Action Memorandum- Request for a Time-Critical Removal Action at Kenosha Trailer site, in Kenosha, Kensoha County, Wisconsin

Memo to Jodi Traub, in regards to asking approval for a proposed removal action of the Kenosha Trailer Site.

000000254304

1993-09-24 00:00:00.0

WI0000002436

Kenosha Trailer Site

PDF

Environmental Protection Agency

Stavros Emmanouil

Administrative Record

Emergency Response & Removal

text

Removal Action

Kenosha Trailer Site

Public Health

Polychlorinated biphenyl (PCB)

Environment

Environmental reporting

Midwest

Environmental Protection Agency

City of Kenosha

1993-09-24

Environmental Protection Agency

City of Kenosha

Copyright undetermined

eng

Kenosha, Wisconsin

PDF

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO, IL 60604-3590

EPA Region 5 Records Ctr.

REPLY TO THE ATTENTION

254304

HSE-5J

MEMORANDUM

SEP 2 4 Q93

DATE:

SUBJECTS

ACTION MEMORANDUM - Request for a Time-Cri
Action at Kenosha Trailer site, in Ke
County, Wisconsin.
/

FROM:

Stavros Emmanouil, On-Scene
Emergency and Enforcement Response Branch - Section II.

TO:

cal Removal
a,/^enosha

f
i Traub, Acting Associate Division
J/Office of Superfund.

THRU:

Richard Karl, Acting Chief
Emergency and Enforcement Response Branch.

Site ID/
PURPOSE
The purpose of this Action Memo is to request approval to expend a
total of $228,016 for the proposed removal action for the Kenosha
Trailer site in Kenosha, Kenosha County, Wisconsin. This action is
necessary to abate the immediate threat to public health and the
environment due to the presence of drums containing very high
concentrations (up to 50%) of polychlorinated biphenyl (PCS)
liquids in an abandoned trailer. The proposed action seeks to
abate a potential threat to human health and the environment by
removing about twenty-seven
(27) 55-gallon drums of PCB
contaminated liquid and disposing of the drums at an incinerator.
This is a time critical removal action since the abandoned trailer
is located about 75 feet from local residences.
The site is not on the National Priorities List (NPL) .

r * . Printed on Recycled Paper

II SITE CONDITIONS AND BACKGROUND
CERCLIS ID/: WI0000002436
A. Site Description
1.0 BACKGROUND:
United States Environmental Protection Agency (U.S. EPA) On-Scene
Coordinator (OSC) Stavros Emmanouil, and Technical Assistance Team
(TAT) members responded to a Wisconsin Department of Natural
Resources (WDNR) request for an assessment of an abandoned tractor
trailer; The assessment was conducted on August 12, 1993. The OSC
and TAT met with WDNR's Michael Ellenbecker, Paul Lazzari of the
Federal Bureau of Investigation (FBI), and James Swanson of the
Criminal Investigation Department (CID) of the U.S. EPA.
Mr. Michael Ellenbecker of WDNR stated that they had investigated
the Kenosha Trailer site on May 22, 1992, and that their contractor
had collected drum samples on June 29, 1992. Twenty-seven (27) 55gallon metal drums and one 5-gallon gas can were observed inside
the trailer. All but seven (7) of these drums were sampled at that
time. Some drums had labels indicating that their contents had as
much as 60% PCBs.
Mr. Travis Halcomb, in an affidavit (WDNR file information) stated
that in February 1989 he purchased property at 6621-6623 35th
Avenue, in Kenosha, Wisconsin.
He said that the property was
formerly owned by Nardi Electric Co. He initially purchased the
said property with Wesley Fechner, who subsequently died, at which
time he purchased his interest in the property. The property had
been under mortgage to First Bank Southeast of Kenosha and the bank
foreclosed when Nardi went out of business. Mr. Halcomb purchased
the property from the bank after the Bank had acquired it in a
foreclosure sale. Mr. Halcomb complained to Larry Christopherson,
the president of Nardi Electric, that he had left some 20 to 30
barrels and a lot of other equipment and materials on the property
and that he wanted Nardi to remove the barrels and equipment since
he now owned the property. On or about March 15, 1989, Mr. Halcomb
helped Mr. Christopherson remove the equipment, materials and
supplies that had been stored on the property at 6621-6623 35th
Avenue, Kenosha, Wisconsin. These equipment and barrels were put
into a white semi-trailer and shortly thereafter were moved to the
place where the semi-trailer is presently parked on the Arneson
Property.
2.

Physical location

The abandoned trailer is located in an open area at 3300 66th
Street, opposite Arneson Foundry, in Kenosha, Kenosha County,
Wisconsin (Figure 1 - site location map). This abandoned trailer
is located about 75 feet from a residence. A warehouse is located
about 125 feet from the trailer.

QUADRANGLE LOCATION

S

EPA REGION V

EMERGENCY AND ENFORCEMENT RESPONSE BRANCH
TITLE

SITE

SITE LOCATION MAP
KENOSHA TRAILER
STATE

KENOSHA

WISCONSIN

1
SCALE

PAN

EWI0419SAA

SOURCE

USGS TOPOGRAPHIC MAP

NONE

REVISED

RESIDENCES
CONCRETE SLAB
75-FEET

FRONT
WAREHOUSE

66th STREET

ARNESON FOUNDARY
OIL CO., INC

N

QUADRANGLE LOCATION

S

EPA REGION V

EMERGENCY AND ENFORCEMENT RESPONSE BRANCH
FKURE*

TITLE

SITE FEATURES MAP
SITE

SCALE

KENOSHA TRAILER

CITY

NONE

STATE

KENOSHA

WISCONSIN

EW10419SAA
DATE

SOUflCE

DRAWN BY: E & E. INC.

3.

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

Analytical results of the samples collected by WDNR from the drums
inside the trailer indicated the presence of PCBs as high as 55%
(550,000 parts per million [ppm]). PCBs are hazardous substances
as defined under section 101(14) of Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA). At least four
of the drum samples had flash points exceeding the regulatory
limits for the Resource Conservation and Recovery Act (RCRA), thus
classifying the drums as flammable liquids.
Any acts of vandalism or acts of nature (rain) poses a potential
threat of a spill from these drums containing high concentrations
of PCBs.
A substantial fire/explosion hazard exists at this trailer site.
Fumes containing high concentrations of PCBs could drift into the
nearby neighborhood. The closest residence is about 75 feet from
the trailer.
The Kenosha Trailer site has not been proposed for the National
Priority List (NPL) and has not received a hazard ranking system
(HRS) score.
B. Other Actions
The Federal Bureau of Investigation (FBI), and the Criminal
Investigation Department (CID) of the U.S. EPA are pursuing
appropriate actions against potentially responsible parties (PRPs) .
The Wisconsin Department of Natural Resources requested the
assistance of U.S. EPA in disposing of the drums found inside the
Kenosha site trailer.
C. State and Local Authorities' Roles
1. State and Local Actions to Date
See section
activities.

IIA

for details of

WDNRs

involvement with

site

2. Potential for continued State/Local Response
WDNRs Michael Ellenbecker indicated continuing assistance, however,
no monetary assistance is expected from WDNR at this time.
Ill THREATS
Conditions observed at the Kenosha Trailer site that may be
considered in determining the appropriateness of a removal action
as specified in paragraph (b) (2) of section 300.415 of the
National Contingency Plan (NCP) include:

(i) Actual or potential exposure to nearby human populations,
animals, or the food chain from hazardous substances or
pollutants or contaminants:
Polychlorinated biphenyl concentrations in one of the drum sample
was as high as 55% (550,000 ppm). At least four other drums had
PCB concentrations ranging from 44% to 52%.
The trailer is
situated in an open lot which could be easily accessed by
trespassers.
The trailer is in poor condition, and found to
contain several holes in its floor.
The nearest residence is
located about 75 feet from the site. The trailer is situated in a
mixed residential and commercial area.
A warehouse was also
situated about 100 feet from the trailer, and workers were seen
working in this open lot.
TAT observed one of these workers
parking a semi-trailer in this open lot. Residents and vandals may
be exposed to the hazardous materials in the event of a spill. PCBs
are known human carcinogens and are a precursor to cancer.
(ii) Hazardous substances or pollutants or contaminants in
drums, barrels, tanks, or other bulk storage containers, that
may pose a threat of release:
During the U.S. EPA site assessment, twenty-seven (27) 55-gallon
drums were observed inside the trailer. Several of these drums had
labels indicating that the drums contained PCBs. WDNR analytical
results of these drums confirmed the presence of PCBs. The trailer
is in an open plot where its access is unrestricted. The trailer
is in poor condition, and as such any acts of vandalism may cause
drums containing high concentrations of PCBs to release their
contents to the environment.
(iii) Weather conditions that may cause hazardous substances
or pollutants or contaminants to migrate or be released:
The trailer, which is in a poor condition, contains flammable
liquids and hazardous substances such as PCBS in drums. The floor
of the trailer was observed to contain several gaps. Continuous
exposure to weather conditions will result to further deterioration
to the trailer and potential release of the drum contents to the
environment.
(iv) Threat of fire or explosion:
At least five (5) drum samples had flash points ranging from less
than 50° F to 98° F. All these liquids are flammable by definition
under 40 CFR (Code of Federal Regulations) section 173.115, which
classifies a flammable liquid as one having a flash point below
100° F and a D001 waste. Temperatures above the flash points of
these liquids pose a high threat of fire or explosion at this site.
Some of the residences which are as close as 75 feet from the
trailer will be in great danger during a fire due to the combustion
of PCB liquids.

IV

ENDANGERMENT DETERMINATION

Given the Kenosha Trailer site conditions, the nature of the
hazardous substances on site, and the potential exposure pathways
to nearby populations described in Sections II and 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 and the
environment.
The material found on site have concentrations as high as 550,000
ppm, which is above the TSCA regulatory level of 50 ppm. Also
several drums have flash points of less than 100° F which is,
according to 40CFR 173.115, classified as a flammable liquid.
V

PROPOSED ACTIONS AND ESTIMATED COSTS

All applicable or relevant and appropriate requirements (ARARs) of
Federal law will be complied with to the extent practicable. A
letter will be sent to the Wisconsin Department of Natural
Resources requesting that it identify State ARARs. Any State ARARs
identified in a timely manner for this removal action will be
complied with to the extent practicable.
A. Proposed Actions
The following actions are proposed to alleviate the potential and
actual threats to human health and the environment posed by the
drums containing PCB contaminated liquids.
a) Remove and dispose of the PCB drums at an approved, permitted
disposal facility.
b) Decontaminate and dispose of the metal, other debris, and
trailer appropriately
Wastes transported off-site will be properly treated and disposed
by the disposal facility. The U.S. EPA off-site disposal policy
will be complied with. The response actions described in this
memorandum directly address actual or threatened releases of
hazardous substances, pollutants or contaminants at the site which
may pose an imminent and substantial endangerment to public health
and safety, and to the environment.
No post-removal site controls or actions are deemed necessary at
this location after the removal of the drums.
The response actions described in this memorandum directly address
actual or threatened releases of hazardous substances, pollutants
or contaminants at the facility 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

affected property disproportionate to the extent to which that
property contributes to the conditions being addressed.
2. Project Schedule
It is estimated that the removal will be completed in ten (10) 12hour work days, not counting for disposal delays. The removal
action is expected to be completed within a year.
Detailed
schedules will be developed prior to initiation of the removal
action.
B Estimated Costs
The detailed Emergency Response Cleanup Services (ERCS) contractor
costs are presented in Attachment I, with the estimated project
costs presented below:
REMOVAL PROJECT CEILING ESTIMATE

EXTRAMURAL COSTS
Cleanup contractor Costs
contingency (25%)
Sub total
Total TAT, including multiplier costs
Extramural subtotal
Extramural contingency
(25% of Extramural Subtotal,
rounded to nearest thousand)
TOTAL, EXTRAMURAL COSTS:

126,050.64
31.512.66
157,563.30
18,893.60
176,456.90

44.000.00
220,456.90

INTRAMURAL COSTS
U.S. EPA Direct Costs
[$30 X (120 Regional Hrs. + 12 HQ hrs)]

3,960.00

U.S. EPA Indirect Costs
[$53 x 120 Reg hrs]

3.600.00

TOTAL, INTRAMURAL COSTS:

7.560.00

TOTAL REMOVAL PROJECT CEILING

228,016.90

VI.

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

Due to the presence of high concentrations of PCBs in the drums, a
delayed action poses a continuing threat of a release to the
environment endangering the nearby residents and workers.
VII. OUTSTANDING POLICY ISSUES
None.
VIII. ENFORCEMENT
For administrative purposes, information concerning the enforcement
strategy for this site is contained in an Enforcement Confidential
addendum (Attachment III) .
IX

RECOMMENDATION

This decision document represents the selected removal action for
the Kenosha Trailer site in Kenosha, Kenosha County, Wisconsin,
developed in accordance with CERCLA as amended by Super fund
Amendments and Reauthorization Act (SARA) , and, not inconsistent
with the National Contingency Plan. This decision is based on the
administrative record for the site (See Attachment II) . Conditions
at the Kenosha Trailer site meet the National Contingency Plan, 40
CFR, Section 300.415 (b) (2) criteria for a removal and I recommend
your approval of the proposed removal action. The total project
ceiling if approved, will be $ 228,016.90. Of this, an estimated
$ 201,563.30 may be used for cleanup contractor costs.
Please
indicate your decision by signing below.
APPROVE:

^^-./^^ } 4 / Y J /
_
Division Dj^pactor, OSF

DISAPPROVE: _
Acting Associate Division Director, OSF

Attachments:

I.
II.
III.

DATE;

DATE:.

Detailed Cleanup Contractor Costs
Administrative Record Index
Enforcement Confidential Information

ATTACHMENT Z
DETAILED CLEAN-UP CONTRACTOR COSTS
CONTRACTOR PERSONNEL

$ 29,990.00

CONTRACTOR EQUIPMENT

$ 21,471.50

UNIT RATE MATERIAL

$

336.00

SUBCONTRACTORS

$

9,158.63

WASTE DISPOSAL AND TRANSPORTATION

$ 57.645.75

CLEAN-UP CONTRACTOR TOTAL

$126,050.64

ATTACHMENT II
U.S. ENVIRONMENTAL PROTECTION AGENCY
REMOVAL ACTION
ADMINISTRATIVE RECORD
FOR
KENOSHA TRAILER SITE
KENOSHA, WISCONSIN
September 22, 1993
DATE

AUIHQJE

RECIPIENT

TITLE/DESCRIPTION

00/00/93

Ecology &
Environment

U.S. EPA

Site Assessment
(Pending)

00/00/00

Emmanouil,
S. , U.S. EPA

Traub, J.,
U.S. EPA

Action Memorandum
(Pending)

EASES

ATTACHMENT III
ENFORCEMENT CONFIDENTIAL ADDENDUM
Redacted-information not relevant to the selection of the removal
action.