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Stevens & Thompson Paper Company

All POLREP's for this site Stevens & Thompson Paper Company
Middle Falls, NY - EPA Region II
POLREP #13
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On-Scene Coordinator - Paul L. Kahn 12/22/2005
Time-Critical - Removal Action Pollution Report (POLREP) #13
Start Date: 12/12/2005
Pollution Report (POLREP) #13
Site Description
The Site is a defunct tissue paper manufacturer aka paper converting) located in a rural area of Greenwich, NY, 20 miles east of Saratoga Springs, NY.

The company became defunct 2 years ago, had filed for liquidation bankruptcy, and the owner walked away from the property. The plant was purchased by St. Regis Investments, LLC, a company based in California. The original intent was to reopen the plant, but due to economic considerations the plant will be demolished and sold for residential development.

The Site occupies 27 acres in a rural/residential area, and is perched on the edge of a cliff over the Battenkill River. It has one large brick and wood, multi-level manufacturing consisting of a warehouse, two hydroelectric power plants, manufacturing areas, a lab, offices, and repair shops. There is a boiler house and an associated 20,000 gallon AST for waste oil. There are a number of small out-buildings used for vehicle and misc. equipment storage.

Security guard service was in-place from 8AM to 6PM, seven days a week, but was discontinued. The facility has limited access via a dirt road, however, the property is unfenced and the buildings are unlocked and unsecured.

Initially, this was an RP-lead removal action without an enforcement document.  However, at a point in the removal activities the RP informed EPA that he did not have the funds to continue the removal action, and asked that EPA take over.  After deliberating on the turn of events, and with a written site referral from the NYSDEC, EPA agreed to complete the removal action.

In connection with this proposed activity, the OSC and members of the US Coast Guard Atlantic Strike Team visited the Site on September 6, 2005 to conduct field sampling/testing on 10 drums of unknown chemicals staged at the Site.  Test results revealed the presence of corrosive waste chemicals and flammable waste chemicals.


Current Activities
Site activities have been suspended for the holidays.  The removal activities will resume on January 3, 2006.

ERRS crew has completed set up of staging area for drums and other containers, and has moved 168 1-gallon cans and more than 150 small chemical containers to the staging area.  A total of 68 55-gallon drums have been staged there also.  The OSC has culled 4-55 gallon drums of usable chemicals and set them aside for the use of the new owner.  The remaining drums will be sampled and disposed of as hazardous waste.

Command Post operations are intermittent due to a generator which keeps shutting down.  OSC and RM periodically working from their vehicles.  This problem will be corrected before the crew returns to work on the 3rd.

ERRS crew discovered approx. 100 linear feet of old asbestos pipe insulation stored on a shelf in one of the myriad of rooms in the Site.  This material will be wetted and placed into double plastic bags for disposal.

EPA OSC reviewed contents of public notice prepared by RST for this Site, which will be published in two newspapers of local circulation.



Planned Removal Actions
ERRS will mobilize a chemist to the Site on 1/3/06 to begin haz-cating unknowns and establishing distinct compatible waste streams.  Composite samples for lab analysis will be taken from each waste stream.  After sampling is completed, chemist will begin lab-packing chemical containers in laboratory.

ERRS crew will begin to retrieve full, and partially full chemical totes from around the Site, estimated to be 20-25, most of which are frozen.  These totes will be brought to an inside staging area where they will be inventoried in anticipation of the original suppliers taking them back as returned goods.


Next Steps
Remobe crew to Site on 1/3/06.

Continue staging smaller chemical containers and drums in loading dock area.

Remove asbestos insulation and prepare for shipping for disposal.

Retrieve  chemical totes and stage for return to original suppliers.

Begin lab packing, haz-cating, and sampling for disposal.


Key Issues
Key issues remain full activation of Command Post; retrieval of loose chemical containers; working in extreme cold weather, including difficulty thawing frozen chemical containers