Brownfields Environmental Assessment Pilot Draft Phase I Report for Frost Manufacturing Incorporated

Report assessment done by Wisconsin Department of Natural Resources (WDNR), to assess site conditions of The Frost Company site, in Kenosha, Wisconsin

254392

1996-10-23 00:00:00.0

WID006090286

Frost Manufacturing Company

PDF

Wisconsin Department of Natural Resources

Administrative Record

Emergency Response & Removal

text

Site conditions

Hazardous substance

Contamination

Environment

Frost Manufacturing Company

Environmental reporting

Midwest

Wisconsin Department of Natural Resources

Environmental Protection Agency

City of Kenosha

1996-10-23

Wisconsin Department of Natural Resources

Environmental Protection Agency

City of Kenosha

Copyright undetermined

eng

Kenosha, Wisconsin

PDF

000^.004

EPA Region 5 Records Ctr.

254392

Brownfields Environmental Assessment Pilot
DRAFT
Phase I Report

for
FROST MANUFACTURING INCORPORATED
Wisconsin Department of Natural Resources
October 23, 1996

John T. Burnett, Project Manager

TABLE OF CONTENTS
Section

Page

I.

INTRODUCTION
A.
Purpose
B.
Objectives
C.
Background

1
1
1
2

II.

PROPERTY OVERVIEW
A.
Site Features
B.
Land Use and Zoning
C.
Records Review
D.
Potential Receptors/Environmentally Sensitive Areas
E.
Geologic and Physiographic Features
1.
Topography
2.
Geology
3.
Hydrogeology

4
4
4
5
11
11
11
11
12

IH.

PROPERTY HISTORY
A.
Sanborn Fire Insurance Maps
B.
Aerial Photography/Historical Topographic Maps
C.
City Street Directories
D.
Title Search

12
13
13
14
20

IV.

REGULATORY HISTORY

16

V.

ENVIRONMENTAL INVESTIGATIONS AND CLEANUPS

19

VI.

CONTACT INTERVIEWS

20

VII.

PHYSICAL RECONNAISSANCE

20

Vin.

FINDINGS AND RECOMMENDATIONS
A.
Findings
B.
Recommendations for Further Action
C.
Recommendations for Phase II Sampling

23
23
23
24

IX.

LIMITATIONS OF THIS PHASE 1 SITE ASSESSMENT

24

FIGURES
Figure
1
2
3
4

Page
Site Location Map
Site Features Map
Map of RCRIS and CERCLIS Sites From Database Search
Map of LUST and ERP Sites From Database Search

3
5
6
7

TABLES
Table
1
2
3
4
5
6
7
8

Page
Records Review Summary
RCRIS Listed Sites Within One Mile of Site
ERP Sites Within One-half Mile of Site
LUST Sites Within One-half Mile of Site
Historical Sources
Property Use at Site
Property Use in Vicinity of Site
Features Not Observed On Property As Of March 12, 1996
APPENDICES

Appendix
A
B
C
D
E

Sanborn Fire Insurance Maps
Record of Property Title
Site Regulatory History Timeline
Photo documentation from Site Reconnaissance
Environmental Site Assessor Qualifications

8
9
9
10
13
14
15
23

I. INTRODUCTION
A. Purpose
A Phase I Environmental Assessment is a report that includes record reviews, interviews, and
physical property inspections to identify areas of potential hazardous substance contamination that
is of environmental significance. The Phase I is used to identify areas from which samples may be
collected for analysis for a Phase II Environmental Assessment. A Phase II Environmental
Assessments a report that details the environmental conditions at the property. The details of
environmental assessments will depend on the past usage of the property, present use of the
property, and other site specific factors.
This Phase I was conducted utilizing guidance from the following documents:
American Standards for Testing Materials (ASTM) 1527-94, Standard Practice for
Environmental Site Assessments: Phase I Environmental Site Assessment Process; and
Department of Natural Resources, Recycling Contaminated Lands in Wisconsin, Fact
Sheet 3: Step One of Conducting a Thorough Environmental Investigation: Phase I
Environmental Assessment and a Phase II Scope of Work.
B. Objectives
This Phase I Property Environmental Assessment was conducted by the Wisconsin Department of
Natural Resources (WDNR) for the City of Kenosha as part of the U.S. Environmental Protection
Agency and WDNR funded Brownfield Environmental Assessment Pilot conducted in Fiscal Year
1996. A Memorandum of Agreement was signed between the municipality and the WDNR to
ensure cooperation and define responsibilities for various aspects of the assessment.
The purpose of the pilot is to conduct a Phase I Environmental Assessment (and Phase II
Assessment if necessary) for municipalities to assess site conditions and to help market abandoned
and/or delinquent properties that are under-utilized. The Frost Company site is a vacant and tax
delinquent site owned by the bankrupt F.P. Incorporated. The WDNR has performed this Phase I
Environmental Assessment at the site to determine whether there is potential contamination at the
property. Knowledge gained from the Environmental Assessment will help the City market the
property for cleanup and redevelopment, hopefully returning the property to productive use and
to the City's tax roll.

The site contacts are:
John Burnett, Project Manager
Wisconsin Department of Natural Resources
(608)266-2632
Sharon Krewsen, Real Estate Agent
Department of City Development, City of Kenosha
(414)653-4028

C. Background
This 4.75 acre site was a metals manufacturing and finishing company from the turn of the
century until 1994. The company operating the facility was incorporated in the state of
Wisconsin November 3, 1902, as P.P. Incorporated. P.P. Incorporated was administratively
dissolved June 18, 1996. The last annual report filed by the company was for 1993.
The site is located in a mixed-use, single family-residential/heavy industrial, area of the city.
The site is entirely fenced or enclosed with the exception of the eastern side adjacent to the
Chicago and Northwestern railroad track.
The company's products included copper tubing, chrome-plated fixtures, copper-plated
fixtures, metal containers, and swimming pool hardware. Wastes handled at the facility
included electroplating sludge, buffing dust, sludge filters, solvents, wastewater and foundry
sand. A new wastewater treatment unit was installed in 1987 for pretreatment of the
electroplating wastewater before discharge to the city's sanitary sewer.
The leaded-brass foundry operation has been inactive since September, 1991 and the rest of the
facility (plating, polishing and machining) has been inactive since 1994. There is one large
building consisting of the original plant (1903) and additions to it, a foundry building located
north of the main building, and several small sheds located on the east side of the property.
Another corporation, S. R. Smith, leased space in the facility for a period of time after Frost
Corporation ceased operating the facility. S. R. Smith used the plating and/or electropolishing
facility at the site.
See Figure 1 for the site location map.

Site Location (address/city/county/state):
6523 14th Ave Kenosha, WI 53143
SE 1/4 of the SE 1/4 of the NW1/4, T IN, R 23E, Kenosha
Kenosha County, Wisconsin

FIGURE 1
SITE LOCATION MAP

II. PROPERTY OVERVIEW
A. Site Features
The Frost property is located in a relatively flat area with the exception of the eastern border of
the property which is adjacent to the Chicago and Northwestern railroad. The railroad is
aproximately 15 feet above the Frost property and the property located adjacent to and east of the
railroad. Most of the site is either paved, asphalt over brick or concrete or contains buildings.
Seven buildings are located on the property. From north to south they are: brass foundry building,
sand storage building, parking shelter, main building and three equipment and parts storage sheds
along the east side of the property. The main building has had several additions to it over the
years and parts of it have deteriorated or been vandalized. The office section of the main building
was set on fire by vandals in May, 1996.
B. Land Use and Zoning
The Kenosha Department of City Development issued The Lincoln Neighborhood Plan in July,
1996. The Frost property, which is included in the 14th Avenue Corridor, is recommended in
plan A to remain in industrial use if there is sufficient demand and the use would not be
detrimental to the adjacent residential areas. Recommended plan B for the frost property
suggests the property be converted to a large scale residential development. If the property is
contaminated and cannot be converted to residential use other alternatives including parkland,
community facilities and institutions may be considered.
C. Records Review
A review of selected state and federal government lists of potentially contaminated sites was
conducted to identify sites within specified distances of the brownfields site that may be a source
of contamination impacting the property. Table 1 presents the lists which were used and the
corresponding search distances. A discussion of the results of the search follows. A visual
presentation of some of the sites located within the searched databases is provided in Figures 3
and 4.

FIGURE 2
SITE FEATURES MAP

FIGURE 3
Map of CERCLIS and RCRIS Sites From Database Search

FIGURE 4
Map of ERP and LUST Sites From Database Search

Table 1 - Records Review Summary
Type of Site

Date

Search Distance

Number Found

NPL

7/19/96

1.0 mile

0

CERCLIS

7/19/96

0.5 mile

0

RCRA-TSD

6/30/96

1.0 mile

2 - identified below

RCRA-Gen

6/30/96

Property and adjoining

Frost property, Outakumpu

ERNS

6/30/96

Property

0

ERP

4/22/96

1.0 mile

1 2 - identified below

Spills

3/28/96

Property and adjoining

0

Solid Waste

3/28/96

0.5 mile

0

UST

7/31/96

Property and adjoining

3 - identified below

LUST

4/22/96

0.5 mile

5

NPL - NPL stands for the National Priorities List, a federal list of sites that are being cleaned up
under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA),
also known as Superfund. There were no NPL sites identified within one mile of the site.
CERCLIS - CERCLIS stands for the Comprehensive Environmental Response, Compensation
and Liability Information System, a federal list of sites which have the potential to become
Superfund sites. There were no CERCLIS listed sites located within l/2 mile of the site.
RCRA-TSD - RCRA stands for the Resource Conservation and Recovery Act, a federal law
addressing hazardous waste management. TSD designates the facilities which treat, store, and/or
dispose of hazardou: \vaste. There were two TSD sites identified within one mile of the site.
RCRA-Gen -This term refers to the generators of hazardous waste. The Brownfield property
itself is listed as a RCRA Large Quantity Generator and there are three other facilities within onehalf mile which are listed.

Table 2 - RCRIS Sites Within Vi Mile and TSD's Within 1 mile
EPA ED #

Name

Status

Address

WID006090286

FROST CO

LQG

6523 14TH AVE

NONE LISTED

BECKER INC

VSQG

6705 14THAVE

WID030664619

MONARCH PLASTICS

SQG

1205 65TH ST

WID988571113

ARMANDOS BODY SHOP

CESQG

171863RDST

WID988605614

AMBROSINI INC

SQG

631020THAVE

WIT5600 12296

*ANACONDA COMPANY THE

TSD

1420 63RD ST

WID023289069

WISCONSIN FUEL AND

TSD

6329 28TH AVE

LQG - Large Quantity Generator, SQG - Small Quantity Generator, CESQ - Conditionally Exempt SQG
* a former name of the Outakumpu facility, Outakumpu is not a TSD facility

ERNS - ERNS stands for the Emergency Response Notification System. This is a federal
program which responds to emergencies, including spills of hazardous materials. The Brownfield
property was not identified on the ERNS list, however Outakumpu, a nearby RCRA Large
Quantity Generator reported five spill incidences from 8/11/89 to 3/21/96. Substances included
acid waste water, 1,1,1-Trichloroethane, kerosene (20 gal.), pickle rinse water and pickle liquor.
ERP - ERP stands for the Environmental Repair Program. This is a state program administered
by the WDNR in order to clean up sites containing a variety of environmental contamination.
There were 12 ERP sites, located within one mile of the Brownfield site, identified in Table 3
below:
Table 3 - ERP Sites Within One Mile of Property
FEO#

ERP Site Name

Address

230078200

WI DOA FECHER PROPERTY

6337 14TH AVE

230103940

K A T REALTY/CHRYSLER CORP

5TH AVE & 55-57TH STS

230004500

CHRYSLER KENOSHA MAIN PLANT

5626 25TH AVE

230110100

CHICAGO & NW RBT-338-68

52ND ST & 6TH AVE

230099870

KENOSHA IRON & METALS CO

55 12-55 14 19TH AVE

230135620

SHADY LAWN NURSING HOME

170360THST

230004390

OUTOKUMPU-AMERICAN BRASS

1420 63RD ST

10

FID#

ERP Site Name

Address

230135730

CHRYSLER BLDG 50

2301 60TH ST

230143210

CHICAGO & NW RR YARD

5410 13THAVE

230060160

HOME CORP

132556THST

230155750

CHRYSLER MP-12 FORMER

26TH AVE & 63RD ST

230159820

HAARSTICK AUTO BODY

6215 SHERIDANRD

Spills - A list of spills which have occurred in the state is maintained by WDNR. There are no
spills on record for the site.
Solid Waste - This is a list of solid waste disposal sites (i.e. landfills) which are licensed by
WDNR. There are no solid waste facilities identified.
UST - UST stands for Underground Storage Tank. The Wisconsin Department of Industry,
Labor, and Human Relations (DILHR) maintains a list of UST's in the state. The database search
identified three UST's on the property. Two 8,000 gallon fuel oil tanks installed in 1930, and one
20,000 fuel oil tank installed in 1972. There may be other unregistered tanks buried on the
properly.
LUST - LUST stands for Leaking Underground Storage Tank. WDNR keeps a record of
LUST's in the state. There were 5 LUST sites identified within one-half mile of the Brownfield
site, as identified in Table 4 below:
Table 4- LUST Sites Within One-Half Mile of Property
FTD#

LUST Site Name

Address

230144860

KENOSHA, CITY OF #9

2121 ROOSEVELT RD

230131000

BURT & RUDY'S MOBIL

6226 SHERIDEN RD

230060600

STAN LOCK BUICK

1011 60THST

230015500

KENOSHA HOSPITAL & MEDICAL
CENTER

6308 8TH AVE

210146400

AMERICAN PETROLEUM

1405 60TH ST

D. Potential Receptors/Environmentally Sensitive Areas

11
WDNR records indicate that there are no water supply wells on the site, and there are no known
potable water supply wells in the area. The City of Kenosha relies on Lake Michigan for its water
supply.

There are no known conservation or preserve areas in the vicinity of the site. Sheridan Park is
located approximately 1000" east of the site and Lincoln Park is located approximately 1000'
southwest of the site.
£. Geologic and Physiographic Features
Information for the following sections was compiled from Soil Survey of Kenosha and Racine
Counties, USDA Soil Conservation Service, Pleistocene Stratigraphic Units of
Wisconsin, Wisconsin Geologic and Natural History Survey Miscellaneous paper 84-1 and
WaterResources of "Racine and Kenosha Counties, Southeastern Wisconsin, Geological Survey
Water-Supply Paper 1878.
1. Topography
The site is located at an elevation of approximately 610 feet MSL and the land surface in the
vicinity of the site is a gently undulating plain formed by glacial action of the Lake Michigan lobe
of the Wisconsin glacier. The eastern border of the site is the Chicago and Northwestern rairoad
which is approximately 15' above the site. Storm water run-off is collected by storm sewers and
discharged to lake Michigan.
2. Geology
The site soil is mapped as a Sisson fine sandy loam with one to six percent slopes. The Sisson
series is made up of loamy, well drained soils developed in laminated lacustrine silt, fine sand and
very fine sand.
The pleistocene formation near surface is the Oak Creek formation deposited by the ice of the
Lake Michigan lobe. The Oak Creek formation is widely distributed in southeastern Wisconsin
and consists of lacustrine silt, clay and sand, some glaciofluvial sand and gravel, and fine textured
glacial till. The till units are found farther west. The site is located in the plain of glacial Lake
Chicago and is probably on lacustrine deposits and possibly some glaciofluvial deposits. The
unconsolidated deposits can range in thickness from 20 to 150' in the area.
Bedrock in the vicinity of the site is Silurian aged dolomite approximately 220' thick . The Silurian
dolomite is a white to grey dolomite with an extensive system of joints and fractures which have
been enlarged through solution. The Silurian dolomite serves as an important aquifer to the area,
though its yield may be variable, determined by the interconnectedness of the fractures.
Underlying the Silurian dolomite is the Ordovician aged Maquoketa shale. The Maquoketa is a
dolomilic shale containing some thick beds of dolomite near the top and is approximately 200'
thick at the site.

12

Underlying the Maquoketa shale are the ordovician aged sandstones which include the Platteville,
Decorah and Galena formations at a thickness of approximately 420'. The next underlying
formation (also Ordovician aged sandstone) is the St. Peter sandstone with a thickness of
approximately ISO1. Underlying the St. Peter is approximately 90' of the Cambrian aged
Trempealeau sandstone. The other Cambrian sandstones below the Trempealeau formation
include the Eau Claire and Mount Simon sandstones of unknown thickness.
3. Hydrogeology
The water table is present in the Pleistocene deposits but the deposits do not serve as an aquifer.
The glacial deposits do allow for the percolation of water to recharge underlying aquifers.
Shallow groundwater flow in the vicinity of the site is believed to be east or northeast toward
Lake Michigan.
The predominant aquifer is the Silurian dolomite, which has an extensive system of joints and
fractures serving to enhance the productivity of wells. Well yields in the Silurian dolomite range
from very small to large depending on the numbers and sizes of joints and fractures penetrated by
the well. The City of Kenosha water supply is pumped from Lake Michigan and there are
probably very few wells within three miles of the site.
The Ordovician and Cambrian sandstones make up the sandstone aquifer which is semi-confined
by the Maquoketa shale and yields small to large quantities of water depending on the specific
formations the well is open to. The St. Peter is the only Ordovician rock that yields water in
significant amounts in Kenosha and Racine Counties. Depth to the top of the sandstone aquifer
ranges from 500 to 800 feet. Some high-capacity wells use this aquifer in the county and they
average: about 1500 feet in depth tapping the Cambrian sandstones which are the most
consistently productive water yielding zones.
ffl. PROPERTY HISTORY
Table 5 provides the historical sources which were consulted to gather information regarding the
history of land use and activities which occurred on the site.

13

Table 5 - Historical Sources
Source

Dates Reviewed and Scale

Comments

Aerial photographs

1941,
1963,
1969,
1979,
1992,

Provides information on land
use changes as well as other
large scale features.

Topographic maps

1958 - 7.5' topo quadrangle
1971 - 7.5" topo quadrangle
1976 - 7.5' topo quadrangle

Provides information on the
relative growth and industrial
development of the area.

Sanborn Fire Insurance Maps

1918-1"-64.5'
1949- 1"~64.5'
1969- l"-64.5'

Provides detailed information
on building features, and
therefore potential industrial
processes which occurred.

City Street Directories

1941-1996
at five year intervals

Name of business located at
both target property and limited
surrounding area

1:20,000, B&W
1:20,000, B&W
1:20,000, B&W
1:40,000, B&W
1:24,000, color IR

A. Sanborn Fire Insurance Maps
Copies of the Sanborn Fire Insurance maps for the years 1918, 1949, and 1969 are presented in
Appendix A.
B. Aerial Photography/Historical Topographic Maps
Historic aerial photos and topographic maps were reviewed at the A.H. Robinson Map Library at
the University of Wisconsin in Madison. Aerial photographs from 1941, 1963, 1969, 1979, and
1992 were reviewed. The topographic map from 1958 was reviewed, as well as a copy which
was photo revised in 1971, and photo inspected in 1976. The following section is a synthesis of
observations made from these two historic sources.
Photographs
The 1941 photograph (scale 1:20,000) shows a large factory/industrial complex occupying several
city blocks to the northwest of the Frost Manufacturing property. There is a large open space on
the block to the east of the Frost building. A rail line running north-south is visible adjacent to the
property to the east. Residential neighborhoods appear to be the predominant land use to the
west, south, and northeast of the Frost property.
In the 1963 photograph (scale 1:20,000) there is a building addition noted since the 1941
photograph, which is located on the southern part of the Frost property. There appears to be a
new free-standing building located on the southeast corner of the property. There has been

14

limited development, appearing to be primarily residential, in the lot to the east. There are no
other significant changes noticed in the areas adjacent to the Frost property since the 1941
photograph.
There is another building addition, the warehouse addition, which appears in the 1969 photograph
(scale 1:20,000), a long rectangular building located along the southern part of the Frost property.
The property to the east remains undeveloped. The residential neighborhoods remain to the west,
south, and northeast of the site. There were no significant changes noticed since the 1963
photograph.
The only noticeable change detected in the 1979 photograph (scale 1:40,000) is the construction
of a large building, Monarch Plastics Inc., on the former vacant lot to the east of the Frost
property.
There were no further changes noticed in the 1992 photograph (scale 1:40,000). The land use
around the Frost Manufacturing property remains primarily residential except, for the large
industrial complex immediately northwest, and the property due east.
Topograiphic Maps
The topographic maps identify Frost Manufacturing and the other industrial factory to the
northwest. The three maps, from 1958, 1971, and 1976, are virtually the same, with the only
change being the addition of the building on the property to the east of Frost, which occurred
sometime between 1958 and 1971. There are no other visible changes represented by the maps
which occurred on or around the Frost property during this period. The surrounding schools, 15
within an approximate one-mile radius of the Frost property, are identified on the maps.
C. City Street Directories
Environmental Data Resources, Inc. (EDR) was retained by the WDNR to review city directories
for this site and adjoining properties. City directories, including Polk, Wright, and other cross
reference directories, were reviewed at five year intervals from 1940 through 1996. The site
property is listed as Frost Co. throughout the entire period. Results from the searches for nearby
properties are summarized in Table 7 below. The address of the foundry building area of the site
is listed by EDR as 6501 65th Street but the actual address is 6501 14th Avenue. The EDR
listing of 6501 14th Ave. or 65th St. does correspond to the 1949 Sanborn map showing the "city
garage and repair shop" at the 6501 14th Avenue location .
Table 6 - Property Use at Site
Year

Address

Property Use/Occupant

1941-1990

6523 14th Ave

Frost Co

1941-1955

6501 14th Ave

City Streets Department

1960-1965

6501 14th Ave

Rudy Tool & Machine Co

15

Table 7 - Property Use in Vicinity of Site
Year

Property Use/Occupant

Address

1941-1985

6405 14th Ave

Apartments

1941-1965

6510 14th Ave

Horochena Food Mart

1970

6510 14th Ave

Residence

1974

6510 14th Ave

Vacant

1941-1974

6514 14th ave

Residence

1941-1990

6518 14th Ave

Residence

1941-1990

6524 14th Ave

Residence

1941-1990

6526 14th Ave

Residence

1941-1990

6530 14th Ave

Residence

1941-1990

6602 14th Ave

Residence

1940-1974

1316 65th St

Residence

1980-1985

13 16 65th St

Vacant

1920-1960

1320 65th St

Residence

1965

1320 65th St

Vacant

1970-1985

1320 65th St

Residence

1941-1985

1322 65th St

Residence

1941-1970

1326 65th St

Residence

1941

1401 65th St

Mid-City Candy Co.

1945-1974

1401 65th St

Model Tavern

1980-1985

1401 65th St

Hank & Sons Tavern

1990

1401 65th St

Hank & Tina's Family Restaurant

1941-1974

1405 65th St

Residence

1980-1990

1405 65th St

Vacant

1941-1990

1409 65th St

Residence

1941-1970

1413 65th St

Residence

1970

141 3 65th St

Vacant

16
1980

1413 65th St

Residence

1985

1413 65th St

Vacant

1990

1413 65th St

Residence

IV. REGULATORY HISTORY
Wastewater Discharge Permit History
The Frost Company reported to WDNR as an industrial user on a Pretreatment Baseline
Reporting Form September 25, 1980. This form includes descriptions of operations, production
rates, raw materials used, flow rates to the sanitary sewer, sampling results, sample locations,
pretreatment system description, and a statement indicating the company was in compliance with
pretreatment standards with the exception of pH control. Installation of a pH control unit to
remedy the pH problems was projected to be completed by November 1, 1980.
WDNR's response October 24, 1980, to the company's form identified missing or incomplete
information. The response included a rejection of the company's statement that pretreatment
standards were being met on a consistent basis.
The company responded March 4, 1981, with a revised Pretreatment Baseline Reporting Form
which appears to have satisfied WDNR's requirements. The revised form briefly described the
pretreanment system as a reverse osmosis unit for reclaiming nickel installed in approximately
1974. The system also incuded the addition of sodium bisulfite for conversion of Cr VI to Cr III.
The pH control system's projected completion date was revised to April 20, 1981.
January 9, 1984, the company was notified via certified letter that pretreatment standards for the
Electroplating and Metal Finishing Point Source Categories for industrial users of pubilcy owned
treatment works (POTW's) were issued in final form by U.S. EPA. The standards are limits to
concentrations of wastewater pollutants that may be introduced to the POTW by electroplating
and metal finishing operations.
February 23, 1984, the company submitted a revised Pretreatment Baseline Reporting Form
indicating separation of regulated and non-regulated water flows, change to standard
concentration limits, changed sampling point, and the completion and operation of the pH control
system.
The Kenosha Water Utility issued the company Wastewater Discharge Permit No. KWU-FST-84
on October 9, 1984. The permit required pretreatment to meet federal/state standards, a
compliance schedule submission, biannual self-monitoring, and a Baseline Monitoring Report.
June 14, 1985, the company received via certified mail a letter from WDNR with a form, Periodic

17
Compliance Report, for biannual reporting on regulated wastewater to the pretreatment program
control authority. This letter stated that regulated wastewater from the electroplating category
includes process bath and rinse water, wastewater from related preparatory and finishing steps
such as clegreasing, cleaning, pickling, coloring, sealing, stripping, wet air pollution control, and
that all electroplating category operations must be included in the Periodic Compliance Report.
WDNR received the first Periodic Compliance Report from the company July 23, 1985 for the
period 1/1/85-6/30/85.
The Kenosha Water Utility sent the company via certified mail, dated November 13, 1985, a
Notice of Violation for the discharge of wastewater not in compliance with the standards
established by U.S. EPA for the Electroplating and Metal Finishing Categories. Copper and
cyanide analyses submited on the Periodic Compliance Report for the period ending June 30,
1984 were not in compliance. The company was also required to submit a compliance schedule
-with its Baseline Monitoring Report but failed to submit the schedule. The Kenosha Water Utility
advised the company that enforcement proceedings were being initiated.
An enforcement conference between the Kenosha Water Utility and the company was held on
December 5, 1985. The company officials stated that they were in the process of replacing the
copper-cyanide plating operation with a caustic bath process and expected to reduce copper in the
effluent by an estimated 60% and eliminate cyanide discharge completely. The Utility requested
the company to submit a letter indicating the change-over schedule with completion date and
when a 90 day compliance period would begin. December 9, 1985 the company submitted a
change-over completion date of January 2, 1986. The utility stated that they anticipated the
company's current pretreatment efforts will be sufficient to satisfy the regulatory requirements.
September 1986, compliance monitoring data from the company indicated non-compliance with
maximum and average categorical limits for chromium, copper and nickel. The utility and the
company negotiated a compliance schedule and the company contracted with Triad Engineering
Incorporated to design and costruct a pretreatment system. The Pretreatment system start-up
date was scheduled for March 1, 1989.
The Kenosha Water Utility sampled wastewater at the Frost company February 15, 1987, and
reported results showed copper levels increasing (both average and maximum) and chromium
marginally within compliance.
The Kenosha Water Utility submitted a request to WDNR June 12, 1987, for a categorical
determination of the company's annealing furnace operation. The copper is cleaned in alkaline
solution, rinsed, acid pickled, and rinsed before forming is done in an annealing furnace. The
process, may be considered Copper Forming rather than Electroplating and Metal Finishing Point
Source Categories. Engineering of the pretreatment system was halted pending the determination
of the process category.

18

WDNR's response, dated July 9, 1987, for categorical determination informed the utility that the
annealing furnace operation was considered to be within the Metal Finishing category unless one
of the basic copper forming processes (hot rolling, cold rolling, drawing, extrusion or forging)
was conducted also.
The Kenosha Water Utility, after consulting with WDNR, issued a Notice of Violation February
17, 1988. Sampling conducted by the utility the week of January 25, 1988 indicated that the
company's discharge exceeded the one-day maximum and four-day average for chromium and
copper, the three-day average for zinc, and was outside the pH range specified in the permit. The
notice asked the company to evaluate operations that could reduce concentrations of chromium,
copper and zinc as well as controlling pH during the compliance interim. The notice also
requested progress reports from the company and Triad Engineering.
March I, 1989 Triad Engineering notified the Kenosha Water Utility that parts of the
pretreatment system were operating (evaporative recovery for nickel and chromium, and reverse
osmosis system for nickel) and that materials for completion of the system were onsite. Triad
Engineering also requested a change to the compliance schedule with completion of pretreatment
start-up scheduled for May 26, 1989.
The company notified the Kenosha Water Utility of the start-up of the pretreatment system on
April 12, 1989.
The Kenosha Water Utility, via certified letter on July 14, 1989, issued a Notice of Violation to
the company stating that effluent was monitored from May 22-26, June 5-9, and June 19-23,
1989, and results for chromium, copper, nickel, and zinc exceeded monthly averages. The utility
indicated that a Show Cause Hearing would need to be scheduled and that enforcement action
would be taken at that time.
The WDNR wastewater program file does not indicate the results of the the Show Cause Hearing.
The next file entry contains a wastewater Discharge permit issued October 12, 1992 with an
expiration date of October 12, 1996. Another Wastewater Discharge permit was issued by the
Kenosha Water Utility on April 29, 1993 expiring on April 29, 1997.
Resource Conservation and Recovery Act History
The Frost Company notified U.S. EPA as a hazardous waste generator on May 4, 1981 and was
assigned EPA ID # WID006090286.
On October 16, 1984 the company received a Notification of Noncompliance as a result of a large
quantity hazardous waste inspection conducted by WDNR on September 24, 1984. Deficiencies
included failure to mark containers with accumulation start dates, waste manifests without the
facility ID number, lack of weekly inspection of containers for leaks and defects, no written
contingency plan and emergency procedures, and no training program for training employees in

19

handling hazardous wastes and emergencies.
On February 13, 1985 WDNR representatives ret with the Frost Company President to request a
plant layout be added to the Contingeny Plan submitted by the company and that the employee
training program still needed to be implemented.
The WDNR submitted a letter April 11, 1985, notifying the company that all required corrections
had been made and the company was in compliance.
On October 31, 1988, WDNR conducted a large quantity hazardous waste inspection at the Frost
Company. Six areas of non-compliance were identified. In a letter dated December 13, 1988,
WDNR notified the company that the corrections required were made and the company was now
in compliance.
0

September 28, 1993, WDNR conducted a large quantity hazardous waste inspection at the Frost
Company. Ten areas of noncompliance were identified and samples of foundry sand and water in
the floor pits (foundry building) were collected. The casting of leaded brass parts was
discontinued in September of 1991. Clean-up bids were being considered by the company.
The WDNR notified the Frost Company on November 3, 1993, that the foundry sand was a
hazardous waste (TCLP lead) and that the company must clean close the building. The WDNR
requested the company to show proof that a qualified environmental consultant was retained
within 10 days, submit a scope of work to document the degree and extent contamination within
30 days, and recommend alternative remedial or closure plans and propose a schedule for
completion.

^^

Upon review of the May, 1994, Closure Plan, The Frost Company Brass Foundry Building, the
WDNR assigned the case a low priority designation and instructed the company to proceed with
site investigation and remedial closure actions without delay.
The WDNR approved the closure report submitted by the company's consultant on February 2,
1995. A closure inspection on October 19, 1994 by WDNR had verified that the company's
unlicensed hazardous waste facility had been closed in substantial conformance with the closure
plan.
V. ENVIRONMENTAL INVESTIGATIONS AND CLEANUPS
The closure of the brass foundry building and area was cleaned up through the use of a high
power vacuum truck equipped with high efficiency filtration. Chip samples from the interior walls
of the building and soil borings beneath the building floor were analyzed and results were included
in the closure report.

20

VL CONTACT INTERVIEWS
James Lanctote, a former Frost Company employee with over 20 years experience at the facility
was interviewed at the site on August 21, 1996. Mr. Lanctote's responsibility was primarily the
management of the automatic plating line. The automatic plating line was installed in the plant in
1957 replacing an older manual plating system. Mr. Lanctote confirmed the locations of the
plating, plating chemical storage rooms, buffing, press, machine and maintenance areas, pipe
bending, inspection, warehouse and wastewater pretreatment system area. Waste from plating
tank clean-out was sent out with used drums (1" depth in each drum) and wastewater streams
went through a pretreatment system prior to discharge to the sanitary sewer according to Mr.
Lanctote. Mr. Lanctote stated that the company discontinued the use cyanide in December of
1985.
VH. PBtYSICAL RECONNAISSANCE
Site visits were completed on July 24, and August 21, 1996. See Appendix B for photos taken
during the site reconnaissance.
Foundry
The foundry building is constructed of brick and contains several floor pits of various
sizes. The pits were partially filled with water. Two fill pipes and a vent pipe located on
die south side of the building next to the boiler room were observed. The building was
completely empty and no foundry sand or waste was observed.
Storage sheds - eastern side of property
There are three buildings located along the eastern side of the site. The souther-most shed
is constructed of wood and the next shed north is block and steel construction. Old
machinery and some drums containing sand and debris are located in the two southernmost buildings. The northern building is a block constructed garage used for foundry
material storage and contained a dismantled engine.
Main Building
The main building is constructed of brick with the exception of the newer steel
constructed warehouse addition on the south end of the main plant. The following
sections are all areas contained within the main building.
Offices and laboratory
The offices were damaged extensively by a fire deliberately set in May, 1996. Some office
furniture and file cabinets remain on the first floor and basement. Damage was contained
to the first floor only. Vandalism has been a problem, furniture and glass cubicle partitions
have been broken and papers strewn around the office and out into the pipe bending and
storage areas. The laboratory was empty.

21

Maintenance, machine shop, pipe bending, receiving
These areas of the building were empty except for some boxes of paper refuse in the
receiving area. Two floor drains in the machine shop area were full to floor level with an
oily substance.
Boiler room
The boiler room contained nine 30 gallon drums labelled "Benz Oil". Some or all of
these drums had been emptied out onto the floor of the room. One large rectangular tank
approximately 6'x2'x4l labelled "drain oil only" and several five gallon pails of waste oil
were also observed.
Press room
Two pits filled with a green, semi-solid waste were observed. The concrete pits probably
had presses mounted above them during the company's operation. Thirty-five drums,
most of them partially full, containing waste were located in the press room also. Some
drums were overturned and the surrounding floor areas were stained with green and white
residue.
Machining and press area
Barrel washer and degreaseing areas were located here and the pickling line was located
along the wall dividing this area from the press room. Fourteen 55-gallon drums were
located in this area and some were overturned staining the floor. Four five-gallon buckets
were also observed. Drums and buckets were partially full with some nearly full.
The pickling line was a major source of copper and zinc. The barrel washer was a
significant source of of oil and grease.
Deep Draw Press area
Two large presses were still present in the deep draw area. Sumps below the presses were
partially full of what appeared to be oil and grease. Drawing compounds were
recirculated from the sumps back to the machines. Beneath each sump is a drainage sump
winch collected leaked hydraulic oil, drawing compounds and hydraulic system cooling
water, and discharged to the sewer.
Stock Storage and packing
Several lugger boxes of metal containers or covers, probably products of the company, are
located in this area. Also located in this area was the manhole into which all process
wastewaters flowed into before discharging into the 18' diameter city sewer.
Electroplating area
The plating room floor was stained with green residue and some sludge. Much of the
floor where the plating and rinse tanks had been was covered with platic sheeting. One of
the sumps was partially full of liquid and the troughs contained some liquid and sludge.

22

Three five-gallon buckets partially full of liquid and sludge were located in the southeast
corner of the plating room.
The electroplating, electropolish, and stripping processes were significant sources of
copper, chromium, zinc, nickel, zinc and cyanide. Caustic solutions dumped from tanks
during operation of the electroplating area totaled 1,325 gallons per week with a
maximum of 4,075 gallons per week. Acid solutions dumped from tanks included
automatic plating tanks, electropolishing and stripping tanks totaling 500 gallons per week
with a maximum of 2,900 gallons per week.
The automatic electroplating line consisted of 32 tanks which contained various cleaners,
rinses and electrolytic baths.
Warehouse, loading dock, shipping and inspection areas
The loading dock and shipping/inspection areas were empty. The warehouse contained 16
full to partially full 5 5-gallon drums. The sump is all that remains of the wastewater
pretreatment system that was located in the southeast corner of the warehouse. Some
green sludge was observed in the sump.
Polishing area and polishing waste area
The polishing waste area is located outside the building but is surrounded by the building.
Some buffing waste was present as fine paniculate. There are two large transformers also
located in this area.

~ -

Electrical transformers
3 200 KVA east side of main plant (between boiler rrom and press room)
1 72 KVA on roof above plating area
1 750 KVA adjacent to polishing waste area
1 300 KVA adjacent to polishing waste area

Table 8 - Features Not Observed as of August 21,1996
lagoons, dumps, dry wells
burning pits
septic systems
settling ponds

grease traps
incinerators
open pipe discharges
landfarming areas

. FINDINGS AND RECOMMENDATIONS

23

A. Findings
The property history indicates that there is a high potential for contamination on the site. Waste
in drums, sumps, floor pits, floor drains and or. the floor in the main building may be hazardous.
Some of the wastes sampled by U.S. EPA had extremely low pH and are likely characteristic
hazardous wastes. Transformers and lighting ballasts on the site may contain PCB's. Roofing
materials and other building materials probably contain asbestos-containing materials.
Wastev/ater from the metal finishing processes conducted at the site were, in many cases, very
low pH wastestreams which may have corroded the metal pipes and connections under the floors
creating pathways for contamination to spread into the underlying soils and groundwater.
Corrosion of concrete sumps and floor pits may also have resulted in contamination of underlying
soils and groundwater.
B. Recommendations for Further Action
The waste located in the main building contained in drums and containers, on the floor, and in
sumps, pits and floor drains should be analyzed and removed. U.S. EPA has initiated an
emergency removal site assessment and samples of some wastes have been collected. A decision
will be made on EPA action at the site when the removal site assessment report is complete.
Areas with high potential for contamination include under-floor piping, sumps, floor pits and soils
underlying the waste handling infrastructure in the facility. Storm sewers in the close vicinity of
the facility may have received contaminated run-off and should be inspected also. Further
investigation of the history of the sanitary and storm sewer connections should be conducted in an
attempt to determine wastewater handling through the long period of the facility's operation.
The UST locations should be confirmed and tanks checked for contents. Soils around the facility,
particularly in the former coal storage, foundry sand storage, former metal plating and finishing,
UST, and sludge storage areas should be investigated further to determine the presence or
absence of contamination.
Roofing over the plant is in poor condition in many areas and was not thoroughly inspected.
Process vents venting to the roof may have contaminated roofing materials and asbestos
containing materials are very likely contained within many areas of the roof.
C. Recommendations for Phase II Sampling
Soils on the site should be sampled using direct-push sampling methods and hollow-stem augering
with split spoon sampling. Borings should be concentrated in the areas determined to be the most
likely contaminated locations but distributed over the site to reasonably assure the detection of
contaminated areas.
The use of field screening techniques such as X-ray fluorimeter, gas chromatography or
immunoassay, and flame-ionization detection should be utilized to limit the number of fixed-base
laboratory samples required. Analyses of fixed-base lab soil samples should include detection and

24

quantification of total metals, cyanide, PCB's, volatile organic compounds and semivolatile
organic compounds as appropriate based on field screening results. Samples from petroleum
contaminated (or suspected) areas should be analyzed for diesel range organics and/or gasoline
range organics as deemed appropriate.
Limited groundwater sampling should also be conducted. It is recommended that up to six
monitoring wells be installed on the property for stratigraphic mapping, water table mapping and
groundwater sample collection. Analyses of fixed-base lab groundwater samples should include
detection and quantification of total metals, cyanide, PCB's, volatile organic compounds and
semivolatile organic compounds. Samples from petroleum contaminated (or suspected) areas
should be analyzed for diesel range organics and/or gasoline range organics as deemed
appropriate.
IX. LIMITATIONS OF THIS PHASE 1 SITE ASSESSMENT
This report was prepared by the Department of Natural Resources (WDNR) in cooperation with
the City of Kenosha as part of a pilot project to assist municipalities wishing to market potentially
contaminated properties for redevelopment. This study is not intended to be a definitive study of
environmental conditions at the site. The information contained in this report is based on readily
available, practically reviewable information as defined in ASTM 1527-94, "Standard Practice for
Environmental Site Assessments: Phase 1 Environmental Site Assessment Process". Information
provided by others has been accepted as true and correct. The conclusions presented in this
report are professional opinions of Department of Natural Resources' staff which are based on the
information reviewed for this report.
Users of this report are cautioned that site conditions may change over time due to natural
processes or activity on the site or adjacent properties. Additional conditions may also exist at the
site that could not be identified based on the limited scope of this investigation.
If you have additional questions concerning this report you may contact the Department of
Natural Resources, Bureau for Remediation and Redevelopment, 101 South Webster Street, P.O.
Box 7921, Madison, Wisconsin 53707-7921. Information reviewed for this report is available as
a public record from die Department of Natural Resources.

APPENDIX A
SANBORN FIRE INSURANCE MAPS

APPENDIX B
PHOTO DOCUMENTATION FROM
SITE RECONNAISSANCE

APPENDIX C
ENVIRONMENTAL SITE ASSESSOR QUALIFICATIONS

ENVIRONMENTAL SITE ASSESSOR QUALIFICATIONS
Site Assessor
Tohn Burnett, Waste Management Specialist, Wisconsin Department of Natural

Education
Degree
B.S. Geography, 1990, University of Wisconsin - LaCrosse
Relevant Coursework
Geomorphology
Physics
Field methods
Maps and Landforms
Conservation of Natural Resources
Other Training
Phase I and Phase II Environmental Assessment Training
Sampling for Hazardous Materials - EPA
Introduction to Groundwater Investigations - EPA

Experience
•Wisconsin Department of Natural Resources - February 1992 to Present
Brownfields Environmental Assessment Pilot - January 1996 to Present
Superfund Site Evaluation - February 1992 to December 1995
Project Management - Prepare Preliminary Assessments, workplans,
conduct field investigations, report writing
4*1"

Resour
ces