Action Memorandum- Request for a Time Critical Removal Action at Kenosha Iron and Metal Site, Kenosha, Kenosha County, Wisconsin

A letter to William E. Muno, asking for approval to conduct removal action, at the Kenosha Iron and Metal site.

254309

1994-07-08 00:00:00.0

WID988574257

Kenosha Iron and Metal

PDF

Environmental Protection Agency

Charles Gebien

Administrative Record

Emergency Response & Removal

text

Soil contaminated

Heavy metals

Polychlorinated biphenyls (PCB)

Kenosha Iron and Metal site

Environmental reporting

Midwest

Environmental Protection Agency

City of Kenosha

1994-07-08

Environmental Protection Agency

City of Kenosha

Copyright undetermined

eng

Kenosha, Wisconsin

PDF

y^V

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO. IL

60604-3590

EPA Region 5 Records Ctr.

254309

BEPir TO ne ATTEWHON of:

JUL 081994
HSE-5J
MEMORANDUM
DATE:

SUBJECT:

FROM:

ACTION MEMORANDUM - Request for a Time Critical Removal
Action at Kenosha Iron and Metal Site, Kenosha, Kenosha
County, Wisconsin.
Charles Gebien, On-Scene Coordinator \JhJ~-

Emergency and Enforcement Response Section II
TO:

William E. Muno, Director, Waste Management Division

THRU: Jodi L. Traub, Acting Associate^ Division Director,
Office of Superfund jj }(*+& 4-tr
SITE ID/: SQ
I.

PURPOSE

The purpose of this memorandum is to obtain your approval to
expend up to $1,000,520 to conduct a time critical removal action
as described herein at the Kenosha Iron and Metal (KIM) site,
Kenosha, Kenosha County, Wisconsin. The site is an abandoned
scrap yard which is unfenced and contains approximately 6,000
cubic yards of soil contaminated with heavy metals and
polychlorinated biphenyls (PCB). The site is located in a
residential area and is used as a shortcut for school children
from two nearby schools. The proposed removal action seeks to
alleviate the threat to public health and the environment from
these hazardous substances by removing and disposing of them.
The proposed removal action is considered a time critical action
due to the inhalation and direct contact threat to the public
from soils that are contaminated with lead, cadmium, and PCBs.
The site is not included on the National Priorities List (NPL).

Printed on Recycled Paper

II.

SITE CONDITIONS AND BACKGROUND

A. Physical Location

The KIM Site is located at 5512-5514 19th Avenue, Kenosha County,
Wisconsin, Latitude 87° 37' 55" north, Longitude 41° 52' 50" west,
(see Figure 1, Site Location Map). The site is bordered on the
north and west by residential homes, and industrial property to
the east and south. Railroad tracks border the south side of the
site and 52nd Avenue borders the east side.
The KIM site is located in an industrial and low-income
residential area. A school is located on 55th Street
approximately 100 feet to the north. A second school is located
two blocks south. According to census data gathered by the
Wisconsin Department of Natural Resources (WDNR), the site is on
the border between Columbus Park census tract (39% of the
population below the federal poverty level) and the Washington
Park census tract (27.5% of the population below the federal
poverty level). The City of Kenosha has a population of 77,685.
B. Site Description and Background
CERCLIS IDf WID988574257

The KIM site is an 1.3 acre abandoned scrap yard that was
involved in the reclamation of batteries and metals. The site is
an empty lot with little vegetation cover with metal and other
debris mixed with the soil. The site is not fenced and is used
as a shortcut for residents and students of two schools that are
within one block of the site.
The KIM site was operated as a scrap yard and metals recycler for
approximately 40 years until approximately 1988. Activities at
the KIM site included the purchase and acceptance of scrap metal,
followed by sorting, sizing, and resale. Ferrous metals were
handled in the yard and the non-ferrous metals were handled in
the former warehouse. The site also accepted batteries and
electrical transformers.
Prior to its use as a scrap yard, the property was used as a coal
storage yard by the Chicago Northwest Railway Company (CNRCO).
In 1948, CNRCO conveyed the property by quit claim deed to the
M & R Land Co. In 1955, the M & R Land Co. conveyed the property
by warranty deed to Maurice Sabin, as trustee. Reportedly, the
site was used as a scrap yard by a Mr. Ruppa until 1983. In
1983, trustee Sabin conveyed the property by land contract to
Harold R. and Roy M. Federman. In a letter dated November 8,
1991, Harold Federman informed the WDNR that he had not fully

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U.S. EPA REGION V
EMERGENCY AND ENFORCEMENT RESPONSE BRANCH
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SITE LOCATION MAP
SITE

SCALE

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KENOSHA IRON & METAL
CtTY

STATE

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WISCONSIN

QUADRANGLE LOCATION Bounce
USGS TOPO QUADRANGLE KENOSHA

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DATE

executed the land contract with trustee Sabin and that ownership
of the property reverted back to trustee Sabin.
Mr. Sabin is a trustee of a land trust which holds title to the
property. Mr. Sabin identified the owners of the land as Max
Wolkomir, Shirley Halper, and Dorothy Berenson. The Kenosha
County Register of Deeds lists the Federmans as the current
owners. The property is abandoned and tax delinquent.
In August 1988, Foth & Van Dyke was retained by the City of
Kenosha to perform an Environmental Site Assessment (ESA) of the
KIM site. The ESA included a legal description of the property,
and the collection and analysis of 43 soil samples from nine soil
borings. The analytical results of the soil samples found
concentrations of lead up to 2,900 parts per million (ppm) and
PCBs up to 102 ppm.
In 1988, Canow, Conibear & Associates, LTD. (CCA) was retained by
the City of Kenosha, Wisconsin to conduct an asbestos survey at
the KIM site. The survey was performed on July 27, 1988. The
survey included a building with a connecting garage, a second
building, and the yard area.
Fifty-three bulk asbestos samples
were collected. No asbestos containing material was found in any
of the buildings. Asbestos material was found on pipes in the
yard, in tile insulation, and in one soil sample.
In 1990, the City of Kenosha razed and removed two buildings onsite. The city also removed deteriorating fencing, a concrete
scale, and metal debris. The asbestos containing material was
removed with the debris.
On September 28, 1993, WDNR performed a Screening Site Inspection
(SSI) at the KIM site. The SSI included the collection of 18
soil samples from the site and from private residences. The
results of the soil sampling at private residences indicated
concentrations of cadmium 61.6 ppm, and lead 1070 ppm. Soil
samples colected on site indicated concentrations of chromium
35,500 ppm, lead 3,380 ppm, and total PCBs 1,140 ppm (See Figure
2).
WDNR interviewed residents bordering the site, who indicated that
there is significant runoff to the north and into the storm sewer
on 55th Street during storm events. The storm sewer discharges
into Kenosha harbor.
No previous removal actions are known to have taken place at the
KIM site.

KENOSHA IRON & METAL, KENOSHA, WISCONSIN
FIGURE 2 SITE FEATURES AND SAMPLE LOCATION MAP

C. Current Site Conditions
On March 30, 1994, the U.S. EPA and the Ecology & Environment
Technical Assistance Team (TAT) conducted an emergency response
site assessment at the KIM site. Bill Ramsey of the WDNR
assisted in assessment activities.
The site was found unsecured by fencing or other means. Children
were encountered on-site during the site assessment.
Fifteen
soil samples were collected from on-site locations and from
residential properties to identify the presence of hazardous
substances (see Figure 2). All soil samples were collected from
1 to 6 inches in depth with a shovel and/or a trowel.
The soil
samples were analyzed by Quality Analytical Labs, Inc. for total
metals (SI through S15), Toxicity Characteristic Leaching
Procedure (TCLP) for metals (SI through S15), and PCBs (S2
through S10 and S13).
Total metals results indicated soils in one residential yard
contained cadmium 60 mg/kg and lead 23,000 mg/kg. Total metals
within site soils were as high as 12,000 mg/kg lead, 120 mg/kg
cadmium, 2,400 mg/kg barium, 12,000 mg/kg chromium, and 5.4 mg/kg
mercury. TCLP analyses of soil sample S13 found cadmium at 1.0
mg/1 and lead at 43 mg/1, which exceed the RCRA Maximum
Concentration of Contaminants for the Toxicity Characteristics.
Soil samples S6 and SlO contained total PCB concentrations of 53
ppm and 55 ppm. PCBs are known carcinogens (cancer-causing) and
are toxic substances regulated by the Toxic Substances Control
Act (TSCA). TSCA disposal requirements apply to materials
contaminated with PCBs at concentrations of 50 ppm or greater.
The TSCA PCB spill Cleanup Policy requires that PCB contaminated
soils in a residential/commercial areas be decontaminated to 10
ppm.
On May 9 through 12, 1994, the TAT, the U.S. EPA On-Scene
Coordinator (OSC) Charles Gebien, and Bill Ramsey of the WDNR
revisited the KIM site to further evaluate the site for a removal
action. An extent of contamination survey was conducted. The
site was divided into a grid with a spacing of 25 feet. Soil
samples were collected at the nodes to a maximum depth of 2 feet.
Two samples were collected at each node point of the grid, from
0-1 foot and 1-2 feet in depth. Deeper samples were not
collected due to buried metal debris.
Each sample was screened with the XRF 880 to determine the
content of barium, chromium, lead, and mercury. The soil samples
were also screened for PCBs at the FASP mobile laboratory using a
Varian 3400 GC with ECD detector. See Figures 3, 4, and 5 for
analytical data results.

KENOSHA IRON & METAL, KENOSHA, WISCONSIN
FIGURE 3 FASP PCB DATA FOR SITE SOILS
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KENOSHA IRON & METAL, KENOSHA, WISCONSIN
FIGURE 4 XRF 880 LEAD DATA FROM SITE SOILS
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KENOSHA IRON & METAL, KENOSHA, WISCONSIN
FIGURE 5 XRF 880 CHROMIUM DATA FROM SITE SOILS
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D. State and Local Authorities' Role
The KIM site lies in the heart of four census tracts that have
been targeted by the City of Kenosha for redevelopment. In August
1988, a City of Kenosha consultant performed an Environmental
Site Assessment (ESA) of the KIM site. The ESA identified soil
contamination within the site, which has halted redevelopment of
the area. In 1990, the City of Kenosha removed buildings and
debris from the site and posted "Health Hazard" warning signs
around the site's perimeter. The City does not have the funds to
conduct a removal action. The City's Health Hazard warning signs
have done little to deter access to the site.
Since 1990, the WDNR has made multiple attempts to contact a site
owner or operator. All parties have denied ownership or
responsibility for the site.
On September 28, 1993, WDNR performed a Screening Site Inspection
(SSI) at the KIM site. The SSI included the collection of 18
soil samples from the site and from private residences which
identified elevated levels of lead, cadmium and PCBs in site
soils and in residential soils. The SSI report has not been
finalized to date.
In March 1994, the WDNR and the U.S. Agency for Toxic Substances
and Disease Registry (ATSDR) requested the Wisconsin Department
of Health and Social Services (WDH) to prepare a public health
consultation for the KIM site. The WDH prepared a draft health
consultation on May 19, 1994, which concludes that lead, cadmium
and PCB contaminated surface soils at the KIM site pose a public
health hazard. The consultation recommends that steps be taken
to restrict public access to the site, prevent contact with lead
and cadmium contaminated soils in residents' yards, control runoff from the site, and measure blood lead concentrations among
children that reside in homes adjacent to the site.
On March 17, 1994, Bill Ramsey of the WDNR referred the site to
the U.S. EPA for further action, as the State of Wisconsin
presently has no funding available for removal actions at the
site.
III. THREAT TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT, AND
STATUTORY AND REGULATORY AUTHORITIES
Conditions present at the KIM site constitute an imminent and
substantial threat to public health and welfare and the
environment, based upon considerations as set forth in the
National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), 40 CFR § 300.415(b)(2). Accordingly, a time critical
removal action is the appropriate response action at the KIM

10

site. These conditions include, but are not limited to, the
following:
1)

Actual or potential exposure to nearby human populations,
animals, or the food chain from hazardous substances or
pollutants or contaminants;

Site investigations and analytical data obtained by the WDNR and
the U.S. EPA have identified surface and subsurface soils
contaminated with lead, cadmium and PCBs. A WDH public health
consultation for the site concluded that the contaminated surface
soils pose a public health hazard and recommended that steps be
taken to control run-off from the site and to restrict public
access. At least one area of contaminated soils within the site
is a RCRA characteristic hazardous waste for lead (D008) and
cadmium (D006). Total concentrations of PCBs in soil samples
were found as high as 1,014 ppm. PCBs are known carcinogens
(cancer-causing) and are toxic substances regulated by the Toxic
Substances Control Act. Cadmium may cause irritation to the nose
and throat. Lead is a suspected carcinogen. Parts of the site
are used by children and local residents as a shortcut, which may
expose them to soil contaminants.
2)

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

Site investigations have documented the presence of lead,
cadmium, and PCBs in surface soils within the site which may
migrate to the surrounding community by wind dispersal, by
runnoff during storm events, and by physical contact with persons
that enter the site. Sample results from WDNR and U.S. EPA site
investigations indicate that soil contaminants have already
migrated to the yards of adjacent residents (See Figure 2). The
results of WDNR soil sampling at private residences found total
concentrations of cadmium 61.6 ppm, and lead 1070 ppm. Soil
samples collected on site indicate total concentrations of
chromium 35,500 ppm, lead 3,380 ppm, and total PCBs 1,140 ppm.
Soil samples collected during the U.S. EPA emergency response
site assessment identified the presence of total cadmium in one
residential yard at 60 ppm and lead at 23,000 ppm. Total metals
within site soils were as high as 12,000 ppm lead, 120 ppm
cadmium, 2,400 ppm barium, 12,000 ppm chromium, and 5.4 ppm
mercury. TCLP analyses of soil sample S13 found cadmium at 1.0
mg/1 and lead at 43 mg/1, which exceed the RCRA Maximum
Concentration of Contaminants for the Toxicity Characteristics.
Residential homes are adjacent to the site and a school is
located across 55th street.

11

3)

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

The KIM site has little vegetative cover. Lead and cadmium have
been found in surface soils in concentrations which exceed RCRA
TCLP levels for 0006 and D008 hazardous wastes. Total PCBs have
been found in site soils in concentrations as high as 1,140 ppm.
Migration of contaminated soils by airborne particulates is
possible during the summer months which promote dry, dusty
conditions. Migration of contaminated soils during storm events
is possible due to leaching of cadmium and lead from soils and
from erosion of the surface soils. Storm runoff from the site is
to the north and into the storm sewer on 55th Street which
discharges into Kenosha harbor.
IV.

ENDANQERMENT DETERMINATION

Site investigations and analytical data obtained by the WDNR and
the U.S. EPA have identified surface and subsurface soils
contaminated with lead, cadmium and PCBs. The WDH concluded in a
site public health consultation that the contaminated surface
soils at the KIM site pose a public health hazard and recommended
that steps be taken to control run-off from the site and to
restrict public access. Some areas of contaminated soils within
the site are also characteristic hazardous wastes for lead (D008)
and cadmium (0006). Total concentrations of PCBs in soil samples
were as high as 1,014 ppm. These wastes pose inhalation,
ingestion, and contact hazards to trespassers and salvage
workers, as well as surrounding residents in this mixed
residential/industrial area.
Given the site conditions, the nature of the hazardous substances
on site, and the potential exposure pathways to nearby
populations described in Section III above, actual or threatened
releases of hazardous substances from this site, if not addressed
by implementing the response actions selected in this Action
Memorandum, may present an imminent and substantial endangerment
to public health, or welfare, or the environment.
V.

PROPOSED ACTIONS AND ESTIMATED COSTS

A.

Proposed Actions

1.

Proposed Action Description

The purpose of this removal action is to mitigate the imminent
and substantial threats posed to public health or welfare or the
environment from contaminated soils at the site. The proposed
time-critical emergency response action includes the following
actions:

12

1) Develop and implement a site health and safety plan.
2) Secure the site and establish utility services.
3) Collect additional samples as may be needed to
characterize contaminated soils for disposal.
4) Make arrangements for off-site disposal of contaminated
soils.
5) Excavate areas of PCB contaminated soils and dispose of
them at at TSCA approved disposal facility.
6) Stabilize areas of D006 and D008 RCRA contaminated soils
to render them non-hazardous and excavate for disposal at a
RCRA subtitle D facility.
7) Verify that excavated areas have been cleaned to preestablished cleanup levels and backfill as needed with clean
soil.
Waste transportation and disposal will be handled in full
compliance with the Agency's off-site policy. Provisions for
post-removal site control are being planned by the OSC consistent
with the provisions of Sections 300.415(k) of the NCP.
The response actions described in this memorandum directly
address actual or threatened releases of hazardous substances,
pollutants, or contaminants at the KIM site which may pose an
imminent and substantial endangerment to public health and
safety, and to the environment. These response actions do not
impose a burden on the affected property disproportionate to the
extent to which that property contributes to the conditions being
addressed.
2.

Contribution to Remedial Performance

The KIM site is a non-NPL site for which remedial actions have
not been planned to date. The proposed removal action will
address all threats meeting the NCP Section 300.414(b)(2) removal
criteria as identified in Section III of this Action Memorandum.
3.

Applicable or Relevant and Appropriate Requirements (ARARs)

All Federal ARARs and any Wisconsin ARARs identified in a timely
manner will be complied with the extent practicable. On June 20,
1994, OSC Charles Gebien contacted Bill Ramsey, Waste Management
Specialist, WDNR, and verbally requested that he identify State
ARARs.

13

4.

Project Schedule

It is estimated that the removal activities will be completed in
sixty (60) 12 hour working days.
B.

Estimated Costs

The estimated costs of the recommended action are summarized in
the following table. The detailed Emergency Response Cleanup
Services (ERCS) contractor costs and initial cost projection
scenario on the Removal Cost Management System (RCMS) is
presented in Attachment A.
EXTRAMURAL COSTS;
Cleanup Contractor Costs

$639,000

Contingency (20%)

$127,800

Subtotal

$766,800

Total TAT, including multiplier costs

$74,000

Extramural Subtotal

$840,800

Extramural Contingency (15%)

$126,120

TOTAL, EXTRAMURAL COSTS

$966,120

INTRAMURAL COSTS;
U.S. EPA Direct Costs
[$30 x (400 Regional Hrs. + 40 HQ Mrs.)]

$13,200

U.S. EPA Indirect Costs

[$53 x 400 Regional Hrs.]

$21,200

TOTAL, INTRAMURAL COSTS

$34,400

TOTAL REMOVAL PROJECT CEILING
VI.

$1,000,520

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

Delayed action will increase the likelihood of release due to
weather conditions which may result in migration of contaminated
soils containing hazardous substances by wind dipersion and
stormwater run-off. Children or salvagers may also spread
contaminants through direct contact. Any such release or
exposure will contribute and ultimately lead to increased risks
to public health and the environment.

14

VII. OUTSTANDING POLICY ISSUES
There are no outstanding policy issues for the KIM site.
II11.

ENFORCEMENT

For administrative purposes, information concerning the
enforcement strategy for this site is contained in an Enforcement
Confidential Addendum presented in Attachment B.
IX.

RECOMMENDATION

This decision document represents the selected removal action for
the Kenosha Iron and Metal Site, Kenosha, Kenosha County,
Wisconsin, developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA)
as amended, and is not inconsistent with the NCP. This decision
is based on the Administrative Record for the site. Conditions
at the site meet the NCP section 300.4l5(b)(2) criteria for a
removal, and I recommend your approval of the proposed removal
action. The total project ceiling, if approved, will be
$1,000,520. Of this, an estimated $892,120 may be used for
cleanup contractor costs. You may indicate your decision by
signing below:
APPROVE:

W^.Crlfi^
DIRECTOR, WASTE MANAGEMENT DIVISION

DI8 APPROVE:

DATE : 1/1/I
DATE :.

DIRECTOR, WASTE MANAGEMENT DIVISION
ATTACHMENTS:

cc:

A.
B.
C.

REMOVAL COST ESTIMATE
ENFORCEMENT CONFIDENTIAL INFORMATION
ADMINISTRATIVE RECORD

T. Johnson, OS-210
Don Henne, Regional Environmental Officer
U.S. Department of the Interior
Custom House, Room 217
200 Chestnut St.
Philadelphia, PA 19106-2904
Paul P. Didier, Director WDNR
P.O. BOX 7921
101 South Webster Street
Madison, WI 53707

15

/

bcc: A. Baumann, HSRL-5J
R. Powers/R. Buckley, HSE-GI

R. Karl, HSE-5J
J. Cisneros, HSE-5J
L. Fabinski, ATSDR, 04ATSR

O. Warnsley, CRU, HSRL-5J
T. Lesser, P-19J
F. Meyers, MS-13J
EERB Read File (L. Taylor)
EERB Delivery Order File (M.E. Gustafson)
EERB Site File (E. Brenneman, SF Central File Room)

Contracting Officer, MC10-J
C. Gebien, On-Scene Coordinator
C. Martwick, Attorney, ORC CM-29A
P. Schwebke, Enforcement Specialist HSE-5J

16

ATTACHMENT A
REMOVAL COST ESTIMATE
Portions of this attachment were redacted which contain
confidential contractor information.

Suaaary Report
Initial Coat ProjectI on Scanarlo: K1NOSMA ItOM t METAL
Projection ID Nusfcer: U10423SA
Claanup Contractor: RESS - Rtedel EnvlronMntal

Pag*: 1

Data: 06/14/94
TAT Contractor: ECOLOGYXENVIRON

Cott Project ion Suaaary

Contractor Personnel
Contractor Equipment
Unit Rate Natariala
At Coat Natariala
Subcontractors
Waata Transportation
Uaata Disposal

211,447.20
35,717.66
73,517.26
0.00
27,629.75
33,215.33
257.759.70

Clean*) Contractor Subtotal

639,286.90

Federal and State Agencies

0.00

Extraaural Subtotal
20 X Extrasural Contingency

639.286.90
127,857.38

Extraaural Subtotal

767,144.28

TAT Personnel
TAT Special Projects
TAT Analytical Services

74,037.60
0.00
0.00

Total TAT Costs

74.037.60

Other Cost Iteaa

0.00

Extraaural Subtotal
15 X Project Contingency

841,161.88
126.177.28

Total Extramural Cost

967,359.16

EPA Regional Personnel

25,560.00

EPA non-Regional Personnel
EPA Headquarters Direct
(10 X of Regional Hours)
EPA Indirect

0.00
2,160.00
38,160.00

EPA Total

65,880.00

Project Total

1,033,239.16

Suavary Report (cent.)
Initial Coat Projection Scenario: K1NOSNA IRON I METAL

Peoe: 2

Dete: 06/U/94
TAT Contractor: ECOLOGYiEHVIRON

Projection ID Nutor: UIM23U
ClMnup Contractor: RES5 • Rlodol EmironMntal

mm

Project Scope

Nufcer
000

Step/Ml Iettone
GEMERAL SITE COSTS

Eatlaatad
Duration
90 Days

Coat
1,033,239.16
1,033,239.16

ATTACHMENT B
ENFORCEMENT ADDENDUM
Redacted - not relevant to the selection of the removal action

ATTACHMENT C
U.S. ENVIRONMENTAL PROTECTION AGENCY
REMOVAL ACTION
ADMINISTRATIVE RECORD
FOR
KENOSHA IRON AND METAL,
KENOSHA, WI
June 23, 1994

IJAIE

AUTHOR

03/17/94

Ramsey, B. , Rivera, R. , Site Referral from
WDNR
WDNR
U.S. EPA

05/19/94

Goldring,
J., WDH

Fabinski,
L. , WDNR/
ATSDR

Health Consultation
for the KIM Site

00/00/00

Ecology &
U.S. EPA
Environment,
Inc.

Site Assessment and
Removal Action Plan
(Pending)

00/00/00

Gebien, C.,
U.S. EPA

Action Memorandum
(Pending)

RECIPIENT

Muno, W.,
U.S. EPA

TITLE /DESCRIPTION

PAGES
142