o v w y | REGION 5 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

% % ^ ^ ? 7 7 W E S T JACKSON BOULEVARD us EPA RECORDS C E N T E R REGION 5

% P R O ^ ° CHICAGO, IL 60604-3590

494772

M E M O R A N D U M REPLY TO THE ATTENTION OF:

SUBJECT: Request for Approval and Funding for a Time-Critical Removal Action at the Spencer Drum Site, 408 E. Willow Drive, Spencer, Marathon County, Wisconsin (Site ID #C58F)

F R O M : Kathy Halbur, On-Scene Coordinator Emergency Response Branch I, Removal Section 1

T H R U : Jason H . El-Zein, Chief Emergency Response Branch I

TO: Richard C. Karl, Director Superfund Division

I. PURPOSE

The purpose of this memorandum is to request and document your approval to expend up to $168,259 to conduct a time-critical removal action at the Spencer Drum Site (or the Site), located in Spencer, Marathon County, Wisconsin 54479. The response actions proposed herein are necessary to mitigate threats to public health, welfare, and the environment posed by the presence of uncontrolled hazardous substances at the Site. The Site contains approximately 90 drums, with unknown contents, many in extremely poor condition, leaking and bulging.

This Action Memorandum seeks approval for EPA, as lead technical agency, to take actions described herein to abate the imminent and substantial endangerment posed by the hazardous substances at the Site. EPA proposes to remove hazardous substances pursuant to Section 104(a)(1) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 U.S.C. § 9604(a)(1), and 40 C.F.R. § 300.415 ofthe National Oil and Hazardous Substances Pollution Contingency Plan (NCP).

The uncontrolled conditions of the hazardous substances present at the Site, and the potential threats they present require that EPA classify this removal action as time-critical. EPA's response actions described in this Action Memorandum wil l require an estimated 10 on-site working days to complete.

There are no nationally significant or precedent setting issues associated with the Site. The Site is not on the National Priorities List (NPL).

Recyc led /Recyc lab le » Printed with Vegetable Oil Based Inks on 100% Recycled Paper (100% Post-Consumer)

II. SITE CONDITIONS AND BACKGROUND

CERCLIS ID: WIN000506072 R C R A ID: None WDNR ID: WI SERTS#20150623WC37-1 Category: Time-Critical

A. Site Description

The Spencer Drum Site is an approximately 17,000 square foot (ft2) warehouse located in a mixed residential and commercial area in Spencer, Marathon County, WI. An aerial photo and site location map can be found in Attachment 1. The building contains two rooms, a larger room to the north and a much smaller room to the south. The larger room was operated as a mechanic shop from 2012 until December 2014 when the owner suddenly passed away. Prior to 2012, the entire warehouse housed a liquidation company and retail shop, Don Smith Sales.

The smaller of the two rooms in the warehouse contains approximately 90 drums that are in extremely poor condition (Attachment 3, photos 2-7). Many of the drums are leaking (Attachment 3, photo 3) and some are bulging (Attachment 3, photo 6). The drums were reportedly acquired in the 1970s by the liquidation company. Almost all of the drums are unlabeled and there are no records available regarding the contents of the drums.

The liquidation company that acquired the drums is now defunct. A Wisconsin Department of Natural Resources (WDNR) Conservation Warden interviewed personnel associated with the liquidation business, but was unable to acquire any credible generator knowledge regarding the origin of the drums or their contents. The property was in foreclosure when it was purchased in July 2012. The purchaser of the property has recently passed bequeathing the warehouse and its contents to the widow. The widow does not have any knowledge of the origin or contents of the drums.

W D N R received an anonymous notification of the drums on June 23, 2015 (WDNR spill report can be found in the Administrative Record (AR), Document #1). Shortly thereafter, W D N R requested assistance from the EPA Emergency Response Branch, Superfund Division (AR, Document #2).

1. Removal site evaluation

On July 21, 2015, EPA OSC Kathy Halbur conducted a reconnaissance visit with W D N R Regional Spills Coordinator Tom Kendzierski. The widow was present to provide access to the warehouse. Based on the deteriorating condition of the drums and their unknown contents, the need to expeditiously characterize the drums was discussed at length with the widow. The process for identifying unknown contents and arranging for proper disposal was also explained to the widow. She indicated that she would continue to acquire quotes from environmental contractors. Concurrently, WDNR interviewed representatives from Don Smith Sales' liquidation company (previous owner/operator) in an attempt to obtain generator knowledge of the drums.

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On August 27, 2015, the Marathon County Hazardous Materials Team, Spencer Fire, Wausau Fire, Marathon County Emergency Management, Wisconsin Emergency Management (WEM), WDNR, and EPA conducted an exercise at the Site (Attachment 3, photos 9-10). Approximately one third of the drums stored at the Site were screened with a Multi-Rae Pro for volatile organic compounds (VOCs), gamma radiation, lower explosive limit, oxygen level, carbon monoxide, and hydrogen sulfide levels. The temperature of the selected drums was also screened with a Fluke Infrared Thermometer and the condition of the selected drums was assessed. Elevated V O C concentrations were detected from every drum screened; levels ranged from 224 to 99,000 parts per billion (ppb). V O C concentrations exceeding 5,000 ppb are considered to be a respiratory hazard, based on the Occupational Safety and Health Administration (OSHA) short term exposure limit (STEL) for benzene. Benzene was selected because it represents a common constituent of petroleum products (which were observed in some of the drums) and has a conservative STEL. VOC concentrations were higher near the floor than in the breathing zone. Temperatures were relatively consistent, ranging from 62-67°F.

Twelve drums were sampled for additional screening and limited hazcatting (Attachment 3, photo 10). Almost all of the samples collected were multi-phase (Attachment 3, photo 8); the materials are so old that they are solidifying. The extent of additional evaluation varied based on the constraints of the exercise (i.e., time, darkness, experience levels of the team members). Types of additional screening conducted included general appearance, pH, flammability (pass/fail), water solubility, density, "Spilfyter" strips, Hazmat ID, and Ahura First Defender. Corrosivity (pH=2) and flammability of some ofthe materials being stored in the warehouse was confirmed using the Spilfyter strips. Of the drums screened, only two appear to be suitable for shipment without additional repackaging. Many of the drums' contents have leaked onto the floor (Attachment 3, photo 3). Contents from the leaking drums has comingled on the floor of the warehouse. Kitty litter had been previously spread to contain spilled material. The drums are stored very close together (Attachment 3, photos 2-3). Bulging drums were observed (Attachment 3, photo 6), but not assessed during the exercise due to safety concerns.

At the conclusion of the exercise, the agencies gave the owner until September 4, 2015, to hire an environmental contractor or consent to access for an EPA Removal Action. The widow contacted EPA on September 5 providing verbal consent and submitted a signed access agreement on September 8, 2015 (AR, Document #4).

2. Physical location

The Site is located at 408 E. Willow Drive, Spencer, Marathon County, WI 54479 (Parcels 181-2602-082-9915 and 181-2602-082-9906) in a mixed residential and commercial area. The geographic coordinates for the Site are Latitude: 44.752219, Longitude: -90.296194. Commercial properties neighbor the Site to the north and the east. The Spencer Area Fire Department station borders the Site to the South. A residential neighborhood borders the Site to the west. The closest residence is located approximately 200 feet to the east of the property. A municipal water tower is approximately 100 feet to the northeast of the warehouse. A n aerial photo and Site location map can be found in Attachment 1.

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An Environmental Justice (EJ) analysis for the Site is contained in Attachment 4. Screening of the surrounding area used Region 5's EJ Screen Tool. Region 5 has reviewed environmental and demographic data for the area surrounding the Site at 408 E. Willow, Spencer, WI, and determined there is a potential for EJ concerns at the Site based on proximity of facilities that use extremely hazardous substances (aka Risk Management Plan or RMP facilities).

3. Site Characteristics

The Site is an unoccupied warehouse in a mixed commercial and residential area. A residential neighborhood borders the Site immediately to the west. The warehouse is comprised of two adjoining buildings. The previous owner used the much larger northern building as a mechanic shop until he died unexpectedly on December 18, 2014. The smaller southern building appears to have been used as drum storage for decades. The drums are stored on pallets on a concrete floor (Attachment 3, photo 2). The condition of the floor under the drums cannot be ascertained. Many of the drums' contents have leaked onto the floor (Attachment 3, photo3). Kitty litter has been placed on top ofthe spilled material to limit the spread of the spill. The rows of drums are very close together. In some areas, the aisles between the drums are too narrow to be passable (Attachment 3, photos 2&6).

Each building has exterior entrances that are kept locked, however break-in attempts have occurred since the owner passed away in December 2014. There is no water to the building. There is electric service to the larger northern building only. This service is controlled by the property owner to the east. The smaller southern building with the drums has no utility service. There are also no windows in the building, making it very dark in the drum storage area. A Site map, including an aerial photo, is available in Attachment 1.

4. Release or threatened release into the environment of a hazardous substance, or pollutant or contaminant

Approximately 90 drums of unknown contents are being stored improperly at the Site. Many of the drums are failing and are already leaking their contents onto the floor. It is possible that the spilled material has migrated beyond the concrete floor into the sub- slab and/or under the foundation. In addition to leaking drums, there are also bulging drums at the Site. Hazardous characteristics, including flammability and corrosivity (pH=2), of stored materials was confirmed by EPA and local fire officials. These materials are defined as hazardous substances in 40 CFR §302.4 and hazardous waste in 40 CFR §261.24.

5. NPL status

This Site is not on the National Priorities List (NPL).

6. Maps, pictures and other graphic representations

Attachment 1: Site Location Map

Attachment 3: Photo Log Attachment 4: Environmental Justice Analysis

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B. Other Actions to Date; State and Local Authorities' Roles

1. Previous actions

WDNR received an anonymous complaint notifying them of approximately 90 drums in poor condition in the warehouse on June 23, 2015 (AR, Document #1). WDNR conducted a Site visit and requested E P A assistance in July 2015 (AR, Document #2). WDNR and E P A notified W E M of the site conditions. W E M organized an exercise on August 27, 2015 with the Marathon County Hazardous Materials Team, Spencer Fire, Wausau Fire, Marathon County Emergency Management, WDNR, and EPA to screen and hazcat drums to determine the risk they pose (Attachment 3, photos 9-10). Screening conducted during the exercise confirmed that hazardous substances were being stored in the drums and that the drums needed to be fully characterized and removed as soon as possible.

2. Potential for continued State/local response

The Spencer Fire Department is the Site's immediate neighbor to the south. The Fire Department has offered to provide decontamination assistance and logistical support to EPA during the removal action.

EPA will assess the warehouse floor after the drums and spilled material is removed. If additional contamination is identified, especially if there are cracks in the floor under the leaking drums, a Brownfields grant will likely be pursued for additional assessment.

III. THREAT TO PUBLIC HEALTH OR THE ENVIRONMENT, AND STATUTORY AND REGULATORY AUTHORITIES

The conditions at the Spencer Drum Site present an imminent and substantial threat to public health or welfare, and the environment, and meet the criteria for a time-critical removal action provided for in 40 C.F.R. § 300.415 (b)(2) of the NCP. These factors include, but are not limited to, the following:

• Actual or potential exposure of nearby human populations, animals, or the food chain to hazardous substances or pollutants or contaminants.

Acidic materials (pH=2) were identified by EPA and fire officials in a drum sampled during the exercise. This waste meets the definition of a characteristic hazardous waste (D002). Samples were only collected from open and deteriorating drums during the exercise. The acidic material (as well as many other unknown materials) is not fully containerized. Site visitors could easily and unknowingly come into contact with the hazardous substances. None of the drums are labeled to warn Site visitors of the hazards contained within the drums. There is no lighting in the drum storage area. There is evidence of attempted break-ins.

• Hazardous substances or pollutants or contaminants in drums, barrels, tanks, or other bulk storage containers that may pose a threat of release;

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Approximately 90 unlabeled drums are being stored at the Site. Many of the drums are in extremely poor condition (Attachment 3, photos2-7). These drums are rusted out, leaking, and/or bulging. The exact age and origin of the drums is unknown; however, credible reports indicate that at least some of the drums are more than 40 years old. Screening conducted by EPA and fire/hazmat officials confirmed that some of the drums contain flammable and corrosive materials. The drums are already leaking onto the warehouse floor (Attachment 3, photo 3). Air monitoring indicated that VOC concentrations are highest near the floor where spilled materials are located.

• High levels of hazardous substances or pollutants or contaminants in soils largely at or near the surface, that may migrate;

The condition of the concrete floor under the leaking drums is unknown and cannot be assessed until the drums are characterized and removed. Based on the age of the unheated warehouse, there are likely cracks on the floor. It is presumed that spilled material from the drums has penetrated the floor and possibly contaminated the sub-slab soil.

• Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released;

The average temperature for Spencer, WI is below freezing five months of the year (November thru March). There is no heat in the drum storage area. Freezing and thawing of the stored contents is believed to be contributing to the deterioration ofthe drums.

• Threat of fire or explosion;

The drums are not labelled to indicate contents; however, some of the drums have flammable stickers on them (Attachment 3, photo 5). Flammability was confirmed during the hazmat team exercise using Spillfyter strips. There is no water service to the building, which is now unoccupied. A fire in the warehouse would likely take a long time to detect and would quickly engulf many other drums which are stored very close together.

• The [lack of] unavailability of other appropriate federal or state response mechanisms to respond to the release;

Local officials, W E M , and WDNR have all requested EPA assistance characterizing and disposing of the waste at the Site. There is no generator knowledge of the drum contents. Hazardous substances that pose an imminent and substantial risk have been confirmed among the contents. The estate of the property owner does not have the resources to hire an environmental consultant to conduct the work.

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IV. ENDANGERMENT DETERMINATION

Given the Site conditions and the nature of the contaminants on-Site, as described in Sections II and III above, actual or threatened releases of hazardous substances from this Site present an imminent and substantial endangerment to public health, welfare, or the environment.

V. PROPOSED ACTIONS AND ESTIMATED COSTS

A . Proposed Actions

1. Proposed Action Description:

EPA proposes response actions to directly address actual or potential releases of hazardous substances on Site that may pose an imminent and substantial endangerment to public health, or welfare, or the environment. EPA's will:

1. Develop and implement a Site-specific Health and Safety Plan, an Air Monitoring Plan, an Emergency Contingency Plan, and a Site Security Plan;

2. Characterize the contents of drums stored at the Site and the spilled materials on the warehouse floor;

3. Properly dispose of drum contents and spilled materials;

4. Assess migration pathway of spilled materials;

5. Clean impacted floor; and

6. Perform any other actions to investigate and address contamination on the property that EPA may determine to be necessary.

EPA's will conduct its removal action in a manner not inconsistent with the NCP. The OSC has initiated planning for provision of post-removal Site control consistent with the provisions of Section 300.415(1) of the NCP.

EPA shall treat, store, or dispose all hazardous substances, pollutants, or contaminants removed off-site pursuant to this removal action at a facility in compliance, as determined by EPA, with the EPA Off-Site Rule, 40 C.F.R. § 300.440.

2. Contribution to Remedial Performance:

The proposed action will not impede future actions based on available information.

3. Engineering Evaluation/Cost Analysis (EE/CA):

Not Applicable

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4. Applicable or Relevant and Appropriate Requirements (ARARs):

EPA will comply with all applicable or relevant and appropriate requirements (ARARs) to the extent practicable. On October 1, 2015, EPA sent a letter to Tom Kendzierski of the WDNR asking for any State of Wisconsin ARARs which may apply to or be relevant and appropriate at the Site (AR, Document #5). WDNR submitted ARARs to EPA on October 2, 2015 (AR, Document #6).

5. Project Schedule:

EPA's response action described in this Action Memo will require an estimated 10 working days to complete.

B. Estimated Costs

R E M O V A L A C T I O N P R O J E C T C E I L I N G E S T I M A T E

Extramural Costs: Regional Removal Allowance Costs:

Total Cleanup Contractor Costs $110,216 (This cost category includes estimates for ERRS, subcontractors, Notices to Proceed, and Interagency Agreements with Other Federal Agencies. Includes a 15% contingency)

Other Extramural Costs Not Funded from the Regional Allowance: Total START, including multiplier costs Total Decontamination, Analytical & Tech. Services (DATS) $30,000 Total CLP $0 Subtotal $0

$30,000 Subtotal Extramural Costs

$140,216 Extramural Costs Contingency (20% of Subtotal, Extramural Costs rounded to nearest thousand) $28,043

TOTAL R E M O V A L ACTION PROJECT CEILING $168,259

VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED OR NOT TAKEN

Given the Site conditions, the nature of the hazardous substances and pollutants or contaminants documented on Site, and the potential exposure pathways to nearby populations described in Sections II, III and IV above, the actual or threatened release of hazardous substances and pollutants or contaminants from the Site presents an imminent and substantial endangerment to public health, welfare or the environment if E P A does not take this action. This will increase the

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potential that hazardous substances will be released, thereby threatening the adjacent population and the environment. Delayed or non-action may result in increased likelihood of external exposure, inhalation, ingestion or direct contact to human populations trespassing at or near the

VII. OUTSTANDING POLICY ISSUES

Not applicable.

VIII. ENFORCEMENT

For administrative purposes, information concerning confidential enforcement strategy for this Site is contained in the Enforcement Confidential Addendum.

Direct Costs + Indirect Costs = Estimated EPA Costs for ($168,259 + $20,000) +(57.47%) x ($188,259) Removal Action ($296,451)

The total EPA costs for this removal action based on full-cost accounting practices that will be eligible for cost recovery are estimated to be $296,451.

IX. RECOMMENDATION

This decision document represents the selected removal action for the Spencer Drum Site, Spencer, Marathon County, WI, developed in accordance with C E R C L A as amended, and is not inconsistent with the NCP. This decision is based on the Administrative Record for the Site (Attachment 2). Conditions at the Site meet the NCP Section 300.415(b)(2) criteria for a removal and I recommend your approval of the removal action proposed in this Action Memorandum.

The total project ceiling i f approved will be $168,259, of which an estimated $138,259 may be used for cleanup contractor costs. You may indicate your approval by signing below.

Site.

Richard C. Karl, Director Superfund Division

DISAPPROVE DATE: Richard C. Karl, Director Superfund Division

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Enforcement Addendum Attachments

1. Site Location Map 2. Administrative Record Index 3. Photo Log 4. Environmental Justice Analysis 5. Detailed Cleanup Contractor Cost Estimate 6. Independent Government Cost Estimate

cc: B. Schlieger, EPA HQ L. Nelson, U.S. DOI, w/o Enf. Addendum (email: lindy_nelson@ios.doi.gov) J. Lowery, Wisconsin Department of Natural Resources, w/o Enf. Addendum (email: jason.lowery@wisconsin.gov T. Kendzierski, Wisconsin Department of Natural Resources, w/o Enf. Addendum (email: thomas.kendzierski@wiscsonin.gov)

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BCC PAGE HAS BEEN REDACTED

NOT RELEVANT TO SELECTION

OF REMOVAL ACTION

ENFORCEMENT ADDENDUM

HAS BEEN REDACTED – THREE PAGES

ENFORCEMENT CONFIDENTIAL

NOT SUBJECT TO DISCOVERY

FOIA EXEMPT

NOT RELEVANT TO SELECTION

OF REMOVAL ACTION

ATTACHMENT 1

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ATTACHMENT 2

ADMINISTRATIVE RECORD INDEX SPENCER DRUM SITE

SPENCER, MARATHON COUNTY, WISCONSIN OCTOBER 2015

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ATTACHMENT II

U.S. ENVIRONMENTAL PROTECTION AGENCY REMOVAL ACTION

ADMINISTRATIVE RECORD

FOR THE

S P E N C E R D R U M S I T E

S P E N C E R , M A R A T H O N C O U N T Y , W I S C O N S I N

ORIGINAL OCTOBER, 2015

NO. SEMS ID DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PAGES

921857 7/23/15 Kendzierski, T., Halbur, K . , U.S. WDNR EPA

Email re: Spill Report for the Spencer Drum Site (Portions of this document have been redacted)

921855 7/30/15 Lowery, J., WDNR Ribordy, M . , U.S. EPA

921856 7/30/15 Lowery, J., WDNR Ribordy, M . , U.S. EPA

921854 9/8/15 Strebe, S, Property U.S. EPA Owner

921853 10/1/15 Halbur, K , U.S. Kendzierski, T , EPA WDNR

921858 10/2/15 Lowery, J., WDNR Halbur, K . , U.S. EPA

10/2015 El-Zein, J., U.S. Strebe, S. EPA

10/2015 El-Zein, J., U.S. Smith, D. EPA

Halbur, K. , U.S. Karl, R., U.S. EPA EPA

Region 5 RISE Information Form for the Spencer Drum Site (Portions of this document have been redacted)

Email re: Request for U.S. EPA Emergency Response Assistance

Consent for Access to Property Form (Portions of this document have been redacted)

Letter re: Request for ARARs at the Spencer Drum Site

Letter re: Identification of ARARs at the Spencer Drum Site

Letter re: General Notice of Potential Liability

Letter re: General Notice of Potential Liability

Action Memorandum re: Request for a Time-Critical Removal Action at the Spencer Drums Site (PENDING)

ATTACHMENT 3

PHOTO LOG SPENCER DRUM SITE

SPENCER, MARATHON COUNTY, WISCONSIN OCTOBER 2015

Photo 1: Entrance to drum storage area

Photo 2: Overview of drum storage room

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Photo 3: Example of spilled material on floor

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ATTACHMENT 4

ENVIRONMENTAL JUSTICE SCREEN SPENCER DRUM SITE

SPENCER, MARATHON COUNTY, WISCONSIN OCTOBER, 2015

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ATTACHMENT 5

DETAILED CLEANUP CONTRACTOR ESTIMATE

HAS BEEN REDACTED – ONE PAGE

NOT RELEVANT TO SELECTION

OF REMOVAL ACTION

ATTACHMENT 6

INDEPENDENT GOVERNMENT COST ESTIMATE

HAS BEEN REDACTED – ONE PAGE

NOT RELEVANT TO SELECTION

OF REMOVAL ACTION