cce.1) STo # UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 5 77 WEST JACKSON BOULEVARD

CHICAGO, IL 60604-3590 US EPA RECORDS CENTER REG ON 5

11D1 11111111111111111111101 Ifi 495095

MEMORANDUM REPLY TO THE ATTENTION OF

SUBJECT: ACTION MEMORANDUM: Request for Approval of an Emergency Removal Action at the Rowland Avenue Mercury Spill Site, Wayne County, Michigan (Site ID #C5EB)

FROM: Jon J. Gulch, On-Scene Coordinator Emergency Response Branch 1 — Response Section 2

THRU: Matthew Mankowski, Chief Emergency Response Branch 1 — Response Section 2

TO: Jason H. El-Zein, Chief Emergency Response Branch 1

I. PURPOSE

This memorandum is to request and document your approval for expending up to $77,000 to abate an imminent and substantial threat to public health, welfare, and the environment posed by the Rowland Avenue Mercury Spill Site (site) in Mansfield, Richland County, Ohio. On November 1, 2016, the U. S. Environmental Protection Agency (EPA) Chief of Emergency Response Branch 2, granted verbal authorization to spend up to $25,000 to begin emergency removal actions at the site. On November 3, 2016, the Chief of Emergency Response Branch 2 authorized an increase of an additional $50,000 to continue cleanup operations at the site, bringing the total amount funded for Emergency and Rapid Response Services (ERRS) to $75,000. EPA's response action was necessary to mitigate the immediate threat to public health, welfare, and the environment posed by the release of mercury, a hazardous substance, from a residential property. There are no nationally significant or precedent-setting issues associated with the response at this non-National Priority List (NPL) site.

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

EPA's initial emergency response actions consisted of assessing, securing, containing, removing

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 50% Recycled Paper (20% Postconsumer)

and properly disposing of mercury and mercury contaminated debris and impacted structures from the source area (a house) (Figure A-1). Ongoing EPA actions included rescreening affected areas; sampling; and verifying the effectiveness of cleanup efforts. The On-Scene Coordinator (OSC) initiated the response based on a hazardous substance released. The mercury cleanup required 10 days to complete.

The site is not on the NPL. There are no nationally significant or precedent setting issues associated with the site.

II. SITE CONDITIONS AND BACKGROUND

CERCLIS ID: 0HN000506655 RCRA ID: N/A State ID: N/A Category: Emergency Response Source Area: Residential Property on Rowland Avenue, Mansfield, Richland County, Ohio 44903

A. Site Description

The site is a single family residence in Mansfield, Richland County, Ohio, where mercury was discovered in a floor drain of the basement by the current resident. The current residents moved into the property in July 2016 and did not discover the mercury until Monday, November 1, 2016. Subsequent investigation led to the discovery of mercury on the basement floor, in a second floor drain, and on a workbench. The mercury vapor readings in the dwelling all exceed 50,000 ng/m3 mercury in the breathing zone in the basement and up the basement stairs.

The Mansfield Fire Department (MFD) responded to a phone call from the owner of the property after the mercury was discovered. Upon investigation, MFD recognized the substance as mercury and immediately sealed the floor drain and contacted the Richland County Health Department (RCHD) and Ohio Environmental Protection Agency (OEPA). OEPA1 refened the site to EPA for assessment and a potential emergency response removal action.

1. Removal site evaluation On November 1, 2016, EPA mobilized with the Superfund Technical Assessment and Response Team (START) contractor to respond to a reported release of mercury at a residential location in Mansfield, Richland County, OH2. The emergency response activities were conducted at the residence where the owner discovered mercury in a floor drain in the basement of the house. EPA gained entry via a verbal

1 NRC Report #1163045, Administrative Record #1 2 Pollution Report #1, Administrative Record #2

2

access agreement with the owner to conduct screening to support safe entry and investigation. These activities included:

Recording site conditions and emergency response activities through photographic documentation and in a site logbook.

• Screening and recording the ambient mercury levels in the basement and first floor living areas of the subject property with a Lumex mercury detector, model RA-915M.

After dressing out in personal protective equipment (e.g., TyvecO, latex booties, nitrile gloves, and air-purifying respirators with mercury absorbent cartridges), the EPA On-Scene Coordinator (OSC) and START contractor screened the basement of the property and the breathing and floor zones of the interior of the house.

The mercury levels in the breathing and floor zones inside the house were all greater than 50,000 ng/m3. Upon discovery of elemental mercury on the floor and in a floor drain in the basement, all windows in the basement were opened and a fan was placed in the exterior doorway to remove mercury vapors. In addition, the OSC mobilized the EPA Emergency and Rapid Removal Service (ERRS) contractor to begin the removal of elemental mercury from the basement.

2. Physical location

The site is located at a residential property on Rowland Avenue, Mansfield, Richland County, Ohio 44903. The location coordinates for the site are Latitude: and Longitude: . The site is located in an urban area.

An Environmental Justice (EJ) analysis for the Site is contained in Attachment 1. 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

, Mansfield, Richland County, Ohio, and determined there is a high potential for EJ concerns at this location.

3. Site Characteristics

The site includes a single family residential home in a residential area.

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

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Mercury vapors were released from the site from an unknown source. Mercury exhibits the characteristic of toxicity (D009), and is therefore characteristically hazardous waste under the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. § 6901 et seq., as amended, and 40 C,F.R. § 261.24. Mercury is also a hazardous substance under Section 101 (14) of CERCLA, 42 U.S.C. § 9601(14). The elemental mercury and mercury vapor was a direct contact and inhalation threat as it was present within the basement, and migrated, was moved or tracked throughout the house. There was a high potential for the mercury to be tracked from the site due to a high level of foot traffic in the basement.

5. NPL Status

The site is not on the NPL and is not expected to be evaluated for the NPL.

6. Maps, pictures, and other graphic representations

A figure detailing the location of the site is included in the attached Site Location Map.

B. Other Actions to Date

1. Previous Actions Not Applicable.

2. Current Actions EPA stabilized the site by removing all elemental mercury and mercury vapors in the breathing zone from the residential property3' 4.

C. State and Local Authorities' Roles 1. State and local actions to date On November 1, 2016, MFD performed an entry into the residential property to investigate the discovery of the owner. After determining that the spilled material was mercury, MFD used visqueen to seal the floor drain and basement floor immediately surrounding the floor drain.

RCHD set-up laboratory screening for the four (4) occupants of the residential property, including two (2) children under the age of 13.

3 Pollution Report #2, Administrative Record #3 4 Pollution Report #3, Administrative Record #4

2. Potential for continued State/local response Given the exigency of the situation, neither the state nor local governments had the resources to conduct a removal action.

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

Nature of Actual or Threatened Release of Hazardous Substances, Pollutants or Contaminants.

The presence of a toxic substance that readily release hazardous vapors inside residences, vehicles and in outdoor areas presented an immediate threat to human health and the environment. As noted above, mercury is a characteristically hazardous waste under RCRA and its implementing regulations, and is also a hazardous substance listed under Section 101 (14) of CERCLA, 42 U.S.C. § 9601(14).

The health effects of mercury are detailed by the ATSDR as follows:

The nervous system is very sensitive to all forms of mercury. Exposure to high levels of metallic, inorganic, or organic mercury can cause death, or peunanently damage the brain, kidneys, and developing fetus. Effects on brain functioning may result in irritability, shyness, tremors, changes in vision or hearing, and memory problems. Short-term exposure to high levels of metallic mercury vapors may cause effects including lung damage, nausea, vomiting, diarrhea, increases in blood pressure or heart rate, skin rashes, and eye irritation'.

A. Factors which were considered in determining the appropriateness of a removal action:

The conditions at the site presented a release or a threatened release of a CERCLA hazardous substance, and met the criteria for an emergency response provided for in the National Contingency Plan (NCP), 40 CFR § 300.415 (b) (2). These criteria included the following:

Actual or potential exposure to nearby human populations, animals or the food chain from hazardous substances or pollutants or contaminants [300.415(b)(2)(i)].

5 ATSDR Mercury ToxFAQ — Administrative Record Item #3

5

EPA documented freestanding mercury beads, and mercury vapor levels in excess of 50,000 ng/m3 in ambient air. This value is greater than the recommended action level for residential property as described in the Chemical-Specific Health Consultation for Joint EPA/Agency for Toxic Substances and Disease Registry (ATSDR) National Mercury.

The presence of elemental mercury and mercury vapors in general, presented an imminent and substantial threat to human health and the environment.

The availability of other appropriate federal or state response mechanisms to respond to the release [300.415(b)(2)(vii)].

OEPA requested U.S. EPA, Region 5, Emergency Response Branch assistance to help evaluate and mitigate a possible threat posed by the Rowland Avenue Mercury Spill site. Neither RCHD nor any other government agency in this area has adequate finances or resources to respond to an emergency or time-critical removal action of this magnitude.

IV. ENDANGERMENT DETERMINATION

Given the site conditions, the nature of the hazardous substance on-site, and the potential exposure pathways 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 have presented an imminent and substantial endangerment to public health, welfare, or the environment.

V. ACTIONS & ESTIMATED COSTS

A. Actions

1. Action description

The response actions described in this memorandum directly addressed actual or potential releases of hazardous substances on-site, which may have posed an imminent and substantial endangerment to public health, or welfare, or the environment. Specific removal activities included:

1) Developing and implementing a site Health and Safety Plan; 2) Removing elemental mercury from the basement and floor drains; 3) Conducting air monitoring throughout the house; and 4) Characterizing, removing, and properly disposing of waste containers in

accordance with EPA's Off-Site Rule (40 CFR § 300.440).

6

EPA's response action was conducted in accordance with Section 104(a)(1) of CERCLA, 42 U.S.C. § 9604(a)(1) and Section 300.415 of the NCP, 40 C.F.R. § 300.415, to abate or eliminate the immediate threat posed to public health and/or the environment by the presence of the hazardous substances. No uncontrolled hazardous substances are expected to remain at the site after the removal action is completed.

EPA's removal action was conducted in a manner not inconsistent with the NCP. The OSC initiated planning provisions for post-removal site control consistent with the provisions of Section 300.415(1) of the NCP. Removal of hazardous material is expected to eliminate the need for post-removal site control.

The threats posed by uncontrolled substances considered hazardous met the criteria listed in the NCP at 40 C.F.R. § 300.415(b)(2), and the response actions proposed herein were consistent with any long-term remedial actions which may be required.

All hazardous substances, pollutants or contaminants removed by EPA off-site pursuant to this removal action for treatment, storage and disposal were/will be treated, stored or disposed of at a facility in compliance, as detelmined by EPA, with the EPA Off-Site Rule, 40 C.F.R. § 300.440.

EPA's response actions described in this memorandum directly addressed the actual or threatened releases of hazardous substances, pollutants or contaminants at the site which posed an imminent and substantial endangerment to public health or welfare or to the environment. EPA's response actions did not impose a burden on affected property disproportionate to the extent to which that property contributed to the conditions being addressed.

2. Contribution to remedial performance

Not Applicable.

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

Not Applicable.

4. Applicable or relevant and appropriate requirements (ARARs)

All known applicable, relevant and appropriate requirements (ARARs) were complied with to the extent practicable.

7

5. Project Schedule

These activities required 10 on-site working days to complete.

B. Estimated Costs

The following cost estimates include costs associated with the emergency response action for purposes of creating a total project ceiling. The costs do not include any past or future investigation costs on the site.

Regional Removal Allowance Costs Cleanup Contractor Costs $ 50,000

Other Extramural Cost Not Funded from the Regional Allowance: START $ 20,000

Subtotal, Extramural Subtotal $ 70,000

TOTAL, Removal Action Project Ceiling $ 70,000

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 at the site, and the potential exposure pathways to nearby populations described in Sections II, III and IV above, resulting in an actual or threatened release of hazardous substances and pollutants or contaminants from the site, failing to take or delaying action may have presented an imminent and substantial endangerment to public health, welfare or the environment, increasing the potential that hazardous substances would have been released, thereby threatening the adjacent population and the environment.

VII. OUTSTANDING POLICY ISSUES

None.

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VIII. ENFORCEMENT

The total EPA costs for this removal action based on full-cost accounting practices that will be eligible for cost recover are estimated to be $129,568.6

($70,000 + $10,000) = $80,000 + (61.96% x $80,000) = $129,568

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

M RECOMMENDATION

This decision document represents the selected remedy for the Rowland Avenue Mercury Site, Mansfield, Richland County, Ohio, developed in accordance with CERCLA as amended, and is not inconsistent with the NCP. This decision is based on the administrative record for the site (Attachment 1).

Conditions at the site met the NCP section 300.415(b)(2) criteria for an emergency response action, and I recommend your approval of the action documented in this Action Memorandum.

The total project ceiling, if approved, will be $70,000. Of this, an estimated $50,000 may be used for cleanup contractor costs. You may indicate your decision by signing below.

APPROVE: 77- J Emergency Response Branch 1 Chief

DATE: 2-2 Z- ID1

DISAPPROVE: DATE: Emergency Response Branch 1 Chief

Enforcement Addendum

Figures: 1. A-1 — Source Area Location Map

6Direct Costs include direct extramural costs and direct intramural costs. Indirect costs are calculated based on an estimated indirect

cost rate expressed as a percentage of site-specific direct costs, consistent with the full cost accounting methodology effective October 2, 2000. These estimates do not include pre-judgment interest, do not take into account other enforcement costs, including Department of Justice costs, and may be adjusted during the course of a removal action. The estimates are for illustrative purposes only and their use is not intended to create any rights for responsible parties. Neither the lack of a total cost estimate nor deviation of actual total costs from this estimate will affect the United States' right to cost recovery.

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Attachments: 1. Administrative Record Index 2. Detailed Cleanup Contractor Cost Estimate 3. Independent Government Cost Estimate 4. Environmental Justice Analysis

cc: Brian Schlieger, U.S. EPA, 5104A schlieger.brian@epa.gov

Lindy Nelson, U.S. Department of the Interior, w/o Enf. Addendum Lindy_Nelson@ios.doi.gov

Scott Nally, Director, OEPA, w/o Enf. Addendum Scott.Nally@epa.state.oh.us

Mike DeWine, Ohio Attorney General, w/o Enf. Addendum Mike.DeWine@ohioattorneygeneral.gov

BCC PAGE HAS BEEN REDACTED

NOT RELEVANT TO SELECTION

OF REMOVAL ACTION

ENFORCEMENT ADDENDUM

HAS BEEN REDACTED – TWO PAGES

ENFORCEMENT CONFIDENTIAL

NOT SUBJECT TO DISCOVERY

FOIA EXEMPT

NOT RELEVANT TO SELECTION

OF REMOVAL ACTION

ATTACHMENT 1

ADMINISTRATIVE RECORD

U.S. ENVIRONMENTAL PROTECTION AGENCY REMOVAL ACTION

ROL WAND AVENUE MERCURY SITE RICHLAND COUNTY, OHIO

FEBRUARY 2017

NO. SEMS ID DATE AUTHOR RECIPIENT PAGES TITLE/DESCRIPTION

1 XXX 11/1/16 National File ToxFAQs Fact Sheet - 3 Response Mercury - CAS #7439-97-6 Center

2 XXXX 11/3/16 Gulch, J., U.S. Distribution Pollution Report (POLREP) 3 EPA List #1 - Initial

3 XXXX 11/7/16 Gulch, J., U.S. Distribution Pollution Report (POLREP) 3 EPA List #2 -Progress

4 XXXX 12/12/16 Gulch, J., U.S. Distribution Pollution Report (POLREP) 4 EPA List #3 -Final

5 XXXX 11/1/16 National U.S. EPA- National Response Center 3 Response Region 5 Report # 1163045 Center

XXXX 2/24/17 Newton, D., TetraTech

Gulch, J., U.S. EPA

Final Letter Report-Rowland Avenue Residential Mercury

40

Spill Emergency Response

7 Gulch, J., U.S. EPA

Bellotti, D., U.S. EPA

Action Memorandum re: Request for Approval of an

19

Emergency Removal Action at the Rowland Avenue Mercury Spill Site (PENDING)

ATTACHMENT 2

DETAILED CLEANUP CONTRACTOR ESTIMATE

HAS BEEN REDACTED – ONE PAGE

NOT RELEVANT TO SELECTION

OF REMOVAL ACTION

ATTACHMENT 3

INDEPENDENT GOVERNMENT COST ESTIMATE

HAS BEEN REDACTED – TWO PAGES

NOT RELEVANT TO SELECTION

OF REMOVAL ACTION

ATTACHMENT 4 U.S. ENVIRONMENTAL PROTECTION AGENCY

REMOVAL ACTION

ENVIRONMENTAL JUSTICE ANALYSIS FOR

ROWLAND AVENUE MERCURY SITE MANSFIELD, RICHLAND COUNTY, OHIO

FEBRUARY 2017

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EJ Index for Ozone 87 84 73

El Index for NATA. Diesel PM 90 87 80

EJ Index for NATA. Air Toxics Cancer Risk 88 85 72

El Index for NATA. Respiratory Hazard Index 87 85 74

0 Index for Traffic Proximity and Volume 90 86 76

El Index for Lead Paint Indicator 91 as 87

0 Index for Superfund Proximity 80 75 65 0 Index for RMP Proximity 85 81 73

El Index for Hazardous Waste Proximity' N/A N/A N/A 0 Index for Water Discharger Proximity 95 94 Etg

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data are available, and the methods used, vary across these indicators. Important caveats and uncertainties apply to this sceeniiv-level information, so it is

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Particulate Matter (Pm zs in isg/m1 10.8 11.3 16 10.6 53 9.32 82

Ozone (ppb) 52 528 38 50.3 74 47.4 75

NATA. Diesel PM (pg/m3) 1.53 0.995 85 0.931 80-90th 0.937 80-90th

NATA. Cancer Risk (lifetime risk per million) 42 37 74 34 80-90th 40 50-60th

NATA Respiratory Hazard Index 2.2 1.8 74 1.7 80-90th 1.8 70-80th

Traffic Proximity and Volume (day naffic count/distance to road) 94 170 65 370 54 590 50

Lead Paint Indicator Os Pre-1960 Housing) 0.72 0.42 80 0.39 81 0.3 88

Superfund Proximity (site courit/km distance) 0 0.091 16 0.12 9 0.13 16

invIP Proximity (facility count/km distance) 0.22 0.4.4 55 0.51 50 0.43 58

Hazardous Waste Proximity+ (radray courit/km distance) N/A 0.1 N/A 0.11 N/A 0.11 N/A

Water Discharger Proximity (facirity ccaint/km distance) 0.56 0.33 83 0.31 84 031 86

Demographic Indicators Demographic Index 49% 27% 85 29% 83 36% 72

Minority Population 36% 19% 82 24% 77 37% 58

Low Income Population 61% 34% 86 33% 88 35% 86

Unguistically Isolated Population 0% 1% 68 2% 59 5% 45

Population With Less Than High School Education 18% 11% 80 11% 81 14% 71

Population Under 5 years of age 8% 6% 74 6% 74 6% 71

Population over 64 years of age 13% 15% 45 14% 49 14% 53

• The National-SGee Air Toxics Assessment (NATA) is EPA's ongoing, comprehensive evaluation of air taxi.= in the United States. EPA developed the NATA to

prioritize air toxics, emission sources, and locations of interest for further study. It is important to remember that NATA provides broad estimates of heath risks

over geographic areas of the country, not definitive risks to specific indhriduals or locations. More information on the NATA analysis can be found

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uncertainty in their demographic and environmental data, particularly when looking at srna'l geographic areas. Important caveats and uncertainties apply to this

screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see

EISCREEN documentation for discussion of these issues before using reports. This screening tool does not provide data on every environmental impact and

demographic factor that may be relevant to a particular location. EJSCREEN outputs should be supplemented with additional information and local knowledge

before taking any action to address potential El concerns.

February 09, 2017 3/3