U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Harris-Thomas Industries Site - Removal Polrep
Final Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
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Subject:
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POLREP #5
FINAL POLREP
Harris-Thomas Industries Site
C5D3
Dayton, OH
Latitude: 39.7648035 Longitude: -84.1699015
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To:
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Matt Wagner, Keramida
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From:
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Steven Renninger, On-Scene Coordinator
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Date:
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2/11/2013
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Reporting Period:
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December 22, 2012 through February 11, 2013
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1. Introduction
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1.1 Background
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Site Number: |
C5D3 |
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Contract Number: |
EP-S5-08-02 |
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D.O. Number: |
30281-105 |
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Action Memo Date: |
4/23/2012 |
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Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
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Response Lead: |
EPA |
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Incident Category: |
Removal Action |
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NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
10/23/2012 |
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Start Date: |
10/23/2012 |
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Demob Date: |
2/14/2013 |
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Completion Date: |
2/11/2013 |
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CERCLIS ID: |
OHN000510707 |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
Ohio EPA notified |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
February 2012 -- At the request of the Dayton Fire Department and the Ohio EPA, U.S. EPA conducted an emergency response action at the abandoned Harris-Thomas Industries Site to stabilize a transformer spill.
October through December 2012 -- U.S. EPA mobilized to begin a time-critical removal action to address abandoned hazardous waste (transformers, drums and containers, metals waste piles). See POLREP #s 1 through 4 for further details for this period.
1.1.2 Site Description
The Site was vacated in 2006 by Harris-Thomas Industries (HTI), which utilized the Site to manufacture steel parts for the automotive and other industries. The property was transferred to HTI by Harris Thomas Drop Forge Company (HTDFC) in 1998. Prior to that time, HTDFC held ownership to the parcels since at least 1960. The Site is occupied by seven separate, mostly one-story buildings (one composed of approximately eight additions) of various construction. The buildings encompass approximately 30,000 square feet of area, and are located on one parcel totaling approximately 2.5 acres. Historic records indicate that the Site has been occupied by varies operators, including an oil distributor (1898), metal foundries (early 1900s), boiler makers (early 1900s), painting contractors (1960s), a metal treating company (1970s) and metal forging companies (1920s to 2006).
On February 2, 2012, the Dayton Fire Department (DFD) and the Ohio Environmental Protection Agency (Ohio EPA) investigated a report of transformer oil leaking from the facility roof onto a City of Dayton right-of-way sidewalk along Harshman Street. Due to site trespassing and vandalism (from “scrappers”), transformer oil was released and spilled on the roof, building, and adjacent sidewalk. Ohio EPA and DFD conducted a site inspection within the facility and not only observed the oil which had been released from the vandalized transformers on the roof to the sidewalk, but also observed numerous abandoned 55-gallon drums, containers and pits containing unknown liquids. Ohio EPA requested emergency stabilization assistance from U.S. EPA. On February 2, 2012, OSC Steve Renninger initiated an emergency stabilization action.
On February 3, 2012, DFD, U.S. EPA OSC Steve Renninger, U.S. EPA’s Superfund Technical Assessment and Response Team (START) and U.S. EPA’s Emergency Rapid Response Services (ERRS) contractors mobilized to the site and conducted emergency stabilization activities to limit the impact of the transformer oil which had been released to the ground from the transformers on the roof. U.S. EPA observed 4 transformers in an unsecured, fenced-in cage on the northwestern corner of the Die Shop Building roof. The ERRS contractor bulked oil-contaminated roofing debris into drums and used absorbent pads and a shop-vac to collect the pools of oil on the roof. ERRS secured the transformer cage with a chain and lock and placed absorbent boom around the transformer cage, placed absorbent boom into the roof gutters and also on the ground where the transformer oil was flowing off the property.
In a letter dated February 3, 2012, Ohio EPA formally requested assistance from U.S. EPA to determine if the Site meets the criteria for a removal action.
On February 6, 2012, DFD requested assistance from U.S. EPA to evaluate the Site for an emergency removal action to remove the hazardous waste on Site.
On February 10 and March 7, 2012, U.S. EPA mobilized to the Site and conducted two site inspections of the facility and observed approximately 25 55-gallon drums and 25 containers (having a volume of 5-gallons or less) containing unknown liquids; 10 pits containing unknown liquids; four roof and three large outside (7 total) transformers (potentially containing polychlorinated biphenyls [PCBs]); compressed gas cylinders; and floor sweepings (similar to foundry sand) on the floors and walls throughout the property. During the inspections, the U.S. EPA documented bulging 55-gallon drums and containers containing flammable, corrosive and toxic hazardous waste. In addition, U.S. EPA documented floor sweepings and wall solids containing elevated heavy metal (chromium and lead) concentrations. Uncontrolled heavy metals-contaminated waste piles were located adjacent to storm-water drains and accumulated near perimeter fencing due to migration during rain events.
All electric utilities have been shut off to the Site. A fence extends around the property to prevent access, but there are numerous breaches in the fence. There have been at least two reported incidents of breaking and entering and vandalism (from “scrappers”) on the property since February 2012.
On March 19, 2012, DFD, Ohio EPA and the City of Dayton’s Division of Environmental Management responded to another transformer oil release at the Site. Trespassers accessed the property and climbed onto the roof (for the second time) of the Die Shop Building. The transformer cage which had been secured by U.S. EPA on February 3, 2012, was cut and removed and one of the four remaining transformers was tipped over and stolen by “scrappers” to access the copper wiring inside the unit. The oil inside the transformer spilled onto the roof and subsequently off the roof, onto the ground and off-site onto the City of Dayton sidewalk right-of-way. A copy of the police report is included as part of the Administrative Record. Ohio EPA requested emergency assistance from U.S. EPA to stabilize the release.
On March 20, 2012, DFD, U.S. EPA, START and ERRS remobilized to the Site and observed that the fencing surrounding the transformers had been breached and that one of the transformers had been stolen and the oil within the transformer had been released onto the roof. ERRS spread absorbent onto the areas where oil was pooled or stained on the roof and the ground. In addition, ERRS replaced the absorbent boom which had been impacted by the release and added additional layers of the absorbent boom at the point where the release had exited the Site.
On October 23, 2012, U.S. EPA initiated a time-critical removal action at the Site.
1.1.2.1 Location
The HTI Site is located at 1400 East 1st Street (an alternate address is 126 Harshman Street) and is situated in a mixed commercial, industrial and residential area of Dayton, Montgomery County, Ohio 45403. The geographical coordinates for the Site are 39° 45’ 53.2938” North latitude and 84° 10’ 11.643” West longitude. The Site is bordered to the north by East 1st Street, beyond which is a vacant lot, to the east by Schumacher Crane Rental and BBC Converters, to the south by East 2nd Street, beyond which are Service Master Clean/Angler Construction and Patented Printing, and to the west by Harshman Street, beyond which is First Street Recycling. Commercial and industrial businesses are located within 500 feet of the Site, and the closest residences are located within 1,000 feet south of the Site.
1.1.2.2 Description of Threat
On February 2, 2012, the Dayton Fire Department and the Ohio EPA investigated a transformer spill at the abandoned Harris-Thomas Industries Site. Site trespassers had vandalized numerous electrical transformers on the building roof. Transformer oil had spilled on to the adjacent roof, building gutters, driveway, and adjacent sidewalk. Evidence of further transformer damage was documented with numerous utility poles cut and transformers removed. Numerous unknown drums and waste piles were noted in the abandoned site.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
On February 10 and March 7, 2012, OSC Renninger and U.S. EPA’s START contractor performed a Site Assessment. Activities performed during the Site Assessment included:
- Documenting Site conditions;
- Using an INNOV-X X-Ray Fluorescence (XRF) metals analyzer;
- Collecting samples from containers, pits, floor sweepings and wall solids; and
- Submitting the samples for commercial laboratory analysis.
During the Site Assessment, approximately 25 55-gallon drums and 25 containers (having a volume of 5-gallons or less) containing unknown liquids, 10 pits containing unknown liquids, compressed gas cylinders and four transformers were documented abandoned on Site. Many of 55-gallon drums and containers contained labels such as “Muriatic Acid”, “Lacquer Thinner” and “Hydraulic Oil.” Numerous drums and containers were in poor condition and bulging. Commercial properties are located within 500 feet of the western and eastern perimeter of the Site. Residential properties are located within 1,000 feet south of the Site.
Field screening and pH testing of 55-gallon drums and containers indicated that many of the materials met the RCRA criteria for characteristic hazardous waste including ignitability and corrosivity. INNOV-X XRF heavy metal field screening of the floor sweepings and unknown solids piled on the walls of the buildings documented widespread heavy metals-contamination with total chromium concentrations as high as 21,617 parts per million (ppm) and total lead concentrations as high as 57,629 ppm.
A total of 34 XRF samples were collected and analyzed with the XRF unit throughout the property. The total lead results from the outside soil, floor sweepings and wall solids were compared to U.S. EPA’s Regional Screening Levels (RSL) for the protection of groundwater. A total of 24 XRF samples from outside soil, floor sweepings or wall solids showed total lead concentrations ranging from 818 to 57,629 ppm, which exceeds the U.S. EPA lead RSL of 800 ppm (industrial properties). The XRF lead results for the floor sweepings and the wall solids were compared to the RSL due to numerous open bay doors leading to the environment and leaking roofs in each of the buildings. XRF results from waste piles located within 5-feet of a storm-water drain showed total lead concentrations as high as 1,035 ppm. The potential exists for rain to enter the various facility buildings and cause lead migration into the outside soil, storm-water sewer drains and the environment, which could then lead to groundwater contamination.
U.S. EPA collected the following samples during its Site Assessment: seven liquid samples from containers and pits; and 14 solids samples from the floor, wall and unknown solids outside of the building. The samples were submitted for commercial laboratory analysis. Analytical results from the Site Assessment documented that ignitable, corrosive and toxic (TCLP MEK) hazardous substances are present on Site. In addition, the Site Assessment documented elevated concentrations of total chromium and total lead are located in the floor sweepings and wall solids throughout the facility.
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
On February 2, 2012, U.S. EPA issued an emergency response delivery order to U.S. EPA contractor Environmental Quality Management (EQM) to stabilize the transformer spill at the site.
In a letter dated February 3, 2012, Ohio EPA formally requested assistance from U.S. EPA to determine if the Site meets the criteria for a removal action.
In a letter dated February 6, 2012, DFD EPA formally requested assistance from U.S. EPA to determine if the Site meets the criteria for a removal action.
In an email dated March 24, 2012, the City of Dayton House Inspection Department’s Nuisance Abatement program, formally requested assistance from U.S. EPA to evaluate the property for additional security measures to limit unauthorized access.
In a letter dated March 26, 2012, City of Dayton Division of Environmental Management formally requested assistance from U.S. EPA to determine if the Site meets the criteria for a time-critical removal action.
On April 23, 2012, the Director of U.S. EPA's Superfund Division approved an Action Memorandum approving funding for a time-critical removal action at the HTI Site.
On October 22, 2012, EPA and DOJ submitted an application for ex parte issuance of administrative warrant to gain access to the HTI Site. The application was submitted to U.S. Magistrate Judge Michael R. Merz (Case No. 3:12mc021).
On October 22, 2012, U.S. Magistrate Judge Merz signed the Warrant granting U.S. EPA access to the HTI Site for a time period of 120 days to conduct a time-critical removal action.
On October 23, 2012, U.S. EPA removal contractors (ERRS and START) mobilized personnel and equipment to the Site to initiate a time critical removal action. A site support zone was established.
For a detailed description of activities between February 2012 - December 21, 2012, see POLREP #s 1 through 4.
2.1.2 Response Actions to Date
Week of December 24, 2012
No work was conducted at the Site, as the Site was shut down for the Holiday break. 24-hour site security was on site.
Week of December 31, 2012
On January 2, 2013, Site operations resumed following the holiday break.
ERRS continued pressure washing the walls and floor of Building B with water and a detergent mixture. Decon water was collected by a vacuum truck and off-loaded into a frac storage tank. A manlift is being used to access the upper portions of Building B. The building is being decontaminated from elevated concentrations of lead and chromium-contaminated foundry sand/dust. ERRS cleaning the floors and pits in Building A.
On January 4, one rolloff box containing 3 tons of contaminated debris was transported
for off-site disposal to Stoney Hollow Landfill, Dayton, Ohio.
Week of January 7, 2013
ERRS completed all debris cleanup in Building A. ERRS cleaning out pits in Building A. ERRS continued pressure washing the walls and floor of Building B. All decon water being collected by a vacuum truck and off-loaded into a
frac storage tank. A manlift is being used to access the upper portions
of Building B. The building is being decontaminated from elevated
concentrations of lead and chromium-contaminated foundry sand/dust.
On January 10, one rolloff box containing metals-contaminated floor
sweepings (foundry sand) was transported for off-site disposal to Stoney
Hollow Landfill, Dayton, Ohio.
On January 11, 6 lab packs were packaged and shipped for off-site disposal to EQ, in Detroit, MI. The lab packs contain hazardous waste solids (D009), oxygen cylinder (D001), caustic liquid (D002), acid liquid (D002) and paint cans (D001).
On January 11, approximately 5,000 gallons of decontamination water was transported for off-site disposal to Clean Ohio Dayton, in Dayton, OH.
Week of January 14, 2013
No site work was conducted during this week. Site security continued.
Week of January 21, 2013
ERRS completed pressure washing the walls and flooring in Buildings A and B. The pits located in Buildings A and B were decontaminated. ERRS completed debris cleanup in Buildings G and J. ERRS completed decontamination of the floor in Building G.
Week of January 28, 2013
No site work conducted from January 28 through January 31, 2013. Site security continued.
On February 1, ERRS filled in the two large pits in Building B with gravel and concrete to prevent a physical hazard.
Week of February 4, 2013
ERRS completed filling in the pits in Building A with gravel and concrete to prevent a physical hazard. ERRS using sweeper attachment on Bobcat unit to conduct a final floor sweep in the buildings and on the driveway.
On February 5, one rolloff box containing 4.46 tons of decontaminated scrap metal was transported for
off-site disposal (recycling) to Franklin Iron & Metal, Dayton,
Ohio.
On February 7, approximately 3,300 gallons of decontamination water was transported for off-site disposal to Clean Water Dayton, in Dayton, OH.
On February 8, one rolloff box containing metals-contaminated floor
sweepings (foundry sand) was transported for off-site disposal to Stoney
Hollow Landfill, Dayton, Ohio.
On February 8, one rolloff box containing contaminated debris was transported
for off-site disposal to Stoney Hollow Landfill, Dayton, Ohio. ERRS completed decontamination of site surface water drains utilizing a jet vac truck. Water and debris was containerized for off-site disposal.
On February 8, all ERRS personnel demobilized from site.
Week of February 11, 2013
On February 11, EPA completed a final site inspection with representatives from Ohio EPA, the City of Dayton Fire Department, the City of Dayton Office of Economic Development, Keramida, and Franklin Iron and Metal Corporation (prospective buyer of the property) to highlight and explain what was completed during the time-critical removal action.
The three office trailers will be demobilized by February 14, 2013
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
U.S. EPA has completed a title search and PRP search. U.S. EPA has sent out 104(e) letters to past owners and operators at the Site.
2.1.4 Progress Metrics
| R5 Priorities Summary |
| This is an Integrated River Assessment. The numbers should overlap. |
Miles of river systems cleaned and/or restored |
0
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| Cubic yards of contaminated sediments removed and/or capped |
0
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| Gallons of oil/water recovered |
0
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| Acres of soil/sediment cleaned up in floodplains and riverbanks |
0
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| Stand Alone Assessment |
Acres Protected |
3
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| Number of contaminated residential yards cleaned up |
0
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| Human Health Exposures Avoided |
100 |
| Number of workers on site |
8
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Contaminant(s) of Concern
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Heavy metals-contaminated foundry sand, contaminated debris and lab packs containing flammables, acids, and caustics. Transformers.
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| Waste Stream |
Medium |
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Manifest # |
Treatment |
Disposal |
| Transformers |
Solid
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3 large
3 small
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None
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Recycle
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Dayton Power & Light
Dayton, Ohio
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| Contaminated debris |
Solid
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140 yards
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None |
Landfill |
Stoney Hollow Landfill
Dayton, Ohio
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| Metals-contaminated (chrome) floor sweepings/foundry sand |
Solid
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100 yards
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None
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Landfill |
Stoney Hollow Landfill
Dayton, Ohio
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Decontamination Water
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Liquid
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12,800 gallons
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None
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Treatment
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Clean Water Ltd.
Dayton, Ohio
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Lab Packs
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Solids and Liquids
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6 lab packs
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010248076 JJK
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Treatment
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EQ Detroit
Detroit, Michigan
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Decontaminated Scrap metal
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Solid
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46.17 tons
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None |
Recycle
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Franklin Iron & Metal
Dayton, Ohio
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2.2 Planning Section
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2.2.1 Anticipated Activities
No additional removal activities are anticipated. The following removal activities were completed during the removal action:
1. Developed and implemented a Site-specific Health and Safety Plan, including an Air Monitoring Plan, and a Site Emergency Contingency Plan;
2. Developed and implemented a Site Security Plan;
3. Secured Site with fence repair, boarding and/or locking windows and doors.
4. Inventoried, sampled, and performed hazard characterization on all substances contained in drums, containers, pits, transformers and waste piles;
5. Consolidated and packaged all hazardous substances, pollutants and contaminants for transportation and off-site disposal;
6. Consolidated and packaged heavy metal-contaminated floor sweepings and wall solids for transportation and off-site disposal;
7. Transported and disposed of all characterized or identified hazardous substances, pollutants, wastes, or contaminants at a RCRA/CERCLA-approved disposal facility in accordance with U.S. EPA’s Off-Site Rule (40 C.F.R. § 300.440).
8. Completed decontamination of building floors and walls.
2.2.1.1 Planned Response Activities
None.
2.2.1.2 Next Steps
None.
The removal action was completed on February 11, 2013.
2.2.2 Issues
None.
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2.3 Logistics Section
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Site Security was conducted during non-working hours. Site security will be terminated on February 13, 2013.
Site gate was locked during non-working hours.
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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2.5.1 Safety Officer
Site HASP has been completed and signed by site personnel.
2.5.2 Liaison Officer
Not applicable.
2.5.3 Information Officer
Not applicable.
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3. Participating Entities
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3.1 Unified Command
Not applicable.
3.2 Cooperating Agencies
Dayton Fire Department
Ohio EPA
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4. Personnel On Site
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U.S. EPA
ERRS Contractor - Environmental Quality Management (EQM) & Inland Waters of Ohio
START Contractor - WESTON Solutions
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5. Definition of Terms
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Not applicable.
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6. Additional sources of information
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6.1 Internet location of additional information/report
Additional information can be obtained at the following Site website:
http://www.epaosc.org/site/site_profile.aspx?site_id=7586
6.2 Reporting Schedule
None. This is the FINAL POLREP.
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7. Situational Reference Materials
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Not applicable.
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