The Diversified Resources Site is an abandoned metal recycling facility.  From approximately 1993 to 2001, Resource Recovery International Corporation (“RRIC,” formerly “Double Day, Inc.” until 2001) and its wholly-owned subsidiary Diversified Resources (Diversified Resources) operated at the Site.  RRIC and Diversified Resources processed large quantities of metal swarf at the facility.  Metal swarf is a waste material generated from metal working operations such as milling and grinding.  The initial intention of the companies was to recycle and reclaim the swarf into a reusable product.  The metal swarf is present in large waste piles and in hundreds of 55-gallon drums, super sacks, cubic-yard boxes, and miscellaneous items on the Site.

There are several structures on the property.  The largest structure is a partially demolished building currently used to store hundreds of drums, super sacks, cubic-yard boxes, and miscellaneous materials.  The property is unoccupied, and the minimum security measures include a locked gate at the east end of the property.

             The Site contains approximately 8,000 to 10,000 tons of “steel swarf”.  Swarf is a waste material generated from metalworking operations such as milling or grinding.  The material is typically mixed with cutting or lubricating oils.  The swarf is stored on the Site in drums, super sacs, Gaylord boxes and in large stock piles.  

Many of the Site buildings are covered with transite panels.  In 2010, a representative of the property owner removed large quantities of the transite panels from some of the buildings.  The removal of the transite panels exposed swarf material and other drums and containers to the elements. 

The Site is located approximately one quarter mile away from a shopping plaza, a residential area, and from a Kent State University Satellite Campus.

The Site is currently vacant.  There is no security presence at the Site, and many of the fences are in a state of disrepair.  The facility does not contain any signs or other deterrents to preclude or warn the public of the potential hazards.  It is possible for trespassers to be exposed to the hazardous substances present on the property.

Analytical results for samples collected during the SA indicated that three tanks and one drum contain flammable hazardous wastes.  Many drums inside the east end of the partially demolished building were inaccessible for sampling during the SA.  Therefore, additional drums could contain flammable hazardous waste.  Some drums in the east end of the partially demolished building had labels or markings indicating that the drums contain flammable solid materials.  Some labels also indicated that the drums contain water-reactive materials.  Unauthorized entry onto the Site could result in the accidental or intentional ignition of flammable materials stored at the Site.  In addition, the drums are located in a partially demolished building, with the potential for exposure to the elements and potential structural failure of the building.

EPA testing has documented asbestos transite panels are scattered throughout the Site.   Asbestos is a listed hazardous substance under 40 C.F.R. § 302.4. If pulverized, friable asbestos has the potential to leave the Site via airborne migration or in rainwater runoff.

On August 22-24, and again on August 28-30, 2012, EPA conducted a site assessment and  collected waste characterization samples and further document Site conditions.

2.1.1 Narrative

2.1.2 Response Actions to Date

Monday, August 31^st 2015

OSC Augustyn mobilized a USEPA owned office trailer to the site.  ERRS mobilized a Bobcat skidsteer to the site.  No other site activities took place.

Tuesday, September 1^st

OSC Augustyn and ERRS crew mobilized to the site to begin site prep.  ERRs conducted site orientation to review site hazards and scope of work.  Crew began general house cleaning in the area of the support zone.  Support zone was established with work areas and stocked with general PPE supplies.  Crew began collecting, and spray painting MT, on all empty drums and staging them in a designated area.

Wednesday through Friday, September 2-4^th 

ERRS unstacked drums and segregated drums with liquid waste from drums containing nonhazardous swarf waste.  Liquid waste was staged for future sampling and hazard characterization.   Approximately 250 drums were segregated with approximately 75 drums containing liquid waste.

Monday, September 7^th, Labor Day Holiday

No site activities.

Tuesday, September 8^th

ERRS began collecting hazard characterization samples from liquid waste drums.  ERRS crew used skidsteer and chain saw to clear vegetation from around three 5,000-gal ASTs.  One crew member was injured using the chain saw which required medivac to a local hospital.  Crew member was treated and released.  Treatment included 4 internal stiches and 10 external.  No permanent damage is anticipated.

Wednesday, September 9^th

ERRS continued collecting hazard characterization samples from liquid waste drums.  ERRS began gathering asbestos containing transite panels stockpiled around the site.  A 30-cubic yard roll off box was mobilized to the site.  ERRS began loading the box with the transite panels for off-site disposal.  The roll off box was picked up and transported to American Landfill in Waynesburg, OH for disposal.

Thursday, September 10^th

ERRS continued collecting hazard characterization samples from liquid waste drums.  ERRS completed loading the 30-cubic yard box with the transite panels for off-site disposal.  A ERRS chemist was mobilized to the site to begin hazard characterization analysis of drum samples.

Friday, September 11^th

ERRS continued collecting hazard characterization samples from liquid waste drums.  ERRS completed loading the 30-cubic yard box with the transite panels for off-site disposal.  A ERRS chemist completed hazard characterization analysis of drum samples.  Waste disposal samples were submitted for laboratory analysis.  A new roll off box was delivered to the site and the full box was picked up and transported to American Landfill in Waynesburg, OH for disposal.

Monday, September 14^th

ERRS crew began segregating liquid waste into waste streams and consolidating partial drums into new drums.  The third roll off box was filled with asbestos transite panels.  All remaining transite was placed in this last box.  Crew began loosening bolts on manholes on 3 large heating oil ASTs in preparation for pumping their contents into a tanker truck.

Tuesday, September 15^th

ERRS crew continued segregating liquid waste into waste streams and consolidating partial drums into new drums.  Crew completed gaining access to all 3 ASTs.  Empty drums are being marked with the letters MT and staged on the property.  The third and final roll off box of asbestos transite panels was picked up and transported to American Landfill in Waynesburg, OH for disposal.

Wednesday, September 16^th

ERRS crew continued segregating liquid waste into waste streams and consolidating partial drums into new drums.  ERRS began draining flammable liquids from Tanks T001, T002, and T003 into 300-gallon totes.

Thursday, September 17^th

ERRS completed containerizing all flammable wastes into 300-gallon totes.  Began containerizing neutral liquid wastes and sludges into shippable containers. 

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

The Ohio EPA issued Notice of Violation (NOV) letters for solid waste violations at the facility to Site owner Von Vittersan-Lecopla, USA, LLC on January 25, 2008 and April 8, 2010; to operator Diversified Resources on January 24, 2008, January 25, 2008, April 10, 2008, and May 20, 2008; and to operator RRIC on January 24, 2008.
 
            Ohio EPA also issued a request on January 16, 2007 to NuFlux Engineered Materials to remove surplus drums of acids/liquids stored in a kiln area, laboratory chemicals stored in the vacated onsite lab, and two pallets of drums of magnesium stored in a locked storage room within the facility.  

            Along with Ohio EPA, the Trumbull County Health Department started issuing NOVs to Diversified Resources, specifically Edgar Knieriem as its principal, in 2001.  The matter was brought before the Trumbull County Board of Health, which issued Findings and Orders against the facility.  The case was eventually referred to the Trumbull County Sheriff’s Office and Trumbull County Prosecutor’s Office.  Mr. Knieriem plead guilty to six counts of open dumping and burning of solid waste on March 12, 2012.

  The Mahoning-Trumbull Air Pollution Control Agency (M-TAPCA) issued Von Vittersan-Lecopla, USA, LLC and Mr. Sergio Dipaolo, a representative of the property owner, NOVs on March 16, 2010, April 8, 2010, and June 11, 2010 for non-compliance with National Emission Standards for Hazardous Air Pollutants (NESHAP) requirements due to the the March and April 2010 demolition work of parts of the structure.  Ohio and Mr. Dipaolo consented to the entry of a consent order and judgment entry in January 31, 2013 for a civil penalty of $30,000.

2.2.1 Anticipated Activities

Complete waste consolidation into shippable containers.  Pump flammable waste into tanker trucks from 4 ASTs on site.  Begin general debris cleanup on the site.

2.2.1.1 Planned Response Activities

Begin restaging drums on the site that are labeled nonhazardous to determine if any additional hazardous waste can be identified.

2.2.1.2 Next Steps

Finalize waste disposal for all hazardous waste on site.

2.2.2 Issues

Contingency planning for Government-wide stop work and possible shut down.