epa - final closeout memorandum for …donald sims (ref. 8). on april 28, 1999, u.s. epa sent...

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION 5

77 WEST JACKSON BOULEVARD CHICAGO, IL 60604-3590

EPA Region 5 Records Ctr.ij! Ill

266292

REPLY TO THE ATTENTION OF

Date:

Subject:

MAR 28 2006ENFORCEMENT CONFIDENTIAL

Final Close-Out Memorandum for Removal Action Baker Wood Creosoting Site, Marion, Marion County, Ohio

From:

To:

Spill No.: B591

Mark DumoOn Scene CoordinatorFile

Statute of Limitations Date: July 17, 2006

Mark PalermoOffice of Regional Counsel

*Mila V. Bensing //AiO

Enforcement Specialist

PART 1. DESCRIPTION OF SITE AND REMOVAL ACTIONS

The Baker Wood Creosoting Site (the Site) is a former wood treatment facility and scrap metal yard located at 1022 Holland Road, Marion, Marion County, Ohio. The Site is bordered by industrial property to the south, residential and commercial property to,the east and north, and agricultural property to the west. Approximately one-half mile west of the Site, North Rockswale Ditch crosses beneath Holland Road and then runs parallel to the road until it meets the Little Scioto River, which is approximately one mile west of the Site (Reference [Ref.] 1). /

The Site property is currently owned by Bakerwood Limited Partnership (BLP). On November 21, 1935, Baker Wood Preserving Co. (Baker Wood) obtained title to the Site property from The Fahey Banking Co. On September 6, 1956, Baker Wood merged into D.B. Frampton & Co., which was owned by D.B. Frampton. D.B. Frampton & Co. sold the Site property to Donald and Lillian Sims in September 1977. On May 27, 1994, Lillian Sims transferred her ownership interest in the property to Donald Sims. Donald Sims, who is the sole partner of Bakerwood Limited Partnership, conveyed the Site property to Bakerwood Limited Partnership on June 10, 1994 (Ref. 2).

Baker Wood operated a facility to treat railroad ties and other wood products using a creosoting process at the Site from 1935 until 1961, when the company went out of business. Historical information indicates that Baker Wood discharged waste creosote materials directly into the City of Marion storm sewer, which

ENFORCEMENT CONFIDENTIAL

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

provided a pathway to the Little Scioto River. The Site was subsequently operated by Sims Brothers, Inc. as a scrap metal facility from the 1970s to the 1990s, at which time operations at the Site ceased. The Site property is currently vacant (Ref. 3, Ref. 4, Ref. 5).

On June 12, 1998, the Ohio Environmental Protection Agency (OEPA) requested the assistance of the United States Environmental Protection Agency (U.S. EPA) in conducting a time-critical removal action of creosote-contaminated waste located at the Site (Ref. 5).

U.S. EPA removal activities at the Site began on April 26, 1999, and were completed on July 17, 2003. During that time, U.S. EPA and its Superfund Technical Assessment and Response Team (START) contractor conducted soil sampling activities, which indicated the presence of elevated levels of volatile organic compounds (VOCs) and polycyclic aromatic hydrocarbons (PAHs). Approximately 3,500 tons of creosote-contaminated soil were excavated and transported off-site for disposal. The excavated areas were backfilled with clean soil, graded, and reseeded. Several creosote-contaminated drainage tiles and sewer tie-

is were removed to prevent further migration of contaminants to the sewer. START collected sediment samples of the Little Scioto River and North Rockswale Ditch to determine the extent of contamination. Approximately four miles of the river and 0.6 miles of the North Rockswale Ditch were determined to be contaminated with creosote. U.S. EPA and START conducted removal activities at the secondary contamination area between June 21, 1999, and July 13, 1999. Contaminated soil was excavated and transported off-site for disposal and excavated areas were backfilled with clean soil. A treatment pad for landfarming of additional contaminated material identified at the Site was established on the western portion of the Site. Contaminated material was spread onto the treatment pad in seven landfarming windrows. Heavy equipment was used to mix the contaminated material. Samples were collected from the windrows to mionitor the degradation of contaminants; however, it was determined that no significant degradation of PAHs had occurred. Approximately 4,000 tons of material were then collected and shipped to an off-site facility for disposal (Ref. 6).

.'ART 2. COSTS RECURRED TO DATE

The U.S. EPA Superfund Accounting & Analysis Section reported the cumulative costs incurred by U.S. EPA during the removal action at this Site through November 30, 2005, in an Itemized Cost Summary Report prepared on December 12, 2005 (Ref. 7). These costs are itemized as follows:

1. Total EPA Costs Before Interest

2. Total Cost Recovered

3. Total Unrecovered EPA Costs

$2,078,380.80

$0.00

$2,078,380.80


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PART 3. ENFORCEMENT ACTIONS AND POTENTIALLY RESPONSIBLE PARTYINFORMATION

ENFORCEMENT ACTIONS

On January 5, 1999, U.S. EPA sent Request for Information letters to BLP, Donald Sims, Lillian Sims, and D.B. Frampton.

No response was received from D.B. Frampton.

On February 8, 1999, counsel for BLP, Donald Sims, and Lillian Sims sent a response to U.S. EPA. According to the response, Lillian Sims is deceased. The response also states that the Site contamination was likely caused by the operations of Baker Wood and D.B. Frampton prior to the purchase of the Site by Donald Sims (Ref. 8).

On April 28, 1999, U.S. EPA sent General Notice of Potential Liability letters to BLP, Donald Sims, and D.B. Frampton. The letter to D.B. Frampton was returned to U.S. EPA undelivered.

On May 10, 1999, counsel for BLP and Donald Sims responded to the General Notice letters. According to the response, neither BLP nor Mr. Sims contributed to contamination at the Site and, therefore, deny responsibility or liability for the Site’s contamination. In addition, neither BLP nor Mr. Sims have the financial wherewithal to finance removal activities at the Site (Ref. 9).

U.S. EPA determined that, based on limited financial information obtained from the responses to the information requests sent to BLP and Donald Sims, BLP and Mr. Sims are not viable PRPs. BLP generates no income and holds assets of only limited value. With regard to Mr. Sims, his reported income and assets "how only a limited ability to pay the total response costs on either a cash flow or debt capacity basis.- urther, Mr. Sims is a retired senior citizen. Mr. Sims is also not directly liable for the response costs on either an owner/operator or generator liability theory, as he owned the Site only after the creosote disposal occurred, he is a limited rather than a general partner of BLP, and his business operations on the site have no relation to the contamination found on-site. Thus, U.S. EPA has determined that it would not likely prevail in a cost recovery action either against Mr. Sims directly or against BLP on the theory that Mr. Sims could be considered a sufficient outside source of funds to allow BLP to afford to pay response costs.

In December 2003, U.S. EPA’s civil investigator interviewed a representative of D.B. Frampton Company. As a result of that interview, the civil investigator determined that D.B. Frampton Company was inactive and had only limited assets, and thus was not financially viable (Ref. 10).

Based on the response to the General Notice letter. Information Requests, and additional investigation performed by the U.S. EPA Civil Investigator, U.S. EPA determined that there are no Potentially Responsible Parties (PRPs) for the Site that are financially viable (Ref. 1).


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POTENTIALLY RESPONSIBLE PARTY INFORMATION

The list of PRPs is:

PRP NAME PRP ROLE REASON TO NOT PURSUE

Bakerwood Limited Partnership

Site Owner PRP is not financially viable

Donald Sims Previous Site Owner PRP is not financially viable

Lillian Sims Previous Site Owner PRP is deceased

D.B. Frampton Previous Site Operator PRP is not financially viable

.'ART 4. RECOMMENDATION AND REQUEST FOR APPROVAL

We recommend that this Site be closed out without further attempt to collect costs because it appears that there are no financially viable PRPs.


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Approval:Richftrd Karl, DirectorSuperfund Division

jeitfam Frey, Acting Regional Office of Regional Counsel

Dat6 /

unsel Date

Disapproval:Richard Karl, Director Superfund Division

Date

Bertram Frey, Acting Regional Counsel Date Office of Regional Counsel


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REFERENCE DOCUMENTS BAKER WOOD CREOSOTING SITE

Reference 1 - Action Memorandum - Request for a Time-Critical Removal Action at the Baker Wood Creosoting Site, Marion, Marion County, Ohio; 04/20/1999

Reference 2 - Multi-Site Potentially Responsible Party Search Title Search Report, Baker Wood Creosoting Site, Marion, Ohio; 01/29/1999

V

Reference 3 - Final Community Involvement Plan for the Baker Wood Creosoting Site, Marion, Ohio; 10/05/1999

Reference 4 ^ Letter Report for the Baker Wood Creosoting Site, Marion, Marion County, Ohio;11/15/1999

Reference 5 - Letter to U.S. EPA from Ohio EPA Re: Baker Wood Creosoting, Marion; 06/12/1998

Reference 6 - Draft On-Scene Coordinator’s Report, Baker Wood Creosoting Site, Marion, Marion County, ■ Ohio; 08/16/2004

Reference 7 - Itemized Cost Summary; Baker Wood Creosoteing (sic); Costs Through 11/30/2005; Report Date 12/12/2005

Reference 8 - Letter to U.S. EPA from Squire, Sanders & Dempsey L.L.P. Re: Responses to U.S. EPA Information Requests Pursuant to Section 104 of CERCLA Relating to Baker Wood Creosoting Site, Marion, Ohio; 02/08/1999

Reference 9 - Letter to U.S. EPA from Squire, Sanders & Dempsey L.L.P. Re: Responses to U.S. EPA General Notices of Potential CERCLA Liability to Bakerwood L.P. and Donald Sims Relating to Baker Wood Creosoting Site, Marion, Ohio; 05/10/1999

Reference 10 -Email from Joseph Kawecki, U.S. EPA, to Mark Palermo, U.S. EPA; Subject: baker wood; 12/02/2003


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Reference 1

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGIONS

77 WEST JACKSON BOULEVARD CHICAGO, IL 60604-3590

APR 2 0 1993

REPL/ rO TR-; AnEiNT7IOf- C‘-

MEMORANDUM

SUBJECT; ACTION MEMORANDUM - Request for a Time-Critical Removal Action at the Baker Wood Creosotlng Site, Marion, Marion County, Ohio (Site 1D#B591)

FROM:

TO:

THRU:

Mark A. Dumo, On-Scene Coordinator Emergency Response Branch - Section 1

Vi/iliiam E. Muno, Director Superfund Division

Wendy L. Carney, Acting Chief Emergency Response Branch tA A-

I. PURPOSE

The purpose of this memorandum is to request and document your approval to expend up to $1,972,740 to abate an imminent and substantia! threat to public health and welfare and to the environment at the Baker Wood Creosoting Site located in Marion, Marion County, Ohio. High concentrations of volatile organic compounds (VOCs) and polynuclear aromatic hydrocarbon (PAH) compounds are contained in surficiai and buried wood treating wastes which have also been deposited into the nea.''by Little Scioto River, a local watenway and tributary to the Scioto, Olentangy, and Ohio Rivers, all major waterways. The contaminants include, but are not limited to, high levels of benzene, ethyl benzene, toluene, styrene, xylene, and numerous PAHs. Elevated levels of pesticides and metals are also present in the waste. These contaminants present a direct contact threat to human populations accessing the area. A 1998 Ohio Environmental Protection Agency ( OEPA) report of this portion of the river demonstrated chronic toxicity to fish and other aquatic life in the Little Scioto River,

This time-critical removal action will include excavation and off-site disposal of creosote-related waste and heavily contaminated soils that may be contributing to offsite migration to the Little Scioto River and that pose a direct contact threat. Other onsite removal activities will include invasive test trenching to identify and characterize other potential ccntamination areas. While on-site, the Little Scioto River will be characterized to determine the extent of sediment contamination as a resulLpf j3islQric_creosote releases. These actions will require an estimated 120 on-site p' ; p

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complete. We believe that these actions will mitigate direct contact threats as well as threats of contaminant migration to local surface and groundwater and may allow for natural attenuation (bioremediation) of residual contaminants.

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

t» SITE COMPmONS AND BACKGROUNDCERCLIS ID#: OHO 001 326 610

The Baker Wood Creosoting Site is located at the northwest corner of Holland Road and Kenton Street (State Route 309), Marlon, Marion County, Ohio, and is approximately one-half mile northwest of downtown Marion. Holland Road is the southern border of the site and intersects Kenton Street. The general land use within one mile of the site is industrial to the south, residential and commercial to the east and north, and agricultural to the west. Approximately Yz mile west of the site, North Rockswaie Ditch crosses beneath Holland Road, then parallels the road west until it meets the Little Scioto River, approximately one mile west of the site. The geographic coordinates for the site are 40'*35'37" north latitude and 83°09’20" west longitude. According to a Region 5 Lan-View Environmental Justice (EJ) analysis, the areas surrounding the Baker Wood Creosoting Site within one mile, meet the regional EJ case criteria for average income being at least two times lower than the state average.

The present owner of the site Is the Baker Wood Limited Partnership. The partnership was created by the previous owner, Sims Bros., Inc., of Marion, Ohio, and has, in the past, utilized the site to operate a scrap metal salvage yard. The site is currently vacant with no on-site workers. Evidence of the old creosoting operation still exists. The foundations of many of the old buildings are present, as are the foundations of the creosote storage tanks. Most of the property (about 50 acres) was utilized as a railroad tie drying and storage yard which encompasses the entire western portion of the site.

The Baker Wood Preserving Company used the property to treat wood products as early as the 1890s until about the 1960s. Historical information indicates that the process at the facility most likely was to treat railroad ties and other v»/ood products in pressure vessels on site. The preservatives used were, based on current analytical information, likely creosote, petroleum, and other solvents. Letters from the Ohio Department of Health dated in 1946 indicate that chemical waste from the site discharged directly to the combined sewers that drain to nearby North Rockswaie Ditch and the Little Scioto River. These letters urged the company to cease discharging due to the concern about water quality in the Little Scioto River.

A combined sanitary/storm sewer is adjacent to the site, along the southern border.The sewer travels beneath Holland Road, following west, and discharges directly into North Rockswaie Ditch. Sewer tie-ins from the site to the sewer may still exist and may be the transport mechanism of creosote discharging off site. According to an OEPA

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Integrated Assessment (LA) report dated March 5, 1998, during heavy precipitation and high water in the combined sewer, the outfall waters carry a visible oil sheen. Potential OPA activities will be evaluated during the Investigative activities described in their action memo. The water in the sewer, as well as the sediments of the ditch, have been sampled and analyzed by OEPA. Analysis demonstrates VOC and PAH compounds, directly related to coal tar and creosote, are present. North Rockswale Ditch drains into the Little Scioto River, where OEPA sampling also demonstrates elevated levels of PAH compounds.

According to the OEPA lA report, extremely high levels of VOC and PAH compounds exist in waste buried or partially buried at the site. Soil and waste samples collected by OEPA in the area formerly housing the wood treating vessels demonstrated, through laboratory analysis, high levels of the following VOCs and PAHs: naphthalene [up to 13,000 parts per million (ppm)], 2-methylnaphthalene (up to 7,700 ppm), acenaphthylene (up to 27 ppm), acenaphthene (up to 6,800 ppm), dibenzofuran (up to 6,600 ppm), fluorens (up to 10,000 ppm), phenanthrene (up to 20,000 ppm), anthracene (up to 33,000 ppm), carbazole (up to 13,000 ppm), fluoanthene (up to 6,400 ppm), pyrene (up to 4,800 ppm), benzo(a)fluoranthene (up to 720 ppm), benzo(a)pyrene (up to 130 ppm), indeno(1,2,3,-ccl)pyrene (up to 61 ppm), benzo(g.h,i)perylene (up to 60 ppm), benzene (up to 9.5 ppm), toluene (up to 51 ppm), ethyl benzene (up to 37 ppm), styrene (up to 22 ppm), and total xylene (up to 170 ppm). In addition, elevated levels of metal anal)rtes and pesticide compounds were also detected in soil and waste on site. Waste samples were collected as shallow as 10 inches and as deep as 12 feet below ground surface.

An OEPA report, "Biological, Sediment and Water Quality Study of the Little Scioto River, Marion, Ohio", dated April 8, 1994, indicates that elevated levels of at least 17 PAH compounds were identified in both Rockswale Ditch and the outfall to the Little Scioto River. The report also confirms that black sludge exhibiting a creosote odor is present in this area of the Little Scioto River. The report states that fish (white sucker and carp) common to the river have been exposed to PAH compounds.

In August 1998, U.S, EPA On-Scene Coordinator (OSC) Mark Durno and the Superfund Technical Assessment and Response Team (START) met with OEPA officials to observe site conditions and plan a course of action for addressing contamination at the site. During the site visit, the OSC and START ooserved some surficial contamination as well as historical features of the site. The group also observed visible v/aste in the sediment of North Rockswale Ditch and the Little Scioto River. Disturbing the sediment caused heavy sheening on the water surface and created an odor that is very characteristic of creosote or coal-tar.

In January 1998, U.S. EPA, START, and a geophysical research team from the Ohio State University (OSU) conducted an Electromagnetic Conductivity (EM) and Ground Penetrating Radar (GPR) survey over the most prevalent waste-containing area of the site. Results from the survey indicated that probable organic waste contamination

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existed near the former process tank and that the highest contamination was most likely from 1 to 4 feet below ground surface, The survey, however, was not conclusive as to the horizontal extent of buried organic contamination due to the limited survey area. Rough estimates indicate that approximately 2,000 cubic yards of waste or highly-

contaminated soil exist on site.

The results from the OEPA report and U,S. ERA geophysical work confirmed the obvious visual conclusion that historic industrial wastes containing high levels of hazardous substances, as defined by Section 101 (14) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), some of which are still relatively volatile, are presenting migration and direct contact threats at the site.

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

The conditions at the Baker Wood Creosoting Site constitute an imminent and substantial danger to public health and welfare or the environment based upon the considerations set forth In the National Contingency Plan (NCR), 40 CFR Section 300.415(b)(2) which include, but are not limited to, the following:

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

The VOC and PAH compounds present at elevated levels at Baker Wood Creosoting present direct contact threats, via dermal absorption and inhalation pathways, to members of the public accessing the area. Benzene is a known carcinogen. The site is unsecured and is located in a mixed industrial, rural and residential area. The hazardous constituents of the Baker Wood waste also present direct contact (dermal absorption) and food chain (ingestion) impact threats to a diverse population of large and small animals inhabiting the rural and wooded portions of the site. OEPA has already demonstrated that the Little Scioto River water and sediment has been adversely impacted as a result of historic discharge from the Baker Wood facility This is significant in that the Little Scioto River is a tributary to the Scioto River, Olentangy River, and the Ohio River, all of which are major United States waterways for commercial and recreational purposes.

ii. Actual or potential contamination of drinking water supplies or sensitive ecosystems;

As mentioned above, the Little Scioto River is a sensitive ecosystem that drains to other sensitive areas. Sediment samples collected from the river bottom at the site and past evidence demonstrate that elevated levels of VOC and PAH compounds have entered the creek from the wastes deposited at the Baker Wood Creosoting Site. Through its 1994 report, OEPA has demonstrated that creek water at this location has chronic aquatic toxicity.

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U.S. EPA will recommend to State and county authorities that they further evaluate the area’s drinking water. While actual contamination of residential drinking water has not been documented, it is not clear that water quality in local residential wells has been fully evaluated. Moreover, since high levels of benzene, toluene, and xylene are associated with the waste in the Little Scioto River, the potential for these mobile, volatile contaminants, as well as PAH contaminants, to contaminate local groundwater may be high. The City of Marion municipal water wells are within 2 miles of the site. Levels of these compounds in the site’s soils and sediments greatly exceed OEPA’s soil cleanup criteria for groundwater protectiveness. There is currently insufficient information available regarding the local drinking water and groundwater relationship to properly evaluate the full extent to which drinking water may be affected, in addition, the City of Marion’s municipal water intakes are approximately 1/4 mile upstream from the visibly-contaminated sediments in the Little Scioto River.

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

High levels of VOC and PAH constituents of the industrial wastes which have been deposited in sensitive areas in the Little Scioto River have migrated to the river’s sediments. Levels of these compounds in the site's soils and sediments greatly exceed State criteria for both residential and industrial clean-up. Due to this, and the potential pathways for waste to enter the Little Scioto River, it lends further support to the conclusion that the surface water quality of the Little Scioto River is at risk. The highest levels of contamination on site have been documented to be within 1 foot of the ground surface.

vii. The availability of other appropriate federal or state response mechanisms to respond to the release;

To date, OEPA has been unable to secure sufficient funding to stabilize the Baker Wood Creosoting Site in a timely fashion; therefore. OEPA requested U.S, ERA'S assistance in evaluating and mitigating site conditions. OEPA has indicated, however, that it may be able to provide ongoing, but limited, support to efforts to determine the full impact of waste disposal at the site in order to facilitate short-term U.S. EPA stabilization as well as to assist in the evaluation and planning of prospective remedial response activities.

IV. ENDANGERMENT DETERMINATION

Until the wastes presently deposited on site and in the Little Scioto River are removed and disposed of, the threats posed by the presence and continued release of VOC and PAH waste constituents, if not addressed by implementing the response actions

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selected in this Action Memorandum, present an imminent and substantial endangerment to public health and welfare and to the environment.

V. PROPOSED ACTIONS AND ESTIMATED COSTS

A. PROPOSED ACTIONS

1. Proposed Action Description

The following actions must be completed to alleviate the potential and actual threats to human health and the environment posed by the hazardous contaminants at the Baker Wood Creosoting Site:

0 Establish site security, including construction of a chain-link fence;

o Establish and implement a site health and safety plan;

o Establish a site command post and control zones;

0 Conduct invasive test excavations to determine more completely the extent of subsurface contamination on site;

0 Excavate, treat (if necessary), transport, and properly dispose (in accordance with U.S. ERA'S Off-Site Rule) of an estimated 2,000 cubic yards of creosote waste and heavily contaminated soil;

o Backfill and restore the waste excavation areas; and

o Fully characterize the extent of contamination in the Little Scioto River and, if necessary, provide engineering support to evaluate removal alternatives for heavily contaminated sediments.

All hazardous substances, pollutants or contaminants removed off-site pursuant to this removal action for treatment, storage and disposal will be treated, stored or disposed of at a facility in compliance with the U.S. EPA Off-Site Rule, 40 C.F.R, § 300.440, 58 Fed Reo. 49215 fSeotember 22. 1993).

The estimated waste volume of 2,000 cubic yards is based upon the assumption that excavation activities will reveal the presence of currently unknown waste pockets and that considerable amounts of heavily-contaminated soils will also require removal.

The response actions described in this memorandum directly address actual, threatened, or potential 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. 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.

This work wi;! take an estimated 120 on-site working days to complete. This time frame may be extended if wet weather conditions are not conducive to excavation in this envi.'onment The OSC has begun planning for post-removal site control per the provisions of Section 300.415 (I) of the National Contingency Plan (NCP). The nature of this site, however, is such that post-removal site control is unlikely to be necessary

2. Applicable or Relevant and Appropriate Requirements (ARARS)

Region 5 sent a letter requesting the identification of state ARARS to Mr. Steve Snyder of OEPA’s Bowling Green, Ohio, office on March 29, 1999. To the extent that the State provides a timely response, ARARs will be complied with to the extent practicable.

B. ESTIMATED COSTS

The detailed Emergency Rapid Response Contractor (ERRS) costs projected to be necessary for project completion are presented in Attachment 1, with the estimated project costs presented below:

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6

RFMOVAL PROJFCT CFiLING EST^^■/^ATE

EXTRAMURAL COSTS;

Cleanup Contractor Costs20Vd Contingency

$1,205,500 241 100

Subtotal $1,446,600

Total STARTUSCG Atlantic Strike Team

125,000

Ejrtramurai Subtotal15% Extramural Contingency

$1,587,600 238 140

TOTAL, EXTRAMURAL COSTS; $1,825,740

INTRAMURAl COSTS:U.S. EPA Direct Costs($30 X 1,500 Regional hours+ 150 HQ hours)

49.500

U.S. EPA Indirect Costs ($65 X 1,500 Regional hours)

97.500

TOTAL, INTRAMURAL COSTS:TOTAL REMOVALPROJECT CEILING

$ 147,000

$1,972,740

VI. EXPECTED CHANGE IN THE SITUATION SHOULD NO ACTION BE TAKEN OR ACTION DELAYED

Increased risk to public health and the environment will result if no or delayed action

ensues.

VH. OUTSTANDING POLICY ISSUES

There are no outstanding policy issues associated with this site.

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VIII. ENFQRCEMgNT

For administrative purposes, Information concerning confidential enforce,ment strategy for this site is in the Enforcement Addendum.

IX. RECOMMENDATION

This decision document represents the selected removal action for the Baker Wood Creosoting in Marion, Marion County. Ohio, developed in accordance with CERCLA as amended, and is not inconsistent with the NCR. This decision is based on the Administrative Record for the site (see Attachment 2).

Because the conditions at the site meet the NCR, Section 300 415(b)(2) criteria for a removal action, I recommend your approval of the proposed removal action. The total project ceiling, if approved, will be $1,972,740. Of this, an estimated $1,684,740 may be used for extramural cleanup contractor costs. Please indicate your decision by signing below.

APPROVE-Director, Superfund Divijbion

DATE:'/u/\

DISAPPROVE:.Director, Superfund Division

Enforcement Addendum Attachments:

1. Detailed Cleanup Contractor Estimate2. Administrative Record Index3. Region V EJ Analysis

DATE;

cc: K. Mould, U.S. ERA HQ, 5202GM. Chezik, U.S. Department of Interior, w/o Enf. Addendum K Clouse, OEPA, w/o Enf. Addendum C. Jones, OEPA, w/o Enf. Addendum

■-'►.I

bcc: A. Baumann, SRT-6J, w/o Enf. AddendumJ. El-Zein. SE-GI W, Carney, SE-5JL. Fabinski. ATSDR, ATSD-4J, w/o Enf. Addendum W, Messenger, SE-5JT. Lesser. P-19J, w/o Enf. AddendumERB Read File (C. Beck), SE-5JERB Delivery Order File (C. Norman), SE-5JERB Site File (M. Bedford, SF Central File Room), SMR-7JContracting Officer, MCC-10J, w/o Enf. AddendumM. Durno, ME-W E. Hahn, C-14JM. Sensing, SE-5J

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ENFORCEMENT ADDENDUM

BAKER WOOD CREOSOTING SITE MARION. MARION COUNTY, OHIO

APRIL 1999

ENFORCEMENT CONFIDENTIAL NOT SUBJECT TO DISCOVERY

The Baker Wood Creosoting Site which is located at 1011 South Prospect Street in Marion, Marion County, Ohio, is a former creosote wood treating facility which needs a time-critical removal action.

The Removal Enforcement Team composing of Eva Hahn, ORC attorney; Mark Durno, ERB On-Scene Coordinator; Joe Kawecki, Civil Investigator; and Mila Sensing, EESS Enforcement Specialist, held an enforcement strategy meeting on December 9, 1S98, to discuss plans and steps to be taken.

The following steps were taken: on December 15, 1998, a Title Search was ordered and the report was received on February 2,1999. On January 5, 1999, a 104(e) Information Request letter with a 21-day turnaround was sent to Baker Wood Ltd., Donald Sims, Lillian Sims; Vince Atriano, an attorney representing Baker Wood Ltd., Donald Sims and Lillian Sims; and D. B. Frampton. The return receipts from Baker Wood Ltd. and Vince Atriano were dated January 9. 1999, while Donald Sims and Lillian Sims' were dated January 11. 1999, Mr. Atriano's voluminous response to the 104(e) Information Request letter dated February 8, 1999, is being reviewed An Action Memo to request for funds to clean up the Site is underway.

The next action will be determined on the responses to the 104(e) Information Request letter which should be anytime soon. Investigative work to determine the PRPs' involvement with the Site may also be necessary.

The Agency has several enforcement options currently under evaluation, including the issuance of a UAO, an AOC, or the use of the Trust Fund.

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ATTACHMENT 1

DETAILED ERRS COST PROJECTION ESTIMATE BAKER WOOD CREOSOTING SITE MARION, MARION COUNTY, OHIO

APRIL 19S9

Mobilization Fence Constaiction Test Excavations Waste Excavation Transportation & Disposal Little Scioto River Evaluation

$ 20,000$ 41,200

$ 68,700 $ 111,300 $ 901,300 S 63.000

TOTAL $1,205,500

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ATTACHMENT 2ADMINISTRATIVE RECORD INDEX BAKER WOOD CREOSOTING SITE MARION, MARION COUNTY, OHIO

APRIL 1999

DATE AUTHOR RECIPIENT TITI F/DESCRIPTION

04/08/94 OEPA PublicDocument

Biological, Sediment, andWater Quality Study of theLittle Scioto River, Marion, OH

53

03/05/98 Reinbold, K. OEPA

U.S.EPA & OEPA

Integrated Assessment Report 21

06/12/98 Clouse, K. OEPA

El-Zein, J, Referral Letter 1

03/99 Daniels, J. OSU

Vendl, M.U.S. EPA

Geophysical displays 2

03/29/99 Dumo, M. U.S. EPA

Snyder, S. OEPA

Letter Requesting ARARs 1

00/00/99 Durno. M. U.S. EPA

Muno, W.US. EPA

Action Memorandum (Pending)

00/00/99 Ecology & Env., Inc.

Nabasny, G, U.S. EPA

Letter Report (Pending)

05 '00 05:4? FR E 2: E CLEUELRND 44U to :7;^EE0TE‘

INDEPENDENT GOVERNMENT COST ESTIMATE BAKER WOOD CREOSOTING SITE MARION. MARION COUNTY. OHIO

APRIL 1999

ERRS CONTRACTOR

1. Mobilization (5 davs^:

Personnel: 1 RM @ $50/hour x 60 hours =1 Foreman @ $40/hour x 60 hours =2 Labor @ $35/hour X 60 hours x 2 =2 Equip Ops. @ $40/hour x 60 hours x 2 =

S 3,000 S 2,400 $ 4,200 S 4,800

Equipment: 1 Dozer @ $800/week1 Loader @ $1,000/week

$ 800 $ 1,000

Other Costs; Command Post Rentals/mobeSite Services (electric, sanitary, etc) $ 10,000

$ 15,000

TOTAL $ 41,200

7 Fenne Construction C5 davsl:

Subcontract: TOTAL $ 20,000

3. Test Excavations f15 davsT

Personnel: 1 RM @ $50/hour x 180 hours =1 Foreman @ $40/hour x 180 hours =3 Labor @ $35/hour x 180 hours x 3 =3 Equip Ops @ $40/hour x 180 x 3 =

$ 9,000$ 7,200$ 18,900 $ 21,600

Equipment; 1 Excavator (g $1,200/week x 3 =1 Dozer @ $800/week x 3 =1 Loader @ $1,000/week x 3 =

$ 3,600 $ 2,400 $ 3,000

Other Costs; Materials and PPE estimate = $ 3,000

TOTAL $ 68.700

^\Ai'aste Excavation and Staging ^20 davs^:

Personnel: 1 RM @ $50yhour x 240 hours -1 Foreman @ $40 x 240 hours =

$ 12,000 $ 9,300

---> 0^' '00 00:43 FR E 3 E CLE^ELHmIi 440 0::::-r -.----r

Equipment:

Other Costs;

1 T&D Coord/Chemist @ $40/hour x 80 hours $ 3,2003 Labor @ $35/hour x 240 hours x 3 = S 25,2003 Equip Ops @ $40/hour x 240 hours x 3 = $ 28,800

2 Excavators @ $4,500/month x 2 $ 9,0001 Dozer @ $3,000/month $ 3,0001 Loader @3,500/month S 3,500

Materials and PPE estimate = S 7,000Laboratory analytical services = $ 10,000

TOTAL $111,300

^_______Transportation and Disposal (20 davs):

Personnel: 1 RM @ $50/hour X 240 hours = $12,0001 Foreman @ $40 x 240 hours = $ 9,6001 T&D Coord/Chemist @ $40/hour X 80 hours $ 3,2003 Labor @ $35/hour x 240 hours x 3 = $ 25,2003 Equip Ops @ $40/hour x 240 hours x 3 = $ 28,800

2 Excavators @ $4,500/month x 2 S 9,0001 Dozer® $3,000/month S 3,0001 Loader @3,500/month S 3,500

Materials and PPE estimate = $ 7,000Transportation/Disposal Subcontract:2,000 CY @ $400 / CY* $800,000

TOTAL $901,300

* The T&D cost estimate is based on incineration or recycling of the waste. Tnere are Land Disposal Restrictions for creosote related waste that become effective on May 12, 1999. These restrictions may prevent landfill disposal after May 12. Conducting this effort prior to this date .Tiay prove significant cost savings.

Equipment:

Other Costs:

6 Little Scioto River Evaluation f20 davsV

Personnel: 1 RM @ $50/hour X 240 hours = $ 12,0001 Foreman @ $40 x 240 hours = $ 9,6001 Engineer @ $ 60/hour x 100 hours $ 6,0002 Labor @ $35/hour x 240 hours x 2 = $ 16,8001 Chemist @ $40/hour x 40 hours = $ 1,600

Other Costs: Materials and PPE estimate = S 7,000Laboratory Subcontract - S 10,000

C":' tj9:4S FR E & E CLB.'ELPhC* -WG 2-E tS23 TO 173-EE2“E“^“-

TOTAL $ 63,000

total errs contract $1,205,600

START CONTRACTOR

START tasks to include oversight, sampling, monitoring, technical support, and extensive support during the Little Scioto River Evaluation:

2,500 Labor hours @ $50/hour TOTAL START CONTR. $125,000

U S. COAST GUARD STRIKE TEAM

U.S. Coast Guard Strike Team members may be used to assist with health and safety oversight, technical support, and cost control oversight:

800 Labor hours @ $20/hour TOTAL STRIKE TEAM $ 16,000

U.S. EPA

U.S. EPA site management activities:

Direct: 1,500 labor hours (+ 160 HQ hours) @ $30/hourIndirect: 1,500 labor hours @ $65/hour =

TOTAL U.S. EPA

$ 49,500 $ 97,500

$147,000

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Region 5 Superfund EJ AnalysisBaker Woods Creosoting Site Marion,Ohio

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BAKER WOOD CREOSOTING SITE MARION, MARION COUNTY, OHIO

ENFORCEMENT ADDENDUM 2April 12,2000

The Baker Wood Creosoting Site which is located at 1011 South Prospect Street in Marion. Marion County, Ohio, is a former creosote wood treating facility which needs a time-critical removal action.

The Removal Enforcement Team composing of Eva Hahn, ORC Attorney; Mark Durno, ERB On-Scene Coordinator; Joe Kawecki, Civil Investigator; and Mila Bensing. EESS Enforcement Specialist, held an Enforcement Strategy Meeting on December 9, 1998. to discuss plans and steps to be taken.

The following steps were taken: on December 15, 1998, a Title Search was ordered and the report was received on Februar)^ 2, 1999. On January' 5, 1999, the Agency sent out 104(e) ■ Information Request letters to Baker Wood Ltd., Mr. Donald Sims, Ms. Lillian Sims, Vince Atriano (Attorney for Baker Wood Ltd., Donald Sims and Lillian Sims), and Mr. D.B. Frampton. A careful review of the answers received and investigations by a U.S. EPA civil investigator determined that there are no viable PRPs for this site. In addition, neither the state nor the local agencies have any resources to complete the removal activities needed at this site. Therefore, it is necessary that the trust fund be used to pay for this removal action and all other acliviites necessary at the site which are related to CERCLA.

Reference 2

MULTI-SITE POTENTIALLY RESPONSIBLE PARTY SEARCH

TITLE SEARCH REPORT

BAKER WOOD CREOSOTING SITE

MARION, OHIO

Prepared For;

U.S. Environmental Protection Agency Region 5

Chicago. IL 60604

Contract No.Work Assignment No.Dynamac No.Site No.Date PreparedEPA Work Assignment Mgr. Telephone No.Dynamac Work Assignment Mgr. Telephone No.

68-W4-0015C05008C008-202-132CB591Januar}' 29, 1999 Ruth A. Miles (312)353-6431 Ron Harris (312) 466-0222

TABLE OF CONTENTS

Section Page

1.0 INTRODUCTION................................................................................................................... 1

1.1 Work Assignment Background ................................................................................... I1.2 Site Background...........................................................................................................11.3 Technical Direction .....................................................................................................1

2.0 TECPINICAL APPROACH.............................. 2e

2.1 Obtaining Title Records.................... ...................................................................... 22.2 Analysis of Title Records............................................................................................ 2

3.0 RESEARCH FINDINGS . ................................................. 3

3.1 Title Search Summary/Description of Parcels................................................. 33.2 Target Property Ownership ............................................................................. 33.3 Special Circumstances Encountered ............................................ 33.4 Additional or Supplemental Research Effons........................................................... 73.5 Telephone and Address Search .................................................................................. 7

4.0 REFERENCES ........................................... 8

5.0 CONTACTS ........................................................................................................................... 9

FIGURES

FIGURE 1: TARGET PROPERTY MAP...........................................................................4FIGURE 2: CHAIN-OF-TITLE ............................................................. 6

TABLE

TABLE 1; TARGET PROPERTY OWNERSHIP AND TRANSACTIONS................. 5

APPENDICES

APPENDIX 1 (REFERENCES 1-6): DEEDS AND RELATED DOCUMENTS APPENDIX 2 (REFERENCE 7); PLAT MAP

Title Search Report Baker Wood Creosoting Site ENFORCEMENT CONFIDENTI.4L

January' 29, 1999 Page i

1.0 INTRODUCTION

1.1 Work Assignment Background

Dynamac Corporation (Dynamac) received Work Assignment C05008 under U.S. Environmental Protection Agency (EPA) Contract No. 68-W4-0015 to provide multi-site Potentially Responsible Party (PRP) Search support for EPA Region 5. One task defmed in EPA's statement of work (SOW) for this work assignment and described in the April 4, 1995, Dynamac Revised Work Plan, is performance of site-specific PRP searches.

On December 17, 1999, Dynamac received technical direction in the form of a Title Search Request Form from Ruth Miles, the EPA Work Assignment Manager (WAM), directing Dynamac to conduct a title search for the Baker Wood Creosoting Site located in Marion, Marion County. Ohio (the target property).

This report describes the technical approach and findings related to Dynamac's title search activities for this Site.

1.2 Site Background

EP.A provided Dynamac with the names of suspected current and former owners of the target property. No maps or other site information was available. EPA indicated that Baker Wood Limited is the owner of record.

1.3 Technical Direction

EPA directed Dynamac to conduct the title search to identify the owners of the target property- back to 1935. EPA also directed Dynamac obtained copies of deeds transferring the target property.

Title Search Report Baker Wood Creosoting Site ENFORCEMENT CONFIDENTIAL

Januar)' 29. 1999 Page 1

2.0 TECHNICAL APPROACH

2.1 Obtaining Title Records

Prior to traveling, Dynamac telephoned the Mmon County Recorder (Recorder's Office) to inquire about hours of operation and location. At the Recorder’s Office, Dynamac was directed to the Marion Counw Auditor (Auditor’s Office) to get assistance in identifying the location of the target property. Once the location was determined, Dynamac returned to the Recorder’s Office and was assisted in locating records of recent target property transfers. Dynamac then searched the grantor/grantee indices to identify deeds transferring the property back to 1935. Dynamac viewed the referenced documents, verified that the documents were relevant to the target property^ and obtained copies of the target property documents. Copies of these records are provided in Appendix 1.

Dynamac also visited the Marion County Treasurer's Office to inquire about the tax status of the target property. Dynamac also obtained a copy of the plat map of the target property from the Auditor's Office. The map of the target property is provided in Appendix 2.

2.2 Analysis of Title Records

Dynamac completed a review and analysis of the title records obtained for the target property. The review and analysis focused on the following areas:

definition of legal boundaries for each tax parcel in the target property boundaries; development of a map depicting tax parcels in the target property boundaries; development of an ownership table for each tax parcel; narrative summary of title search results; andorganization of title documents for convenient reference as attaclrments to this repon.


January' 29, 1999 Page 2

3.0 RESEARCH FINDINGS

3.1 Title Search Summary/Description of Parcels

The target property is located west of the intersection of State Route 309 and County Road 95-A. on the West side of the City of Marion, Marion County, Ohio. Figure 1 is a map that identifies the location and boundaries of the target property and its parcels. The target propeny consists of two sections totaling approximately 60 acres.

Target Propert} Legal Description

The target property is composed of the parcel described below;

Situated w the County of Marion in the State of Ohio, and in the Township of Morion and bounded and described as follows:

Known as being the South part of the East half of the Northwest quarter containing 25 acres, more or less, and being the South part if the Northeast quarter containing 35 acres, more or less, in the aggregate sixty (60) acres, more or less, all in Section 20, Township 5 South, Range 15 East, beginning in the center of the'gravel tract of the Marion and Big Island Free Turnpike Road (now Harding Highway) at a point where the same crosses the East and West half section line of Section 20, Township 5 South, Range 15 East: thence on said half section line South 87 'A degees West, 55 chains and 80 links to a stone at the southwest comer of the East half of the northwest quarter of said Section 20; thence on the West line of said last described lot North 1 degee West. 12 chains and 48 links to a stake: thence on a line parallel to the aforesaid East and West half section line North 87 '/: degees East 37 chains and 70 links to a stake in the West side of a certain lane: thence along the West side of said lane and the East garden fence North 9 deg'ees East 1 chain and 82 links to the center of the gaveled track of the aforesaid Free Turnpike Road (now Harding Highway:): thence along and in the g-aveled track of said road South 53 degees East 22 chains and 25 links to the beginning, containing 60 acres be the same more or less. (Ref 1)

3.2 Target Property Ownership

The target property is currently owned by Bakerwood Limited Partnership, which acquired the property from Donald E. Sims on June 10, 1994 (Ref 1). Mr. Sims appears to be both the only general partner and the only limited partner in Bakerwood Limited Partnership (Ref 2). and thus retains control of the property. Table 1 indicates the target property ownership and transactions from 1935 to the present. Dynamac prepared a Chain-of-Title (Figure 2), which indicates the changes in ownership for the target property from 1935 to the present. Both Table 1 and Figure 2 are in reverse chronological order.

3.3 Special Circumstances Encountered

Dynamac encountered no special circumstances in completing this title search.


januar>' 29. 1999 Pace 3

FIGURE 1TARGET PROPERTY MAP

BAKER WOOD CREOSOTING SITE MARION, OHIO

800 ft

Scale

North

County Road 95-A

Title Search Report Baker Wood Creosoting Site

ENFORCEMENT CONFIDENTIAL January 29, 1999 .Page 4

TABLE ITARGET PROPERTY OWNERSHIP AND TRANSACTIONS


DOCUMENT GRANTOR GRANTEE DATE DOCUMENT REFERENCETYPE RECORDED NUMBER NUMBER

Warranty Deed Donald E. Sims Bakerwood Limited Partnership 06/10/94 Vol.251Page 291

1

Warranty Deed Lillian Sims Donald E. Sims 05/27/94 Vol. 249Page 888

3

Warranty Deed D.B. Frampton & Co. Donald E. & Lillian Sims 09/27/77 Vol. 539Page 912

4

Agreement of Merger Baker Wood Preserving Co. (Into) D.B. Frampton & Co. 09/06/56 Vol. 340Page 440

5

Warranty Deed The Fahey Banking Co. Baker Wood Preserving Co. 11/21/35 Vol. 197Page 583

6

Title Search Report Baker Wood Crcosoting Site ENlOUCICMLNI (JONTIDENUAL

January 29, 1999 Page 5

FIGURE 2 CHAIN-OF-TITLE

BAKER WOOD CREOSOTING SITE MARION, OHIO

The Fahey Banking Co.

Baker Wood Preserving Co. Warranty Deed 1 1/21/35 Vol. 197, P. 583, Ref. 6

Bakerwood Limited Partnership Warranty Deed 06/10/94

Donald E. Sims Warranty Deed 05/27/94

Donald E. & Lillian Sims Warranty Deed 09/27/77 Vol. 539, P. 912, Ref. 4

D.B. Frampton & Co. Agreement of Merger 09/06/56

Vol. 340, P. 440, Ref. 5

Title Search Report ENFORCEMENT CONFIDENTIALBaker Wood Creosoting Site


3.4 Additional or Supplemental Research Efforts

Dynamac inquired about the property tax status of the parcels at the Marion Count}' Treasurer's Office (Treasurer's Office). The Treasurer’s Office indicated that the target propert}- is not delinquent in

property tax payments.

3.5 Telephone and Address Search Results

Dynamac utilized the internet and a computer database (ProCD PhoneBooks) to locate the telephone number and address of the former and current target property owners identified in this title search. Using the computer database, and directory assistance when necessary, Dynamac obtained the following addresses and phone numbers;

Bakerwood Limited Partnership P.O. Box 1170 Marion, OH 43302 No listing

Donald E. Sims 1410 Woodridge Rd. Marion, OH 43302 740-389-2142


Januar>' 29, 1999 Page 7

4.0 REFERENCES

Warranty Deed. Grantor: Donald E. Sims. Grantee: Bakerwood Limited Partnership. Date Recorded: June 10, 1994. Volume 251, Page 291.

Certificate of Limited Partnership. Name: Bakerwood Limited Partnership. Agent: Donald E. Sims. Date Recorded: June 10, 1994. Volume 251, Page 262.

Warranty Deed. Grantor: Lillian Sims. Grantee: Donald E. Sims. Date Recorded: May 27, 1994. Volume 249, Page 888.

Warranty Deed. Grantor: D. B. Frampton & Co.. Grantee: Donald E. and Lillian Sims. Date Recorded: September 27, 1977. Volume 539, Page 912.

Agreement of Merger, Baker Wood Preserving Co. into D. B. Frampton & Co. Date Recorded: September 6, 1956. Volume 340, Page 440.

Warranty Deed. Grantor: The Fahey Banking Co. Grantee: Baker Wood Preserving Co. Date Recorded: November 21, 1935. Volume 197, Page 583.

Plat Map of part of Section 20, Range 5 South, Range 15 East, Undated, Scale 1" = 400'.



Reference 3

FINAL COMMUNITY INVOLVEMENT PLAN FOR THE

BAKER WOOD CREOSOTING SIT]^MARION, OHIO ^ (

) O

Prepared For:

U.S. Environmental Protection Agency Region 5

Chicago, IL

Work Assignment No. Date Prepared Contract No.SciComm WA Manager Telephone No.EPA W A Manager Telephone No.

1014-000 October 5, 1999 95-2115-YAWW Ralph Falzone (301)652-1900 Susan Pastor (312)353-1325

TABLE OF CONTENTS

Section Page

1. Introduction ........................................................ .. .................................................. ............1

2. Site Background.................................................................................................................... 32.1 Site Location .........................................................................................................................32.2 Site History ............................................... 42.3 Removal Action.................................................................................................................... 5

3. Community Background ......................................................... 63.1 Community Profile............................ 63.2 History of Neighborhood Involvement ....................................... 73.3 Community Concerns ............................................................... 8

4. Objectives for the Community Involvement Plan . ............... 104.1 Educational Materials ............................... .................... ........................................ .. 114.2 U.S. EPA’s and Ohio EPA’s role................................................................. 114.3 Site Cleanup Progress ......................................................... .. ...........;...................... 11

5. Community Involvement Activities.................................................................................... 125.1 Administrative Record.................. 125.2 Point of contact ..................................... 125.3 Mailing list................................................................................ 125.4 Fact Sheets.................................................................................... 135.5 Press Releases .....................................................................................................................135.6 Public Meetings...................................................................................... 135.7 Historical Site Information.......... ........... 14

Appendix

A List of Interested Parties, U.S. EPA Representatives, State of OhioRepresentatives, Media Organizations, and Elected Officials......................... A-3

B Locations for a Public Meeting and Administrative Record......................... B-3

Figures and Tables

Figure 1 Picture of Little Scioto Ri ver.....................................................................................3Figure 2 Stacks of Railroad ties drying after the creosote application....................................4Table 1 Schedule of Communitv Involvement Activities ....................................................15

Community Involvement Plan Baker Wood Creosoting Site

Marion, OH October 1999

1. INTRODUCTION

The U.S. Environmental Protection Agency (U.S. EPA) developed this community

involvement plan (CIP) to determine specific community involvement activities for the Baker Wood

Creosoting Site in Marion, OH. Under the auspices of the Federal “Superfund” program, U.S. EPA

has undertaken a time-critical removal of creosote-contaminated soil at the site of the former Baker

Wood Preserving Company. In 1980, Congress passed the Comprehensive Environmental

Response, Compensation, and Liability (CERCLA) law or “Superfund,” thus creating a Federal

program under U.S. EPA to clean up polluted, hazardous and/or abandoned sites. The Superfund

program was re-authorized and amended by Congress in 1986 through the Superfund Amendments

and Reauthorization Act. At the Baker Wood Creosoting Site, the creosote contamination may be

spreading to the nearby Little Scioto River and thereby poses a health hazard to local residents.

A strong component of the Superfund program is the community involvement program. By

establishing communications between the community and U.S. EPA, the community is informed of

site activities and is involved in the decision-making process. In order to determine the level of

interest in the community about a Superfund site, U.S. EPA conducts interviews with residents;

Federal, State, and local government officials; and environmental or community interest groups.

After the interviews, U.S. EPA develops a CIP that summarizes the community’s needs and concerns

and recommends community involvement activities that are tailored to those needs and concerns.

From July 21-23, 1999, U.S. EPA interviewed local residents; State and local government

officials; and environmental groups in Marion and Columbus, OH about their interests in and

concerns about the Baker Wood Creosoting Site. At that point, the initial removal of creosote-

1

contaminated soil had been completed. As a result of these interviews, U.S. EPA has identified the

following three objectives for community involvement at the Baker Wood Creosoting Site:

1.

2.

3.

Provide educational materials about the Superfund program;

Clarify the differences between U.S. EPA’s role and Ohio EPA’s role at the site; and

Keep the community informed of the cleanup process.

This CIP consists of the following sections as well as an Introduction:

Site Background— the site’s location, history, and cleanup actions to date.

Community Background —a profile of the community, neighborhood involvement and

community concerns and interests.

Highlights of the Community Involvement Program — objectives for the community

involvement plan.

Community Involvement Activities — a list of recommended activities for the community

based on the community interviews.

• ■ Appendix A — a contact list of interested parties, U.S. EPA representatives. State of Ohio

representatives, media organizations, and elected officials.

Appendix B — locations for a public meeting and administrative record.

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2. SITE BACKGROUND

2.1 Site Location

The Baker Wood Creosoting Site is located at the northwest comer of Holland Road and

Kenton Street (State Route 309) in Marion, Ohio. Both the Little Scioto River and the North

Rockswale Ditch lie on the site’s west side. The Little Scioto River is a tributary to the Scioto,

Olentangy, and Ohio Rivers, all of which provide drinking-water supplies for Columbus, Ohio.

Originally abandoned in the 1970s, the 60-acre site was not fenced against trespassers and none of

the company buildings remained on the site.

The surrounding area is a combination of homes, industry, and agriculture. On the north and

east sides, there are residential neighborhoods and farms. On the south and west sides, the site is

bordered by Union Tank Car and the CSX and Norfolk Southern railroad yards. The site is located

about one-half mile northwest of downtown Marion.

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Figure 1. Little Scioto River

2.2 Site History

Before moving to Marion, OH, the Baker Wood Preserving Company was located in

Washington Court House, OH where it was founded in 1920 by G. Damon Baker. The Baker Wood

Preserving Company began operating in Marion, OH in 1935 under the management of Frank

Parrott. In 1937, Mr. Parrott sold the business to D.B. Frampton who owned the company until it

went out of business in 1961. The primary business of the Baker Wood Preserving Company was

creosoting railroad ties and utility poles. Creosote is a heavy, oily liquid used chiefly as a

preservative. The creosoting process involved loading the wood into tram cars and then, driving

the tram cars through a large steel tube that forced the liquid creosote into the wood by applying

pounds of pressure. After this process, the wood was unloaded and stacked to dry.

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Figure 2. Stacks of railroad ties drying after the creosote application

When the Baker Wood Preserving Company went out of business in 1961, the site was sold

to the Sims Brothers company who used it to scrap railroad box and tank cars. During the 1970s,

there was a lot of railroad consolidation, so the Sims Brothers eompany used the site to store box

cars which they then broke down or sold. After the 1970s, the site was abandoned.

J

2.3 Removal Action

In Spring 1998, the Ohio Environmental Protection Agency (Ohio EPA) was concerned about

the site’s contamination and requested that U.S. EPA perform potential time-critical cleanup

activities for creosote-contaminated waste at or near the ground’s surface. Over the past year, U.S.

EPA (in cooperation with Ohio EPA) made site visits, conducted a geophysical survey, and

developed a plan for addressing the contamination. The geophysical survey indicated that the

contamination was greatest approximately one to four feet below the ground’s surface.

In early April 1999, U.S. EPA began cleanup activities at the site. Through mid-May, U.S.

EPA erected a chain-link fence to enclose the contaminated areas of the site; excavated, treated and

removed 2,742 cubic yards (3,565 tons) of creosote-contaminated soil; backfilled, graded and

seeded the excavated areas to restore the site’s original appearance; and tested other areas of the site

to locate additional contaminated areas. Throughout the excavation and removal process, U.S. EPA

monitored the air along the edges of the site to ensure that volatile organic compounds (VOCs) and

polynuclear aromatic hydrocarbons (PAHs) were not entering the air and moving to nearby homes

and businesses. PAHs are often found in creosote. VOCs, chemicals also found on site, pose a

potential health threat because they evaporate quickly when exposed to the air.

In mid-May, U.S. EPA discovered four more smaller contaminated areas along the eastern

edge of the site. The amount of soil that still needs to be treated totals approximately 1,500 cubic

yards (2,000 tons). Currently, U.S. EPA has completed a treatability study for the soil and is in the

process of reviewing the data for feasibility. If it is feasible, U.S. EPA will begin bioremediation

at the site in a few weeks.

U.S. EPA also sampled sediments in the Little Scioto River and in the North Rockswale

Ditch to determine the extent of the creosote contamination there. The samples have been sent to

an independent laboratory for analysis and more samples may be collected in the coming months to

ensure that the full scope of the sediment contamination is addressed. U.S. EPA is still awaiting the

data analysis of the samples from the laborator}' before determining an appropriate course of action

for the river sediment. The laboratory, where the sediment samples were sent, has been delayed in

performing the samples’ data analysis due to a large influx of emergency sampling. Due to this

delay and the approaching winter season, it is likely that potential cleanup work on the river sediment

will not start until late Spring 2000.

3. COMMUNITY BACKGROUNDP] .. .!

3.1 Community Profile

According to the 1998 Marion County Regional Planning estimate, the population of Marion

County is 68,663. With a population of 38,611, the City of Marion accounts for the majority of

residents in Marion County. The City of Marion is the county seat for Marion County. Marion is

a small-sized city with an area of 8 square miles while all of Marion County has an area of 409

square miles.

Key industries in Marion include agriculture, manufacturing, and the railroads. Companies

like Central Soya, Vogel Popcorn, Golden Valley Popcorn, and Wyandot Snacks are agriculture-

related industries that rely on local corn and soybeans. Manufacturing companies like Whirlpool

and Marion Steel are two of the largest industrial employers in Marion County. Higher education

institutions include the Ohio State University at Marion campus and the Marion Technical College.

The labor force has predominantly achieved the education level of high school graduate or higher

and consists of approximately 32,000 workers in Marion County. For the last two years, the

unemployrnent rate in Marion County has been, on average, lower than the national unemployment

rate.

Marion is a community proud of its heritage as the former home of 29**’ U.S. President

Warren G. Harding. Local monuments to President Warren G. Harding include the Harding Home

and Museum, and the Harding Memorial. Marion also celebrates its status as the “Popcorn Capital

.. j

_J

of the World” with the Wyandot Popcorn Museum and the Marion Popcorn Festival held every

September.

Marion County is governed by three elected county commissioners who have offices in the

city of Marion, since Marion is the county seat. The City of Marion is governed and managed by a

mayor, who is elected every four years and a council, whose members are elected every two years.

Although the Baker Wood Creosoting Site is located near the City of Marion, its actual voting

district is outside the city limits in Marion Township. Marion Township is governed by a three-

member board of tmstees and assisted by a Township clerk, all of whom are elected to staggered four

year terms. The City of Marion has its own health department that provides services to city

residents. Both the Marion City health department and the Marion County health department have

been kept informed of activities at the Baker Wood Creosoting Site.

The demographics profile for the City of Marion and Marion County demonstrates that the

majority of both city and county residents fall between the lower middle to middle class income

brackets. As of the 1990 census, the median family income for the City of Marion is $27,049 and

for Marion County is $30, 567. In the neighborhoods surrounding the Baker Wood Creosoting Site,

residents appear to be mostly lower income-level families and senior citizens.

3.2 History of Neighborhood Involvement

To date, local residents living near the Baker Wood Creosoting Site have not expressed a

major interest in the cleanup activities. Through mailings, U.S. EPA has informed the community

about the removal action and the subsequent additional cleanup that is required, but few residents

have stopped by the on-site office or contacted U.S. EPA with questions. Organized environmental

groups have expressed concern about the Baker Wood Creosoting Site contributing to the

contamination of the Little Scioto River; however, there was not much interest expressed about the

actual site cleanup.

In interviewing local residents from July 21-23, 1999, U.S. EPA was able to determine that

overall the community is not worried about the creosote contamination spreading due to their belief

that the creosote will stay in place. One nearby resident was concerned about the possible

contamination of his drinking wells; however, this concern was due to potential chemical rather than

creosote contamination.

Local officials indicated that there has been little interest from residents about the site as

evidenced from the lack of complaints or inquiries. One local official did note that he received

some telephone calls from people concerned about the creosote; however, he informed them that

their concern was unwarranted since the creosote remains in place.

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3.3 Community Concerns

Based on interviews conducted by U.S. EPA from July 21-23, 1999 in both Marion and

Columbus, OH, the following is a list of community concerns. The drinking-water and ground-

water contamination concerns are shared by local officials and residents. These concerns are

indirectly related to the site cleanup, since the river contamination may have been caused by the

Baker Wood Creosoting Site. Actual site cleanup concerns were limited to one individual who

believed that the quickness of the U.S. EPA removal response demonstrated a high level of

contamination. Otherwise, the majority of the residents and the local officials were pleased with the

site cleanup.

Drinking-Water and Ground-Water Contamination Concerns —Environmental groups;

State, and local health officials; elected leaders; and selected community residents have expressed

concern about the link between the Baker Wood Creosoting Site and contamination in the Little

Scioto River. As a result of the contamination, the Little Scioto River currently has a health advisory

placed on it that recommends no fishing, swimming or general contact with the water. State health

officials mentioned that this advisory warning stems from elevated levels of PAHs found in the river

sediment. One local official mentioned that attention was drawn to a link between contamination

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in the river and the Baker Wood Creosoting Site when fish began dying a few years ago. Elected

officials stated that their constituents have expressed concern about the health advisory on the river

and would like to see it cleaned up. One resident expressed his concern about the creosote

contamination that he believes is spreading to the south and to the west of the site. The same

individual mentioned that the well field should be tested for groundwater contamination. He would

like to see a shield placed in front of the wells to protect the water.

Several residents and environmental groups noted that they had expressed their concerns

about the Little Scioto River to Ohio EPA. Both parties stated that they thought their concerns went

unheeded.

Public Information Concerns — All of the residents, officials and environmental groups

praised U.S. EPA for keeping them informed periodically about the progress at the Baker Wood

Creosoting Site. Most interviewees were aware of the site even if they did not express concern

about it. Nearby residents noted that they had received the fact sheets that U.S. EPA sent out and

did discuss activities at the site with their neighbors. Other interviewees mentioned that they had

seen articles about the cleanup at the Baker Wood Creosoting Site from Marion Star and Columbus

Dispatch newspaper articles. Although most interviewees were not concerned directly with the

cleanup at the Baker Wood Creosoting Site, they stated that they wanted to continue being informed

in a timely manner about activities at the site.

Public Health Concerns — The nearby neighborhood is not concerned with any health

issues resulting from the creosote contamination at the Baker Wood Creosoting Site; however, a

State health official did indicate that he was concerned. One resident explained that the community

has grown accustomed to living with the site and has not experieneed any adverse health effects from

the contaminated soil. For the most part, the resident reiterated that the community believes the

creosote contamination will remain in place in the soil.

The State health official interviewed commented that he was concerned about people

accessing and playing on the site without realizing the potential danger to their health from the

creosote-contaminated soil. His concern stemmed from the fact that individuals may have utilized

the site before U.S. EPA erected a fence. Most interviewees could not recall any evidence of

recreational use at the site; however, a nearby resident remembers racing go-carts on the site as a

child with other neighborhood children.

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Cleanup Concerns — For the most part, U.S. EPA was commended by the interviewees for

its quick cleanup action of the site. However, one individual perceived the hasty cleanup action as

an. indication that the site was highly toxic and, thus, was concerned about the contaminants. The

U.S. EPA Community Involvement Coordinator (CIC) explained that the contamination was

classified as a potential threat to human health and therefore, qualified for removal under the

Emergency Response and Removal Branch of the Superfund Division in Region 5. This enabled

U.S. EPA to clean up the site quickly. In addition, the U.S. EPA CIC clarified that soil

contamination is easy to remove in a removal action, but that other contamination is harder to

remove. For example, she mentioned that should ground-water contamination become part of the

site cleanup, the responsibility for that long-term cleanup would be transferred to the Remedial

Response Branch of the Superfund Division in Region 5.

4. OBJECTIVES FOR THE COMMUNITY INVOLVEMENT PROGRAM

U.S. EPA develops community involvement objectives based on several factors including

the community’s level of interest and concerns about the Superfund site. Federal requirements under

the Superfund program, and the nature of the site cleanup. To be effective, the community

involvement objectives and activities should be tailored to how the community has expressed that

it would like to be kept informed of and involved in the site cleanup.

For the Baker Wood Creosoting Site, U.S. EPA has determined that the following objectives

will establish an effective community involvement program based on the responses from the

community interviews.

4.1 Provide educational materials about the Superfund program

Most of the individuals that U.S. EPA interviewed were aware of the Superfund program,

but several individuals were confused about specific Superfund program responsibilities. By

providing educational materials about the Superfund program structure, this will alleviate any

misconceptions about site cleanup activities and the time line associated with different cleanups.

4.2 Clarify the difference between U.S. EPA’s and Ohio EPA’s role at the Site

Originally, Ohio EPA was responsible for the Baker Wood Creosoting Site; however, the

State agency transferred its responsibility to U.S. EPA, Region 5 in Spring 1998. Ohio EPA is also

involved in the cleanup of another site in Marion, so there is some confusion between U.S. EPA’s

and Ohio EPA’s responsibilities at both sites. To help clear up any public confusion, U.S. EPA will

provide information regarding U.S. EPA’s responsibility for the site as well as Ohio EPA’s role.

4.3 Keep the community informed of the cleanup progress at the Site

Residents, officials and environmental groups are receptive to receiving periodic updates

about the cleanup action at the Baker Wood Creosoting Site. U.S. EPA will continue to provide

clear and understandable information about the progress of the cleanup site.

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5. COMMUNITY INVOLVEMENT ACTIVITIES

5.1 Maintain Administrative Record

An administrative record has been established at the Marion Public Library in Marion so site-

related documents like fact sheets and reports will be available to the public. As more reports and

fact sheets are developed in conjunction with progress at the site, they will also be placed there. The

exact location and hours of the Marion Public Library are listed in Appendix B of this CIP.

5.2 Maintain point of contact

U.S. EPA has established a point of contact at the site directly and at the Region 5 office in

Chicago, Illinois. Concerned individuals may contact Mark Dumo, the On-Scene Coordinator

(OSC) at the site or Susan Pastor, the CIC in Chicago. Detailed information on how to contact

either individual will be included on all written materials sent to the public, and it is also listed under

U.S. EPA Representatives in Appendix A.

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5.3 Maintain mailing list

A mailing list was developed to include the neighborhoods and businesses surrounding the

site and local officials. This mailing list has been used to distribute fact sheets about cleanup

activities at the site, and it will continue to be used to distribute information about public meetings,

cleanup progress, and other site-specific information. Adjustments are continuously made to the

mailing list to reflect address changes and new interested parties. Individuals may contact the U.S.

EPA CIC if they are interested in being placed on the mailing list. !.ti

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5.4 Develop Fact Sheets

As of October 1999, U.S. EPA distributed two fact sheets to provide information on the

initiation and progress of cleanup activities at the Baker Wood Creosoting Site. All fact sheets can

be found in the administrative record and on the EPA Region 5 web site. The EPA Region 5 web

site is located at http://www.epa.gov/region5 .

Interviewees indieated to the CIC that the fact sheets are the preferred method of notifying

them of any progress or changes in activities at the site. In response, U.S. EPA will continue to

notify the community through fact sheets. By sending out a fact sheet promptly when progress is

made at the site, U.S. EPA will also be effectively responding to one of the community’s concerns.

5.5 Send Press Releases

In addition to distributing fact sheets to individuals on the mailing list and placing

information on the web site, U.S. EPA will prepare press releases about significant, new findings

at the site and send them to local media. This will ensure that interested individuals will be notified

of significant findings as well as be able to participate in the cleanup process. A list of media

organizations that will be sent press releases is in Appendix A.

5.6 Hold Public Meetings

Under Superfund, U.S. EPA may hold public meetings before, during and after a cleanup.

At the Baker Wood Creosoting Site, a public meeting may be held to discuss proposed cleanup

plans with the community if further cleanup activities are scheduled for the river sediment in the

Little Scioto River. During the community interviews, there was little interest in public meetings

to discuss the site. As a result, there are no plans to hold a public meeting, but this may change in

the future based on the level of community interest.

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5.7 Acquire historical information on Site practices

When the Baker Wood Creosoting Site was transferred to U.S. EPA’s jurisdiction, there was

little historical information concerning the Baker Wood Preserving Company and its origins. As a

result, U.S. EPA appealed to the community for assistance in discovering more information about

the Baker Wood Preserving Company’s daily operations and the possible creosote-contaminated

areas. One local area resident helpfully responded to U.S. EPA’s request and pinpointed where

several of the creosote-contaminated areas were on the site. Other residents contacted Mark Dumo,

the OSC, with information about the Baker Wood Preserving Company’s office buildings and daily

operations. Based on the community’s contributed knowledge of the company and the site, U.S.

EPA has been successful in tracing the company’s history and in locating predominantly creosote-

contaminated areas on the site.

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Table 1. Schedule of Community Involvement Activities

ACTIVITY TIMEFRAME

Maintain an administrative record Continual

Maintain a point of contact Continual

Expand and update the mailing list As needed

Develop and distribute fact sheets As needed:

• To inform the community after significant

new findings are discovered

• To explain proposed cleanup plans

• To afford the opportunity to request a

public meeting

Prepare press releases As needed:

• To inform the community after significant

new findings are discovered

• To afford the opportunity to request a

public meeting

Coordinate a public meeting As needed

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APPENDIX A

List of Interested Parties, U.S. EPA Representatives, State of Ohio Representatives, Media Organizations, and Elected Officials

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Appendix AList of Interested Parties, U.S. EPA Representatives, State of Ohio

Representatives, Media Organizations, and Elected OfRcials

Federal Elected Officials State Elected Officials

U.S. Senator George V. Voinovich 317 Hart Senate Building Washington, D.C. 20510 (202) 224-3353

District Office 37 West Broad Street Room 960Columbus, OH 43215 (614) 469-6697

U.S. Senator Mike Dewine 140 Russell Senate Building Washington, D.C. 20510 (202)224-2315

District Office 37 West Broad Street Room 960Columbus, OH 43215 (614) 469-5186

U.S. Representative Mike Oxley 2233 Rayburn House Office Building Washington, D.C. 20515 (202) 225-2676

District Office 100 East Main Cross Street Findlay, Ohio 45840 (419) 423-3210

Governor Bob Taft 77 South High Street 30'*’ FloorColumbus, Ohio 43266-0601 (614) 466-3555

District Office 77 South High Street 29'*’ FloorColumbus, Ohio 43266-0601 (614) 466-9627

State Senator Larry A. Mumper Senate Building Room #035, First Floor Columbus, OH 43215 (614) 466-8049

State Representative Robert Gooding 77 South High Street 10'*’ FloorColumbus, OH 43266-0603 (614)644-6265

City of Marion Elected Officials

Jack Kellogg Mayor233 West Center Street Marion, OH 43302 (740)387-3591

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Citv Council Joan StewardClerk of Council

Paul VitartasPresident

(740) 383-5816

(740)383-4538 Citv of Marion Officials

Scott Schertzer Dale OsbornCity Council At-Large Safety/Service Director(740) 387-6509 233 West Center Street

Marion, OH 43302Bob CoyerCity Council At-Large

(740) 387-5865

(740)383-3970 Mike FieldingCity Health Commissioner

Paul Cressor 233 West Center StreetCity Council At-Large Marion, OH 43302(740) 387-6734 (740) 387-2875

Ralph Cumpston, IIL‘ Ward

Marion Countv Elected OfHcials

(740) 383-4500 Kathy LyonsMarion County Commissioner

Phil Hatch 100 North Main Street2"' Ward Marion County Courthouse(740) 383-5917

Michael Thomas

Marion, OH 43302-3089 (740) 387-9947

3^^* Ward M. Kirk Moreland(740) 387-8141 Marion County Commissioner

100 North Main StreetAimee Davis Marion County Courthouse4^'’ Ward Marion, OH 43302-3089(740) 382-2992 (740) 387-9947

Brian Hempstead John Watkins5'*’ Ward Marion County Conmiissioner(740)383-1315 100 North Main Street

Marion County CourthouseC. Richard Arndt Marion, OH 43302-30896'" Ward (740) 389-4537

(740) 387-9947

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Marion County Officials U.S. EPA Representatives

Lowell LufkinDirector, Environmental Health Marion County Health Department 98 McKinley Boulevard Marion, OH 43303 (740) 387-6520

Keith A. Bailey District Coordinator DKMM Solid Waste District 203 South Prospect Street Marion, OH 43302-3921 (740) 383-1551

Marion Township Elected Trustees

Peggy Blevins Marion Township Trustee 1120 Keener Avenue Marion, OH 43302 (740)383-5615

Joe DawsonMarion Township Trustee 523 Carolyn Drive Marion, OH 43302

Donald Golden Marion Township Trustee 1467 Lush Road Marion, OH 43302

Frank ReeverClerk of Marion Township 710 Vernon Heights Boulevard Marion, OH 43302 (740)387-5308

Susan PastorCommunity Involvement Coordinator U.S. EPA (P-19J)77 West Jackson Boulevard Chicago, IL 60604 (312)353-1325 1-800-621-8431 [email protected]

Mark Dumo On-Scene Coordinator U.S. EPA (ME-W)25089 Center Ridge Road Westlake, OH 44145 (216) 522-7260 [email protected]

State of Ohio Representatives

Jeff SteersAsst. Chief, Northwest District Office Ohio EPA Northwest District Office 347 North Dunbridge Road Bowling Green, OH 43402 (419) 373-3079 Jeff, steers @epa.state.oh.us

Steve SnyderEnvironmental SpecialistOhio EPA Northwest District Office347 North Dunbridge RoadBowling Green, OH 43402(419) [email protected]

A-5

Ying FengManager, Environmental Health and ToxicologyOhio Department of Public Health 246 North High Street Columbus, OH 43302 (614)466-3543 [email protected]

Bob FreyOhio Department of Public Healtn 246 North High Street Columbus, OH 43302 (614)466-1069 [email protected]

Media Organizations

Newspaper

The Columbus Dispatch 34 South Third Street Columbus, OH 43215 (614) 461-5200 1-800-282-0263

Marion Star 150 Court Street Marion, OH 43302 (740) 387-0400

Television

Tom Griesdom General Manager WBNS-TV P.O. Box 1010 Columbus, OH 43216 (614) 460-3700

Sam Stallworth General Manager WSYX-TV, and WTTE-TV 1261 Dublin Road Columbus, OH 43215 (614) 481-6666

Dale Ouzts General Manager WOSU-TV2400 Olentangy River Road Columbus, OH 43210 (614) 292-9678

Bill Katsafanas General Manager WCMH-TV3165 Olentangy River Road Columbus, OH 43202 (614) 263-5555 1-800-232-9264

Radio

Diana Glassmeyer Manager WMRN AM-FM 1330 North Main Street Marion, OH 43302-1525 (740)387-8173

Diana Coon Station Manager WMAN AMRegency Communications P.O. Box 8 1400 Radio Lane Toledo, OH 44901 (419) 529-2211

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Michael Randolph Station Manager WCBE FM 540 Jack Gibbs Road Columbus, OH 43215 (614) 365-5555

John Potter General Manager WCOLFM 1301 Dublin Road Columbus, OH 43215 (614)273-9265

Alan Goodman Station Manager WVKO AM 4401 Carriage Hill Lane Columbus, OH 43220 (614)451-2191

Interested Groups

Susan StuderOhio Environmental Council 1207 Grandview Avenue Suite 201Columbus, OH 43212 (614) 487-7506

JeffSkeldingScioto River Valley Federation 4631 Olentangy Boulevard Columbus, OH 43214-2539 (614)263-8113

Marilyn WallSierra Club - Ohio Chapter 515 Wyoming Avenue Cincinnati, OH 45215 (513)761-4003

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APPENDIX B

Locations for a Public Meeting

and Administrative Record


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Appendix BLocations for a Public Meeting

and Administrative Record

Administrative Record Location

Marion Public Library 445 East Church Street Marion, Ohio 43302

Telephone Number; (740) 382-3951Hours of Operation: Monday through Friday 9 a.m. - 9 p.m.

Saturday 9 a.m - 5:30 p.m.Sunday 1 - 5 p.m.

Possible Public Meeting Location

Marion County Courthouse 100 North Main Street Marion, Ohio 43302

Telephone Number: (740) 387-5871

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Reference 4

LETTER REPORT FOR

THE BAKER WOOD CREOSOTING SITE MARION, MARION COUNTY, OHIO

TDD: S05-9808-011 PAN: 8G1101SIXX

START DOCUMENT CONTROL NUMBER: START-05-23-05096

November 15,1999

Prepared for:

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Emergency Response Branch 77 West Jackson Boulevard

Chicago, Illinois 60604

Prepared by:Kelly S^thj START Project Manager

Date: J l-i^-99

Reviewedandapproved by: ^

Anne A. Busher, Assistant START Program ManagerDate:

ec eiiviroiimeiit., incol&I 6777 ENGLE ROAD, CLEVELAND, OHIO 44130, TEL. (216) 243-3330

International Specialists in the Environment

recycled paper

II )gy aiici esi¥sroiMiieiif<5International Specialists in the Environment

6777 Engle RoadCleveland, Ohio 44130Tel: (216) 243-3330, Fax: (216) 243-6923

November 15, 1999

Ms. Gail NabasnySTART Project Officer (SE-5J)United States Environmental Protection Agency Emergency Response Branch 77 West Jackson Boulevard Chicago, Illinois 60604-3690

Baker Wood Creosoting Site Marion, Marion Coimty, Ohio TDD: S05-9808-011 PAN: 8G1101SIXX

Dear Ms. Nabasny:

The United States Environmental Protection Agency (U.S. EPA) tasked the Ecology and Environment, Inc. (E & E), Superfimd Technical Assessment and Response Team (START) to assist U.S. EPA On-Scene Coordinator (OSC) Mark Dumo in conducting a site assessment (SA) at the Baker Wood Creosoting (BWC) site in Marion, Marion County, Ohio. START was requested under Technical Direction Document (TDD) number S05-9908-011 to prepare and implement a health and safety plan, compile background information, conduct a site assessment, perform baseline air sampling, document on-site activities, and evaluate threats to human health and the environment posed by the BWC site. Site activities were conducted on December 2, 1998; January 11 and 12, 1999; January 21, 1999; and April 7 and 8, 1999.

SITE BACKGROUND

The BWC site is located at 1022 Holland Road West in Marion, Marion County, Ohio (Attachment A).The geographical coordinates for the BWC site are 40°35'37"N latitude and 83°09'20"W longitude. The BWC site is approximately 60 acres in size and is located on the western edge of the City of Marion. The site is located in a mixed residential, agricultural, and commercial area situated at the northwestern comer of the intersection of State Route 309 and Holland Road West. The BWC site is bordered on the south by Union Tank Car, which is a cleaning operation for empty railcars. The BWC site is the former location of the Baker Wood Creosoting Company facility. The site is currently abandoned and unsecured with no workers on site.

Approximately 0.5 miles west of the site is North Rockswale Ditch, which flows west beneath and then parallel to Holland Road West until it meets the Little Scioto River. Along the southern border, adjacent to the BWC site is a combined sanitary/storm sewer. The sewer is located beneath Holland Road West and flows west until it discharges directly into North Rockswale Ditch. Maps of the City of Marion sewer system indicated the facility sewer tie-ins may still be in placed.

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SITE HISTORY

From the 1890s until the 1960s, the Baker Wood Creosoting Company operated at the site as a preserver of lumber products. A 1892 Sanborn insurance map refers to the western portion of the property as the railroad tie yard (^proximately 2,200 feet by 300 feet). In this area, railroad ties were preserved with creosote and stacked to dry. The railroad tie yard has become a densely overgrown woodltmd, containing several areas of stressed vegetation. The creosote operation was located on the eastern ]X)rtion of the property. The foundations of the old building and creosote storage tanks are still evident. The most likely process utilized at this fecility was to treat wood in pressurized cylinders with creosote, in combination with petroleum or solvents. It is not known if any other wood preserving techniques, such as using pentachlorophenol or aqueous solutions of copper, chromium, and arsenic were utilized during operations.

In the 1950s, the B^er Wood Creosoting Company merged with the D.B. Frampton Company of Columbus, Ohio, and continued to operate the site to preserve lumber products. The facility was purchased by Sims Brothers, Inc, which utilized the eastern portion of the BWC site from the 1970s imtil the 1990s. Sims Brothers, Inc., operated as a scrap metal salvage yard, specifically for railroad tank cars. However, it is not known what type of practices occurred during the salvage operations. The BWC site is presently owned by the Baker Wood Limited Partnership, which was created by the previous owner, Sims Brothers, Inc., of Marion, Ohio.

In October 1999, the Ohio Environmental Protection Agency (OEPA) conducted an Integrated Assessment (lA) at the BWC site. The lA was performed under the U.S. EPA site investigation protocol in order to determine if work or dispibsal practices released contaminants into the environment, specifically to the site’s soils and nearby surface water bodies. Soil samples were collected to determine the potential for direct exposure of contaminants to the public and to determine any potential migration pathways from the surface and subsurfece soils to the Little Scioto River. In addition, surface water samples were collected to determine the potential for surface and subsurface soils to leach contaminants to the Little Scioto River. Analytical results detected volatile organic compounds (VOC), polyaromatic hydrocarbons (PAHs), and pesticides in soil and surface water samples at levels above background. Refer to Appendix C for tables of comprehensive results from soil and surfece water samples.

SITE ACTIVITIES

On Decernber 2, 1998, START member John Nordine met with the U.S. EPA OSC Mark Dumo; U.S.EPA Technical Support Unit (TSU) representatives Mark Vendal and Jim Ursic; and Ohio State University (OSU) Professor Jeff Daniels at the BWC site to conduct a site visit to prepare for a future geophysical survey. Ground penetrating radar (GPR) and electromagnetic conductivity (EM) instriunents would be utilized to detect subsurfece variations in the former process area and to delineate the extent of creosote contamination. A site walk through of the former process area was conducted to locate potential survey areas. The proposed geophysical survey area, which is approximately 250 feet (ft) by 1,500 ft, includ^ the former process area. START preformed air monitoring activities, with no readings in the breathing zone above background observed during the site visit. Refer to Attachment B for photographic documentation of site activities. U.S. EPA OSC Dumo proposed that START arranged for the removal of the bmsh, debris, arid trees in the proposed survey area and the TDD was amended to include these activities.

On January 11 and 12, 1999, START member Nordine met with representatives from E & E

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subcontractor. Heritage Environmental Services (HES), of Indianapolis, Indiana, to clear the proposed geophysical area at the BWC site. HES representatives included John FafBn, an equipment operator and Mark Greeno, a laborer. HES used a bulldozer and a chainsaw to clear the surface of the proposed geophysical area. START preformed air monitoring activities, with no readings above background in the breathing zone observed during the clearing activities.

On January 21, 1999, START member Nordine.met with U.S. EPA OSC Dumo, U.S. EPA TSU crew Vandal and Ursic, OEPA representatives Steven Snyder and Dale McLane, OSU Professor Daniels, and four of his graduate students at the BWC site to conduct a geophysical survey. A grid, 100 ft by 300 ft with a line spacing of three feet, was laid out in a north to south alignment in the former process area. The GPR unit was setup with a 500 MHz antenna. TTie GPR unit utilized was a Geophysical Survey Systems, Inc., SIR, Model PSIOAC and CD-IOA. The survey started on the east end of the grid, and data was collected north to south, and south to north. The EM survey used a G.I. GEM 300 instrument and was started on the west end of the grid. The G.I. GEM 300 instrument was used in the continuous read mode, and data was collected north to south, and south to north with a line spacing of three feet. START preformed air monitoring activities, with no readings above background in the breathing zone were observed during the geophysical activities. The geophysical surveys indicated that the contamination is localized in the process area. This localized area of contamination is referred to as the source.

On April 7 and 8, 1999, START members Justin Bowerman and Wade Balser conducted baseline air sampling at the BWC site. A total of 16 air samples were collected from the former processing area of BWC site. Samples consisted of eight summa canister samples analyzed for non-polar VOC and tentatively identified compounds and eight sorbent tubes samples analyzed for PAH compounds. One summa canister sample and one sorbent tube sample were set up at each of eight sample locations. AU-01 was located upwind of the source and utilized as a background location. AD-02 was downwind of the source and used to assess o£f-site migration . AXL-03 and AXR-04 were crosswind of the source and used to assess ofF-site migration. AS-05 was located at the source and used to assess source contamination. ASB-06, ASB-07, and ASB-08 were downwind at the boundary of the source to determine source area contamination. All samples were analyzed by Air Toxics, LTD, located in Folsom, California, under TDD number S05-9904-802. Refer to Attachment D for tables of analytical results and Attachment E for data review memorandums.

DISCUSSION OF THREATS

The conditions at the Baker Wood Creosoting site constitute an imminent and substantial danger to public health and welfare or the environmental based upon the considerations set forth in the National Contingency Plan, 40 Code of Federal Regulations Section 300.145(b)(2) which include, but are not limited to, the following:

• High levels of hazardous substances or pollutants or contaminants in soils largely at or near the surface, that may migrate; High levels of VOC and PAH, constituents of industrial waste, which have migrated from the site and have been deposited in the sediments of the Little Scioto River. Levels of these compounds in the site’s soil and sediment exceed action levels for hydrocarbon-contaminated soil. “The State of Ohio action levels for hydrocarbon-contaminated soil are 0.006 to 0.500 parts per million (ppm) benzene, 4 tol2 ppm toluene, 6 to 18 ppm ethylbenzene, and 28 to 85 ppm total xylenes.” Analytical results from site soU sample exceed these levels with benzene at 9.5 ppm, toluene at 51 ppm, ethyl benzene at 37 ppm, and total xylene

3

at 170 ppm. Due to this and the potential pathways for waste to enter the Little Scioto River, it lends further support to the conclusion that the surface water quality of the Little Scioto River is at risk. The highest levels of contamination on site have been docmnented to be within 1 foot of the ground sur&ce and the likelihood if contaminants migrating off site are high.

Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances or pollutants or contaminants; The VOC and PAH compounds present at the BWC site present direct contact threats (via dermal absorption and inhalation pathways) to members of the public accessing the area. VOC detected in the soil within 1 foot from the surface consisted of 2-butanone, ranging from 14 parts per billion (ppb) to 42 ppb; benzene, ranging from 5 ppb to 9,500 ppb; toluene, ranging from 8 ppb to 51,000 ppb; ethyl benzene, ranging from 46 ppb to 37,000 ppb; styrene, '^jnging from 4 ppb to 22,000 ppb; and xylene (total), ranging from 110 ppb to 170,000 ppb. In addition, PAH compounds detected consisted of naphthalene, ranging from 2.6 parts per million (ppm) to 13,000 ppm; 2-methylnaphalene, ranging from 1 ppm to 7,700 ppm; acenaphtUene, as high as 27 ppm; acenaphthene, ranging from 0.46 ppm to 6,800 ppm; dibenzofiiran, ranging from 0.94 ppm to 6,600 ppm; fluorene, ranging from 0.42 ppm to 10,000 ppm; phenanthrene, ranging from 1.7 ppm to 20,000 ppm; anthracene, ranging from 1.2 ppm to 33,000 ppm; carbozole, ranging from 0.74 ppm to 13,000 ppm; fluoranthene, ranging from 6.7 ppm to 6,400 ppm; pyrene, ranging from 8 ppm to 4,800 ppm; benzo(a)anthracene, ranging from 4.7 ppm to 1,200 ppm; chrysene, ranging from 5 ppm to 1,110 ppm; benzo(b)fluoranthene, as high as 780 ppm; benz^)fluoranthene, as high as 720 ppm; benzo(a)pyrene, ranging from 2.9 ppm to 130 ppm; indo(l,2,3-cd)pyrene, as high as 51 ppm; and benzo(g,h,i)perylene, as high as 60 ppm.

The site is unsecured and is located in a mixed industrial, rural, and residential area. The hazardous constituents of the BWC waste also present direct contact (dermal absorption) and food chain (ingestion) impact threats to a diverse population of large and small animals inhabiting the rural and wooded portions of the site.

OEPA has already demonstrated that the Little Scioto River water and sediment have been adversely impacted as a result of historic discharge from the BWC site. Therefore, the threat of a “discharge” as defined in Section 311(a)(2) of the Clean Water Act (CWA) and Section 1001(7) of the Oil Pollution Act is possible at or near the site. Discharge is defined as any spilling, leaking, pumping, pouring, emitting, emptying, or dumping of oil, but excludes discharges in compliance with a permit under section 402 of the CWA. This is significant in that the Little Scioto River is a tributary to the Scioto River. The Scioto River is a tributary to the Olentangy River and the Ohio River, all of which are major United States waterways for commercial and recreational purposes.

The BWC site poses an imminent and substantial threat to the public health or welfrue because of the threat of discharge of petroleum derived tar from the site in violation of Section 311(b) of the CWA.

Actual or potential contamination of drinking water supplies or sensitive ecosystems; The Little Scioto River is a sensitive ecosystem that drains to other sensitive areas. Sediment samples collected from the river bottom adjacent to the BWC site and past evidence demonstrates that elevated levels of VOC and PAH compounds have entered the creek from the wastes deposited at the BWC site.

While actual contamination of residential drinking water has not been documented, water quality in local residential wells has been fully evaluated. Moreover, since high levels of benzene, toluene, and xylene are associated with the waste in the Little Scioto River, the potential for these mobile, volatile contaminants, as well as PAH contaminants, to contaminate local groundwater may be high. The City ofMarion municipal water wells are located within two miles of the site. levels of these compounds in the site’s soils and sediments greatly exceed the State of Ohio action levels as stated above. The City of Marion’s municipal water intakes are located ^proximately 1/4 mile upstream from the visibly-contaminated sediments in the Little Scioto River.

• The availability of other appropriate federal or state response mechanisms to respond to the release; To date, OEPA h^ not had the resources to address the BWC site and requested the U.S. EPA’s assistance in evaluating and mitigating site conditions. OEPA has indicated, however, that it may be able to provide ongoing, but limited, support in effort to determine the full impact of waste at the site in order to frcilitate short-term U.S. EPA stabilization as well as to assist in the evaluation and planning of future remedial response activities.

The preparation of this letter report serves as final deliverable and completes this TDD, as the OSC did notrequire any additional assistance from START. If you have any questions or require any additionalinformation regarding this site, please contact this office.

Sincerely,

Kelly A. SmithSTART Project Manager

^ K---Anne A. BusherSTART Assistant Program Manager

Attachments: A Site MapsB Photodocumentation C OEPA Analytical Data D Analytical Tables E Data Review Memorandum

cc: Mark Dumo, U.S. EPA On-Scene Coordinator, Westlake, Ohio Mary Jane Ripp, START Program Manager, Chicago, Illinois File

Reference 5

State of Ohio EnviromnentaJ Protection Agency

STREET ADDRESS: MAJUNG ADDRESS:

1600 WaterMarIc Drive Columbus. OH 43215-1099

TELE: (6i4) 644-3020 FAX: (614) 644-23^June 12, 1998

P.O. Box 1049 Columbus. OH 43216-1049

Mr. Jason El-ZeinEmergency Response Branch, Chief U.S. EPA, Room 2169311GrohRoad , ...... .. -Grosse He, MI 48138-1697 ^ - - ■" ' - -

Re: Baker Wood Creosoting, MarionDear N^Cfel^ein: .

The purpose of this correspondence is to request that a USEPA OSC perform a site reconnaissance on the Baker Wood Creosoting site in Marion, Ohio and evaluate the site for a possible time- critical removal action. Ohio EPA performed an Integrated Assessment (LA) on the site in 1996. The result of this LA determined, at a minimum, the site should be prioritized high on the list for Site Assessment Team (SAT) formation and a consequent non-time critical removal action. In addition, Ohio EPA is concerned that concentrations of PAHs on the site exceed USEPA removal levels creating a surface soil exposure pathway (site is not secured).

A surface water pathway also exists. Historical information indicates that the Baker Wood Creosoting Company discharged waste creosote materials directly to the City of Marion storm sewer. This sewer provided a pathway for creosote materials to be transported to Rockswale Ditch and then into the Little Scioto River. Please note that there is a no contact/no fish consumption advisory for a four mile section of the Little Scioto River issued in 1992 by the Ohio Department of Health.

Ohio EPA has contacted the site owners and requested a fence be placed around the site to restrict access. The owners agreed to post "no trespassing" signs but refused to put up a fence. We are requesting an OSC evaluate the site to determine if time critical actions should be taken to restrict access and/or conduct removal actions.

Please have the assigned OSC contact Karl Reinbold of the Site Investigation Field Unit at 614/728- 1721, to set up a date and time to conduct the site visit. Mike Czeczele is the district contact from our Bowling Green Office. Mike can be reached at 419/373-3146.

Please let me know what you think and^f^^free to call me at 614/ 644-2083 with any questions.

Sincei^ly,

^-------

Kivin C. Clouse, Manager Emergency Response & Special Investigations

cc: Scott Shane, ERSIS/COSteve Snyder/Mike Czeczele, ERSIS-NWDO Jeff Hines, Acting Chief, DERR Karl Reinbold, SIFU

ri.

J

JUN 1 8 199a

George V. Voinovich. Governor Nanc,- F. L’.. Goven>or

Reference 6

DRAFT OSC REPORT BAKER WOOD CREOSOTING SITE MARION, MARION COUNTY, OfflO

Prepared for

U.S. ENVIRONMENTAL PROTECTION AGENCY Region 5 Emergency Response Branch

25089 Center Ridge Road Westlake, Ohio 44145

TDD No.;Date Prepared:Contract No.:Prepared by:START Project Manager: Telephone No.:U.S. EPA On-Scene Coordinator; Telephone No.:

S05-0012-009 August 16, 2004 68-W-00-129 Tetra Tech EM Inc. Kelly Smith (440)234-0886 Mark Dumo (440)250-1743

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION 5

DATE: August 16, 2004

SUBJECT: ON-SCENE COORDINATOR’S REPORT - Removal Action at the Baker WoodCreosoting site, Marion, Marion County, Ohio, Site ED# B591

FROM: Jason El-Zein, Acting ChiefEmergency Response Branch, SE-5J

TO: Richard Karl, Actomg DirectorR5-R7 Accelerated Response Center, 5201-G

THROUGH: William E. Muno, Director Division of Superfund, S-6J

Please find attached the United States Environmental Protection Agency (U.S. EPA) On-Scene Coordinator’s (OSC) report for the removal action conducted at the Baker Wood Creosoting site in Marion, Marion County, Ohio. This report follows the format outlined in the National Oil and Hazardous Substances Pollution Contingency Plan, Section 300.165. The removal was initiated on April 22, 1999, and was completed on July 17, 2003. The OSC for this site was Mark Dumo.

U.S. EPA took the action to mitigate immediate threats to public health, welfare, and the environment posed by abandoned chemicals at the site. The chemicals were used to preserve lumber products from approximately 1890 to 1960. The process most likely used at the site was wood treatment in pressurized cylinders using creosote in combination with petroleum or other solvents. During the removal action, contaminated soil was excavated and either sent off site for final disposal or pretreated through landfarming and then sent off site for final disposal.

Costs under control of the OSC are estimated at $(insert final cost), of which $1,147,085.52 was for the Emergency and Rapid Response Services contractor. Additional costs incurred by state and local agencies are not included in these costs.

In this OSC report, any specific costs incurred at the site are only approximate and subject to audit and final determination by U.S. EPA. The OSC report is not a final presentation of the costs associated with a particular site.

Portions of the OSC report appendices may contain confidential business or enforcement-sensitive information and must be reviewed by the Office of Regional Counsel prior to release to the public. The Baker Wood Creosoting site is not on the National Prionties List.

Attachment

cc: K. Mould, U.S. EPA, OERR, 5202-G, with OSC Report

DRAFTON-SCENE COORDINATOR’S REPORT


NPL STATUS: NON-NPL

Removal Dates: 4/22/99-7/17/2003

UNITED STATESENVIRONMENTAL PROTECTION AGENCY

Emergency Response Branch Superflind Division

Region 5

EXECUTIVE SUMMARY OF REMOVAL ACTIVITY

SITE: Baker Wood Creosoting Site

LOCATION: Marion, Marion County, Ohio

PROJECT DATES: 4/22/1999 - 7/17/2003

INCIDENT DESCRIPTION: The Baker Wood Creosoting (BWC) site is not listed on the National Priorities List. This site is a former lumber preserving facility located in the City of Marion at the northwestern comer of the intersection of State Route 309 and Holland Road in Marion, Marion County, Ohio.

The former Baker Wood Preserving Company operated the BWC site from approximately 1890 to 1960. The process most likely used at the facility was wood treatment in pressurized cylinders vrith creosote, in combination with petroleum or other solvents. The Ohio Department of Health (ODH), predecessor to the Ohio Environmental Protection Agency (OEPA), first cited the Baker Wood Preserving Company as a contributor of contamination to surface water on September 4, 1946. In a letter dated December 4,1946, to the Baker Wood Preserving Company, the ODH informed the company that it should install a waste treatment system. The treatment system was not in place until May 1953. Following the installation of the treatment system, ODH dpcumented the discharge of creosote materials from the Baker Wood Preserving Company property.

Analytical results obtained by the OEPA and the Superfund Technical Assessment and Response Team (START) indicate that volatile organic compounds (VOC) and polycyclic aromatic hydrocarbons (PAH) are present in the soil at the BWC site at elevated levels that present a human health threat through direct contact to members of the public accessing the site area. The BWC site was unsecured prior to removal actions and located in a mixed industrial, rural and residential area. Hazardous constituents present at the BWC site also present a threat to the environment. OEPA has documented that surface water and sediment in the Little Scioto River have been adversely impacted by site-related contamination. The Little Scioto River is a tributary to the Scioto, Olentangy, and Ohio Rivers. There is a great potential for the migration of contamination in the soils at the site through the air, surface water, and ground water pathways

On April 20, 1999, The United States Environmental Protection Agency (U.S. EPA) initiated a removal action at the site to mitigate threats to public health and the environment posed by the presence of PAHs at the BWC site. Funding for the removal action was provided under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA).

ACTIONS: In April 1999, U.S. EPA On-Scene Coordinator (OSC) Mark Dumo initiated a removal action at the BWC site. A task order was issued to the Emergency and Rapid Response Service (ERRS) contractor. Environmental Quality Management, Inc. (EQM), located in Cincinnati, Ohio. U.S. EPA, START, and ERRS mobilized personnel and equipment to the BWC site.

The following removal activities were performed: site mobilization and set-up, excavation of contaminated soil from the former process area, test pit and trench excavation, Little Scioto River assessment, excavation and staging of the secondary contamination area, landfarming set-up, landfarming, and disposal of contaminated materials. Under EQM’s Deliveiy Order No. 68-5S-9801-0026, a total of 3,565 tons of contaminated soil from the former process area was transported to Environmental Quality (EQ), Wayne Disposal in Belleville, Michigan, for final disposal. A total of 4,010 tons of non-hazardous soil was transported to County Environmental in Carey, Ohio, for disposal after landfarming activities. All removal activities were completed on July 17, 2003.

Mark Dumo U.S. EPA, Region 5 Westlake, Ohio

TABLE OF CONTENTS

Section Page

Executive Summary....................................................................... iiList of Figures ............................................................................................................................................. vList of Tables................................................................................................................................................. viOSC Report Standard Appendices List.................................................................................................... vii

l. SUMMARY OF EVENTS............................................................................................................. 1A. Site Conditions and Background...................................................................................... 1

1. Initial situation ...................................................................................................... 12. Location of hazardous substance(s).................................................................... 43. Cause of the release or discharge........................................................................ 44. Efforts to locate and obtain response by responsible parties............................. 5

B. Organization of the Response.......................................................................................... 5C. Injury or Possible Injury to Natural Resources................................................................ 5

1. Content and time of notification to natural resource trustees ............................ 52. Trustee damage assessment and restoration actives........................................... 5

D. Chronological Narrative of Removal Activities.............................................................. 71. Threat abatement actions taken ........................................................................... 7

1.1 Site mobilization and set-up .................................................................. 71.2 Former process area excavation ............................................................ 71.3 Test pit and trench excavation study............................................... . . . 81.4 Little Scioto River assessment . .......................................................... 131.5 Excavation of secondaiy'contamination area ..................................... 131.6 Landfarming set-up............................................................................... 131.7 Landfarming ........................................................................................ 141.8 Disposal of treated waste...................................................................... 16

2. Treatment, disposal, or alternative technology approaches pursued.............. 163. Public information and community relations activities................................... 17

E. Resources Committed ................................................................................................ .. . 17

n. EFFECTIVENESS OF REMOVAL ACTIVITIES..................................................................... 17A. Actions Taken by PRPs.................................................................................................. 17B. Actions Taken by State and Local Agencies................................................................... 17C. Actions Taken by Federal Agencies and Special Teams .............................................. 17D. Actions Taken by Contractors, Private Groups, and Volunteers ................................... 17

m. DIFFICULTIES ENCOUNTERED............................................................................................ 18A. Items That Affected the Response........................................ 18B. Issues of Intergovernmental Coordination .................................................................... 18C. Difficulties Interpreting, Complying With, or Implementing Policies and Regulations 18

IV. RECOMMENDATIONS.............................................................................................................. 20A. Means to Prevent a Recurrences of Discharge or Release ........................................... 20B. Means to Improve Removal Activities ................................ 20

IV

LIST OF FIGURES

Figure P^e

Site Location............................................................................................................................... 2

Site Features

LIST OF TABLES

Table Page

1 Organization of Response.............................................................................................. 6

2 Soil Sample Analytical Results .................................................................................................... 9

3 Air Sample Analytical Results for Polycyclic Aromatic Hydrocarbons ................................... 11

4 Air Sample Analytical Results for Volatile Organic Compounds.............................................. 12

5 Removal Project Estimated Total Costs .......... 19

VI

Emergency Response Branch Office of Superfund, U.S. EPA, Region 5

OSC REPORT STANDARD APPENDICES LIST*

Site Name: Baker Wood Creosoting Site, Marion, Manon County, Ohio

Site ID #: B591 Delivery Order #: 68-5S-98-01-0026

1. OPERATIONAL FILES

2.

- Action Memos/ Additional Funding Requests/ Time Exemptions- POLREPs- Site Entry/Exit Log- Hot Zone Entry/Exit Log- Site Safety Plan- Site Logs- Community Relations Plan- Daily Work Orders/Daily Work Reports- Site Monitoring Logs (Air, Equipment)- Site Maps- Site Contacts/Business Cards- General Correspondence/Information- Newspaper Articles- Site Photos/Videos- Security Guard Reports- Administrative Order- General Notice Letters/104(e) Information Requests- Administrative Record- Enforcement

FINANCIAL FILES

- Delivery Order/Procurement Requests/Modifications to Contract (ERRS)- Technical Direction Documents/Modifications (START)- Daily Cost Reporting U.S. EPA Form 1900-55s (ERRS)- Daily Cost Reporting U.S. EPA Form 1900-55s (Government)- Await and Final Bill Tracking Logs- Incident Obligation Log- ERRS Invoices- Subcontract Bid Sheets- START Cost Documentation Forms

1-A1-B1-C1-D1-E1-F1-G1-Hl-I1-J1-K1-L1-M1-N1-01-P1-Q1-R1- S

ID#

2- A 2-B 2-C 2-D 2-E 2-F 2-G 2-H 2-1

VI1

OSC REPORT STANDARD APPENDICES LIST (continued)

TECHNICAL FILES

- State Information- Analytical Results- Manifest- Disposal Information- Vat and Tank Logs- Drum Logs- Compatibility Results- Chain of Custody- Waste Profile Sheets

ID#

3-A3-B3-C3-D3-E3-F3-G3-H3-1

Portions of these OSC report appendices contain confidential business information or enforcement-sensitive information and must be reviewed by the Office of Regional Counsel prior to release to the public.

Certain files for this site are maintained elsewhere by the Emergency Response Branch. The appendices listed here are those files maintained by the OSC during the removal action.

Vlll

I. SUMMARY OF EVENTS

A. Site Conditions and Background

1. Initial situation

The Baker Wood Creosotmg (BWC) site is located at the northwestern comer of the intersection of State Route 309 and Holland Road in Marion, Ohio. The geographical coordinates for the BWC site are latitude 40°35'37" north and longitude 83°09'20" west (see Figure 1).

The BWC site encompasses approximately 100 acres and is located in a mixed residential, agricultural, and commercial area. The BWC site is bordered to the south by Holland Road and Union Tank Car, Inc. and to the northeast by Kenton Road (State Route 309). Approximately 0.5 mile west of the BWC site. North Rockswale Ditch crosses under Holland Road. At this point, a combined sanitary/storm sewer travels beneath Holland Road. North Rockswale Ditch then parallels the road for approximately a 0.5 miles before discharging into the Little Scioto River (see Figure 2).

The former Baker Wood Preserving Company operated as a preserver of lumber products in Marion from approximately 1890 to 1960. A 1892 Sanborn insurance map indicates that railroad ties were preserved at the site using creosote and stacked to dry on the western portion of the property referred to as the railroad tie yard measuring approximately 2,200 feet by 300 feet. The process most likely used at the site was wood treatment in pressurized cylinders using creosote in combination with petroleum or other solvents. The Ohio Department of Health (ODH), predecessor to the Ohio Environmental Protection Agency (OEPA), first cited the Baker Wood Preserving Company as a contributor of contamination to surface water on September 4, 1946. In a letter dated December 4, 1946, to the Baker Wood Preserving Company, the ODH informed the company that it should install a waste treatment system. The treatment system was not in place until May 1953. Following the installation of the treatment system, ODH documented the discharge of creosote materials from the Baker Wood Preserving Company property. The D.B. Frampton Company merged with the Baker Wood Creosoting Company in the 1950s. Specific practices during their operations are unknown.

From 1970 until the early 1990s, the eastern portion of the BWC site was used as a scrap metal salvage yard. Sims Brothers, Inc., salvaged metal railroad tank cars at the yard. Sims Brothers, Inc., purchased the BWC site from the D.B, Frampton Company of Columbus, Ohio, in 1970.

B3°10'40" W 83°10'10" W 83°09'40" W

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\


TDD NO.:S05-0012-009

MarionFIGURE 1

SITE LOCATION

ESletra Tech EM Inc.

n

RESIDENTIAL AND COMMERCIAL PROPERTY

FARM LAND

APPROXIMATELY 0.5 MILE

AREA

HOLLAND ROAD

COMBINED SANITAI SEWER OVERFLOW


TDD NO.: S05-0012-009

FIGURE 2

SITE features

iSTetra Tech EM /nc.

Location of hazardous substance(s)

fiii

Analytical results obtained by OEPA and Superfund Technical Assessment and Response Team (START) contractor Ecology and Environment, Inc. (E & E), indicate that volatile organic compounds (VOC) and polycyclic aromatic hydrocarbons (PAH) are present at the BWC site in soil at elevated levels that present a human health threat through direct contact to members of the public accessing the site. The BWC site was unsecured prior to removal activities and is located in a mixed industnal, mral, and residential area. Hazardous constituents present at the BWC site also present a threat to the enviromnent. OEPA has documented that the water and sediment in the Little Scioto River have been adversely impacted by site-related contamination. The Little Scioto River is a tributary to the Scioto, Olentangy River, and Ohio Rivers. There is a great potential for the migration of contamination in the soil at the site through the air, surface water, and ground water migration pathways.

Cause of the release or discharge

In October 1991, the OEPA Site Investigation Field Unit conducted a field investigation at the BWC site. The purpose of the investigation was to determine whether hazardous substances existed at and were migrating from the BWC site. The study concluded that PAHs were present in site soils.

On March 20, 1992, the ODH issued an advisory against swimming, wading, and eating fish caught in a 4-mile length of the Little Scioto River west of the city of Marion fi-om Holland Road south to State Route 739.

From August 1992 to February 1993, the OEPA Division of Surface Water conducted biological community, fish tissue, biomarker, sediment, and surface water sampling of the Little Scioto River. Sediment sampling was also conducted in the North Rockswale, Rockswale, and Columbia Ditches. These investigations indicated severe biological and water quality degradation in the Little Scioto River (at river mile 6.5), in the entire Rockswale Ditch, and in the lower 1 mile of the Columbia Ditch. Concentrations of PAH compounds in sediments from these areas were among the highest observed in published literature. Five of the PAH compounds identified in Little Scioto River sediment have been recognized as possible human carcinogens (benzo[a]anthracene, benzo[b]fluoranthene, benzo[a]pyrene, chrysene, and dibenzo[a,h]anthracene).

■Tj

On December 2, 1998, United States Environmental Protection Agency (U.S. EPA) On-Scene Coordinator (OSC) Mark Dumo, U.S. EPA Technical Support Unit representatives, E & E START, and a professor from the Ohio State University (OSU) met at the BWC site to conduct a site reconnaissance for a future geophysical suivey. The proposed geophysical sur\'ey area (approximately 250 by 1.500 feet) included the fonner process area.

On Januaiy 11 and 12 1999, E & E START and representatives from Heritage Environmental Services cleared bnish and debris from the proposed geophysical survey area. On January 2 L 1999, E & E START, U.S. EPA OSC Mark Dumo, representatives'from the U.S. EPA Technical Support Unit, OEPA, and OSU set up a grid and used a ground-penetrating radar (GPR) unit and an electromagnetic survey unit to survey the fonner processing area. A grid measuring 100 by 300 feet with a line spacing of 3 feet was established. The grid was set up with a north south-alignment. Surv'ey results indicated that most of the former process area was contaminated.

Efforts to locate and obtain response by responsible parties

No financially viable potentially responsible party (PRP) was found to undertake a full cleanup.

B. Organization of the Response

Removal activities at the BWC site were initiated by U.S. EPA on April 22, 1999. The lead OSC for the removal action was Mark Dumo. From April 22, 1999, through December 2000, E & E START members were present at the BWC site. In December 2000, Tetra Tech EM Inc. (Tetra Tech) assumed the START contractor role. From December 2000 through July 2003, Tetra Tech START members were present at the BWC site. Table 1 outlines the agencies and personnel involved in the removal activities at the BWC site and the action(s) each took or the role(s) each served.

C. Injury or Possible Injury to Natural Resources

1. Content and time of notification to natural resource trustees

No formal notification has been issued to the Ohio Department of Natural Resources or other organizations regarding the status of possible natural resource damage at the BWC site.

2. Trustee damage assessment and restoration activities

No damage assessment or restoration work was necessary at the BWC site.

TABLE 1

ORGANIZATION OF RESPONSEBAKER WOOD CREOSOTING SITEMARION, MARION COUNTY, OfflO

Agencies orParties Involved Contact

Description of Participation

U.S. EPA - Region 5Emergency Response Branch25089 Center Ridge RoadWestlake, Ohio 44145 (440)250-1743

Mark Dumo Federal OSC responsible for overall response activities

U.S. EPA-Region 5Emergency Response Branch77 West Jackson Blvd.Chicago, Illinois 606041-800-621-8431

Ginny Narsete Provided community relations and media support

OEPA-Northwest District Office347 N. Dunbridge Road419-373-3040

Steve SnyderJeff Wander

Provided historical information and assisted with assessment of Little Scioto River

Environmental Quality Management, Inc.1800 Carillon BoulevardCincinnati, Ohio 452401-800-500-0575

Scott StaehlingJoe Fesick

Provided personnel and equipment necessary for removal and conducted the cleanup

Clay M. Corman, Inc.2601 Wilmore RoadNicholasville, Kentucky 40356 (606)885-7139

Clay Corman Provided personnel and equipment for removal activities

Ecology & Environment, Inc. (E & E)33 North Dearborn StreetSuite 501Chicago, DL 60602 (312) 578-9243

Justin Boweirnan Provided OSC with technical assistance, administrative support, multimedia sampling, site documentation, and site safety support prior to December 2000

Tetra Tech EM Inc. (Tetra Tech)6801 Engle Road, Suite GMiddleburg Heights, Ohio 44130 (440) 234-0886

Kelly Smith Provided OSC with technical assistance, administrative, multimedia sampling, air monitoring, documentation, site safety support, and draft report preparation after December 2000

D. Chronological Narrative of Removal Activities

1. Threat abatement actions taken

1

Response activities were conducted under the authority of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Section 104(a). On April 20, 1999, William E. Mimo, Regional Administrator, Office of Superfimd, U.S. EPA Region 5, authorized fimding to mitigate the imminent and substantial threats to human health and the environment present at the BWC site. An action memorandum was approved on April 20, 1999, with authorized expenditures of up to $ 1,972,740 to mitigate threats to human health and the environment posed by site-related contamination. Delivery Order (DO) No. 68- 5S-98-01-0026 for $200,000 was issued to the Region 5 Emergency and Rapid Response Service (ERRS) contractor. Environmental Quality Management Inc. (EQM), on July 20, 2001. On April 21, 2001, authorized expenditures for DO No. 68-5S-98-01-0026 were increased to $1,200,000.

The following sections describe, in chronological order, removal actions at the BWC site which included site mobilization and set-up, former process area excavation, test pit and trench excavation. Little Scioto River assessment, excavation of the secondary contamination area, landfarming set-up, landfarming, and. disposal of treated waste.

1.1 Site mobilization and set-up

On April 22, 1999, U.S. EPA mobilized its contractors, ERRS and E&E START, to the BWC site to perform a site walk-through and to schedule removal activities.

Between April 26 and 29, 1999, site personnel and heavy equipment were mobilized to the BWC site. Vegetation was removed fi-om around potentially impacted areas. Office trailers were mobilized and electric and telephone services were installed. Security personnel were procured for all non-operating hours.

1.2 Former process area excavation

U.S. EPA ERRS, and E&E START conducted removal activities at the former process area between May 3 and 13,1999. Test pits were excavated to determine the extent of contamination in the former process area.. A total of 3,565 tons of contaminated soil was excavated from the former process area and transported to EQ, Wayne Disposal, in Belleville, Michigan, for final disposal. Clean backfill was delivered to the BWC site for backfilling excavated areas. A1 excavated areas were backfilled with clean soil, graded, and seeded. A1 construction fencing around the fomier process area was removed.

r-l < :•

Following excavation of an area, a composite confirmation soil sample was collected. The following soil samples were collected:

• CBW-01 from the western excavated area;• CBW-02 from the eastern excavation area;• CBW-03 from the northeastern section of the trench running along the

drainage ditch; and• CBW-04 from potentially contaminated soil approximately 40 feet north

of tank pad 4.

All soil samples were sent to Specialized Assays in Cincinnati, Ohio, for total VOC and total serriivolatile organic compound (SVOC) analysis. Table 2 summarizes soil sample analytical results.

E & E START conducted continuous air monitoring of the work zones during all intrusive work using a combustible gas indicator (CGI) and a photoionization detector (PID) or flame ionization detector (FID). Monitoring results indicated that Level C personnel protective equipment (PPE) was appropriate for activities. Site security personnel were on duty during non-operational hours

On May 3 and 4, 1999, six air samples and five SUMMA canister air samples were collected from the BWC site. The air samples were analyzed for PAH and creosols/phenols analyses and the SUMMA canister air samples were analyzed for VOCs. Samples were shipped to Air Toxics, LTD, in Folsom, California for analysis. Sampling locations consisted of downwind, upwind, crosswind, and source locations. Tables 3 and 4 summarizes air sample and SUMMA canister air sample analytical results.

Test pit and trench excavation study

Between May 17 and 21, 1999, test pit and trench excavation activities were conducted to determine the extent of contamination, if any, throughout the remainder of the BWC site.

Additional contamination was identified and delineated in four on-site areas. The combined volume of the four areas was estimated at approximately 1,455 cubic yards. Soil sample CBW-05 was collected to determine the hazardous constituents of additional waste discovered during trenching activities. The sample was sent to Specialized Assays in Cincinnati, Ohio, for total VOC and total SVOC analyses. Table 2 summanzes soil sample analytical results. Two entrances along the southern border of the BWC site were secured using heavy wire. During this time, five representatives from the OEPA visited the BWC site to observe site activities.

E & E START conducted continuous air monitoring of the work zones during all intrusive work using a CGI and a PID or FID. Monitoring results indicated that Level C PPE was appropriate for activities. Site security personnel were on duty during non-operational hours.

TABLE 2

SOIL SAMPLE ANALYTICAL RESULTSBAKER WOOD CREOSOTING SITEMARION, MARION COUNTY, OfflO

Sampling Date: May 4th to May 18th, 1999

Annlvtp®

Sample No.

CBW-01(mg/kg)

CBW-02(nig/kg)

CBW-03(Pg/kg)

CBW-04(gg/kg)

CBW-05(gg/kg)

••• ■ ■ ■ .g ' ---

Benzene ND ND 240 ND ND

n-Butylbenzene ND - ND ND ND 2,610

sec-Butylbenzene ND ND ND ND 2,280

n-Propylbenzene ND ND ND ND 2,040

Ethylbenzene ND ND 4,200 ND ND

Isopropylbenzene ND ■ ND 430 ND 918

4-Isopropyltoluene ND ND 333 ND ND

Napthalene 17.8 412.0 ND 7,700 ND ■'

Styrene ND ND 488 ND ND

Toluene ND ND 2,110 ND ND

1,2,4-Trimethylbenzene ND 0.68 10,700 ND 376

1,3,5-Trimethylbenzene ND 0.36 4,760 ND ND

Xylenes ND ND 9,260 ND ND

Sen.lvo,aMU organic '• •. •.''■‘a ,-VT: ■'A:; ;2;.

Acenaphthene ND 304 252,000 1,820 5,620

Acenaphthylene 4.12 ND 8,160 1,370 1,940

Anthracene 33.0 85.8 200,000 4,820 2,140

Benzo(a)anthracene 24.8 60.7 49,000 13,700 2,140

Benzo(a)pyene 29.7 40.3 23,700 21.100 1,940

Benzo(b)fluoranthene 42.9 92.4 32,600 36,700 1.940

TABLE 2

SOIL SAMPLE /\JNAL\nriCAL RESULTSBAKER WOOD CREOSOTING SITEMARION, MARION COUNTY, OfflO

Sampling Date: May 4th to May 18th, 1999

Analvtp*

Sample No.

CBW-01(mg/kg)

CBW-02(mg/kg)

CBW-03(Pg/kg)

CBW-04(Pg/kg)

CBW-05(gg/kg)

Benzo(g,h,i)perylene 10.6 9.24 4,490 J 2,630 1,940

Benzo(k)fluoranthene 41.2 92.4 28,200 25,600 1,940

Carbazole 9.4 38.9 89,000 816 ND

Chrysene 44.6 66.0 65,300 25,200 2.330

Dibenzofuran 14.2 271.0 215,000 1,660 4,850

Dibenz(a,b)anthrancene 7.92 ND ND 1,740 ND

2,4-Dimethylphenol ND ND 7,420 ND ND

Fluoranthene 56.1 495 311,000 31,900 ND

Fluorene 21.4 363 282,000. 2,000 8.150

Indeno( 1,2,3-cd)pyrene 12.4 11.2 5,250 J 2,790 1,940

2-Methylynaphthalene 6.76 85.8 267,000 816 36,500

2-Methyl phenol ND ND 4,490 J ND ND

m,p-Methyl phenol ND ND 3,000 J ND ND

Naphthalene 6.10 54.1 616,000 1,450 3,290

Phenanthrene 54.4 858.0 630,000 14,000 16,700

bis(2-ethylhexyl) phthalate ND ND ND 188 J ND

Pvrene 59.4 343 200 000 25 200 5 620

Notes:

mg/kg Milligram per kilogram pg/kg Microgram per kilogram

ND,1

Not detected Estimated value

List of analytes only includes compounds detected above detection limits.

: i!

„J

TABLE 3

AIR SAMPLE ANALYTICAL RESULTS FOR POLYCYCLIC AROMATIC HYDROCARBONSBAKER WOOD CREOSOTING SITEMARION, MARION COUNTY, OHIO

Sampling Date: May 3,1999

Analyte'

Sample Location

006(Downwind)(pg/sample)

008(Upwind)

(pg/sample)

009(Crosswind)(pg/sample)

010(Downwind)(pg/sample)

on(Upwind)

(pg/sample)

012(Source)

(pg/sample)

Naphthalene 3.0 BDL 28.0 86.0 BDL 79.0

2-MeliiyInaplilhalene BDL BDL 6.7 23.0 BDL 15.0

Acenaplilhene BDL BDL 2.6 9.5 BDL 5.1

I'liiorene BDL BDL BDL 3.4 BDL 1.5

Phenanthrene RDl, RDL RDT, 7 0 RDL RDL

Notes:

|ig/sample Microgram per sampleBDL Below detection limit

List of analytes only includes compounds detected above detection limits.

TABLE 4

AIR SAMPLE ANALYTICAL RESULTS FOR VOLATILE ORGANIC COMPOUNDSBAKER WOOD CREOSOTING SITEMARION, MARION COUNTY, OfflO

Sampling Date: May 4,1999

Analyte”

Sample Location

Summa 1(Crosswind)

(

Summa 2(Downwind)

( Rg/m^)

Summa 3(Crosswind)

( Rg/m^)

Summa 4(Upwind)

( Rg/m^)

Summa 5(Source)(iig/m^)

Chloromethane 4.0 J 4.3 J 4.4 J 4.4 J 5.1 J

Trichlorelhane ND 6.9 J ND ND ND

Toluene 19 4.2 J 6.8 J ND 12 J

m.p-Xylene ND 6.4 J 9.0 J ND 7.5 J

1,2,4-Trimclliylbenzene ND ND 7.6.1 ND ND

Acetone 11 J .10 J ND ND 10 J

Hexane 18 J ND ND ND ND

RthannI ND ES .1 ND ND ND

Notes:

Hg/m^ Micrograms per cubic meterND Not detectedJ Estimated value

l.ist ofanalytes only includes compounds detected above detection limits

1.4 Little Scioto River assessment

From June 7 though 16, 1999, E & E START mobilized to the BWC site to conduct a study of the extent of contamination on the Little Scioto River and North Rockswale Ditch. Sediment core samples were collected from the Little Scioto River and North Rockswale Ditch using a vibrocoring unit. OEPA provided GPS data support and a mobile laboratory trailer. A total of 79 samples were collected from the Little Scioto River, and 15 samples were collected from North Rockswale Ditch. Samples were processed to determine the extent of creosote contamination and to characterize the individual layers of sediment. A total of nine samples and two duplicate samples from the Little Scioto River were analyzed for VOCs, SVOCs, polychlorinated biphenyls, Resource Conservation and Recovery Act metals(including copper and zinc), and pesticides. In addition, the samples were analyzed for total organic content and particle size. It was estimated that approximately 4 miles of the Little Scioto River and 0.6 mile of North Rockswale Ditch are contaminated with creosote. The total volume of contaminated material was estimated at approximately 34,000 cubic yards.

Excavation of secondary contamination area

U.S. EPA, ERRS, and E & E START conducted removal activities at the secondary contamination area between June 21 and July 13, 1999. --Personnel and heavy equipment were mobilized to the site, transportation and disposal was coordinated, and an area was cleared for a truck tum-around.

Clean material from the contaminated area was removed and staged prior to excavation. Contaminated soil was excavated, staged, and covered with polyethylene sheeting until disposal and/or treatment options were finalized. All excavated areas were backfilled with clean soil.

Two 5-gallon buckets of contaminated material were collected for further investigation of landfarming treatment and other options. All heavy equipment was decontaminated and demobilized from the BWC site.

E & E START conducted continuous air monitoring of the work zones during all intrusive work using a CGI and a PID or FED. Monitoring results indicated that Level C PPE was appropnate for activities. Site security personnel were on duty during non-operational hours.

1.6 Landfarming set-up

Between October 13 and November 19, 1999, personnel and heavy equipment were mobilized to the BWC site to establish a treatment pad for landfarming activities. A work plan for land fanning activities was also drafted.

The treatment pad was established on the western portion of the BWC site. The

a

area to be used for the treatment pad was graded and covered with sand. On-site clay was excavated and transferred to this area to establish a berm around the treatment pad. A 20-millimeter-thick plastic liner measuring 300 by 360 feet was installed at the treatment pad, and sand was spread on top of the liner. Areas from which on-site clay had been excavated for the berm were backfilled.

After the treatment pad was established, a decontamination area was established and work zones delineated. Rainwater that had accumulated in the treatment pad was pumped out, and contaminated material was spread onto the treatment pad in seven landfarming windrows. Chicken manure was added to each windrow as a nutrient additive to aid in bioremediation. An additional additive. Biosolve™, was added to two of the seven landfarming windrows.

Five shallow monitoring wells were installed at the BWC site. All persormel and heavy equipment were demobilized from the BWC site for the winter months.

Landfarming

On March 14, 2000, E & E START collected initial samples from the landfarming windrows to monitor the degradation of contaminants. Analytical results indicated that the total average PAH concentration was 11,964 milligrams per kilogram (mg/kg), and the average plate count was 15,986 aerobic plate count per gram (APC/g).

Between May and September 2000, active landfarming was conducted at the BWC site. Heavy equipment was used to mix the seven landfarming windrows of contaminated material. Rainwater contained in the treatment pad was spread over the windrows of contaminated material. Samples were collected from the windrows to monitor the degradation of contaminants. Below is a summary of analytical results for 2000.

• May 18, 2000, analytical results indicated that the total average PAH concentration was 9,075 mg/kg, and the average plate count was 87,043 APC/g.

• June 28, 2000, analytical results indicated that the total average PAH concentration was 4,035 mg/kg, and the average plate count was 25,571 APC/g.

• August 2, 2000, analytical results indicated that the total average PAH concentration was 5,571 mg/kg, and the average plate count was 22,980 APC/g. This average PAH concentration was higher than the concentration for the sample collected on June 28, 2000. Increased PAH concentration was attributed to the fact that the soil was not completely homogenized.

On September 6. 2000, liquid fertilizer was spread on the windrows of contaminated material. The fenilizcr contains nutnents that accelerate the

14

degradation of contaminants. Site demobilization was then conducted at the BWC site for the winter months.

On March 13, 2001, multimedia sampling activities were conducted at the BWC site. Groundwater samples were collected from the five on-site monitoring wells. The samples were sent to Test America, Inc., in Nashville, Texas, for VOC and PAH analysis. Low concentrations of VOCs and PAHs were detected in samples from wells MW-04 (west of windrows) and MW-05 (east of the windrows). A 10-point composite soil sample was collected from each windrow. The soil samples were sent to Test America, Inc., in Nashville, Texas, for PAH analysis and to Q Laboratones Inc. in Cincinnati, Ohio, for total plate count analysis. Analytical results indicated that the total average PAH concentration was 3,764 mg/kg, and the average plate count was 39,000 APC/g. The pH, temperature, and nutrient concentrations for each windrow was determined.Plate count and nutrient concentrations indicated that the biopopulation in the windrow was at a viable level for degradation and that no additional fertilizer was necessary at that time.

Between May and September 2001, active landfarming was again conducted at the BWC site. Heavy equipment was used to mix the seven landfarming windrows of contaminated material. Rainwater contained in the treatment pad was spead over the windrows of contaminated material. Repairs to the treatment pad berm were made due to deterioration that occurred over the winter months. Samples were collected from the windrows to monitor the degradation of contaminants. Below is a summary of analytical results for 2001.

• June 13, 2001, analytical results indicated that the total average PAH concentration was 2,091 mg/kg and the average plate count was 5,200 APC/g. The decrease in the plate count could be attributed to either a decrease in PAH concentrations (decreased food supply) or a decrease in nutrients within the windrows.

• July 23, 2001, analytical results indicated that the total average PAH concentration was 3,469 mg/kg and the average plate count was 170,000 APC/g.

• September 12, 2001, analytical results indicated that the total average PAH concentration was 2,896 mg/kg, and the average plate count was 190,000 APC/g. The pH, temperature, and nutrient concentrations for each windrow were also determined.

On July 30 and August 6, 2001, an ERRS subcontractor applied two applications of Biosolve™, a surfactant, to the windrows to increase the microbial population and enliance degradation of contaminants. Approximately 210 gallons of Biosolve™ and 6,400 gallons of water were applied to the windrows.

On April 25, 2002, a 10-point composite soil sample was collected from each

15

windrow. The soil samples were sent to Simalabs International in Cincinnati, Ohio, for PAH and total organic carbon analysis and to Q Laboratories Inc. in Cincinnati, Ohio, for total plate count analysis. Analytical results indicated that the total average PAH concentration was 3,857 mg/kg and the average plate count was 1,400,000 APC/g. The pH, temperature, and nutrient concentrations were also determined for each windrow.

Based on the analytical data, no significant degradation of PAHs had occurred since March 2001; therefore, U.S. EPA decided to evaluate disposal options for contaminated materials from the BWC site.

2.

1.8 Disposal of treated waste

On June 26, 2003, a 10-point composite soil sample was collected from the windrows for disposal analysis. The soil sample was sent to Kemron Environmental Services in Marietta, Ohio, for disposal analyses and to Q Laboratories Inc. in Cincinnati, Ohio, for total plate count analysis. Analytical results verified that the matenal could be disposed of as non-hazardous waste.

From July 9 through 17, 2003, disposal activities were conducted at the BWC site. Heavy equipment and personnel were mobilized to the BWC site along with stone and gravel. An area was cleared for work zones, a loading pad was constructed, and standing water in the treatment pad was drained.Approximately 4,010 tons of non-hazardous material was transported from the BWC site to County Environmental in Carey, Ohio, for disposal. All equipment and personnel were then demobilized from the BWC site.

Treatment, disposal, or alternative-technology approaches pursued

From May 4 to 11, 1999, a total of 3,565 tons of contaminated soil from the former process area was transported to EQ, Wayne Disposal, in Belleville, Michigan, for final disposal.

Because of the land disposal restnction on listed creosote waste that went into effect prior to excavation of the secondary contamination area, U.S. EPA had to evaluate other disposal methods. Tractability studies indicated that landfarming would be the most cost- effective method for treatment. From March 14, 2000, to June 26, 2003, approximately 4,000 tons of contaminated soil was land farmed at the BWC site; however, no significant degradation of PAHs occurred after March 2001. Therefore, U.S. EPA decided to evaluate other disposal options.

From July 14 through 16, 2003, approximately 4,010 tons of non-hazardous material was transported from the site to County Environmental in Carey, Ohio, for disposal.

lo

3. Public information and community relations activities

Because of the local media coverage of site activities, a number of residents having knowledge of historical site activities have contacted U.S. EPA. The infonnation that they have provided greatly assisted the removal team in determining where to conduct on-site test excavations.

The U.S. EPA OSC provided regular updates of site activities through meetings and pollution reports to the City of Marion. Area newspapers interviewed OSC Dumo regarding site activities. The U.S. EPA Office of Public Affairs issued fact sheets about the BWC site in April 1999, July 1999, July 2000, and June 2001.

E. Resources Committed

Cleanup activities under CERCLA were conducted at the BWC site by the ERRS contractor, EQM, under contract No.68-S5-98-01, and DO No. 0026. Site activities under CERCLA commenced on April 22, 1999, and were completed July 17, 2003. Daily expenditures under CERCLA for sennces provided by EQM totaled $1,147,085.59. Table 5 presents a break down of contractor expenditures into major categories of labor, equipment, and other field cost, as well as cost incurred by U.S. EPA and START.

Specific costs indicated are only approximate and subject to audit and final determination by U.S. EPA. The OSC report is not meant to be a fmdl presentation of costs associated with a particular site.

II. EFFECTIVENESS OF REMOVAL ACTIVITIES

A. Actions Taken by PRPs

No viable PRP has been identified to date.

B. Actions Taken by State and Local Agencies

OEPA provided historical data and assisted with establishing site-specific removal criteria for PAH contamination at the BWC site. OEPA also provided GPS data support and a mobile labaratory trailer for use during the Little Scioto River assessment.

C. Actions Taken by Federal Agencies and Special Teams

Monetary resources for all site activities were provided by U.S. EPA under CERCLA. Under the guidance of the OSC, actions were taken to effectively mitigate threats posed by hazardous substances present at the BWC site.

D. Actions Taken by Contractors. Private Groups, and Volunteers

From April 1999 to December 2000, E & E START provided technical assistance, administrative, site documentation, multi-media sampling, air monitonng, Little Scioto

17

L.-

n

River assessment support, and completed site reports.

From December 2000 to July 2003, Tetra Tech START provided technical assistance, administrative, site documentation, and multimedia sampling support, and completed site reports.

On-site cleanup activities were performed and completed by the U.S. EPA ERRS contractor, EQM, and its subcontractors. ERRS procured analytical services, site security, and the transportation and disposal of wastes. All health and safety protocols and safety and environmental laws were followed during all site activities.

UI. DIFFICULTIES ENCOUNTERED

B.

C.

Items That Affected the Response

On May 12, 1999, a land disposal restriction on listed creosote wastes, such as those in the former process area, went into effect. Cleanup activities at the BWC site were accelerated so that waste could be disposed of before this land disposal restriction went into effect. Based on the amount of contamination estimated prior to removal activities, disposal before May 12, 1999, saved approximately $675,000 in disposal costs.

After the land disposal restriction on listed creosote waste went into effect, the secondary contamination area was discovered. The initial disposal option for this waste was stabilization at Dynecol in Detroit, Michigan, and transportation to Safety Kleen in Samia, Ontario, for fmal disposal; however, this disposal arrangement was cancelled due to various international concerns. Additional disposal options were therefore evaluated.

Treatability studies were conducted to evaluate whether or not the secondary contamination area waste could be chemically treated (by oxidation) to bring key organic contaminants down to levels to meet landfill requirements. Although the material could be treated, the process proved not to be cost effective. Landfarming and bioremediation treatability studies were conducted and results indicated that this technology would be a feasible and cost-effective option for treatment of contaminated soil from the site.

The rate of degradation at the BWC site decreased significantly as the PAH concentration approached 3,000 mg/Kg. Because of project time constraints, U.S. EPA decided that the material should be transported off site for fmal disposal.

Issues of Intereovernmental Coordination

No issues of intergovernmental coordination arose throughout BWC site activities.

Difficulties Interpreting. Complviiia With, or Implementing Policies and Regulations

No difficulties interpreting, complying with, or implementing policies and regulations arose at the BWC site.

IS

:'"1

TABLE 5

REMOVAL PROJECT ESTIMATED TOTAL COSTSBAKER WOOD CREOSOTING SITEMARION, MARION COUNTY, OfflO

Extramural Costs:

Total ERRS Costs $ 1,147,085.52

Total E & E START Costs $ 93,517.94

Total TETRA TECH START Costs“ $ 44,689.03

Extramural Subtotal $ 1,287,292.49

Intramural Costs:

U.S. EPA Costs $

Intramural Subtotal $

Estimated Total Project Costs $

Project Ceiling $ 1,972,740

Source: Tetra Tech START cost based on May 2004 Monthly Status Report.

19

IV. RECOMMENDATIONS

A. Means to Prevent a Recurrences of Discharge or Release

To be determined (TBD) by OSC

B. Means to Improve Removal Activities

Landfarming was proven to be an effective teehnology for reducing PAH concentrations in soil as a result fo creosote contamination. However, in its third year of land farming, PAH reduction slowed down considerably. Therefore, the goals of the removal action could not be met in a timely and cost effective manner. This technology should not have been considered. As developed for this site, the work plan for landfarming as a cost-effective remedy would have taken many more years to complete. If the future, landfarming should not be considered for sites that involve creosote contamination, this untimely remedy is not an appropriate alternative to meet time-critical goals.

20

Reference 7

• .

r-’t PRO'*-

DEC 1 57005

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGIONS

77 WEST JACKSON BOULEVARD .CHICAGO, IL 60604-3590

REPLY TO THE ATTENTION OF:

MEMORANDUM

Subj ect:

From :

Through:

To:

Superfund Site No. B591 Baker Wood Creosoteing, OH Itemized Cost Summary Request

Darius L. Taylor, FiMncial Specialist Cost Recovery Team

Analysis ScProgram Account^'

(ICyprian Ejiasa,^' Comptroller Branch

al Comptroller/FMO

Mila V. Bensing, Envir. Protection Specialist SFD, Emergency Enforcement & Support Section

The attached Itemized Cost Summary outlines all of the cumulative cost expenditures in the Integrated Financial Management System for Baker Wood Creosoteing/ OH site.

We have computed and included for your information Region Vs indirect costs. Based on adjustments recommended by the Office of Inspector General's Superfund audit for Fiscal Years 83 through 86, final indirect cost rates will be $71.00 (FY83); $61.00 (FY84);$53.00 (FY85); $51.00 (FY86); $53.00 (FY87); $64.00 (FY88); and $64.00 (FY89), respectively. Indirect cost rates for these years were conservative and did not result in allocating all indirect costs to sites. Therefore, starting in FY90 a new full cost indirect cost rate methodology will be applied to Superfund sites.This essentially means that the new indirect cost rates will be

expressed as a percentage of total direct site^ costs as opposed to a dollar rate per hour (as was 'true under the old methodology) .

The resulting indirect cosh rates for FY90 through FY 2003 are based on actual costs for those fiscal years and are as follows: 31.03% (FY90) , 27.61% (FY91) , -29.75% (FY92), 33.32% (FY93), 35.87%(FY94), 26.84% (FY95) , 32.57% (FY96) , .39.72% (FY97) , 38.85% (FY98) , ' 39.21% (FY99) , 38.26% (FY 2000)'., 42.38% (FY 2001), 52.45% (FY 2002), and 55.15% (FY 2003), respectively. Indirect cost rates for FY 2004, FY 2005 and FY 2006 will be 55.15%. and are based on FY 2003 costs. These rates are provisional and will be updated upon

Racycled/flecyclable . Printed with Vegetable Oil Based Inks on 100% Recycled Paper (50% Postconsumer)

V

subsequent indirect cost calculations.

The third report lists all the non-payroll and indirect cost expenses related to the site, i.e., travel, shipping purchases, state assistance agreements. Interagency Agreements and contractor costs. The reports are current through November 30, 2005. We have also attached a listing that gives definitions of the various object class codes that may appear on the reports.

If you have any questions or require any additional assistance, please contact Darius Taylor at FTS 353-3241.

Attachments

OBJECT CLASS LIST

OBJECT CLASS DEFINITION

21.11 Per Diem & Subsistence while on Travel.

21.13 Common Carrier.

21.14 Privately Owned Vehicle.

21.15 Commercial Rental Vehicle.

21.17 Incidental Costs.

22.09 Other Transportation - Other expenses such as parcel post, contractual charges for the transportation and care to things. Management & Support Contracts - Contracts for management support, or administrative requirements not otherwise classified.

25.35 Program Contracts - Planned dollars for contracts which support program operations. Included in this category are contracts for monitoring, for surveillance and analysis, for Regional laboratory analysis and analysis of programs.

25.70 Interagency Agreements Goverment Agencies.

Contracts and agreements with other

25.76 Site Supervision & Development Interagency Agreements - Agreements for the purpose of construction monitoring, investigating, studying and cleaning up hazardous waste sites or emergeny response on spills.

31.06 Protective Equipment and Clothing - Personal.

31.80 Other Equipment valued at more than $500.

31.90 Other Equipment valued at less than $500.

41.83 Investigations, Surveys, or Studies Awards to governmental or nongovernmental or individuals for investigations, surveys, or studies of solid waste pollution. ^

41.85 Superfund Remedial Planning & Implementation Awards to organization or individuals for remedial planning or disposal for hazardous materials.

Report Date: 12/12/2005

Itemized Cost Summary

BAKER WOOD CREOSOTEING, OH. OH SITE ID = B5 91J

Costs Through 11/30/2005.

Page 1 of 1

REGIONAL PAYROLL COSTS.... ......................... ...................... $56,200.98

HEADQUARTERS PAYROLL COSTS................ .............................................................. $687.89

REGIONAL TRAVEL COSTS................................................ .............................................. $6,478.29

ENFORCEMENT SUPPORT SERVICES (ESS) CONTRACTDYNAMAC CORPORATION (68-W4-0015).......................................................... $4,311.46

ENGINEERING SUPPORT SERVICES (ENGR)LOCKHEED MARTIN SERVICES, INC. (68-C9-9223)................................. ......... $48,136.95

ENVIRONMENTAL RAPID RESPONSE SERVICES (ERRS)ENVIRONMENTAL QUALITY MANAGEMENT (68-S5-9801)......................... $1,173,681.27

ENVIRONMENTAL SERVICES ASSISTANCE TEAMS (ESAT)IIT RESEARCH INSTITUTE (68-W0-1014)............................................................. $501.74

SUPERFUND TECH. ASSISTANCE & RESPONSE TEAM (START)TETRA TECH EM. INC. (68-W0-0129).................................................................... $63,022.85

ECOLOGY & ENVIRONMENT (68-W6-0011)......................................................... ' $26,250.00

TECHNICAL SERVICE AND SUPPORTARCTIC SLOPE REGIONAL CORP(ASRC) (68-W0-1002).................... ............ $31.72

DYNCORP INFORMATION & ENGINEERING TECH. (68-W0-1034).................. $834.92

CONTRACT LAB PROGRAM (CLP) COSTSFINANCIAL COST SUMMARY......................................................................... $12,663.55

MISCELLANEOUS COSTS (MIS)............................................................ ............................. $69,331.70

EPA INDIRECT COSTS ............................................................................................................ $616,247.48

Total Site Costs: $2,078,380.80

Report Date: 12/12/2005 Page 1 of 10

Regional Payroll Costs

BAKER WOOD CREOSOTEING, OH, OH SITE ID = B5 91


Emplovee Name

AUKER, KARLA M. ENVIRONMENTAL SCIENTIST

BARNES, SHEILA FINANCIAL ASSISTANT

BARWICK, BRIAN A. GENERAL ATTORNEY

BELLOT, MICHAEL E. ENVIRONMENTAL SCIENTIST

SENSING, MILAGROS V.ENVIRONMENTAL PROTECTION SPECIALIST

FiscalYear

PayPeriod

Payroll Hours ‘ '

PayrollCosts

1999 17 7.50 281.0920 8.50 318.7021 8.00 299.83

. 24.00 $899.62

1999 14 0.25 4.801518

0.25 4.780.25 4.780.75 $14.36

2002 20 1.75 101.8326 0.25 14.56

2003 04 3.00 174.1805 3.25 180.2606 11.00 610.0307 7.00 407.2108 24.00 1,396.1409 2.00 120.4110 2.50 150.5111 14.00 .842.8612 7.50 451.53

2004 03 1.50 93.4604 1.00 62.3105 1.00 62.3122 10.00 704.36

89.75 $5,371.96

1999 10 9.00 354.8911 2.00 78.8612 22.00 867.50

' 13 2.00 78.8635.00 $1,380.11

1999 06 16.00 527.7207 6.00 197.8908 5.00 171.9910 4.00 137.6014 9.00 309.5915 10.00 343.99





Fiscal Pay Payroll PayrollEmolovee Name Year Period Hours Costs

BENSING, MILAGROS V. 1999 16 9.00 309.56' 17 4.00 137.59

18 7.00 240.7519 1.00 34.39

2002 05 2.50 99.5721 0.50 20.87

2003 17 2.00 87.3822 2.00 87.3823 5.00 218.46

2004 06 3.00 131.0807 1.00 43.70

87.00 $3,099.51

BILL. BRIANAC. 2001 24 0.50 19.85PUBLIC AFFAIRS SPECIALIST

0.50 $19.85

BORRIES, SAMUEL F. 2000 18 18.00 782.85ENVIRONMENTAL SCIENTIST

18.00 $782.85

BYRD, SHEILA M. 1999 02 1.25 24.19FINANCIAL ASSISTANT

1.25 $24.19

CORTES, JOSE R. 2001 26 2.00 19.18

2.00 $19.18

DURNO, MARK 1999 01 4.00 113.50ENVIRONMENTAL ENGINEER 03 17.00 482.34

04 1.00 28.38r 05 12.00 340.48

06 3.00 85.1107 2.00 56.7408 1.00 28.6309 13.00 372.2211 1.00 28.6312 9.00 257.6915 26.00 744.46


Employee Name




FiscalYear

DURNO, MARK 1999

2000

2001

Pay Payroll PayrollPeriod Hours Costs

16 74.50 2,132.9317 54.00 1,543.9218 20.00 591.8519 17.00 595.5120 51.50 1,711.5021 56.00 1,907.0022 11.00 374.5923 7.00 238.3824 2.00 68.1225 3.00 102.1626 5.00 170.2627 4.00 136.2102 20.00 664.1703 90.50 2,966.3504 48.50 1,671.6705 5.00 170.2806 1.00 34.0608 2.00 71.4409 6.00 214.3310 2.00 71.4411 2.00 71.4412 1.00 35.7217 14.00 500.1118 14.00 500.1119 7.00 258.3620 1.00 36.9121 1.00 36.9122 1.00 36.9123 7.00 258.3624 1.50 55.3625 2.00 73.8226 3.00 110.7327 1.00 36.9001 5.00 184.5505 . 43.50 1,552.2507 2.00 73.8208 2.00 73.8214 1.00 39.54

Report Date: 12/12/2005 ' Page 4 of 10





DURNO, MARK 2001 15 1.00 39.5416 8.00 316.3117 18.00 711.6918 10.00 395.3919 15.00 611.6220 4.00 163.1021 8.00 326.2022 14.00 570.8323 8.00 326.2024 4.00 163.1025 5.00 203.8726 7.00 285.4227 2.00 81.55

2002 01 3.00 122.32) 02 3.00 122.32

03 3.00 122.3211 1.00 42.69

. 12 3.00 128.0713 2.00 85.3915 10.00 426.9116 12.00 512.2818 4.00 170.76

2005 04 8.00 413.24

~ 831.00 $28,251.09

FOX, CATHERINE L. 1999 07 0.50 22.59SUPERVISORY GENERAL ATTORNEY 15 0.50 23.47

2000 15 0.50 26.33

1.50 $72.39

FREITAG, ROZANNE A. 1999 09 0.25 4.24SECRETARY (TYPING) 14 0.50 8.47

0.75 $12.71

GAWLINSKI, DENISE M. 2003 17 0.25 13.63BATTAGLIA, DENISE M.PUBLIC AFFAIRS SPECIALIST

0.25 $13.63





Employee Name

GRAY. MARGARET C. SECRETARY (TYPING)

HAHN, EVA GENERAL ATTORNEY

FiscalYear

1999

1999

HANS, MICHAEL E.PUBLIC AFFAIRS SPECIALIST

2001

1999

JONES, ENESTA P.PUBLIC AFFAIRS SPECIALIST

KAWECKI, JOSEPH A. CIVIL INVESTIGATOR

2002

1999

1999

PayPeriod

PayrollHours

0.50

PayrollCosts

9.77

0.50 $9.77

06 3.00 87.5809 0.50 15.1910 ^ 1.50 45.5414 1.00 30.3515 7.00 212.5416 0.50 15.1917 0.50 15.1920 1.50 45.5521 0.25 7.6122 0.75 22.7823 0.50 15.1925 2.00 60.7101 0.50 18.93

19.50 $592.35

13 0.50 15.6815 1.50 47.0116 0.75 , 23.5217 0.25 7.8420 1.50 47.0121 0.25 7.8522 0.25 7.8519 1.25 55.23

6.25 $211.99

15 6.00 .171.79

6.00 $171.79

02 2.00 82.2603 29.00 1,192.9506 1.00 41.1417 1.00 42.86

^ Report Date: 12/12/2005

,Regional Payroll Costs

s BAKER WOOD CREOSOTEING, OH, OH SITE ID = B5 91


Page 6 of 10

Employee Name

KAWECKI, JOSEPH A.

MBOGO, VANESSA M. SIMMONS, VANESSA ACCOUNTANT

NGUYEN, GIANGVAN

FiscalYear

PayPeriod

PayrollHours

PayrollCosts

2004 06/ 2.00 109.92

35.00 $1,469.13

2000 09 1.00 34.98

1.00 $34.98

1999 18 10.00 152.0119 7.00 106.4120 6.00 91.2022 1.00 15.7124 2.00 31.43

2001 08 2.00 49.8609 2.75 70.3810 0.50 12.8016 1.25 32.00

2002 02 1.00 25.5903 1.50 38.3904 ■3.00 76.7705 1.25 32.0006 1.00 25.5907 3.75 95.9708 1.50 38.3909 1.50 39.7710 1.75 46.4111 1.00 26.5212 0.75 19.8913 0.75 19.8914 1.25 33.1515 0.75 21.9416 0.25 7.3117 0.50 14.62

2003 09 1.00 30.132004 • 03 1.00 36.60

04 0.25 9.1705 0.50 18.2906 0.50 18.29

Report Date; 12/12/2005




Page 7 of 10

Employee Name

NGUYEN, GIANGVAN

PALERMO, MARK J. GENERAL ATTORNEY

PASTOR, SUSAN J.PUBLIC AFFAIRS SPECIALIST

FiscalYear

PayPeriod

PayrollHours

PayrollCosts

2004 07 0.25 9.1709 0.50 18.7111 0.50 18.7113 0.50 18.7114 0.50 . 21.5215 0.25 11.0218 0.25 11.0224 0.25 11.02

60.25 $1,356.36

2003 16 0.75 38.1822 0.75 38.1224 0.50 25.41

2004 05 1.00 49.68^ ■ .

06 1.50 74.5218 0.25 13.4125 1.00 ■ 53.5726 0.25 13.38

2005 09 0.25 14.40• 10 1.75 100.78

20 0.25 14.408.25 $435.85

1999 10 2.00 81.0812 11.00 445.8913 3.00 121.6114 3.50 141.9015 11.00 445.8916 - 27.50 1,114.6617 3.00 121.6018 0.50 20.2619 0.50 20.2620 4.00 162.1421 4.50 182.3922 30.00 1,215.9524 0.50 20.2626 2.00 81.06

2000 01 2.00 81.06

Report Date; 12/12/2005 Page 8 of 10


BAKER WOOD CREOSOTEING, OH, OH :SITE ID = B5 91



PASTOR, SUSAN J. 2000 02 0.50 20.2603 1.00 40.5504 1.00 40.5405 5.00 202.6606 1.50 60.8007 ' 0.50 20.2620 10.00 439.7721 1.50 65.9822 1.00 43.98

2001 13 0.50 24.6117 0.50 22.93

t 18 2.00 91.7119 3.00 137.5524 0.50 22.93

2002 16 0.50 24.88

134.00 $5,515.42

RAFATI, MOHAMMAD R. 1999 14 6.00 122.37ENV PROTECTION SPECIALIST 15 5.00 101.98

11.00 $224.35

RIPLEY, LAURA J. 2003 02 2.50 117.15ENVIRONMENTAL SCIENTIST 03 0.50 23.43

20 1.00 52.1626 .4.00 208.6227 2.00 104.32

10.00 $505.68

RUTA, TADAS K. 2004 06 21.00 808.08FINANCIAL ANALYST •

21.00 $808.08

SIMES, WILLIAM W. 2000 02 31.00 1,169.28ENVIRONMENTAL SCIENTIST

31.00 , $1,169.28

SMITH, TRACY L. 1999 14 1.25 20.95CARROLL, TRACY L. 16 0.75 12.59OFFICE AUTOMATION CLERK 17 2.25 38.08



BAKER WOOD CREOSOTEING, OH. OH SITE ID = B5 91

1Costs Through 11/30/2005.

Emolovee NameFiscalYear

PayPeriod

PayrollHours

PayrollCosts

SMITH, TRACY L. 1999 . 18 0.50 8.3920 1.25 20.9521 0.75 12.7122 . 0.75 12.59

2000 02 0.25 4.2003 1.25 21.0904 1.25 20.9505 0.75 12.59

11.00 $185.09

STIMPLE, BRADLEY T. 2000 04 37.00 1,415.83ENVIRONMENTAL SCIENTIST

37.00 $1,415.83

SULLIVAN, NANCY E.PUBLIC AFFAIRS SPECIALIST

1999 16 0.50 20.76

. ;0.50 $20.76

URSIC, JAMES R.GEOLOGIST

1999 09 27.00 1,157.52

27.00 $1,157.52

VENDL, MARK A.GEOLOGIST

1999 09. 24.00 919.42

24.00 $919.42

WILLIS, DOROTHY L SUGGS-WILLIS,SECRETARY (TYPING)

2003 13 1.50 35.88

• 1.50 $35.88

Total Regional Payroll Costs 1,536.50 $56,200.98

TIME SHEET IS UNAVAILABLE AT PRESENT.(2) TIME SHEET IS UNAVAILABLE AT PRESENT.(3) TIME SHEET IS UNAVAILABLE AT PRESENT. W TIME SHEET IS UNAVAILABLE AT PRESENT.





Employee NameFiscalYear

PayPeriod

PayrollHours

PayrollCosts

(5) TIME SHEET IS UNAVAILABLE AT PRESENT.

Report Date: 12/12/2005 Page l.of 1

Headquarters Payroll CostsBAKER WOOD CREOSOTEING, OH, OH SITE ID = B5 91



PayPeriod

PayrollHours

PayrollCosts

ALLEN, HARRY L„ III 1999 24 4.00 196.54ENVIRONMENTAL SCIENTIST 25 4.00 196.54

26 2.00 98.2727 4.00 196.54

'' 14.00 $687.89

Total Headquarters Payroll Costs 14.00 $687.89


Regional Travel Costs



Treasury

Page 1 of 2

^HANS, MICHAEL E.

PUBLIC AFFAIRS SPECIALIST

PASTOR, SUSAN J.

PUBLIC AFFAIRS SPECIALIST

SIMES, WILLIAM W.

ENVIRONMENTAL SCIENTIST

STIMPLE, BRADLEY T.


TM0043116 ACHA02197 07/18/2002

TA99P171

990502105

990503094

4495021

ACHA99091 04/05/1999

ACHA99145 05/27/1999

ACHA99221 08/11/1999

000A99313 11/12/1999

4495050 ACHA99342 12/10/1999

T ravel Treasury ScheduleTraveler/Vendor Name Number Schedule ’ Date Travel Costs

BELLOT, MICHAEL E. 4495739 ACHA99081 03/24/1999 300.48


$300.48

BORRIES, SAMUEL F. 4461245 ACHA00172 06/22/2000 231.77


$231.77

DURNO, MARK 4467370 ACHA99160 06/11/1999 1,556.81

ENVIRONMENTAL ENGINEER 4520607 ACHA99210 08/02/1999 646.16

4520684 ACHA99334 12/02/1999 890.11

4475958 ACHA00174 06/26/2000 104.86

$3,197.94

327.94

$327.94

178.40

490.05

578.25

$1,246.70

218.50

$218.50

486.15

URSIC, JAMES R, 4472409 000A99034 02/05/1999

$486.15

236.03


Regional Travel Costs



Traveler/Vendor NameGEOLOGIST

VENDL, MARK A. GEOLOGIST

Total Regional Travel Costs

TreasuryTravel Treasury ScheduleNumberSchedule Date Travel Costs

4472408 000A99034 02/05/1999

$236.03

232.78

$232.78

$6,478.29


Headquarters Travel Costs



Traveler/Vendor NameTravel . Number

Treasury Treasury ScheduleSchedule Date

Page 1 of 1

Travel Costs


Contract Costs



ENFORCEMENT SUPPORT SERVICES (ESS) CONTRACT

Contractor Name:

EPA Contract Number:

Project Officer(s):

Dates of Service:

Summary of Service:

Total Costs:

DYNAMAC CORPORATION

68-W4-0015

PARIKH, PANKAJ J.

From:-01/03/1999 To; 02/27/1999

$4,311.46

VoucherNumber5556

VoucherDate

02/20/199903/20/1999

VoucherAmount

Treasury Schedule Number and Date

48,086.99 R9416 76,815.81 R9488

03/22/199904/22/1999

Total:

SiteAmount3,638.07

3.43

$3,641.50

AnnualAllocation

669.330.63

$669.96


Contract Costs



ENFORCEMENT SUPPORT SERVICES (ESS) CONTRACT

Contractor Name:


Project Officer(s):

Dates of Service:

Summary of Service:

Totai Costs:

DYNAMAC CORPORATION

68-W4-0015

PARIKH, PANKAJ J.

From: 01/03/1999 To: 02/27/1999

$4,311.46

Voucher Number5556

Schedule NumberR9416R9488

Rate TypeClassClass

AnnualAllocation Rate

0.183979 0.183979


Contract Costs



ENGINEERING SUPPORT SERVICES (ENGR)

Contractor Name:

ERA Contract Number:

Project Officer(s):

Dates of Service:

Summary of Service:

Total Costs:

LOCKHEED MARTIN SERVICES, INC.

68-C9-9223

SINGHVI, RAJESHMAL ZOWNIR, ANDRE P.

From: 08/23/1999 To: 03/24/2002

$48,136.95

VoucherNumberEAC19901 06190364 06193372 06199302 06196773R 06201628 06208968 06205909 06212085 06214349 06218312R1 06226820 06230955 06223749R 06233431R1 06236917R1 06240727R1 06251107 06243152 06247605 06254776R 06258743 06262449R 06266008 06269158 06272254 06275889 06286648

VoucherDate

10/06/199911/08/199912/09/199902/07/200003/06/200003/06/200005/24/200006/07/200006/01/200006/30/200008/31/200011/03/200011/30/200012/05/200003/01/200102/02/200104/04/200106/06/200103/28/200105/03/200107/16/200108/07/200109/06/200110/08/200111/04/200111/28/200101/10/200202/07/2002

VoucherAmount

781,981.351,254,459.881,081,107.971,083,552.601.018.160.73 1,272,738.32 . 1,319,037.41 1,149,398.93 1,194,769.56 1,136,320.64 1,295,697.91 1,299,107.471.393.242.74 1,180,012.58 1,275,515.111.095.014.29 1,069,933.66 1,252,963.40 1,215,384.80 1,119,152.43

996,754.76 . 1,144,833.38

949,529.38 /1.313.695.30 1,418,891.10 ■ 1,216,695.69 1,832,318.83 2,039,444.68


SiteAmount

R0056R0120R0185R0303R0344R0346R0514R0518R0518R0578R0689R1115R1159R1162R1387R1387R1387R1489R1493R1493R1585R1641R2035R2058R2112R2168R2246R2298

11/01/199912/02/199912/23/199903/01/200003/21/200003/21/200006/19/200006/21/200006/21/200007/26/200009/25/200011/29/200012/26/200012/27/200004/27/200104/27/200104/27/200106/20/200106/22/200106/22/200108/08/200108/30/200110/18/200111/01/200111/28/200112/28/200102/04/200203/04/2002

1,881.461,412.032,210.936,599.317,372.234,305.532,783.004,929.502,250.551,266.59

362.33374.6746.67

1,219.17281.2448.76

1,537.61301.21

3,420.282,345.44

,65.19163.01169.79149.30188.4829.5367.0714.25


Contract Costs



ENGINEERING SUPPORT SERVICES (ENGR)

Contractor Name:


Project Officer(s):

Dates of Service:

Summary of Service:

Total Costs:

LOCKHEED MARTIN SERVICES, INC.

68-C9-9223

SINGHVI, RAJESHMAL ZOWNIR, ANDRE P.

From; 08/23/1999 To: 03/24/2002

$48,136.95

VoucherNumber06296344

VoucherDate

04/14/2002

VoucherAmount


SiteAmount

1,579,775.88 R2415 05/07/2002

Total:

2,341.82

$48,136.95


Contract Costs



ENVIRONMENTAL RAPID RESPONSE SERVICES (ERRS1

Contractor Name:


Delivery Order Information

Project Officer(s);

Dates of Service:

Summary of Service:

Total Costs;

ENVIRONMENTAL QUALITY MANAGEMENT

68-S5-9801

DO # Start Date End Date5026 04/22/1999 09/05/2003

DURNO, MARK DURNO, MARKA.NABASNY, GAILFrom: 04/22/1999 To: 09/05/2003

$1,173,681.27

VoucherNumber

VoucherDate

Voucher Treasury ScheduleAmount Number and Date

SiteAmount

AnnualAllocation

141-026-001 06/18/1999 390,873.01 99668 . 07/14/1999 390,873.01 12,554.84141-026-002 08/13/1999 115,197.87 99794 09/09/1999 115,197.87 3,700.16141-026-003 09/14/1999 15,026.92 00016 10/13/1999 15,026.92 482.66141-026-004 12/06/1999 92,384.81 00183 12/23/1999 92,384.81 1,609.90141-026-005 01/14/2000 136,882.53 00261 02/10/2000 136,882.53 2,385.31141-026-006 07/26/2000 54,408.89 00626 08/22/2000 54,408.89 948.13141-026-007 09/22/2000 40,837.22 01035 10/19/2000 40,837.22 711.63141-026-008 11/20/2000. 49,768.49 01147 12/15/2000 49,768.49 693.82141-026-009 01/09/2001 6,215.77 01234 02/05/2001 6,215.77 86.65141-026-010 06/26/2001 25,502.53 01550 07/20/2001 25,502.53 355.53141-026-011 08/21/2001 42,596.25 01676 09/17/2001 42,596.25 593.83141-026-012 10/11/2001 58,186.57 02069 11/07/2001 58,186.57 811.18141-026-013 02/14/2002 3,317.72 02321 03/14/2002 3,317.72 46.25141-026-014 02/20/2003 7,494.53 03296 03/19/2003 7,494.53 104.48141-026-015 09/08/2003 105,735.51 04003 10/03/2003 105,735.51 1,474.06141-026-016 12/02/2003 1,474.11 04160 12/30/2003 1,474.11 20.55141-026-017 01/30/2004 1,183.07 0427,5 02/26/2004 1,183.07 16.49

Total: $1,147,085.80 $26,595.47


Contract Costs



ENVIRONMENTAL RAPID RESPONSE SERVICES (ERRS)

Contractor Name:

EPA Contract Number-


Project Officer(s):

Dates of Service:\Summary of Service:

Total Costs:

ENVIRONMENTAL QUALITY MANAGEMENT

68-S5-9801

DO # Start Date5026 04/22/1999

End Date 09/05/2003

DURNO, MARK ,DURNO, MARK A.NABASNY, GAIL .

From: 04/22/1999 To: 09/05/2003

$1,173,681.27

Voucher Number Schedule Number Rate Tvoe Allocation Rate141-026-001 99668 . Final 0.032120141-026-002 99794 Final 0.032120141-026-003 00016 Final 0.032120141-026-004 00183 Final 0.017426141-026-005 00261 Final 0.017426141-026-006 00626 Final 0.017426141-026-007 01035 Final 0.017426141-026-008 01147 Provisional 0.013941141-026-009 01234 Provisional 0.013941141-026-010 01550 Provisional 0.013941141-026-011 01676 Provisional 0.013941141-026-012 02069 Provisional 0.013941141-026-013 02321 Provisional 0.013941141-026-014 03296 Provisional 0.013941141-026-015 04003 Provisional 0.013941141-026-016 04160 Provisional 0.013941141-026-017 04275 Provisional 0.013941

y


Contract Costs



ENVIRONMENTAL SERVICES ASSISTANCE TEAMS (ESATV

Contractor Name:



Project Officer(s):

Dates of Service:

Summary of Service:

Total Costs:

IIT RESEARCH INSTITUTE

68-W0-1014

DO # Start Date4 11/23/20025 11/23/2002

THAKKAR, JAYANTILAL R.

From: 11/23/2002 To: 12/20/2002

$501.74

End Date12/20/200212/20/2002

VoucherNumber212768-25212769-25

VoucherDate

01/03/200301/03/2003

VoucherAmount


SiteAmount

7,737.79 R321924,320.87 , R3219

01/31/200301/31/2003

Total:

216.02285.72

$501.74


Contract Costs



SUPERFUND TECH. ASSISTANCE & RESPONSE TEAM (START1

Contractor Name:


Project Officer(s):

Dates of Service:

Summary of Service:

Total Costs:

TETRA TECH EM, INC.

68-W0-0129

KOSIK, LORRAINE KOSIK, LORRAINE C.NABASNY, GAIL

From; 11/30/2000 To: 10/03/2004

$63,022.85

VoucherNumberG9009-001G9009-002G9009.-003G9009-004G9009-005G9009-006G9009-007G9009-008G9009-009G9009-010G9009-011G9009-012G9009-013G9009-014G9009-015G9009-016G9009-017G9009-018G9009-019G9009-20G9009-21G9009-22G9009-23G9009-25G9009-26G9009-27G9009-28G9009-29

VoucherDate

01/19/200102/19/200103/12/200104/18/200105/15/200106/05/200107/18/200108/17/200109/07/200110/19/200111/19/200111/12/200101/10/200202/08/200202/28/200203/10/200205/09/200205/30/200207/11/200208/08/200208/29/200210/17/200211/05/200201/13/200302/06/200302/28/200303/14/200305/09/2003

VoucherAmount


70,939.74136,379.99225.069.84258.822.21 151,075.04313.970.26298.447.87234.218.87446.587.21470.834.79350.918.79447.624.71 372,560.76 417,376.74 358,073.43498.209.71 586,108.78429.831.26626.616.84 454,624.91468.744.85 717,243.16 485,933.50 534,670.55316.660.25 374,405.36502.767.25 429,713.66

SiteAmount

R1257R1311R1353R1416R1467R1508R1603R1667R2003R2084R2154R2195R2257R2302R2342R2415R2475R2510R2592R2641R2684R3076R3103R3231R3274R3307R3381R3427

02/15/200103/16/200104/06/200105/14/200106/11/200107/03/200108/14/200109/12/200110/03/200111/15/200112/18/200101/10/200202/07/200203/06/200203/26/200205/07/200206/06/200206/26/200208/08/200209/05/200209/27/200211/14/200212/02/200202/06/200303/05/200303/26/200305/09/200306/09/2003

503.30167.19 208.51

3,399.141.364.86 2,343.48 2,986.93 2,034.26 2,301.29 2,206.97

428.20 547.95 350.67 224.25 332.32 462.69

1.434.86 2,466.82 1,284.52

298.83859.47178.41272.14167.91414.49

3,417.68456.24372.22

AnnualAllocation

222.43 73.89 92.15

1,502.26 603.20

1,035.71 1,320.08

899.05 1,017.06

975.37 179.66229.91147.13 94.09

139.43194.13 602.03

1,035.02538.96125.38 360.61

74.86114.1870.45

173.91 1,433.98

191.43 156.17


Contract Costs



Page 2 of 4

SUPERFUND TECH. ASSISTANCE & RESPONSE TEAM (START)

Contractor Name:

EPA Contract Number;

Project Officer(s):

Dates of Service:

Summary of Service:

Total Costs:

TETRATECH EM, INC;

68-W0-0129


From: 11/30/2000 To: 10/03/2004

$63,022.85

VoucherNumber

VoucherDate


SiteAmount

AnnualAllocation

G9009-30 06/05/2003 369,872.53 R3463 07/01/2003 301.98 126.70G9009-31 07/14/2003 562,962.80 R3527 08/11/2003 123.16 51.68G9009-32 08/07/2003 404,092.23 R3570 09/04/2003 1,840.84 772.37G9009-33 08/28/2003 376,172.25 R4002 10/02/2003 601.82 252.51G9009-35 11/05/2003 378,461.04 'R4110 12/03/2003 33.65 13.96G9009-36 11/18/2003 7,235.34 R4160 12/30/2003 ' 64.13 26.61G9009-37 12/04/2003 346,473.48 R4163 12/31/2003 5.86 2.43G9009-38 01/08/2004 ' 418,894.41 R4228 02/05/2004 65.20 27.06G9009-40 03/09/2004 366,530.38 R4336 04/05/2004 123.87’ 51.40G9009-041 04/09/2004 353,745.85 R4388 05/05/2004 1,554.13 644.94G9009-42 05/06/2004 424,095.73 R4434 06/02/2004 782.17 324.59G9009-43 06/03/2004 383,940.25 R4492 06/30/2004 3,706.62 1,538.19G9009-44 07/09/2004 669,928.97 R4554 08/04/2004 2,930.90 1,216.28G9009-45 08/05/2004 374,470.71 R4604 08/31/2004 62.90 26.10JVD3306 09/15/2004 0.00 D3306 09/15/2004 -5,350.35 -2,220.31JVD3314 09/15/2004 0.00 D3314 09/15/2004 5,350.35 2,220.31G9009-46 09/03/2004 450,155.97 R4657 09/30/2004 367.64 . 152.57G9009-47 10/20/2004 472,278.64 R5097 11/17/2004 100.68 41.78

Total; $44,151.15 $18,871.70


Contract Costs




Contractor Name:


Project Officer(s):

Dates of Service:

Summary of Service:

Total Costs:

TETRA TECH EM, INC.

68-W0-0129

KOSIK, LORRAINE KOSIK, LORRAINE C.NABASNY, GAILFrom: 11/30/2000 To: 10/03/2004

$63,022.85

AnnualVoucher Number Schedule Number Rate Tvoe Allocation RateG9009-001 R1257 Final 0.441952G9009-002 R1311 Final 0.441952G9009-003 R1353 Final 0.441952G9009-004 R1416 Final 0.441952G9009-005 R1467 Final 0.441952G9009-006 R1508 Final 0.441952G9009-007 R1603 . Final 0.441952G9009-008 R1667 Final 0.441952G9009-009 R2003 Final 0.441952G9009-010 R2084 Final 0.441952G9009-011 R2154 Class 0.419577G9009-012 R2195 Class 0.419577G9009-013 R2257 Class 0.419577G9009-014 R2302 Class 0.419577G9009-015 R2342 Class 0.419577G9009-016 R2415 Class 0.419577G9009-017 R2475 Class 0.419577G9009-018 R2510 Class 0.419577G9009-019 R2592 Class 0.419577G9009-20 R2641 Class 0.419577G9009-21 R2684 Class 0.419577G9009-22 R3076 Class 0.419577G9009-23 R3103 Class 0.419577G9009-25 R3231 Class 0.419577G9009-26 R3274 Class 0.419577G9009-27 R3307 Class 0.419577G9009-28 R3381 Class 0.419577G9009-29 R3427 Class 0.419577'


Contract Costs


Costs Through 11/30/2005. .


Contractor Name:


Project Officer(s):

Dates of Service:

Summary of Service:

Total Costs:

TETRA TECH EM, INC.

68-W0-0129


From: 11/30/2000 To: 10/03/2004

$63,022.85

Voucher Number Schedule Number Rate TvoeAnnual

Allocation RateG9009-30 R3463 Class 0.419577G9009-31 R3527 Class 1 0.419577G9009-32 R3570 Class 0.419577G9009-33 R4002 , Class 0.419577G9009-35 R4110 Class 0.414985G9009-36 R4160 Class 0.414985G9009-37 R4163 Class 0.414985G9009-38 R4228 Class ^ 0.414985G9009-40 R4336 Class . 0.414985G9009-041, R4388 Class 0.414985G9009-42 R4434 Class 0.414985G9009-43 R4492 Clas.s 0.414985G9009-44 R4554 Class 0.414985G9009-45 R4604 Class 0.414985JVD3306 D3306 Class * 0.414985JVD3314 D3314 Class 0.414985G9009-46 R4657 , Class 0.414985G9009-47 R5097 Class 0.414985


Contract Costs




Contractor Name:


Project Officer(s):

Dates of Service:

Summary of Service:

Total Costs:

ECOLOGY & ENVIRONMENT

68-W6-0011

KOSIK, LORRAINE C:

From: 12/26/1999 To: 12/16/2000

$26,250.00

VoucherNumber

VoucherDate


SiteAmount

AnnualAllocation

53 02/23/2000 465,507.25 R0346 03/21/2000 1,872.00 785.4555 04/12/2000 522,864.31 R0433 05/09/2000 1,508.72 633.0257 05/19/2000 490,621.58 R0511 06/16/2000 2,565.75 1,076.5358 07/03/2000 596,644.31 R0585 08/01/2000 1,239.32 519.9959 08/01/2000 528,180.39 R0634 08/25/2000 3,626.50 1,521.6060 09/07/2000 457,090.98 R10Q2 10/03/2000 992.96 416.6261 10/10/2000 530,541.00 R1070 11/07/2000 - 2,147.34 900.9762 10/31/2000 442,307.99 R1122 12/04/2000 1,238.31 . 519.5763 11/27/2000 513,313.79 R1158 12/22/2000 1,222.67 513.0064 12/14/2000 800,024.79 R1192 01/11/2001 678.90 284.8565 02/01/2001 549,804.74 R1281 03/01/2001 1,051.78 441.3066 04/16/2001 352,382.96 R1412 05/11/2001 221.94 93.1267R 09/25/2001 279,346.39. R2043 10/23/2001 125.24 52.55

Total: $18,491.43 $7,758.57


Contract Costs




Contractor Name:


Project Officer(s):

Dates of Service:

Summary of Service:

Total Costs:

ECOLOGY & ENVIRONMENT

'68-W6-0011

KOSIK, LORRAINE C.

From: 12/26/1999 To: 12/16/2000

$26,250.00

AnnualVoucher Number Schedule Number Rate Tvoe Allocation Rate53 R0346 Class 0.41957755 R0433 Class 0.41957757 R0511 Class 0.41957758 R0585 Class 0.41957759 R0634 Class 0.41957760 R1002 Class 0.41957761 R1070 Class 0.41957762 R1122 Class 0.41957763 R1158 Class 0.41957764 R1192 Class 0.41957765 R1281 Class 0.41957766 R1412 Class 0.41957767R R2043 Class 0.419577


Contract Costs



TECHNICAL SERVICE AND SUPPORT

Contractor Name:

EPA Contract Number;


Project Office r(s):

Dates of Service:

Summary of Service:

Total Costs:

ARCTIC SLOPE REGIONAL CORP(ASRC)

68-W0-1002

DO # Start Date End Date302 03/01/2004 03/28/2004

PFUNDHELLER, JANET

From: 03/01/2004 To: 03/28/2004

$31.72

VoucherNumber

VoucherDate

04/07/2004


54,340.41 R4388 05/05/2004

Total:

SiteAmount

31.72

$31.72


Contract Costs




Contractor Name:


Project Officer(s):

Dates of Service:

Summary of Service:

Total Costs:

DYNCORP INFORMATION & ENGINEERING TECH.

68-W0-1034

TAYLOR, LUCINDAFrom: 11/22/2002 To: 03/27/2003 '

$834.92

VoucherNumber1929ADJ

VoucherDate

01/08/200311/19/2003

VoucherAmount


SiteAmount

563,167.24 R3222 926,156.07 R4137

02/03/200312/16/2003

Total:

535.0958.98

$594.07

AnnualAllocation

217.3523.50

$240.85


Contract Costs




Contractor Name:


Project Officer(s):

Dates of Service:

Summary of Service:

Total Costs:

DYNCORP INFORMATION & ENGINEERING TECH.

68-W0-1034

TAYLOR, LUCINDA

From: 11/22/2002 To: 03/27/2003 ..

$834.92

Voucher Number 1929ADJ

Schedule NumberR3222R4137

Rate TypeClassClass

AnnualAllocation Rate

0.406196 0.398375


Financial Cost Summary for the Contract Lab Program


" Costs Through 11/30/2005.

CONTRACT LAB PROGRAM (CLP) COSTS

Page 1 of 3

Total Routine Analytical Services (RAS) Costs $12,663.55

Total Financial Cost Summary $12,663.55






Page 2 of 3

Routine Analytical Services (RAS)

Total Costs: $12,663.55

Voucher,Number

VoucherDate

Voucher Treasury Schedule Amount Number and Date

Case Number: 31117

EPA Contract Number: 68-W0-0087. DATACHEM LABORATORIES INC.

SiteAmount

Totals for Routine Analytical Services: $9,261.02

Class/SMOAmount

102-8201 12/02/2002 1,671.15 R3178 01/09/2003 1,671.15 613.99I02-8289 12/05/2002 1,471.30 R3189 01/15/2003 1,471.30 540.56

Totals for 68-W0-0087: $3,142.45 $1,154.55

EPA Contract Number: 68-W9-9024. ENVIROSYSTEMS INC20258 11/29/2002 6,118.57 R3177 01/09/2003 6,118.57 2,247.98

Totals for 68-yy9-9024: $6,118.57 $2,247.98

. Totals for Case Number 31117: $9,261.02 $3,402.53

$3,402.53






Page 3 of 3

FiscalYear2003

Rate Type-Provisional

Class / SMO Rate

0.367403


Miscellaneous (MIS) Costs


Costs Through 11 /30/2005.

Miscellaneous (MIS) Costs

Total Costs:

ProcurementNumber

$69,331.70

VoucherNumber

VoucherDate

VoucherAmount


SiteAmount

1BUCKNER & SONS MASONRY. INC.

952134YAW W 1 05/14/1999 28,041.60 000A99158 06/09/1999 28,041.60

Vendor Total: $28,041.60

SCI-COMM INC. •952115YAWW 1014-1 05/14/1999 2,270.12 000A99155 06/08/1999 2,270.12

952115YAWW 10142 06/21/1999 4,647.49 000A99195 07/16/1999 4,647.49

952115YAWW 10140003 08/12/1999 1,720.28 000A99225 08/17/1999 1,720.28

952115YAWW 1014-000-5 10/20/1999 3,918.37 000A99295 10/26/1999 3,918.37

952115YAWW 1014-000-6 11/15/1999 709.56 000A99320 11/18/1999 709.56

952115YAWW 10140007 12/09/1999 721.9,6 000A99344 12/14/1999 721.96

952115YAWW 1014-000-8 01/31/2000 6.67 000A00032 02/03/2000 6.67

952115YAWW 10140009 02/25/2000 2,873.71 000A00056 02/29/2000 2,873.71

952115YAWW 10140004 03/06/2000 6,662.26 000A00066 03/08/2000 6,662.26

952115YAWW 101400010 03/23/2000 94.02 000A00084 03/28/2000 94.02

952115YAWW 101400011 03/29/2000 160.49 000A00090 04/03/2000 160.49

952115YAWW 101400012 05/11/2000 245.64 000A00133 05/16/2000 245.64952115YAWW 1014131415 11/29/2000 3,589.81 000A00336 12/05/2000 3,589.81

952115YAWW 1014-000-16 07/31/2001 2,669.34 000A01213 08/03/2001 2,669.34

952115YAWW 101400017 09/18/2001 201.60 000A01262 09/21/2001 201.60

952115YAWW 101400018 11/04/2002 130.80 000A02309 11/07/2002 130.80

952115YAWW ' 101400019 11/04/2002 2,984.10 000A02309 11/07/2002 . 2,984.10

952115YAWW 101400020 11/04/2002 21.16 000A02309 11/07/2002 21.16

952115YAWW 000021 06/03/2003 119.00 000A03156 06/09/2003 119.00

952115YAWW 101400022 07/29/2003 2,788.78 000A03212 08/04/2003 2,788.78

952115YAWW 1 02/09/2004 4,754.94 000A04041 02/12/2004 4,754.94

Vendor Total; $41,290.10

Total Miscellaneous Costs: $69,331.70


EPA Indirect Costs



Page 1 of 1

Fiscal Year Direct Costs Indirect Rate( %) Indirect Costs1999 594,413.38 39.21% 233,069.392000 384,554.90 38.26% 147,130.742001 219,747.02 42.38% 93,128.772002 87,277.51 52.45% 45,777.072003 43,684.76 . 55.15% 24,092.162004 131,770.47 55.15% 72,671.422005 685.28

1,462,133.3255.15% ^ 377.93

Indirect Costs $616,247.48

Report Date: .12/12/2005

EPA Indirect Costs



Page 1 of 24

PAYROLL DIRECT COSTS

Employee Name

ALLEN, HARRY L„ III

FiscalYear

1999

AUKER, KARLA M. 1999

BARNES, SHEILA 1999

BELLOT, MICHAEL E. 1999

BENSING, MILAGROS V. 1999

PayPeriod

242526 27

172021

1415 18

10111213

060708 101415161718

PayrollCosts

Ind.Rate(%)

IndirectCosts

196.54 39.21% 77.06196.54 39.21% 77.0698.27 39.21% 38.53

196.54 39.21% . 77.06687.89 $269.71

281.09 39.21% 110.22318.70 39.21% 124.96299.83 39.21% 117.56899.62 $352.74

4.80 39.21% 1.884.78 39.21% 1.874.78 39.21% 1.87 .

14.36 $5.62;

354.89 39.21% 139.1578.86 39.21% 30.92

867.50. j

39.21% 340.1578.86 39.21% 30.92

1,380.11 $541.14

527.72. 39.21% 206.92197.89 '39.21% 77.59171.99 39.21% 67.44137.60 39.21% 53.95309.59 39.21% 121.39343.99 39.21% 134.88309.56 39.21% 121.38137.59 39.21% 53.95240.75 39.21% 94.40


EPA Indirect Costs



Employee Name


FiscalYear

BENSING, MILAGROS V.

BYRD. SHEILA M.

DURNO, MARK

1999 ,

1999

1999

FOX, CATHERINE L. 1999

PayPeriod

PayrollCosts

Ind.Rate(%)

IndirectCosts

19 34.39 39.21% 13.48

' 2,411.07 $945.38

02 24.19 39.21% 9.4824.19' $9.48

01 113.50 39.21% 44.5003 ' 482.34 39.21% 189.1304 28.38 39.21% 11.1305 340.48 39.21% 133.5006 85.11 39.21% 33.3707 56.74 39.21% 22.2508 28.63 39.21% 11.2309 372.22 39.21% 145.95

,11 28.63 39.21% 11.2312 257.69 39.21% 101.0415 744.46 39.21% 291.9016 . 2,132.93 39.21% 836.3217 1,543.92 39.21% 605.3718 59l‘.85 39.21% 232.0619 595.51 39.21% 233.5020 1,711.50 39.21% 671.0821 1,907.00 39.21% 747.7322 374.59 39.21% 146.8823 238.38 39.21% 93.4724 68.12 39.21% 26.7125 , 102.16 39.21% 40.0626 170.26 39.21% 66.7627 136.21 39.21% 53.41

.12,110.61 $4,748.58

07 22.59 39.21% 8.86


EPA Indirect Costs,



Page 3 of 24


Ind.


PayPeriod

PayrollCosts

Rate(%)

IndirectCosts

FOX, CATHERINE L. 1999 15 23.47 . 39.21% 9.2046.06 $18.06

FREITAG, ROZANNE A. 1999 09 4.24 39.21% 1.6614 8.47 39.21% 3.32

12.71 $4.98

GRAY, MARGARET C. 1999 ' 20 9.77 39.21% 3.839.77 $3.83

HAHN, EVA 1999 06 87.58 39.21% 34.3409 15.19 39.21% 5.9610 45.54 39.21% 17.8614 , 30.35 39.21% 11.9015 212.54 39.21% 83.3416 15.19 39.21% 5.9617 15.19 39.21% 5.9620 45.55 39.21% 17.8621 7.61 39.21% 2.9822 22.78 39.21% 8.9323 15.19 39.21% 5.9625 60.71 39.21% 23.80

573.42 $224.85

HANS. MICHAEL E. 1999 13 15.68 39.21% 6.1515 47.01 39.21% 18.4316 23.52 39.21% 9.2217 7.84 39.21% 3.0720 47.01 39.21% 18.4321 7.85 39.21% 3.08


EPA Indirect Costs



Page 4 of 24

PAYROLL DIRECT COSTSInd.


PayPeriod

PayrollCosts

Rate(%)

IndirectCosts

HANS, MICHAEL E. 1999 22 7.85 39.21% 3.08

\156.76 $61.46

JONES, ENESTA P. 1999 15 171.79 39.21% 67.36}

171.79 $67.36

KAWECKI, JOSEPH A. 1999 02 82.26 39.21% 32.2503 1,192.95 39.21% 467.7606 41.14 39.21% 16.1317 42.86 39.21% 16.81

1,359.21 $532.95

NGUYEN, GIANGVAN 1999 i 18 152.01 39.21% 59.6019 106.41 39.21% 41.7220 91.20 39.21% 35.76

) 22 15.71 39.21% 6.1624 31.43 39.21% 12.32

396.76 $155.56

PASTOR, SUSAN J. 1999 10 81.08 39.21% 31.7912 445.89 39.21% 174.8313 121.61 39.21% 47.6814 141.90 39.21% 55.6415 445.89 39.21% 174.8316 1,114.66 39.21% 437.0617 121.60 39.21% 47.6818 20.26 39.21% 7.9419 20.26 39.21% 7.94

- 20 162.14 39.21% 63.58- 21 182.39 39.21% 71.52

22 1,215.95 39.21% 476.77r 24 20.26 39.21% 7.94

Report Date:. 12/12/2005 Page 5 of 24

EPA Indirect Costs




Ind.


PayPeriod

PayrollCosts

Rate(%)

IndirectCosts

PASTOR. SUSAN J. 1999 26 81.06 39.21% 31.78

■ '

4,174.95 $1,636.98

RAFATI, MOHAMMAD R. 1999 14 122.37 39.21% 47.9815 101.98 39.21% 39.99

224.35 $87.97

SMITH, TRACY L. 1999 14 20.95 39.21% 8.2116 12.59 39.21% 4.9417 38.08 39.21% 14.9318 8.39 39.21% 3.2920 20.95 39.21% 8.2121 12.71 39.21% 4.9822 12.59 39.21% 4.94

126.26 $49.50

SULLIVAN. NANCY E.•

1999 16 20.76 39.21% , 8.1420.76 $8.14

URSIC, JAMES R. 1999 09 1,157.52 39.21% 453.861,157.52 $453.86

VENDL, MARK A. 1999 09 919.42 39.21% 360.50-919.42 $360.50

Total Fiscal Year 1999 Payroll Direct Costs: 26,877.59 $10,538.65


EPA Indirect Costs



Page 6 of 24

TRAVEL DIRECT COSTS

\Traveler/Vendor Name

TravelNumber

Treasury ■ Schedule

DateTravelCosts

Ind.Rate(%)

IndirectCosts

BELLOT, MICHAEL E. 4495739 03/24/1999 300.48 39.21% 117.81300.48 $117.81

DURNO, MARK 4467370 06/11/1999 1,556.81 39.21%^ 610.434520607 08/02/1999- 646.16 39.21% 253.36

2,202.97 $863.79

PASTOR, SUSAN J. TA99P171 04/05/1999 178.40 39.21% : 69.94990502105 05/27/1999 490.05 39.21% 192.14990503094 08/11/1999 578.25 39.21% 226.73

1,246.70 $488.81

URSIC, JAMES R. 4472409 02/05/1999 236.03 39.21%236.03

92.54$92.54

VENDL, MARK A. 4472408 02/05/1999 232.78 39.21%232.78

91.27$91.27

Total Fiscal Year 1999 Travel Direct Costs:

OTHER DIRECT COSTS

Contract, lAG, SCA, Misc.NO

68-S5-9801

VoucherNumber

141-026-001

141-026-002

TreasurySchedule

Date

07/14/1999

09/09/1999

SiteAmount190,873.01 200,000.00

' ■ . 115,197.87

. 506,070.88

4,218.96

Annual/SMO 'nd. Allocation Rate

Costs (%)

6,130.846,424.003,700.16

16,255.00

$1,654.22

39.21%39.21%39.21%

IndirectCosts

77,245.2180,938.8546,619.92

$204,803.98

68-W4-0015 03/22/1999- 3,638.07 669.33 39.21% 1,688.93


EPA Indirect Costs



Page 7 of 24


VoucherNumber

68-W4-0015

952115YAWW 1014-1 10142 10140003

952134YAW W 1

OTHER DIRECT COSTS

Treasury Schedule

Date

04/22/1999

06/08/199907/16/199908/17/1999

06/09/1999

Total Fiscal Year 1999 Other Direct Costs;

Total Fiscal Year 1999;

SiteAmount

Annual/SMOAllocation

Costs

Ind.Rate(%)

IndirectCosts

3.43 0.63 39.21% 1.593,641.50 669.96 $1,690.52

2,270.12 0.00 39.21% 890.114,647.49 0.00 39.21% 1,822.281,720.28 0.00 39.21% 674.528,637.89 0.00 $3,386.91

28,041.60 0.00 39.21% 10,995.1128,041.60 0.00 $10,995.11

546,391:87 16,924.96 $220,876.52

594,413.38 $233,069.39


Employee Name

BORRIES, SAMUEL F.

DURNO, MARK

FiscalYear

PayPeriod

PayrollCosts

Ind.Rate(%)

IndirectCosts

2000 18 782.85 38.26% 299.52782.85 $299.52

2000 02 664.17 38.26% 254.1103 2,966.35 38.26% 1,134.9304 1,671.67 38.26% 639.5905 170.28 38.26% 65.1506 34.06 38.26% 13.0308 71.44 38.26% 27.3309 214.33 38.26% 82.0010 71.44 38.26% 27.3311 71.44 38.26% 27.33


EPA Indirect Costs



Page 8 of 24


Employee Name

DURNO, MARK

FOX, CATHERINE L.

MBOGO, VANESSA M.

PASTOR, SUSAN J.

Ind.Fiscal Pay Payroll Rate IndirectYear Period Costs (%) Costs

2000 12 35.72 38.26% 13.6717 500.11 38.26% 191.3418 500.11 38.26% 191.3419 258.36 38.26% 98.8520 36.91 38.26% 14.1221 36.91 38.26% 14.1222 36.91 38.26% 14.1223 258.36 38.26% 98.8524 55.36 38.26% 21.18.25 73.82 38.26% 28.2426 110.73 38.26% 42.3727 36.90 38.26% 14.12

7,875.38 $3,013.12

2000 15 26.33 38.26% 10.0726.33 $10.07

2000 09 34.98 ' 38.26% 13.3834.98 $13.38

2000 01 81.06 38.26% 31.0102 20.26 38.26% 7.7503 40.55 38.26% 15.5104 40.54 38.26% 15.5105 202.66 38.26% 77.5406 60.80 38.26% 23.2607 20.26 38.26% 7.7520 439.77 38.26% 168.2621 65.98 38.26% 25.2422 43.98 38.26% 16.83

1,015.86 $388.66


EPA Indirect Costs



Page 9 of 24



PayPeriod

PayrollCosts

Ind.Rate(%)

IndirectCosts

SIMES, WILLIAM W. 2000 02 1,169.28 38.26% 447.371,169.28 $447.37

SMITH, TRACY L. 2000 02 4.20 38.26% 1.6103 21.09 38.26% 8.0704 20.95 38.26% 8.0205 12.59 38.26% 4.82

58.83 $22.52

STIMPLE, BRADLEY T. 2000 04 1,415.83 38.26% 541.701,415.83 $541.70


TRAVEL DIRECT COSTS

Treasury Ind.Travel Schedule Travel Rate Indirect

Traveler/Vendor Name Number Date Costs (%) Costs

BORRIES, SAMUEL F. 4461245 06/22/2000 231.77 38.26% 88.67231.77 $88.67

DURNO, MARK 4520684 12/02/1999 890.11 38.26% 340.564475958 06/26/2000 104.86 38.26% 40.12

994.97 $380.68

SIMES, WILLIAM W. 4495021 11/12/1999 218.50 38.26% 83.60218.50 $83.60


EPA Indirect Costs



Page 10 of 24

Traveler/Vendor Name

STIMPLE, BRADLEY T.

TRAVEL DIRECT COSTS

Treasury Travel ScheduleNumber Date

4495050 12/10/1999

Travel-Ciis.t.S-

Ind.Rate(%)

486.15 38.26%486.15

IndirectCosts

186.00$186.00

Total Fiscal Year 2000 Travel Direct Costs: 1,931.39 $738.95

OTHER DIRECT COSTSContract, lAG, SCA, Misc.NO

VoucherNumber

treasurySchedule

DateSite

Amount

Annual/SMO 'nd. Allocation Rate

Costs (%)IndirectCosts

68-C9-9223 EAC19901 11/01/1999 1,881.46 0.00 38.26% 719.8506190364 12/02/1999 1,412.03 0.00 38.26% 540.2406193372 12/23/1999 2,210.93 0.00 38.26% 845.9006199302 03/01/2000 6,599.31 0.00 38.26% 2,524.9006201628 03/21/2000 4,305.53 0.00 38.26% 1,647.3006196773R 03/21/2000 7,372.23 0.00 38.26% 2,820.6206208968 06/19/2000 2,783.00 0.00 38.26% 1,064.7806205909 06/21/2000- 4,929.50 0.00 38.26% 1,886.0306212085 06/21/2000 2,250.55 0.00 38.26% 861.0606214349 07/26/2000 1,266.59 0.00 38.26% 484.6006218312R1 09/25/2000 362.33 0.00 38.26% 138.63

35,373.46 0.00 $13,533.91

68-S5-9801 141-026-003 10/13/1999 15,026.92 482.66 38.26% 5,933.97141-026-004 12/23/1999 92,384.81 1,609.90 38.26% 35,962.38141-026-005 02/10/2000 136,882.53 2,385.31 38.26% 53,283.88141-026-006 08/22/2000 54,408.89 948.13 38.26% 21,179.60

298,703.15 5,426.00 $116,359.83

68-W6-0011 53 03/21/2000 1,871.89 785.40 38.26% 1,016.680.11 0.05 38.26% 0.06

55 05/09/2000 1,508.72 633.02 38.26% 819.4357 06/16/2000 2,565.75 1,076.53 38.26% 1,393.54


EPA Indirect Costs



OTHER DIRECT COSTS

Contract, Treasury Annual/SMO l^id. ,lAG, SCA, Voucher Schedule Site Allocation R^teMisc.NO Number Date Amount Costs (%)

IndirectCosts

68-W6-0011 58 08/01/2000 1,239.32 519.99 38.26% 673.1159 08/25/2000 3,626.50 1,521.60 38.26% 1,969.66

' 10,812.29 4,536.59 $5,872.48

952115YAWW 1014-000-5 10/26/1999 3,918.37 0.00 38.26% 1,499.17-1014-000-6 11/18/1999 709.56 0.00 38.26% 271.4810140007 12/14/1999 721.96 0.00 38.26% 276.221014-000-8 02/03/2000 6.67 0.00 38.26% 2.5510140009 02/29/2000 2,873.71 0.00 38.26% 1,099.4810140004 03/08/2000 ^6,662.26 0.00 38.26% 2,548.98101400010 03/28/2000 94.02 0.00 38.26% 35.97101400011 04/03/2000, 160.49 0.00 38.26% 61.40101400012 05/16/2000 245.64 0.00 38.26% 93.98

15,392.68 0.00 $5,889.23

Total Fiscal Year 2000 Other Direct Costs: 360,281.58 9,962.59 $141,655.45

Total Fiscal Year 2000: 384,554.90 $147,130.74


Ind.Fiscal Pay Payroll Rate Indirect'

Emolovee Name Year Period Costs (%) Costs

BILL, BRIANA C. 2001 24 19.85 42.38% 8.4119.85 $8.41

CORTES, JOSE R. 2001 26 19.18 42.38% 8.1319.18 $8.13

DURNO, MARK 2001 01 184.55 42.38% 78.2105 1,552.25 42.38% 657.84


EPA Indirect Costs



Page 12 of 24


Employee Name

DURNO, MARK

FiscalYear

2001

HAHN, EVA

NGUYEN, GIANGVAN

2001

2001

PASTOR, SUSAN J. 2001

PayPeriod

PayrollCosts

Ind.Rate(%)

73.82 42.38%

IndirectCosts

31.2808 73.82 42.38% 31.2814 39.54 42.38% 16.7615 39.54 42.38% 16.7616 316.31 42.38% 134.0517 711.69 42.38% 301.6118 395.39 42.38% 167.5719 • 611.62 42.38% 259.2020 163.10 42.38% . 69.1221 326.20 42.38% 138.2422 570.83 42.38% • 241.9223 326.20 42.38% 138.2424 163.10 42.38% 69.1225 203.87 42.38% 86.4026 285.42 42.38% 120.9627 81.55 42.38% 34.56

6,118.80 $2,593.12

01 18.93 42.38% 8.0218.93 $8.02

08 49.86 42.38% 21.1309 70.38 42.38% 29.8310 , . 12.80 42.38% 5.4216 32.00 42.38% 13.56

165.04 $69.94

13 24.61 42.38% 10.4317 22.93 42.38% 9.7218 91.71 42.38% 38.8719 137.55 42.38% 58.29


EPA Indirect Costs



Page 13 of 24


Employee Name

PASTOR, SUSAN J.

FiscalYear

2001

PayPeriod

PayrollCosts

Ind.Rate(%)

22.93 42.38%299.73

IndirectCosts

9.72$127.03

Total Fiscal Year 2001 Payroll Direct Costs:

OTHER DIRECT COSTS

Contract, . lAG, SCA, Misc.NO

68-C9-9223

68-S5-9801

68-W0-0129

VoucherNumber

TreasurySchedule

DateSite

Amount

6,641.53


Costs

$2,814.65

Ind.Rate(%)

IndirectCosts

06226820 11/29/2000 374.67 0.00 42.38% 158.7906230955 12/26/2Q00 46.67 0.00 42.38% 19.7806223749R 12/27/2000 1,219.17 0.00 42.38% 516.6806236917R1 04/27/2001 48.76 0,00 42.38% 20.6606240727R1 ^ 04/27/2001 1,537.61 0.00 42.38% 651.6406233431R1 04/27/2001 281.24 0.00 42.38% 119,1906251107 06/20/2001 301.21 0.00 42.38% 127.6506243152 06/22/2001 3,420.28 0.00 42.38% 1,449.5106247605 06/22/2001 2,345.44 0.00 42.38% 994.0006254776R 08/08/2001 65.19 0.00 42.38% 27.6306258743 08/30/2001 163.01 0.00 42.38% 69.08

9,803.25 0.00 $4,154.61

141-026-007 10/19/2000 40,837.22 711.63 42.38% 17,608.40141-026-008 12/15/2000 48,053.23 669.91 42.38% 20,648.87

1,715.26 23.91 42.38%' 737.06141-026-009 02/05/2001 6,215.77 86.65 42.38% 2,670.97141-026-010 07/20/2001 25,502.53 355.53 42.38% 10,958.65141-026-011 09/17/2001 42,596.25 593.83 42.38% 18,303.96

j

164,920.26 2,441.46 $70,927.91

G9009-001 02/15/2001 503.30 222.43 42.38%_ 307.56G9009-002 03/16/2001 . 167.19 73.89 42.38% 102.17


EPA Indirect Costs



Page 14 of 24

OTHER DIRECT COSTS


VoucherNumber

TreasurySchedule

DateSite

Amount


Costs

Ind.Rate(%)

IndirectCosts

68-W0-0129 G9009-003 . 04/06/2001 208.51 '92.15 42.38% 127.42G9009-004 05/14/2001, 3,399.14 1,502.26 42.38% 2,077.21G9009-005 06/11/2001 1,364.86 603.20 42.38% 834.06G9009-006 07/03/2001 2,343.48 1,035.71 42.38% 1,432.10G9009-007 08/14/2001 2,986.93 1,320.08 42.38% 1,825.31G9009-008 09/12/2001 2,034.26 899.05 42.38%, 1,243.14

13,007.67 5,748.77 $7,948.97

68-W6-0011 60 10/03/2000 992.96 416.62 42.38% 597.38-917.78 -385.08 42.38% -552.15917.78 385.08 42.38% 552.15

61 11/07/2000 163.08 68.42 42.38% 98.111,984.26 832.55 42.38% 1,193.76

62 12/04/2000 1,238.31 519.57 42.38% 744.99-1,238.31 -519.57 42.38% -744.991,238.31 519.57 42.38% 744.99

63 12/22/2000 1,222.67 513.00 42.38% 735.5864 01/11/2001 678.90 284.85 42.38% 408.4465 03/01/2001 1,051.78 441.30 42.38% 632.7766 05/11/2001 221.94 93.12 42.38% 133.52

7,553.90 3,169.43 $4,544.55

952115YAWW 1014131415 12/05/2000 1,923.35 0.00 42.38% 815.121,666.46 0.00 42.38% 706.25

1014-000-16 08/03/2001 2,669.34 0.00 42.38% 1,131.27101400017 09/21/2001 201.60 0.00 42.38% 85.44

6,460.75 0.00 $2,738.08

Total Fiscal Year 2001 Other Direct Costs: 201,745.83 11,359.66 ' $90,314.12



EPA Indirect Costs



Page 15 of 24



PayPeriod

PayrollCosts

Ind.Rate(%)

IndirectCosts

BARWICK, BRIAN A. 2002 20 101.83 52.45% 53.4126 14.56 52.45% 7.64

116.39 $61.05

BENSING, MILAGROS V. 2002 05 99.57 52.45% 52.2221 20.87 52.45% 10.95

120.44 $63.17

DURNO, MARK/

2002 01 122.32 52.45% 64.1602 122.32 52.45% 64.1603 122.32 52.45% 64.1611 42.69 52.45% 22.3912 128.07 52.45% 67.1713 85.39 52.45% 44.7915 426.91 52.45% 223.91

, 16 512.28 52.45% 268.6918 170.76 52.45% 89.56

1,733.06 $908.99

HANS, MICHAEL E. 2002 19 55.23 52.45% 28.9755.23 $28.97

NGUYEN, GIANGVAN 2002 02 25.59 52.45% 13.4203 38.39 52.45% 20.14

. 04 76.77 52.45% 40.2705 32.00 52.45% 16.7806 25.59 52.45% 13.4207 95.97 52.45% 50.3408 38.39 52.45% 20.1409 39.77 52.45% 20.8610 46.41 52.45% 24.3411 26.52 52.45% 13.91


EPA Indirect Costs



Page 16 of 24



PayPeriod

PayrollCosts

Ind.Rate(%)

IndirectCosts

NGUYEN. GIANGVAN 2002 12 19.89 52.45% 10.4313 19.89 52.45% 10.4314 33.15 52.45% 17.3915 21.94 52.45% 11.5116 7.31 52.45% 3.8317 14.62 52.45% 7.67

562.20 $294.88

PASTOR, SUSAN J. 2002 16 24.88 52.45% 13.0524.88 $13.05

Total Fiscal Year 2002 Payroll Direct Costs; 2,612.20 $1,370.11

TRAVEL DIRECT COSTS

Traveler/Vendor NameTravelNumber

TreasurySchedule

Date

HANS. MICHAEL E. TM0043116 07/18/2002

TravelCosts

Ind.Rate(%)

IndirectCosts

327.94 52.45% 172.01327.94 $172.01

Total Fiscal Year 2002 Travel Direct Costs:

OTHER DIRECT COSTS

327.94 $172.01


VoucherNumber

TreasurySchedule

DateSite

Amount


Costs

Ind. , Rate • (%)

IndirectCosts

68-C9-9223 06262449R 10/18/2001 169.79 0.00 52.45% 89.0506266008 11/01/2001 149.30 0.00 52.45% 78.3106269158 11/28/2001 188.48 0.00 52.45% 98.8606272254 12/28/2001 29.53 0.00 52.45% 15.4906275889 02/04/2002 67.07 0.00 52.45% 35.1806286648 03/04/2002 14.25 0.00 52.45% . 7.47


EPA Indirect Costs


Costs Through 11/30/2005...

Page 17 of 24

\.

OTHER DIRECT COSTS


VoucherNumber

TreasurySchedule

DateSite

Amount


Costs

Ind.Rate(%)

IndirectCosts

68-C9-9223 06296344 05/07/2002 2,341.82 0.00 52.45% 1,228.28

t'

2,960.24 0.00 $1,552.64

68-S5-9801 141-026-012 11/07/2001 58,186.57 811.18 52.45% 30,944.32141-026-013 03/14/2002 3,317.72 46.25 52.45% 1,764.40

61,504.29 ^ 857.43 $32,708.72

68-W0-0129 G9009-009 10/03/2001 2,301.29 1,017.06 52.45% 1,740.47G9009-010 11/15/2001 2,206.97 975.37 52.45% 1,669.14G9009-011 12/18/2001 428.20 179.66 52.45% 318.82G9009-012 01/10/2002, 547.95 229.91 52.45% 407.99G9009-013 02/07/2002 ■ 350.67 147.13 52.45% 261.10^G9009-014 03/06/2002 224.25 94.09 52.45% 166.97G9009-015 03/26/2002 332.32 139.43 52.45% 247.43G9009-016 05/07/2002 ^ 462.69 194.13 52.45% 344.50G9009-017 06/06/2002 1,434^86 602.03 52.45% 1,068.35G9009-018 06/26/2002 2,466.82 1,035.02 52.45% 1,836.72G9009-019 08/08/2002 1,284.52 538.96 52.45% 956.42G9009-20 09/05/2002 298.83 125.38 52.45% 222.50G9009-21 09/27/2002 859.47 360.61 52.45% 639.93

13,198.84 5,638.78 $9,880.34

68-W6-0011 67R 10/23/2001 125.24 52.55 52.45% 93.25

)

125.24 52.55 $93.25


Total Fiscal Year 2002: 87,277.51 . $45,777.07


EPA Indirect Costs



Page 18 of 24


Employee Name

BARWICK, BRIAN A.

BENSING, MILAGROS V.

GAWLINSKI, DENISE M.

NGUYEN, GIANGVAN

PALERMO, MARK J.

RIPLEY, LAURA J.

FiscalYear

t

PayPeriod

PayrollCosts

Ind.Rate(%)

IndirectCosts

2003 04 174.18 55.15% 96.0605 180.26 55.15% 99.4106 610.03 55.15% 336.4307 407.21 55.15% 224.5808 1,396.14 55.15% 769.9709 120.41 55.15% 66.4110 150.51 55.15% 83.0111 842.86 55.15% 464.8412 451.53 55.15% 249.02

4,333.13 $2,389.73

2003 ■ 17 ^ 87.38 55.15% 48.1922 87.38 55.15% 48.1923 218.46 55.15% 120.48

393.22 $216.86

2003 17 13.63 55.15% 7.5213.63 $7.52

2003 09 30.13 55.15% 16.6230.13 $16.62

2003/

16 38.18 55.15% 21.0622 38.12 55.15% 21.0224 25.41 55.15% 14.01

101.71 $56.09

2003 02 117.15 55.15% 64.6103 23.43 55.15% 12.9220 52.16 55.15% 28.7726 208.62 55.15% 115.05


EPA Indirect Costs


Costs Through 11/30/2005. ,

Page 19 of 24


Ind.Fiscal Pay Payroll Rate Indirect

Emolovee Name Year Period Costs (%) Costs

RIPLEY, LAURA J. 2003 27 104.32 55.15% . 57.53505.68

,

$278.88

WILLIS, DOROTHY L 2003 13 35.88 55.15% 19.7935.88 $19.79


OTHER DIRECT COSTS

Contract, T reasury Annual/SMO Ind.lAG, SCA, , Voucher Schedule Site Allocation Rate IndirectMisc.NO Number Date Amount Costs (%) Costs

68-S5-9801 141-026-014 03/19/2003 7,494.53 104.48 55.15% 4,190.857,494.53 104.48 $4,190.85

68-W0-0087 102-8201 01/09/2003 1,671.15 613.99 55.15% 1,260.25102-8289 01/15/2003 1,471.30 540.56 55.15% 1,109.54

'3,142.45 1,154.55 $2,369.79

68-W0-0129 G9009-22 11/14/2002 178.41 74.86 55.15% 139.68G9009-23 12/02/2002 272.14 114.18 55.15% 213.06G9009-25 02/06/2003 167.91 70.45 55.15% 131.46G9009-26 03/05/2003 414.49 173.91 55.15% 324.50G9009-27 03/26/2003 3,417.68 1,433.98 55.15% 2,675.69G9009-28 05/09/2003 456.24 191.43 55.15% 357.19G9009-29 06/09/2003 372.22 156.17 55.15% 291.41G9009-30 07/01/2003 301.98 126.70 55.15% 236.42G9009-31 08/11/2003 123.16 51.68 55.15% 96.42


EPA Indirect Costs



Page 20 of 24

OTHER DIRECT COSTS


VoucherNumber

TreasurySchedule

DateSite

Amount


Costs

Ind.Rate(%)

IndirectCosts

68-W0-0129 G9009-32 09/04/2003 1,840.84 772.37 55.15% 1,441.19

•7,545.07 3,165.73 . $5,907.02

68-W0-1014 212768-25 01/31/2003 216.02 0.00 55.15% 119.14212769-25 01/31/2003 285.72 0.00 55.15% 157.57

501.74 0.00 $276.71

68-W0-1034 19 02/03/2003 535.09 217.35 55.15% 414.97535.09 217.35 $414.97

68-W9-9024 20258 01/09/2003 6,118.57 2,247.98 55.15% 4,614.156,148.57 2,247.98 $4,614.15

952115YAWW 101400020 11/07/2002 21.16 0.00 55.15% 11.67101400018 11/07/2002 130.80 0.00 55.15% 72.14101400019 11/07/2002 2,984.10 0.00 55.15% 1,645.73000021 06/09/2003 119.00 0.00 55.15% 65.63101400022 08/04/2003 2,788.78 0.00 55.15% 1,538.01

6,043.84 0.00 $3,333.18




Employee Name

BARWICK, BRIAN A.

FiscalYear

2004

PayPeriod

0304

Ind.PayrollCosts

93.46 55.15%62.31 55.15%

IndirectCosts

51.5434.36


EPA Indirect Costs



Page 21 of 24


Ind.


PayPeriod

PayrollCosts

Rate(%)

IndirectCosts

BARWICK, BRIAN A.j

2004 05 62.31 55.15% 34.3622 704.36 55.15% 388.45

' 922.44 $508.71

BENSING, MILAGROS V. 2004 06 131.08 55.15% 72.2907 43.70 55.15% 24.10

174.78 $96.39

KAWECKI, JOSEPH A. 2004 06 109.92 55.15% 60.62109.92 $60.62

NGUYEN, GIANGVAN 2004 03 36.60 55.15% 20.1804 9.17 55.15% 5.0605 18.29 55.15% ^ 10.09

06 18.29 55.15% 10.0907 9.17 55.15% 5.0609 18.71 55.15% 10.3211 18.71 55.15% 10.3213 18.71 55.15% 10.3214 21.52 55.15% 11.8715 11.02 55.15% 6.0818 11.02 55.15% 6.0824 11.02 55.15% 6.08

202.23 $111.55

PALERMO, MARK J. 2004 05 49.68 55.15% 27.4006 74.52 55.15% 41.1018 13.41 55.15% 7.4025 53.57 55.15% 29.54


EPA Indirect Costs



Employee Name

PALERMO, MARK J.


FiscalYear

2004

PayPeriod

PayrollCosts

Ind.Rate(%)

13.38 55.15%204.56

IndirectCosts

7.38$112.82

RUTA, TADAS K. 2004 06 808.08 55.15%808.08

445.66$445.66

Total Fiscal Year 2004 Payroll Direct Costs:

OTHER DIRECT COSTS

2,422.01 $1,335.75


VoucherNumber

Treasury Schedule /

DateSite

Amount


Costs

Ind.Rate(%)

IndirectCosts

68-S5-9801 141-026-015 10/03/2003 105,735.51 1,474.06 55.15% 59,126.08141-026-016 12/30/2003 1,474.11 20.55 55.15% 824.30141-026-017 02/26/2004 1,183.07 16.49 55.15% 661.56

108,392.69 1,511.10 $60,611.94

68-W0-0129 G9009-33 10/02/2003 " 601.82 252.51 55.15% 471.16G9009-35 12/03/2003 33.65 13.96 55.15% 26.26G9009-36 12/30/2003 64.13 26.61 55.15% 50.04G9009-37 12/31/2003 5.86 2.43 55.15% 4.57G9009-38 02/05/2004 65.20 27.06 55.15% 50.88G9009-40 04/05/2004 123.87 51.40 55.15% 96.66G9009-041 05/05/2004 1,554.13 644.94 55.15% 1,212.79G9009-42 06/02/2004 782.17 324.59 55.15% 610.38G9009-43 06/30/2004 -17.92 -7.44 55.15% -13.99

1,101.66 457.17 55.15% 859.69967.68 401.57 55.15% 755.14

>1,637.28 679.45 55.15% 1,277.68, 17.92 7.44 55.15% 13.99

G9009-44 08/04/2004 2,930.90 1,216.28 55.15% 2,287.17G9009-45 08/31/2004 62.90 26.10 55.15% 49.08


EPA Indirect Costs

BAKER WOOD CREOSOTEING, OH, OH SITE 1D,= B5 91

Costs Through 11/30/2005. .

Page 23 of 24

OTHER DIRECT COSTSContract, lAG, SCA, Misc.NO

VoucherNumber

TreasurySchedule

DateSite

Amount


Costs

Ind.Rate(%)

IndirectCosts

68-W0-0129 JVD3314 . 09/15/2004 5,350.35 2,220.31 55.15% 4,175.22JVD3306 09/15/2004 -5,350.35 -2,220.31 55.15% -4,175.22G9009-46 09/30/2004 367.64 152.57 55.15% , 286.90

10,298.89 4,276.64 $8,038.40

68-W0-1002 6 05/05/2004 31.72 0.00 , 55.15% 17.4931.72 0.00 $17.49

68-W0-1034 29ADJ 12/16/2003 58.98 23.50 55.15% 45.4958.98 23.50 $45.49

952115YAWW 1 02/12/2004 4,754.94 0.00 55.15% 2,622.354,754.94 0.00 $2,622.35

Total Fiscal Year 2004 Other Direct Costs; 123,537.22 5,811.24 $71,335.67


PAYROLL DIRECT COSTS ,Ind.

Fiscal Pay Payroll Rate IndirectEmplovee Name Year Period Costs (%) Costs

DURNO, MARK 2005 04 413.24 55.15% 227.90413.24 $227.90

PALERMO, MARK J. 2005 . 09: 14.40 55.15% 7.9410 100.78 55.15% 55.58


EPA Indirect Costs





PayPeriod

PayrollCosts

Ind.Rate(%)

IndirectCosts

PALERMO, MARK J. 2005 20 14.40 55.15% 7.94129.58 $71.46

Total Fiscal Year 2005 Payroll Direct Costs: 542.82 $299.36

■ OTHER DIRECT COSTS

Contract, Treasury Annual/SMO Ind.lAG, SCA, Voucher Schedule Site Allocation Rate IndirectMisc.NO Number Date Amount ' Costs (%) Costs68-W0-0129 G9009-47 11/17/2004 100.68 41.78 55.15% 78.57

100.68 41.78 $78.57

Total Fiscal Year 2005 Other Direct Costs: 100.68 - 41.78 $78.57

Total Fiscal Year 2005: 685.28 $377.93

Total EPA Indirect Costs $616,247.48

Reference 8

y,/./,Arû

f&yjyJ yff.-j-yy.9.o

<'-«<'v>^J<'/^ aJ a/

/l5*A?^y c/î/t /■//?^ /r n ~ê?z-/(eyH

February 8, 1999

!2)ui/ .y^«//(//.

(614) 365-2783

BY AIRBORNE EXPRESS

Ms. Mila V. BensingEmergency Enforcement Support Section, SE-5J U.S. Environmental Protection Agency, Region 5 Enforcement and Compliance Assurance Branch (DE-9J)77 West Jackson Boulevard Chicago, IL 60604-3590

Re: Responses to U.S. EPA Information Requests Pursuant to Section 104of CERCLA Relating to Baker Wood Creosoting Site, Marion, Ohio

Dear Ms. Bensing:

This letter responds to the four (4) information requests under Section 104 of CERCLA issued by U.S. EPA to “Baker Wood Ltd.”, “Vince Atriano c/o Baker Wood Ltd.”, Donald Sims and Lillian Sims relating to the former Baker Wood Creosoting Site in Marion, Ohio (hereinafter “the Requests”).

Please be advised that Lillian Sims is deceased. Accordingly, the information request addressed to her is being returned to you unopened. In addition, Mark Dumo, U.S. EPA On Scene Coordinator for the Site, confirmed that the information request addressed to undersigned legal cotmsel was actually directed to my client, Bakerwood Limited Partnership (hereinafter “Bakerwood L.P.”), whose proper name and address is as follows:

Bakerwood Limited Partnership c/o Donald Sims1789 Somerlot-Hoffman Road West Marion, Ohio 43302

Please correct your records. This response is made on behalf of both Bakerwood L.P. and Donald Sims (hereinafter “Respondents”).

• , IV//- ■ yfn^/unyAn

^ L.L.P. '

Ms. Mila V. Bensing Page 2

February 8. 1999

GENERAL OB.IECTIONS

Respondents make the following general objections to the Requests. These objections shall not be repeated in response to specific requests for information, but apply to each such request as appropriate:

1. Respondents object to the extent the Requests are unreasonable, overly broad or unduly burdensome.

2. Respondent object to the extent the Requests are vague, ambiguous or susceptible to more than one interpretation. Without waiving this objection, Respondents will attempt to respond to each request for information based upon a reasonable interpretation thereof

3. Respondents object to the extent the Requests seek privileged or confidential information that would be protected from civil discover>'.

4. Respondents object to the Requests to the extent they request or seek conclusions of law or appear to assume conclusions of law as a premise. These responses are not intended, and shall not be construed, to acknowledge, concede or admit any legal conclusions whatsoever.

5. Respondents object to the Requests to the extent they seek information or documents already in the possession, custody or control of U.S. EPA or its delegee, Ohio EPA. Respondents do not interpret the information requests to request production of Ohio EPA inspection reports and other documents from Ohio EPA files which are available to U.S. EPA.

6. Respondents object to the Requests to the extent they exceed the scope of U.S. EPA’s statutory authority or are otherwise unlawful, arbitrary or capricious.

7. Respondents object to the Requests to the extent that the information requested is contained in the documents provided herewith.

8. Respondents object to the factual and legal allegations in the cover letters to the Requests, and do not admit, concede or acknowledge the accuracy of any such allegations or any liability relating to the Site.

9. Respondents object to Instruction 4. which requests identification of all contributing sources of information for ever>' single response, on the grounds that it is unreasonable, unduly burdensome and exceeds U.S. EPA's statutory authority.

10. Respondents object to Instruction 5. which seeks to impose a potentially endless obligation on Respondents to supplement its responses, on the grounds that it is unreasonable, unduly burdensome and exceeds U.S. EPA’s statutory authority.

L.L.r.

Ms. Mila V. Sensing Page 3

February 8. 1999

11. Respondents objects to Instruction 9, which seeks to require responses to objectionable requests, on the grounds that it is unreasonable, arbitrary, capricious and exceeds U.S. EPA’s statutory authority.

12. Respondents object to the definitions of “you” and “Respondent” in Definition 1 to the extent they may be construed to refer to anyone other than Bakerwood L.P. or Donald Sims.

13. Respondents object to the definition of “Site” in Definition 3 because the Site address is incorrect. The correct address for the Baker Wood Creosoting Site is Southwest Comer of Kenton Avenue and Holland Road, Marion, Ohio. Please correct your records.

14. Respondents object to all other definitions in the Requests other than statutory definitions under CERCLA to the extent they differ from the common meanings of the terms defined.

15. Respondents submit this response without conceding the relevancy, materiality or admissibility of any information produced, and without prejudice to their right to object to further requests for information. Respondents expressly reserve all rights to assert all defenses available under law in any action or proceeding.

RESPONSES TO REQUESTS IN ATTACHMENT B

1. Identify all persons consulted in the preparation of the answers to these Requests.

Response: Respondents object to Request 1 on the ground that it is unreasonablebecause it potentially requires identification of all persons, including legal counsel and staff, who incidentally contributed to the preparation of this response. Without waiving any objection. Respondents state that the principal persons consulted in the preparation of these responses are Donald Sims and Stan Casey, an employee of Sims Brothers, Inc.

2. Identify all documents consulted, examined, or referred to in the preparation of the answers to these Requests, and provide copies of all such documents.

Response: Respondents object to Request 2 to the extent it seeks a listing of alldocuments produced herewith on the ground that such documents are identified by their production. Without waiving any objecftQn, such documents are produced herewith.

3. If you have reason to believe that there may be persons able to provide a more detailed or complete response to any Requests or who may be able to provide additional responsive documents, identify such persons.

T'- L.L.P.


February 8, 1999

Response: Respondents object to Request 3 on the grounds that it is vague andambiguous. Without waiving any objection. Respondents state that the only other person known to them who may be able to provide more detailed information or documents regarding past operations at the Site is D. B. Frampton, if he is still living.

4. List the EPA Identification Numbers of the Respondent.

Response: Respondents object to Request 4 on the grounds that it is vague andambiguous. Without waiving any objection. Respondents state that they have no EPA Identification Numbers.

5. Identify the acts or omissions of any persons, other than your employees, contractors, or agents, that may have caused the release or threat of release of hazardous substances, pollutants, or contaminants, and damages resulting therefrom.

Response: Respondents object to Request 5 on the grounds that it is vague,ambiguous, overly broad and seeks legal conclusions. Without waiving any objection, Respondents state that on information and belief, the only any acts or omissions they are aware of that may have contributed to any alleged contamination of the Site would have been the operations of Baker Wood Preserving Company and D. B. Frampton which occurred prior to Donald Sims’ purchase of the Site in 1977. Respondents are unaware of the exact nature of such acts or omissions, however.

6. Identity all persons having knowledge or information about the generation, transportation, treatment, disposal, or other handling of hazardous substances by you, your contractors, or by prior owners and/operators.

Response: Respondents object to Request 6 on the grounds that it is vague,ambiguous, overly broad and seeks legal conclusions. Without waiving any objection. Respondents state that they did not handle or transport hazardous substances at or to the Site. On information and belief. Respondent believes that the persons with knowledge or information regarding the handling of hazardous substances, if any, by the Site’s prior owners are D. B. Frampton, the former employees of Baker Wood Preserving Company who are unknown to Respondents, and possibly Ohio EPA personnel who have investigated the Site.

7. Did you ever use, purchase, store, treat, dispose, transport or otherwise handle any hazardous substances or materials? If the answer to the preceding question is anything but an unqualified "no", identify:


February 8. 1999

a) The chemical composition, characteristics, physical state (e.g., solid, liquid) of each hazardous substance;

b) Who supplied you with such hazardous substances;

c) How such hazardous substances were used, purchased, generated, stored, treated, transported, disposed, or otherwise handled by you;

d) When such hazardous substances were used, purchased, generated, stored, treated, transported, disposed, or otherwise handled by you;

e) where such hazardous substances were used, purchased, generated, stored, treated, transported, disposed, or otherwise handled by you; and

f) The quantity of such hazardous substances used, purchased, generated, stored, treated, transported, disposed or otherwise handled by you.

Response: Respondents object to Request 7 on the grounds that it is overly broad,vague and ambiguous, particularly with respect to the term “hazardous materials”, which is not defined by the Requests or CERCLA. Respondents further object on the ground that it seeks legal conclusions. Without waiving any objection. Respondents state that they did not handle or transport hazardous substances at or to the Site.

8. Identify all liability insurance policies held by Respondent from 1977 to the present time. In identifying such policies, state the name and address of each insurer and of the insured, the amount of coverage under each policy, the commencement and expiration dates for each policy, whether or not the policy contains a "pollution exclusion" clause, and whether the policy covers or excludes sudden, nonsudden, or both types of accidents. In lieu of providing this information, you may submit complete copies of all relevant insurance policies.

Response: Respondents object to Request 8 on the grounds that it is overly broad andseeks irrelevant information and therefore is arbitrary, capricious and unreasonable. Without waiving any objection. Respondents state that Bakerwood L.P. has not purchased any insurance policies relating to the Site. Donald Sims has purchased only personal insurance, such as homeowner's or automobile insurance, and has not purchased any insurance policies relating to the Site.

9. Provide copies of all income tax returns sent to the Federal Internal Revenue Ser\'ice in the last five years.

Response: Respondents object to Request 9 on the grounds that it seeks irrelevantconfidential information and invades Mr. Sims' personal privacy. Respondents further

^ L.L.P. ^

Ms. Mila V. Bensing Page 6

February 8. 1999

10.

a)

object that it is arbitrary, capricious and unreasonable. Without waiving any objection. Respondents state that copies of their federal tax returns filed within the last five years is produced herewith.

If Respondent is a Corporation, respond to the following requests:

Provide a copy of the Articles of Incorporation and By-Laws of the Respondent.

b) Provide Respondent's financial statements for the past five fiscal years, including, but not limited to those filed with the Internal Revenue Service.

c) Identify all of Respondent's current assets and liabilities and the persons who currently own or are responsible for such assets and liabilities.

Response: Not applicable to Respondents.

11. If Respondent is a Partnership, provide copies of the Partnership Agreement.

Response: Not applicable to Donald Sims. A copy of the Partnership Agreement forBakerwood L.P. is provided herewith. Please note that the General Partner for Bakerwood L.P. is Bakerwood Co. See Partnership Agreement, Sec. 4.1 & Schedule A. The Consent to Access for Property form incorrectly identified Donald Sims as the General Partner.

12. If Respondent is a Trust, provide all relevant agreements and documents to support this claim.

Response: Not applicable to Respondents.

13. Have you or any other person working with you or on your behalf ever accepted waste materials for transportation to the Site from any person? If the answer to this question is anything but an unequivocal no, identify:

a) The persons from whom you or such other persons accepted waste materials for transpon to the Site;

b) Every date on which waste materials were so accepted or transported;

c) For each transaction, the nature of the waste materials accepted or transported, including the chemical content, characteristics, physical state (e.g.. solid, liquidj.and the process for which the material was used or the process which generated the material;


February 8, 1999

d) For each material, describe any warnings given to you with respect to its handling;

e) The owner of the materials so accepted or transported;

f) The quantity of the material involved (weight or volume) in each transaction and the total quantity for all transactions;

g) All tests or analyses and analytical results concerning each material;

h) The price charged for transport and/or disposal per drum, barrel, container, load (or whatever unit used) of waste materials brought to the Site.

Response: Respondent object to Request 13 on the grounds that it is vague,ambiguous and seeks legal conclusions. Respondents understand the term “waste materials” as used therein not to refer to usable products, fill or inventory. Without waiving any objection. Respondents state that they have not accepted waste materials for transportation to the Site.

14. Identify all persons, including yourself, who may have arranged for disposal or treatment or arranged for transportation for disposal or treatment of waste materials, including hazardous substances, at the Site or to the Site. In addition, identify the following:

a) The persons with whom you or such other persons made such arrangements, including, but not limited to (provide list of transporters];

b) Every date on which such arrangements took place;

c) For each transaction, the nature of the waste material or hazardous substance, including the chemical content, characteristics, physical state (e.g., solid, liquid) and the process for which the substance was used or the process which generated the substance;

d) The owner of the waste materials or hazardous substances so accepted or transported;

e) The quantity of the waste materials or hazardous substances involved (weight or volume) in each transaction and the total quantity for all transactions;

f) All tests, analyses, and analytical results concerning the waste materials;

g) The person(s) who selected the Site as the place to which the waste materials or hazardous substances were to be transported;


February 8, 1999

Response: Respondents object to Request 15 on the grounds that it is vague,ambiguous and seeks legal conclusions. Without waiving any objection, Respondents state that they have not handled hazardous substances at the Site.

16. State the dates during which you owned, operated, or leased the Site, and provide copies of all documents evidencing or relating to such ownership, operation, or lease arrangement (e.g., deeds, leases, etc.).

Response: Respondents object to Request 16 on the grounds that it is vague andambiguous. Without waiving any objection. Respondents state that Donald Sims owned the Site from September 27, 1977 until title to the Site was conveyed to Bakerwood L.P. on or after June 8, 1994. Prior owners leased track, rights of way and small storage areas at the Site to various railroad companies. In addition, easements at the Site were granted to various utility companies. In 1994, Bakerwood L.P. allowed Swift Transportation Co., Inc. to use part of the Site to park truck trailers. From 1977 until perhaps the early 1990’s, Respondents allowed Sims Brothers, Inc. to use portions of the Site to dismantle railroad cars. Responsive documents are provided herewith.

17. Provide information about the Site, including but not limited to the following:

a) Property boundaries, including a written legal description;

b) Location of underground utilities (telephone, electrical, sewer, water main, etc.);

c) Surface structures (e.g., buildings, tanks, etc.);

d) Ground water wells, including drilling logs;

e) Storm water drainage system, and sanitary sewer system, past and present, including septic tank(s), subsurface disposal field(s), and other underground structures; and where, when and how such systems are emptied;

f) Any and all additions, demolitions, or changes of any kind on, under, or about the Site, to its physical structures, or to the property itself (e.g., excavation work); and any planned additions, demolitions, or other changes to the Site; and

g) All maps and drawings of the Site in your possession.

Response: Respondents object to Request 17 on the grounds that it is vague,ambiguous, overly broad and unreasonable. Without waiving any objection. Respondents state that responsive information in their possession is contained in the documents produced herewith.

T'' L.L.P.


February 8, 1999

18. Identify all past and present solid waste units (e.g., waste piles, landfills, surface impoundments, waste lagoons, waste ponds or pits, tanks, container storage areas, etc.) on the Site. For each such solid waste, unit identified, provide the following information:

a) A map showing the unit's boundaries and the location of all known solid waste units whether currently in operation or not. This map should be drawn to scale, if possible, and clearly indicate the location and size of all past and present units;

b) The type of unit (e.g., storage area, landfill, waste pile, etc.), and the dimensions of the unit;

c) The dates that the unit was in use;

d) The purpose and past usage (e.g., storage, spill containment, etc.);

e) The quantity and types of materials (hazardous substances and any other chemicals) located in each unit; and

f) The construction (materials, composition), volume, size, dates of cleaning, and condition of each unit.

g) If unit is no longer in use, how was such unit closed and what actions were taken to prevent or address potential or actual releases of waste constituents from the unit.

Response: Respondents object to Request 18 on the grounds that it is vague,ambiguous, overly broad and unreasonable. Without waiving any objection. Respondents state that responsive information is contained in the documents produced herewith and in Ohio EPA inspection reports.

19. Identify the prior owners of the Site. For each prior owner, further identify:

a) The dates of ownership;

b) All evidence showing that they controlled access to the Site; and

c) All evidence that a hazardous substance, pollutant, or contaminant, was released or threatened to be released at the Site during the period that they owned the Site.

Response: Respondents object to Request 19 on the grounds that it is vague,ambiguous, overly broad and unreasonable. Without waiving any objection. Respondents

L.L.r.


February 8, 1999

28. Did any leaks, spills, or releases of hazardous materials occur on the Site when such materials were being:

a)

b)

c)or

Delivered by a vendor;

Stored (e.g., in any tanks, drums, or barrels);

Transported or transferred (e.g., to or from any tanks, drums, barrels, or recovery units);

d) Treated.

Response: Respondents object to Request 28 on the grounds that it is vague,ambiguous and seeks legal conclusions. Without waiving any objection. Respondents state that they have no personal knowledge of any such events other than those alleged in Ohio EPA inspection reports.

29. Has soil ever been excavated or removed from the Site? Unless the answer to the preceding question is anything besides an unequivocal "no," identify:

a) Amount of soil excavated;

b) Location of excavation:

c) Manner and place of disposal and/or storage of excavated soil;

d) Dates of soil excavation;

e) Identity of persons who excavated or removed the soil;

f) Reason for soil excavation;

g) Whether the excavation or removed soil contained hazardous materials and why the soil contained such materials;

h) All analyses or tests and results of analyses of the soil that was removed from the Site;

I) All persons, including contractors, with information about (a) through (h) of this request.

Response: Respondents object to Request 29 on the grounds that it is vague,ambiguous overly broad and unreasonable. Without waiving any objection. Respondents state that the only excavation they are aware of at the Site was in the late 1980’s, when a

L.L.P.


February 8. 1999

holding pit was excavated for the temporary holding of railroad car wheels after they were pressed off the axles. The excavated dirt was deposited as fill on the ground at the Site. Respondents have no further responsive information regarding this excavation.

Should you have any questions or need any clarification of the foregoing objections or responses, please contact me.

(objections:

Vincent Atriano

VA/

Enclosures

Copy: Donald Sims (w/o ends.)

Reference 9

I s %UNITED STATES ENVIRONMENTAL PROTECTIO: AGENCY

REGIONS77 WEST JACKSON BOULEVARD

CHICAGO, IL 60604-3590

JAN 0 5 1999REPLY TO THE ATTENTION OF:

SE-5JPROMPT REPLY NECESSARYCERTIFTTCD MATL; RETURN RECEIPT REQUESTED

Ms Lillian Sims 1410 Woodridge Rd Marion, OH 43302

Re: Request for Information Pursuant to Section 104 of CERCLAfor Baker Wood Creosgteing Site in Marion, Ohio

Dear Sir:

This letter seeks your cooperation in providing information>and documents relating to the contamination of the Baker Wood Creosoteing Superfund Site in Marion, Ohio ("Site") . A Superfund site is a site contaminated with high levels of hazardous substances that may present a threat to human health or the environment.

We encourage you to give this matter your immediate attention and request that you provide a complete and truthful response to this Information Request and attached questions (Attachment B) within twenty one (21) days of your receipt of this letter.

The United States Environmental Protection Agency ("U.S. EPA") is investigating the release or threat of release of hazardous substances, pollutants, or contaminants at the Site. U.S. EPA is seeking to obtain information concerning the generation, storage, treatment, transportation, and methods used to dispose of such substances that have been, or threaten to be, released from the Site. U.S. EPA will study the effects of these substances on the environment and public health. In addition, U.S. EPA will identify activities, materials, and parties that contributed to contamination at the Site. U.S. EPA believes that you might have information which may assist the Agency in its investigation of the Site.

In March 1998, the Ohio Environmental Protection Agency completed an integrated site assessment report at the Site that documents the presence of creosote containing high levels of potentially

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BY FAX AND AIRBORNE EXPRESS

Ms. Mila V. BensingEmergency Enforcement Support Section, SE-5J U.S. Environmental Protection Agency, Region 5 Enforcement and Compliance Assurance Branch (DE-9J)77 West Jackson Boulevard Chicago, IL 60604-3590

Re; Responses to U.S. EPA General Notices of Potential CERCLA Liability to Bakenvood L.P. and Donald Sims Relating to Baker Wood Creosoting Site, Marion, Ohio

Dear Ms. Bensing:

This letter responds to the two general notice of potential CERCLA liability letters dated April 28, 1999 from U.S. EPA to my clients, Bakerwood Limited Partnership and Mr. Donald Sims, relating to former Baker Wood Creosoting Site in Marion, Ohio (hereinafter “the Site”).

Your letters advise that U.S. EPA is planning to conduct certain activities at the Site and in The Little Scioto River, and encourages my clients to agree to reimburse the Agency for its costs arising out of these activities. Your letters direct my clients to respond within 10 days after receipt of your correspondence.

As explained in my clients’ February 8, 1999 response to U.S. EPA’s Information Requests vmder Section 104 of CERCLA, neither Bakerwood L.P. nor Mr. Sims have contributed to any alleged contamination at the Site in any way. They have no relationship to the original Baker Wood Preserving Company and have no knowledge regarding any acts or omissions of that Company, all of which took place prior to the date when Mr. Sims originally purchased the Site in 1977. My clients have no knowledge of any waste disposal or releases at the property. Accordingly, my clients deny any responsibility or liability for any alleged contamination at the Site.

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May 10, 1999

Furthermore, as I have discussed with Assistant Regional Counsel Eva Hahn, my clients lack the wherewithal necessary to finance the activities U.S. EPA plans to undertake with respect to the Site. Thus, my clients would not be able to reimburse the Agency in any event.

Please note that my clients have cooperated fully with U.S. EPA’s efforts to investigate and address the Site. They have voluntarily granted U.S. EPA full access to the property and have provided all information in their possession responsive to the Information Requests.

You should direct all further contact with my clients regarding this matter to my attention at the address and telephone numbers indicated above. Should you require any explanation or clarification of this letter, please give me a call.

Very tmly yours.

Vincent Atriano

VA/

Copy: Eva Hahn, Esq. (by fax)Donald Sims

Reference 10

'7

JOSEPHKAWECKI/R5/USEPA/US

12/02/2003 12:31 PM

Mark Palermo/R5/USEPA/US@EPA, MILAGROS BENSING/R5/USEPA/US0EPA

cc

Subj ectbaker wood

Mrs Albertina Snyder is listed as the last known RA for D.B. Frampton. I talked to her today and she provided the following information.

She stated was D.B. Frampton in 1961 and was a corporate officer (Secretary). She stated that the company had already sold the Baker Wood business before she started so she did not know about it. She stated that after a couple years Peter Frampton D.B.'s son bought certain assets of the company and started his own business. This is most likely Frampton Industries. When D.B. died the company was dissolved and the assets went to his daughter Francis Wigglesworth of Naples, FL, 941-262-4563. The D.B. Frampton Company is an inactive company but still has assets consisting of mineral rights to 4000 acres. Snyder believes that Mrs. Wigglesworth still gets some royalties from a gas or oil lease. Snyder believes that Mrs Wigglesworth is trying to sell these last assets of the company at this time.