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Friction Division Products

All POLREP's for this site Friction Division Products
Lawrence Township (Trenton), NJ - EPA Region II
POLREP #6
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On-Scene Coordinator - Paul L. Kahn & Eric M. Daly 10/5/2006
Time-Critical - Removal Action Pollution Report (POLREP) #6
Start Date: 6/15/2006
Pollution Report (POLREP) #6
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
EPA's Office of Regional Counsel has drafted an Administrative Consent Order (ACO) which was sent to the attorney for the RP on August 24, 2006.  A meeting was convened between the RP and EPA, at which time certain revisions to the ACO were discussed.  A revised ACO was sent to the RP on 9/28/06, and based on subsequent phone conversations with the RP, EPA believes that the RP is satisfied with the terms of the ACO and will be willing to sign it so that the removal work can be started prior to the onset of winter.

Planned Removal Actions
One final phone call between EPA and ORC is scheduled for 10/6/2006, presumably to resolve some minor points in the draft ACO.  Once all outstanding issues are resolved, the ACO will be finalized and sent to RP for signature.  Upon returning to EPA, the Order will be signed (issued) and the RP-lead removal will commence ASAP.

Next Steps
Resolve any outstanding issues with RP and submit final version of ACO to EPA management for concurrence.



Key Issues
Finalizing draft of ACO.