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Friction Division Products

All POLREP's for this site Friction Division Products
Lawrence Township (Trenton), NJ - EPA Region II
POLREP #3
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On-Scene Coordinator - Paul L. Kahn & Eric M. Daly 5/19/2006
Emergency - Removal Assessment Pollution Report (POLREP) #3
Pollution Report (POLREP) #3
Site Description
This site, a defunct automotive brake pad manufacturer, was brought to the attention of EPA by the NJDEP for a possible referral for a CERCLA removal action.  An inspection by EPA OSCs and a DEP responder on 12/23/05 revealed the following hazardous materials/wastes were abandoned at the site:  tons of asbestos material, tons of elemental sulphur, 1,000+ drums of mostly unknown materials or materials that do not match the label description, hundreds of smaller containers, acids, flammable liquids, iron and aluminum powders, flammable solids, waste oil, solvents, and other contaminants or pollutants.  The site is semi-controlled, with most doors being locked but numerous open windows or sections of sheet metal walls missing.  A maintenance man is on-site for a few hours Mon-Fri.  The owner of the building (not the business) has balked at doing a cleanup, but with pressure from the DEP, he has hired a company to provide him with an estimate of the clean-up cost. The former operator of the actual manufacturing business has left the state and resumed the same business in Pennsylvania.


Current Activities
OSC conducted a site inspection with a rep from NJDEP on 5/15/06.  Results of inspection revealed that all solid wastes from Building #8 have been removed, but there is a residue all over the unused portion of that building.  In Building #7, where the bulk of the chemicals were located, it was observed that most of the chemical containers are still there, having only been restaged within the building.  Some of the containers have been moved directly under active roof leaks, and there are signs of chemical residue on the floors.

Planned Removal Actions
EPA is in the process of having this Site referred from the NJDEP for a removal action. A CERCLA site ID has been assigned, an attorney from ORC has been assigned, and the Action Memo is being drafted.

Next Steps
EPA will mobilize a team to the Site to haz-cat drums of unknown materials and to sample labeled drums.

Key Issues
Site access, completion of documentation of threat of release, and initiation of contact with the two RPs.  EPA will also have to devise an enforcement strategy prior to initiating any federally funded removal action.