos and numerous drums and compressed gas cylinders presents potential threats to human health and the environment by exposures to impacted air, soil and water at and around the Site.
 
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 PCBs (Aroclor 1242 and 1254).

See Initial Polrep for additional information.

2.1.1 Narrative

The Time-Critical Removal Action at the New Lyme Metals Site is addressing the presence of heavy metals and PCBs in the soils by excavating and disposing of the impacted material off site.  All asbestos containing materials, drums and compressed gas cylinders will also be removed and disposed of at an off site facility.  Air monitoring and sampling is being conducted for the protection of the workers and the public.  In addition, well samples have been collected to determine if any of the contaminants on Site have impacted the ground water. 

2.1.2 Response Actions to Date
During the period of July 25 to July 29, 2011, U.S.EPA along with START and ERRS contractors continued removal activities at the Site, these activities included:  

• Began excavation of TSCA/TCLP grid C-9
• Completed treatment of a portion of TSCA/TCLP grid C-9 with Free Flow 100
• Transported 28 loads of Non-Hazardous Soil to American Landfill for disposal
• Dewatered excavation areas and pumped water to an on Site frac-tank for on-site treatment
• Continued decontamination of tires for recycling
• Continued consolidating asbestos panels, capacitors and mercury rectifiers
• Continued dust suppression efforts at load out area and excavation areas
• Continued application of Rusmar AC-645 to suppress PCB vapors
• Continued site survey with Ludlum Model 192 gamma radiation detector
• Continued air sampling for arsenic, cadmium, lead, PCBs and asbestos at site perimeter
• Collected activity specific air samples for analysis of PCBs
• Confimation sample results identified grids H-7, K-7 and L-7 as requiring additional excavation

Due to heavy rains, standing water covered portions of excavated and unexcavated areas of the Site.  The site boundaries had previously been bermed and silt fenced to contain any runoff. Samples collected from the pooled runoff identified PCBs at concentrations above the Ohio MCL regulatory criteria of 0.5 ug/L for public water, ground water, and surface water systems.  Because of the saturated ground, continued dewatering of the low areas by pumping the liquids onto impacted areas was infeasible.  A frac tank was mobilized to contain water pumped from the pooled areas.  A second frac-tank will be brought it to store treated runoff until lab analysis can verify it can be discharged into the creek.

A drain was discovered in the TCLP treatment cell and was excavated and plugged to prevent any runoff from the treatment cell to discharge into excavated areas.

Air sampling results continue to show detectable concentrations of PCBs at the Site perimeter that are well below the OSHA PEL and considered in an acceptable range by ATSDR.

Asbestos (chrysotile and amosite) have been detected in perimeter air samples on three occasions.  The results were forwarded to ATSDR.  The concentration were determined not to be a health concern and sampling will continue.

To date, no metals have been detected in any perimeter or activity specific air samples.  The frequency of metals sampling will be restricted to when excavation activities occur in areas of high metals concentrations as idenditified by work in July 2010.  The Site perimeter will still be monitored for total particulates and the Site action levels adjusted accordingly. 

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
U.S. EPA continues its efforts in determining viable potentially responsible parties as well as identifying and locating additional locations where the operations took place.  Currently, U.S. EPA has identified two possible locations where activities, similar to those at New Lyme Metals, may have taken place.   

2.1.4 Progress Metrics

This Reporting Period:

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 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
• Backfilling, grading and restoration of excavated areas

2.2.1.2 Next Steps

• Continue removal activities
• Continue perimeter air sampling for asbestos, PCBs and heavy metals
• Review results of air and ground water samples
• Complete assessment of creek and property immediately to the west of the Site
• Conduct confirmation sampling 
• Install water filtrations systems on wells
• Work with ATSDR to develop a site specific action level for PCBs 

2.2.2 Issues
Currently assessing options for disposal of RCRA/TSCA mixed waste with PCB concentrations over 1000 ppm.