In August 2010, U.S. EPA conducted a site assessment at the facility to quantify and characterize the abandoned waste.  The building was in generally good condition, however significant pooling of water on the floor was observed from numerous leaks in the roof.  The majority of the material was waste oil, some containing PCBs.  Limited quantities of corrosive materials were also identified.  Some of the older drums abandoned at the facility were under pressure.  Oil had been spilled on the floor in many areas of the building, resulting in very slippery conditions.  Numerous open pits filled with liquid waste were observed throughout the facility.  There is no power to the building and sources of natural light are very limited.  Other than the perimeter fence, the building is unsecured.  Conditions in the facility presented a significant safety hazard for anyone in the building.  Evidence of recent trespassing included graffiti and empty soda and beer cans. 

In September, 2010, U.S. EPA initiated negotiations with the PRPs to clean-up the abandoned waste at the facility.  Due to concerns related to winter weather conditions, Tecumseh Products and TecumsehPower (owners/operators of the facility prior to Heus Manufacturing) ceased AOC negotiations in November, 2010 and commenced a voluntary clean-up at the Site.  Chief Industrial Services was retained to conduct the clean-up.  The clean-up was conducted consistent with the National Contingency Plan, with U.S. EPA overseeing the removal.  See Initial POLREP for additional information.

A small amount of the work agreed upon could not be completed due to the onset of freezing temperatures in December.  On April 8, 2011, OSC Halbur and the WDNR Project Manager returned to the Site to check on Site conditions prior to Tecumseh and Chief returning to the Site.  Heavy snow caused a portion of the deteriorating roof to collapse during the winter.  Storm water was found in the facility as a result of the opening in the roof.  One previously cleaned pit had refilled with water.

Tecumseh and Chief returned to the Site on April 26, 2011 to complete the remaining removal work.  The chromium pit was emptied and cleaned; 3,750 gallons of D007 liquid waste was shipped to Envirite of Illinois.  Chief also removed 9,450 gallons of non-hazardous liquid waste from the wastewater treatment tanks.  Chief attempted to clean the wastewater tanks, but the residual oil did not release well from the still cold concrete.  It was determined that the wastewater tanks could not be effectively steam cleaned until the facility was warmer.  

Tecumseh and Chief returned to the Site again on June 7, 2011 to clean the wastewater tanks.  The tanks were successfully steam cleaned during this visit.  Approximately, 2,150 gallons of non-hazardous wastewater was generated during the cleaning process.  The wastewater was sent to Chief's facility in Winneconne, WI.  The handrails along the raised walkway in front of the wastewater tanks were also cleaned by Tecumseh at the request of OSC Halbur.  Site work was completed on June 8, 2011.

U.S. EPA received Tecumseh's Final Report on the Voluntary Cleanup on July 15, 2011.  The Final Report is complete and deemed acceptable to close this action.

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

The facility is owned by Edward Jones.  Mr. Jones has been non-responsive to U.S. EPA's General Notice Letter and Demand Letter. Tecumseh Products and TecumsehPower (owners/operators of the facility prior to Mr. Jones' operation of Heus Manufacturing at the Site) are conducting a voluntary clean-up.

2.1.3 Progress Metrics

Heavy snow caused a portion of the deteriorating roof to collapse during the winter of 2010.  Storm water is re-entering the facility thru the opening in the roof.