In September, 2007, NYSDEC Region 5 rep. Mike McClean contacted the EPA Region 2 Regional Response Center and requested EPA assistance with an abandoned paint store in the City of Glens Falls, NY. The building had been acquired by the City through a tax foreclosure and the dangerous condition of the building was discovered by while the property was being evaluated for a Brownfields redevelopment Grant.
The building was located in the center of a residential area, adjacent to an elementary school and ball field. The materials inside the building were identified by DEC and Brownfields assessors as paint and solvents. It was reported by the DEC that a strong solvent odor was emanating from the building.
On September 20, 2007, OSC Eric Daly met with NYSDEC and City officials and performed a preliminary assessment of the building. OSC Daly observed that the roof structure was deteriorated and that approximately 1,000 rusted containers of paint and solvent were haphazardly stacked throughout the facility. EPA conducted air monitoring along the perimeter of the building, inside the premises, and along the school grounds. Readings above background were discovered inside the building where the bulk of the containers were located.
The building consisted of three levels: the main level, a basement, and an attic. The entire structure was unstable. The roof was dramatically bowed and perforated, and the main room ceiling was collapsing. Containers of solvents and leaking/rusted containers of paint and unknown substances were located on all 3 levels and haphazardly stacked.
EPA was officially requested to conduct a removal action by the Mayor of Glens Falls, the Glens Falls Fire Department, and the Principal of Sanford Street Elementary School. NYSDEC issued a verbal referral of the site to EPA on September 20, 2007, and, based on the verbal referral, on September 20, 2007, ERRD Director G. Pavlou gave a verbal authorization to proceed with a removal action. A formal written referral was received by EPA on September 21, 2007.
EPA mobilized its ERRS contractors on September 24, 2007. Initial efforts concentrated on stabilizing the structure and identifying/consolidating the containers. All hazardous substances were packaged into cubic-yard boxes and staged in Conex shipping containers positioned in an adjacent parking lot.
The hazardous substances were shipped off-site for disposal and on October 10, 2007 the removal action was completed. The City demolished the empty structure in the fall of 2007. Subsequently, the City hired a consultant to perform a Phase II soil sampling/analysis. On June 24, 2008 the City received a Phase II report which revealed the presence of elevated levels of mercury in the soil underneath the footprint of the building. Following the release of this report, EPA received a written request from the City for assistance in removing the contaminated soil; a second referral letter is pending from NYSDEC. Inasmuch as the school year will start on September 3rd, the time frame in which to acquire additional sampling data and perform the necessary soil excavation may not be sufficient to complete any required remediation. ERRS may be tasked to secure and cover the Site until a removal action is authorized. OSC Paul Kahn has taken the lead role in this phase of the removal assessment.
Site soil sampling event occurred on 8/4/08. Nineteen Site soil, one fly-ash, and one background soil samples were acquired in a one day event. Representative of the NYSDEC was present, as was an official from City Hall.
A reporter from the local newspaper visited the Site, photographed sampling activities, and interviewed EPA personnel for news article.
Samples were express mailed to lab in Rhode Island for analysis.
OSC obtained a sample of deteriorated and peeling paint that was on the portion of the floor left on the Site after the building was demolished. This thick layer of peeling paint is migrating off the Site and into the surrounding property. Sample will be taken to EPA lab in Edison with the hope that it can be analyzed for lead content. If it contains lead this information will be used to decide if a removal action is warranted.
OSC will await the results of the lab analyses and a decision to take further action at the Site will be based (partially) on these results and other considerations, as per the NCP.
Wait for analytical results.
The key issues are: 1) the proximity of the contaminated soil to the school and any public threat it poses; 2) the level of public concern that may surround any public threat/removal action.
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