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Bio-Tech Mills OPA Removal Site

All POLREP's for this site Bio-Tech Mills OPA Removal Site
Battenville, NY - EPA Region II
POLREP #8
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On-Scene Coordinator - Paul Kahn 12/14/2006
Non-Time-Critical - Removal Action Pollution Report (POLREP) #8
Start Date: 6/6/2006
Site Description
Site is a defunct paper converter which manufactured tissue and toilet paper, and is located within 10 feet of the Battenkill River in upstate rural NY. Owner operates a business office at the site, but manufacturing ceased 12 years ago.

Since April, 2004, OSC has been working with the owner to remove approx. drums of hydraulic fluid, PCB fluids, waste oil and other chemical substances.  The CERCLA removal action was completed in June, 2005.

During the removal action, the OSC observed a large oil tank on the property.  Closer examination revealed the presence of approx. 10,000 gallon of aged #6 oil being stored in what was a deteriorated metal tank that had inadequate secondary containment.

Inasmuch as the mill has been shut down for 12 years and will never operate again, the OSC determined that the oil being stored in the deteriorated tank, with less than adequate secondary, constituted a significant threat of a release of petroleum to a navigable waterway of the United States.  Because of the Petroleum Exclusion in CERCLA, the oil will be now be addressed with funding authority under CWA-Oil Pollution Act '90.  The owner has agreed to cooperate with EPA and have the oil removed.  

See separate site profile for "Bio-Tech Mills-CERCLA" for additional information.





Current Activities
Crew remobed to Site on 12/6-7-8/2006 and 12/11-12-13/2006, prepared tank, removed portions of block containment wall and overhead piping, and began sparging tank with hot compressed air.

On 12/11/06 2,000 gallons of warm #2 oil was added to the tank under air agitation.  With the air mixing and heating gradually the #6 oil became thinner and started to circulate in the tank through heat convection. Crew will continue to sparge and circulate the oil through 12/18, at which time it should be thin enough to be extracted from the tank by using a vac truck.

While touring the mill the OSC discovered a sump inside the mill that is partially filled with hundreds of gallon of #6 oil. Two large ceramic pipes are connected to this sump, and are partially filled with #6 oil. The owner of the mill stated that this sump was used to move process waste-water to the on-site WWTP, and
had no idea how it became filled with oil.
After conferring with ERRS Response Manager, it was decided that the threat of release posed by this oil being in the mill was significant enough to warrant it's removal.  As an added activity this area of concern would only require 2-3 days of concurrent work to address with existing personnel and equipment.

Rep from DEC field office in Warrensburg stopped at the Site to observe removal activities.  DEC rep was pleased with the progress we were making, and advised the OSC on options for dealing with the oil tank after it was emptied and washed out.


Planned Removal Actions
It is anticipated that 3 vac truck load-outs will be required to empty the tank. This should be accomplished during the week of 12/18/2006. At the same time ERRS crew will begin sparging the #6 oil in the open sump inside the mill.  Once this oil is thin enough to pump it will be vacuumed out into the trucks off-loading the oil tank.

Next Steps
Complete emptying the #6 oil tank and the open sump inside the mill.

The empty tank will be power-washed to remove any residual oil adhering to the inner surface.  The clean, empty tank will be sealed and left in place for the owner to dispose of accordingly.


Key Issues
Key issues are:  emptying and cleaning the oil storage tank; emptying the oil from the open sump and pipes inside the mill; disposal of the oil and oil-water rinsate from the storage tank.