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Factory H

All POLREP's for this site Factory H
Meriden, CT - EPA Region I
POLREP #2
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On-Scene Coordinator - Athanasios Hatzopoulos 1/15/2008
Time-Critical - Removal Action Pollution Report (POLREP) #2
Start Date: 9/28/2007
Pollution Report (POLREP) #2
Site Description
The Factory H Site is located in a mixed residential and commercial zoned area. It is part of the former “International Silver Company” (original site) which is comprised of approximately 7.2 acres.  Three buildings currently remain on the foot print of the original site.  A fourth building was destroyed by fire in 1980 and subsequently demolished.  The three existing buildings consist of Building A, a 76,000 square foot (ft2); Building B, a 900 ft2 two-story transformer/electrical house constructed over Harbor Brook; and Building C, a 3,600 ft2 two-story power plant and boiler house east of Harbor Brook.  The former fourth building, Building D, was a series of three buildings in the northeast corner of the Site consisting of a 22,000 ft2 machine shop facility, a 6,000 ft2 foundry facility, and a 1,700 ft2 pattern shop.  Other structures currently located on the Site consist of two bridges crossing the Harbor Brook and an inactive water tower.  

The Factory H Site is the 76,000 ft2 building (Building A).  The building is made up of three connected multi-story buildings.  The major portion of the building is a one story saw-tooth style building and has an approximately 5 foot deep sub floor.  The other portions of the building are made up of a two story and four story sections.  The greater portion of the floors is made of wood. The others are concrete.  There are many openings in the floors where the sub floor is exposed, thus making the floors structurally unsafe.  These openings are a result of the former machinery being removed by the previous owners.  The floor openings have gotten larger through the years because the sections of glass ceiling of the saw-tooth portions of the roof are missing.  This allowed many years of precipitation to enter the building, damage the floors and fill the sub-floor areas with water.  A portion of the fourth floor of the four story section is structurally unsafe because an area of the floor is missing as well. In addition to the above, most of the glass windows are either missing or broken from vandalism activities.

Currently there is a fence around the building and entrances to the building are locked.  However, general public access is unrestricted as evidenced by the presence of burned debris piles within the building in addition to graffiti inside and outside of the building.
According to the EPA Region 1 Environmental Justice Mapping Tool, the Site is in an environmental justice area.

On July 25, 2007, the EPRB and its Technical Assessment and Response Team, Weston Solutions, Inc., conducted a Preliminary Assessment and Site Investigation (PA/SI).  The PA/SI included sampling floor debris and pipe insulation material that had fallen on the floors for asbestos content.  In addition, the debris on the floors was sampled for heavy metal content (lead).  Thirty nine samples were collected in total.  From those samples, twenty one were analyzed for asbestos and 18 were analyzed for lead content. The chemical analysis for the asbestos revealed that all but two samples contain amosite and chrysotile asbestos with the highest concentration of 45% chrysotile.  All of the samples analyzed for lead, revealed lead levels ranging from 450 mg/Kg to 6,600 mg/Kg.

The PA/SI was concluded and based on Site conditions and preliminary analytical results, a time critical removal action was recommended in a closure memorandum dated August 27, 2007. The request for a Removal Action Memorandum was signed by the EPA Region 1 OSRR Director on September 25, 2007.







Current Activities
November 5, 2007 through November 16, 2007
Personnel from EPA’s Superfund Technical Assessment and Response Team (START) and from EPA’s contractor, Shaw Environmental (Shaw), mobilize to the Factory H Site (the Site) to establish a command post, prepare for delivery of supplies and equipment, prepare work
zones, and establish site security.  The ERRS subcontractor, Fleet Environmental, LLC, delivers a decontamination trailer for personnel.  Additional supplies are delivered to site, including negative air machines and a 4,000-gallon water tank to be used for wetting down asbestos and for decontamination showers for personnel.

ERRS and Fleet personnel begin constructing a roll-off containment area for the load-out of bags containing asbestos- and asbestos-containing-material (ACM) at the northern edge of the
building.  Fleet personnel also begin securing all openings within the work areas with sheets of polyethylene.  ERRS collects two samples of contaminated debris within the building structure for developing waste profiles for disposal purposes.

START conducts interior air monitoring before extensive work begins inside the building, using a combustible gas/oxygen meter to ensure the absence of volatile organic compounds, explosive gases, and compromised oxygen levels.  No levels above background are detected.

ERRS hires RPS Special Services to provide site security during non-working hours.  (Manned security will be maintained throughout the duration of the Factory H Removal Action.)

November 19, 2007 through November 21, 2007
Fleet establishes containment barriers and installs negative air machines throughout the 3rd and 4th stories, and initiates asbestos removal activities on the 4th floor.  Fleet personnel clear debris from the area adjacent to the containment  area, as well as clear an area on the 1st floor for the storage of asbestos-containing bags.  

START establishes 5 air monitoring stations along the perimeter of the site to ensure that fibers         are not being released to the immediate surrounding community at levels exceeding site actions
levels, which are based on one-tenth of OSHA Permissible Exposure Levels (PELs). This sampling will be performed throughout the duration of the Removal Action.  During the asbestos removal activities, a percentage of the asbestos removal workers will wear personal air pumps to ensure that their exposure to asbestos is below the OSHA PELs.

Security personnel continue to monitor the Site during non-working hours.

November 26, 2007 through November 30, 2007
Fleet continues asbestos removal on the 4th floor. Fleet personnel stack and segregate the large amount of debris on the first floor – relics from former manufacturing activities – and clear runways for workers and machines to access the debris for crushing and loading.  This debris is largely comprised of ACM contaminated wood.

Perimeter and personal air monitoring continues to be conducted.  Analytical results of all perimeter air samples collected to date indicate that fiber concentrations in the surrounding community are well below site action levels.  Analysis of personal air samples determines that no worker exposure to fiber levels near or above applicable OSHA standards has occurred.

Security personnel continue to monitor the Site during non-working hours.

December 3, 2007 through December 7, 2007
Fleet repairs openings in the 3rd and 4th floors and continues the asbestos removal activities. Approximately 500 bags of asbestos and asbestos-containing material have been collected by mid-week.  Fleet personnel continue to stack and segregate the piles of debris on the first floor to clear runways for workers and machines to access the debris for crushing and loading.  Thirteen 30-cu.yd roll offs and one 100- cu.yd trailer are delivered from TransWaste, Inc.  Fleet begins
to place the bags of ACM into the roll-offs.  Perimeter and personnel air monitoring continues to be conducted.

Analytical results of all perimeter air samples collected to date indicate that fiber concentrations in the surrounding community are well below site action levels.  Analysis of personal air samples
determines that no worker exposure to fiber levels near or above applicable OSHA standards has occurred.

Security personnel continue to monitor the Site during non-working hours.

December 10, 2007 through December 14, 2007
Fleet continues asbestos removal activities and completes the removal activities on the 3rd and 4th floors. START personnel photodocuments work progress. Thirteen 30-cu.yd roll-offs containing ACM are sent to Modern Landfill in York, Pennsylvania for off-site disposal.

Perimeter and personnel air monitoring continues to be conducted.  Analytical results of all perimeter air samples collected to date indicate that fiber concentrations in the surrounding community are well below site action levels.  Analysis of personal air samples determines that no worker exposure to fiber levels near or above applicable OSHA standards has occurred.

Security personnel continue to monitor the Site during non-working hours.

December 17, 2007 through December 28, 2007
Six 30-cu.yd roll-offs containing ACM are sent to Modern Landfill in York, Pennsylvania for off-site disposal. A visual inspection is conducted of the abated work areas on the 3rd and 4th floors to confirm that no visual residue remains.  In addition, clearance samples are collected to confirm that the indoor air does not contain levels of fibers exceeding OSHA standards for post-abatement re-occupancy.  Fleet establishes containment barriers and installs negative air machines throughout the second floor.  Fleet begins asbestos removal on the 2nd floor,
including removal of ACM floor tiles. By December 28, approximately 700 bags of asbestos and ACM are ready for load-out and disposal.

Perimeter and personnel air monitoring continues to be conducted.  Analytical results of all perimeter air samples collected to date indicate that fiber concentrations in the surrounding community are well below site action levels.  Analysis of personal air samples determines that no worker exposure to fiber levels near or above applicable OSHA standards has occurred.

Security personnel continue to monitor the Site during non-working hours.

January 2, 2008 through January 11, 2008
Fleet completes asbestos removal on the 2nd floor.  A visual inspection is conducted of the abated work areas to confirm that no visual asbestos remains. Clearance samples are collected to confirm that the indoor air does not contain levels of fibers exceeding OSHA standards for post-abatement re-occupancy.  Thirteen 30-cu. yd.  roll-offs containing ACM are sent to Modern Landfill in York, Pennsylvania for off-site disposal.  One 100-cu. yard box trailer, containing approximately 3,700 bags of bulk asbestos, is sent to BFI Imperial Landfill in Imperial, Pennsylvania.  Fleet continues the wrapping and load-out of ACM debris on the 1st floor.

Perimeter and personnel air monitoring continues to be conducted.  Analytical results of all perimeter air samples collected to date indicate that fiber concentrations in the surrounding community are well below site action levels.  Analysis of personal air samples determines that no worker exposure to fiber levels near or above applicable OSHA standards has occurred.


Planned Removal Actions
Continue the removal of asbestos and ACM.