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Site Number: |
C5ZB |
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Contract Number: |
EP-S5-08-02 |
D.O. Number: |
0144 |
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Action Memo Date: |
8/12/2014 |
Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
Response Lead: |
EPA |
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Incident Category: |
Removal Action |
NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
9/22/2014 |
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Start Date: |
9/22/2014 |
Demob Date: |
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Completion Date: |
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CERCLIS ID: |
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RCRIS ID: |
None |
ERNS No.: |
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State Notification: |
WDNR |
FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Time Critical Removal Action
1.1.2 Site Description
The Site is a 2.8 acre lot with a 61,000 ft2 abandoned industrial building, formerly occupied by Wisconsin Die Casting, LLC, in a mixed residential, commercial, and industrial area. The Site building is currently vacant and has fallen into disrepair, with continuous and persistent trespassing by scavengers and vandals.
1.1.2.1 Location
The Site is located at 201 West Oklahoma Avenue in Milwaukee, Milwaukee County, Wisconsin.
1.1.2.2 Description of Threat
The Site contains abandoned foundry ovens as well as numerous piles of dusts, wastes, pipe wrap, broken floor tile, and containers of waste oil. Some of the waste containers are open, bulging, and/or leaking. Fallen lead and PCB-contaminated paint chips and friable asbestos are uncontrolled in the building. There is evidence that contamination is being tracked out of the building.
On December 12, 2013, RACM sent a letter requesting assistance from EPA. According to RACM, broken doors/windows and continued dilapidation of the Site building create entrance points, exposing friable asbestos and PCB contaminated building materials to the elements, rendering the building an imminent threat to the neighborhood.
MHD sent a letter to EPA on July 17, 2014 requesting immediate action by EPA to remove all contaminated building materials on the floor of the Site building. On July 18, 2014, WDHS sent a letter to EPA concluding that the conditions at the Site pose a human health hazard and requesting EPA Removal Assistance with the contamination at the Site
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
On March 20, 2014, EPA conducted a site reconnaissance to document Site conditions. Numerous drums and containers were observed that were open or in poor condition, knocked over, bulging, or with visible evidence of spills. In addition, several overhead and personnel doors were open with evidence of recent trespassing for scavenging and vandalism.
On April 23, 2014, EPA collected samples of liquids in containers; solid wastes in containers and on the floor; wipe samples; paint chip samples; surface soil samples outside the building; and building material samples. The removal site assessment documented metals and PCBs in solid wastes strewn about the floors throughout the building at concentrations above EPA RMLs for industrial soils.
PCBs were found in several solid waste samples taken from the floors inside the building. One sample of floor solids had a concentration of PCBs at 6,900 mg/kg, exceeding the EPA RML for industrial soil of 100 mg/kg. Another floor solid sample had a PCB concentration at 1,600 mg/kg, exceeding the EPA RML for industrial soil of 44 mg/kg.
Paint chip samples taken from floor debris had detections of lead at concentrations exceeding EPA RMLs. One paint chip sample in a high traffic area for trespassers leading out a side door had a total lead level of 19,000 mg/kg, which exceeds the EPA RML for industrial soils of 800 mg/kg.
Surface soil samples were taken along a pathway leading from the adjacent railroad property through breaches in the fence to broken doors and windows of the Site building. Results from samples taken along this pathway detected PCBs (as high as 23 mg/kg), which documents the migration of PCBs outside of the building.
Friable ACMs were identified in dislodged, broken and/or crushed floor tiles at numerous locations on floors throughout the building. Detections ranging from 2.5% to 24.5% chrysotile (by volume) were detected in samples of materials found on the floors in high traffic areas for trespassers. In addition, pipe insulation is strewn about the building floors, presumably by scavengers removing metal piping. There is clear visual evidence that trespassers are handling and walking over the pipe wrap, which has become friable, on the building floors.
At least thirteen drums of liquids and solids are present inside the building. Several of the drums have missing bungs or are laying on their sides. The liquid contents of these drums appear to be waste oil, mineral oil, and or oil/water mixtures.
On August 8, 2014, EPA observed that several of these drums had been tipped over with their contents spilled onto the floor, presumably by scavengers seeking scrap value in the metal drums.
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