Pollution Report Profile - EPA OSC Response

Abrachem Chemical
Clifton, NJ - EPA Region II
POLREP #41

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On-Scene Coordinator - Paul L. Kahn, Michael Hoppe	6/12/2009
Time-Critical - Removal Action	Pollution Report (POLREP) #41
Start Date: 1/2/2009

Site Description
At 1615 hours on 10/29/08 EPA received a notification from the NRC that a chemical release was occurring at Abrachem Chemical, a bulk chemical packaging facility that leased a building in Clifton, Passaic County, NJ.  The NJ Dept. of Environmental Protection was on-scene and requested EPA's presence.

At 1730 hours OSC Ellen Banner and OSC Paul Kahn responded to the scene.  The company was found to be storing drums and bulk containers of known and unknown chemicals in 17 56-foot long intermodal shipping carriers (ISCs), stacked 3 tiers high (approx. 35 feet).  Only 5 of the ISCs could be opened, and inside those it was observed that drums and bulk containers were staged behind tiers of empty poly drums, giving  the impression that the ISCs were used for new drum storage.  EPA observed that in the one ISC where the release originated at least one drum was leaking its contents onto a wooden pallet; strong chemical odors emanated from the open door of the ISC and were also pervasive in the general area.

The Operator of Abrachem retained the services of a remediation company, and contractor personnel were advised to lay poly sheeting and begin removing and overpacking the leaking and unknown drums that were readily accessible.  Work commenced almost immediately, but at 2100 hours was halted due to lack of adequate lighting and inability to phyusically access the majority of the drums through the narrow doorway.

The Operator of Abrachem and the Owner of the property was issued a Field Expedient Notice, and in response the Operator stated he would initiate a removal action.  When his efforts to respond to the release, and threats of a release, proved to be inadequate EPA sought voluntary access to initiate a response action.  This access was denied on two occasions.  On 12/4/2008 EPA issued a Unilateral Administrative Order (UAO) for access.  The Operator refused to comply with the UAO and EPA referred the matter to the Department of Justice for a legal remedy.  On 1/8/2009 a federal Magistrate issued an access warrant to EPA to initiate a response action at the Site.

Current Activities
Removal activities continue.  OSC continues to work with chemical suppliers to retrieve their chemicals for reuse or disposal.  OSC has contacted Exxon-Mobil which has agreed to dispose of 12 drums of aged resin.  OSC has identified the owner of 10 drums of sodium permanganate (40% soln.) as Shaw E & I, in Hopkinton MA.  These drums were sold to Shaw by CBW-Chemie, a German manufacturer, in 2004.  Shaw has indicated a willingness to retrieve their drums for reuse or disposal.  Arrangements with Exxon-Mobil and Shaw are pending.  These two companies are the last ones connected to chemicals found at the Site.

Two 30-cu. yard roll-offs of used PPE and clean poly drums were shipped for fuel-blending during the week of 6/8, and four drums of amines were retrieved by Protameen Chemical on 6/10 for reuse.  On 6/12 two drums of mineral oil with organic additives and one drum of synthetic organics was shipped by IFF to it's facility in FL for reuse at no cost to the government.

Despite efforts to enlist the cooperation of chemical companies to pay for the T & D of their chemicals, certain Site-related costs such as: security guard services, emergency response events within the removal action, technical  support, the large number of drums for EPA disposal, and numerous time-consuming confined-space entries have resulted in higher expenditures than originally anticipated.  Consequently, the OSC is seeking additional funds to complete the removal action, and an Action Memo documenting this need is being drafted for mitigation contracting and other direct costs.

Planned Removal Actions
ERRS will begin bulking compatible chemicals on 6/8. These chemicals are in drums for which no original supplier can be identified, and will be eventually disposed of by ERRS as part of the removal action.

The third 30-cu. yard roll-off of used PPE and empty poly drums, and a 30 cu. yard roll-off of contaminated debris and wood pallets will be shipped during the week of 6/15 for T & D.

Monson Industries will pick up one drum of polymerized (solid) toluene diisocyanate on 6/19 to ship for incineration at no cost to the government. Ashland Chemical will ship 7 drums of amines for incineration at no cost to the government.

Next Steps
Continue working with chemical companies to have them dispose of their chemicals. Begin bulking activities, continue to dispose of combustible debris such as used PPE, cardboard, and old wooden pallets.

Key Issues
See above.

Disposition Of Wastes

Waste Stream	Quantity	Manifest #	Disposal Facility
empty poly drums, used PPE, poly sheeting, misc. plastic	1 30-cu. yd. roll-off	non-haz waste manifest	Covanta, Chester PA
empty poly drums, used PPE, poly sheeting, misc. plastic	1 30-cu. yd. roll-off	non-haz waste manifest	Covanta, Chester, PA
corrosive liquid amines (Protox C-2)	4 55-gallon drums (1,760 lbs)	bill-of-lading	drums returned to original supplier for reuse
mineral oil with organic additives; synthetic organic	2 55-gallon drums mineral oil, 1 55-gallon drum synthetic organic	bill-of-lading	Drums shipped to IFF, original supplier in Jacksonville FL for reuse.