On August 6, 2010, the U.S. Environmental Protection Agency (“EPA”) ERRD received a request from the New Jersey Department of Environmental Protection (“NJDEP”), to evaluate the Site for a Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended (“CERCLA”) removal action.

The first and second floors of the buiding show evidence of recent vandalism including copper stripping and removal.  Two open entry points (one window and one door) were discovered on the first floor despite the City of Camden’s best efforts to secure the building.  Containers of various sizes are scattered throughout the first floor.  Over 100, 55-gallon drums are observed including at least 20 hazardous waste (based on labeling) salvage or overpacked drums in the loading dock area.  Waste identified on labels included caustics, corrosives and flammable materials.

The second floor contains a large laboratory that has over 1,000 small containers of chemicals, reagents and unknown chemical mixtures.  Container labels indicated the presence of acetone, tetrachloroethylene (“PCE”), carbon tetrachloride, 1,1,2,2-tetrachloroethene, chloroform, pyridine, toluene, hydrochloric acid, acetic acid, sulfuric acid, nitric acid, acetic anhydride, butyl alcohol, kerosene, and ammonia in the lab.  The second floor contains over 100, 55-gallon drums with labels indicating that contents included sulfonic acid, styrene, isopropyl alcohol, sodium methylate, monoethanol amine, propylene glycol, ethylene glycol, sodium hydroxide, cresylic acid, and ammonia.  Some of the containers have open tops and/or material on the drum top that has spilled out of the container.  There is evidence of chemical leakage onto the floor and running down the outside wall of the building.

The third floor contains approximately 100, 55-gallon drums of chemicals and various products manufactured at the facility including waxes, soaps and lubricants.  Also present are large quantities of combustible packaging materials including cardboard boxes, paper, empty fiber drums, and plastic sheeting.

The basement level contains numerous drums (approximately 100) and 225-gallon capacity plastic totes (approximately 30-50); however, further observations were limited in this area due to low ceilings and poor lighting.  Also, a large volume of liquid (up to six inches deep) is present on the floor in the basement due to possible leakage/spillage from containers and pipes.  This material is bright green in color or multi colored (brown, white, and orange) depending on the location.

The eastern third of the building from the basement to the third floor houses the mixing tanks and process equipment.  Most tanks appeared empty; however at least five contain unknown liquids or solids.  Tanks ranged in size from 250 to 10,000 gallons.  The tanks, equipment, floor, walls, and piping in this area of the building are coated with process related materials (waxy and soapy residuals).

Pipes throughout the building are insulated with PACM.  Much of the insulation is damaged and has either fallen off the pipes onto the floor or onto objects below the pipes.  The insulation is exposed to the outside elements and may be releasing to the outside environment through the broken windows on the upper floors.

Six above ground storage tanks (“ASTs”), ranging in size from 15,000 to 20,000 gallons are present outside the building on the southern portion of the property.  The tanks appear to be empty; however there is evidence of strong chemical odor emanating from tanks.

The information on the labels of some of the containers, inside the building, indicates flammable and corrosive materials.  Labeling on containers in the laboratory and on drums throughout the building indicate the presence of CERCLA designated hazardous substances.  Many of these chemicals are believed to have been used as raw materials in the manufacturing processes at the facility.  These materials are CERCLA designated hazardous substances as defined in Section 101(14) of CERCLA, 42 U.S.C. § 9601(14).  Containers with unknown contents could potentially contain additional CERCLA designated hazardous substances.  In addition, the pipe insulation that is PACM and in a friable state is also a CERCLA designated hazardous substance.  The Site is defined as a facility under Section 101(9) of CERCLA, 42 U.S.C. § 9601(9).  The leakage of unknown chemicals from containers and the damaged PACM constitutes a "release," or threat of “release” of hazardous substances as defined in Section 101(22) of CERCLA, 42 U.S.C. Section § 9601(22).

On August 23, 2010, On-Scene Coordinators (OSCs) from the RAB conducted a Site visit as part of a removal assessment.  Based upon the information documented and presented, a verbal authorization was requested and on August 25, 2010 the Division Director authorized RAB to initiate a removal action.  A 24-hour armed security service was established on September 3, 2010 to deter trespassing and vandalism and minimize the threat of potential fire or explosion.  On September 28, 2010, the Action Memorandum to conduct a removal action at the Site was authorized.  On September 29, 2010, a warrant from the US Magistrate Judge was granted to access the property for removal action.  On October 4, 2010, the EPA met at the Site with its ERRS Contractor, Environmental Restoration, Inc. personnel and began establishment of on-site support facilities.  On October 12, 2010, representatives from the United States Coast Guard (USCG) began the evaluation of the building contents, which included drum, tanks, pails and laboratory items.  This evaluation identified the following materials*:

Not Applicable.

• New Jersey Department of Environmental Protection
• City of Camden, Department of Public Works

1 EPA OSC

2 ERRS – Response Manager and Field Clerk (Environmental Restoration) 

PACM:  Presumed Asbestos Containing Material

ERRS:  Emergency Rapid Response Service contract (Environmental Restoration, Inc.)