Time critical removal action; PRP lead (AOC Docket No. V-W-13-C-007)

The Milwaukee Die Casting (MDC) Site is located at 4132 N. Holton Street in Milwaukee, Milwaukee County, Wisconsin.  The Site is 3.7 acres.  The 70,000 square foot building that housed the former Milwaukee Die Casting Company is the only structure on the Site.  MDC produced aluminum and zinc alloy parts for a variety of industries, including automotive, small engine, and process control manufacturers.  Phosphate ester oil (PEO), a fire retardant oil which contained polychlorinated biphenyls (PCBs), chlorinated solvents, and cyanide, was used and stored at the Site.  Trichloroethylene (TCE) was also used and stored at the Site.  A tunnel system is located under the die-casting room floor.  The tunnel system provided access and utility lines to the die-casting machines. The tunnels are approximately 3-6 feet wide and up to 10 feet deep. Fluids collected in the tunnel system were discharged to an outdoor sump located near the northeastern wall of the building, which was connected to the sanitary sewer. Die casting operations at the Site ceased in 1997.  The property owner died in June, 2009, abandoning the property.  The City of Milwaukee foreclosed and assumed ownership of the Site, then transferred ownership to the Redevelopment Authority of the City of Milwaukee (RACM) in March, 2013.

After securing an ex parte warrant from the United States District Court, Eastern District of Wisconsin in April, 2011, EPA conducted a Site Assessment that revealed the presence of elevated PCBs in the building, in the building’s tunnel system, in the soils under the building and around the building, including on neighboring properties to the north and east of the Site, and in the groundwater on and off-site.  Chlorinated solvents were also identified in soils on-site as well as in soils off-site and in the groundwater.  Sub-slab air samples were above vapor intrusion action levels.  Friable asbestos was identified in the building.  Part of the roof has failed, allowing for storm water to enter the building.  The Site is secured by a fence and the building is boarded up, however, evidence of trespassing was found inside and outside the building.

On December 13, 2011, the Wisconsin Department of Natural Resources (WDNR) conducted a subsequent investigation of the Site’s perimeter.  During the inspection, WDNR detected an additional area of off-site soil contamination on the neighboring property to the east of the Site.  Evidence of access to the property under the perimeter fence was documented in this same area.  WDNR also identified a make-shift weir (wooden board) at the end of a sewer lateral leading from the eastern side of the building to the City of Milwaukee storm sewer.  A sample of the liquid dammed behind the board was collected by WDNR and analyzed by EPA (at WDNR’s request).  The sample was an oily water which separated in the sample jar.  The PCB concentration of the oil portion of the sample was 410,000 mg/kg.  The storm sewer where the sample was collected ultimately discharges to the Milwaukee River, located less than ¼ mile to the east. 

On February 2, 2012, EPA removed the oily water in the lateral immediately behind the dam and conducted video surveillance of the lateral in an attempt to identify the source of the oil.  However, the source could not be identified.  On May 29, 2012, EPA re-evaluated the manhole, lateral, and weir.  The wooden board was still in place and oily water had reaccumulated behind the board.  A sample of the reaccumulated material had a PCB concentration of 220,000 mg/kg.

On May 3, 2012, the Wisconsin Department of Health Services (WDHS) issued a Health Consultation for the Milwaukee Die Casting Site that concluded that the conditions at the Site pose immediate, medium term, and long-term public health concerns.

EPA and Respondents (Pharmacia LLC and Fisher Controls International LLC) finalized an Administrative Order on Consent (AOC) for a time critical removal action on March 12, 2013.  Per the schedule in the AOC, the first work plan was submitted on April 9, 2013.  Site stabilization activities (around the clock on-site security) began on May 17, 2013.  During May-August, 2013, site preparation and stabilization activities, such as removal of an unstable/leaning trailer, reinforcing the perimeter fence, and vegetation clearing occurred.  A significant amount of additional characterization sampling (soil, groundwater, building, etc) also occurred during this period. 

On September 17, 2013, the property was disconnected from the City of Milwaukee storm sewer system, thereby stopping an ongoing discharge of PCBs from the Site.  Two laterals were abandoned at the property line and respective manholes.  The “mid-central lateral”, which was found to have an uncontrolled source of high concentration PCB liquid waste in it, was cleaned, excavated, and containerized for disposal as TSCA regulated waste.  Two additional camera surveys were conducted to attempt to determine the source of the oily material.  The source was not identified.

On September 18, 2013, the sewer work was completed and interim storm water management measures were put into place.  The downstream half of the property is surrounded by silt fencing and hay bales to filter sheet flow leaving the Site.  Two pumps and water storage capacity of 80,000+ gallons were put into place to collect storm water from rain events.

This removal action is being conducted in accordance with AOC Docket No. V-W-13-C-007.  Respondents are Pharmacia LLC and Fisher Controls International LLC.

Work plans are expected soon for off-site soil excavation and building demolition (schedule dependent upon sampling results).  Respondents are expected to submit a 761.61(c) application for a risk-based PCB clean-up level for on-site soil contamination no later than November 30, 2013.  The Milwaukee Fire Department is planning training exercises to occur at the Site in October, 2013 and immediately prior to building demolition.

2.2.2 Issues
There have been numerous delays impacting the speed and progress of the removal action, such as difficulty obtaining off-site access, slow groundwater recharge, quality issues with the selected contract lab, and unanticipated sample results.

Nothing to report at this time.

Not applicable

Milwaukee Fire Department

Redevelopment Authority of the City of Milwaukee

Wisconsin Department of Health Services

Wisconsin Department of Natural Resources

EPA: 2

START: 2

Respondents & Contractors: 30

City of Milwaukee: 1

WDNR: 1

Polreps will be issued as significant events are completed.