1.1.1 Incident Category
Emergency removal action, referred by the New York State Department of Environmental Conservation (NYSDEC) on June 27, 2013.

1.1.2 Site Description
The former Jones & Laughlin Ore Company property is a 54-acre iron ore processing facility that ceased operations in the late 1970’s. The “Site”, as referred by the NYSDEC, consists of a 36 acre portion of the property that includes several deteriorating buildings.

The Site was part of a former ore processing facility in which operations shutdown in 1978. Since that time one private entity, Dongrove Holdings, has held title to the property with its primary use being building demolition and metal scrapping in the early 1990s. At some point in the early 1990s, Dongrove Holdings abandoned the property leaving many of the Site buildings in a deteriorated condition.  Since that time, additional unauthorized access and vandalism has occurred at the Site.  Due to years of neglect and acts of vandalism and/or unauthorized scrapping of Site metals, most of the Site buildings are in a severe state of deterioration.  Deteriorated or collapsed roofing on some buildings have also caused additional weather damage to internal building materials such as plaster walls and ceilings.

Portions of the site are wooded and overgrown with the Little River flowing from east to west through the central portion of the site. A former 2.5-mile long, 200 feet deep, strip mine (Benson Mines) has flooded and now forms an approximate 300 acre lake along the site’s northern border.

1.1.2.1 Location
The Site is located at 4669 State Route 3, Clifton, NY (St. Lawrence County), at the intersection of State Highway 3 and County Route 50.

Latitude: 44.1676820 / Longitude: -74.9952508

1.1.2.2 Description of Threat
There is a threat to human health posed by friable ACM and mercury containing devices present at the Site. Friable ACM was observed in decaying bags and lying on the ground in several areas of the Site. Mercury containing devices were found in decaying condition and mixed within debris of deteriorating building materials. Disturbance of these materials would result in a direct contact threat.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

On June 27, 2013, the NYSDEC referred the Site to EPA to assess and consider the Site for a removal action to address CERCLA hazardous substance that are present and pose a potential threat of direct contact to human health. EPA reviewed the NYSDEC’s request along with associated assessment reports and conducted two site inspections on July 15, 2014 and July 31, 2014. During the Site inspections EPA observed friable asbestos containing materials (ACM) in decaying bags in one building as well as friable ACM pipe insulation laying on the floors of other buildings on the Site. EPA also observed mercury containing devices (i.e. switches and components) within two Site buildings. These devices were in decaying condition and posed a potential threat of release. Along with the friable ACM and mercury devices, approximately 1 dozen small storage containers and drums of unknown material were observed at the Site.

An EPA review of the NYSDEC assessment reports along with observations made during the EPA Site inspections concluded that conditions at the Site meet the criteria for a removal action under CERCLA as documented in Section 300.415(b)(2) of the National Contingency Plan.

Response Activities

During the week of September 15, 2014, EPA, with support of its Removal Support Team 3 (RST3) contractor and Emergency Rapid Response Services (ERRS) contractor, recovered and packaged 5 cubic yards of friable ACM and recovered and packaged several mercury containing devices and mercury contaminated debris.

Several deteriorating bags containing friable ACM were repackaged and securely staged on site for future disposal.  The aforementioned bags of ACM were removed from building 6.  Friable ACM was also recovered from the floor areas of buildings 7 and 9.  Recovered ACM was wetted with amended water and placed into 6 mil poly bags with pre-printed asbestos hazard warnings.  All ACM was double-bagged in accordance with asbestos handling regulations.  Bagged ACM was later placed into (5) 1-cubic yard boxes for future off-site disposal.

Thirteen (13) mercury containing devices were removed from buildings 7 and 20.  The devices and any contaminated debris was packaged into two (2) 55 gallon drums for future off-site disposal.  Air monitoring for mercury, using an Ohio Lumex 915 was conducted before, during and after the recovery of the mercury containing devices.  Air monitoring results following the removal of mercury devices reported levels primarily below 0.5 ug/m3, well below the Agency for Toxic Substance and Disease Registry (ATSDR) recommended action level of 25 ug/m3 for industrial properties.  Following the removal of mercury devices, RST3 and ERRS inspected the areas for any signs of visual mercury.  No visual signs of mercury were reported.  In one case, building 20, a peak reading of 20 ug/m3 was reported but that result was not reproduced and no signs of visual mercury were found at that location.

Fifteen (15) smaller containers (5-55 gallons) of unknown materials were observed and sampled at the Site.  The sampling was conducted in order to perform field screening for hazard characterization (haz-cat).  Haz-cat testing results from eight (8) of the containers (solids) indicated the material exhibited corrosive characteristics.  Haz-cat testing results from three (3) of the containers (liquids) indicated the material was most likely an oil.  The remaining four (4) containers tested did not exhibit any significant hazard characteristics.  A sampling scheme is currently being developed to fully characterize the containerized waste for off-site disposal.

One (1) high pressure cylinder was found on-site in building 5.  The cylinder cap had to be cut in order to access the valve.  Upon access to the valve it was determined that this cylinder was empty.  The valve was removed and the cylinder will be recycled.

ERRS initiated Requests for Quotes (RFQs) for the transportation and disposal of the recovered ACM and mercury debris/devices.  Bids were received and evaluated on 9/18/2014 and ERRS is currently working to complete the off-site shipment and disposal of the ACM and mercury waste streams.  Activities related to off-site shipment for any of the containerized (5-55 gallon drums) waste stream(s) is pending further sampling of those wastes.

Assessment Activities

On September 16-17, 2014, RST 3 collected 41 samples from wall and ceiling plaster materials from inside buildings at the Site.  The samples were submitted for bulk asbestos analysis by polarized light microscopy (PLM).  Validated results are anticipated on or about the week of October 13, 2014. 

On September 17, 2014, RST 3 collected 4 samples from wood-block flooring in building 12.  These samples were submitted for PCB analysis.  Validated results are anticipated on or about the week of October 13, 2014.

Enforcement Activities

No viable potentially responsible parties (PRPs) have been identified at this point in time.  EPA will continue to work to identify any viable PRPs.

Waste Disposition

Planned Response Activities
Transportation and disposal of ACM and mercury waste streams

Sampling of container materials for off-site disposal

Transportation and disposal of container (drums) waste

Issues
None to report

* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.