Pollution Report Profile - EPA OSC Response

Robinson Fiddlers/Green Manufacturing Site
Town of Concord, NY - EPA Region II
POLREP #2 - Final Polrep

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On-Scene Coordinator - Cris D'Onofrio	4/17/2006
Time-Critical - Removal Action	Pollution Report (POLREP) #2
Start Date: 7/15/2004	Completion Date: 7/31/2005

Site Description
The following is an update to the original site description that clarifies dates of corporate operations. See the previous POLREP for the complete description of the site background.

Robinson Fiddlers Green Manufacturing Co., Inc. (“Robinson/Fiddlers Green”) operated at the Site and at three adjacent parcels to manufacture kitchen utensils, including cutlery and plastic food preparation tools, from 1994 until approximately July 2001, when their business failed and they abandoned the Site. The AOC respondent, AMP Technologies, Inc., operated similarly at the Site to manufacture kitchen utensils, including cutlery and plastic food preparation tools, from approximately July 2001 until they relocated from the Site in the beginning of 2003.

Current Activities
The required removal of hazardous materials specified in the Administrative Order on Consent (Index Number CERCLA-02-2004-2007) was completed in May 2005.  During the Removal Action, a dispute arose between the PRP and the PRP’s clean-up contractor. At the time, the dispute could not be resolved in a timely fashion and was an impediment to the progression of the site clean-up.   The current property owner, not named as a PRP in the AOC, therefore volunteered to complete the Action.  All wastes specified under the AOC were removed from site as of May 9, 2005.

A total of 151 drums containing hazardous materials and oily wastes; approximately 7 tons of contaminated soil and grinding swarf; approximately 2.5 tons of furnace media; and 22 lab pack-sized containers were shipped for off-site disposal.  As part of the drum removal, a total of 36 drums containing TCE and TCE contaminated materials were removed from site for an approximate total of 11,720 pounds of TCE-related waste.  A total of 2,643 gallons of oil liquids and 2,043 gallons of oily sludges from 3 floor pits and 3 tanks/vats were also removed and shipped off-site for fuels blending/recycling.   An addtional 2,700 gallons of oil-contaminated water were also recovered from drums and shipped for recycling/treatment.  Wastes streams were consolidated as feasible in order to maximize the cost effectiveness of disposal.

The following is a chronological summary of the activities that were conducted under the AOC:

September 28, 2004 through September 30, 2004:

Clean-up operations under the approved work plan were initiated.  Oil liquids and sludges from 2 floor pits, 2 tanks and 74 waste oil drums were consolidated using a vacuum truck.  On September 28, 2004, approximately 2,556 gallons of oil and sludge and 2,700 gallons of oily water were shipped for recycling/treatment to the Booth Oil facility in Buffalo, New York.  Oily-water waste was also recovered from a floor pit in the east side of the building and placed into nine 55 gallon drums for shipment to Safety-Kleen’s facility in Smithfield, Kentucky.  Additionally, 30 drums of trichloroethylene contaminated liquids (approximately 9,650 lbs.), 12 drums of corrosive liquids and one drum of paint waste were shipped for disposal to the Smithfield, Kentucky facility.

Other work conducted during this period included the overpacking of drums for later disposal.  Oil was also removed from the containment area in the grinding room and the outdoor lean-to/sheds that were previously used for storing drums.  Free oils were removed from these areas using corn cob absorbent materials which were placed in drums for transportation purposes.  A total of 10 x 55 gallon drums of oil/absorbent were generated and staged for later disposal.

October 8 through October 13, 2004:

Twenty-seven drums of non-RCRA hazardous waste were shipped for disposal to the Safety-Kleen facility in Smithfield, Kentucky on October 8, 2004.  The drums had been previously overpacked and staged for disposal during the week of September 28, 2004.  Drummed wastes included in this shipment consisted of  oil/absorbent from site clean-up operations, buffing compounds, non-cyanide containing hardening salts and lubricating compounds.  An approximate total of 13,200 pounds of wastes were shipped on this date.

Consolidation of waste streams was continued during this period.  The contaminated soil pile that was previously staged on the concrete pad in the courtyard was loaded into a roll-off container.  Grinding swarf was removed form the shed in the courtyard and from the floor in the grinding room.  The grinding swarf was combined for disposal with the soil in the roll-off container.  Empty plastic drums were cut up on-site and also added to the roll-off.  The roll-off container - with a combined total of 13,140 pounds of soil, cut plastic drums and grinding swarf - was shipped as a non-RCRA hazardous waste to the Waste Management/CID landfill in Chaffee, New York for disposal on October 13, 2004.

Also during this period, sixteen drums of furnace media were overpacked in preperation for disposal.   Various other materials from throughout the building were also consolidated and placed in drums as necessary.  A detailed inspection of the building was conducted and several small containers of oil, degreasers, 2 drums of used hydraulic oil and miscellaneous bags of dry chemicals were gathered from various locations throughout the building, packaged as needed and staged for disposal.  A final inspection of the building was conducted to ensure that no miscellaneus containers of oil and/or hazardous materials had been missed.

A total of 17 drums of RCRA-hazardous wastes and one drum of non-RCRA waste were shipped to the Chemical Waste Management (CWM) facility in Model City, New York on October 13, 2004.  Sixty-five RCRA-empty drums were also shipped off-site to Vexor Technology, Inc. in Medina, Ohio.

On October 20, 2004, approximately 275 gallons of TCE were recovered from the solvent tank at the degreaser in the mirror finishing area.  The recovered TCE was placed into five 55 gallon drums for shipment purposes.  A total of 10 drums of waste, including the 5 drums of TCE, were shipped for disposal to the Safety-Kleen facility in Smithfield, Kentucky.

December 2, 2004 through January 6, 2005:

After October 20, 2004, work was temporarily discontinued because of a dispute between the PRP and their clean-up contractor over billing and payment for services.  The issue could not be resolved in a timely fashion, so the new building owner, although not named as a PRP in the AOC, offered to fund the remainder of the clean-up activities cited in the approved work plan.

Work activities were resumed on December 2, 2004 when removal of the salts from the hardening pots was initiated.   The material was removed from the pots via jack-hammer and placed into drums for shipping purposes.  A total of six drums of hardening salts were recovered from the pots.  Additionally, the contents from a third pit were removed via vac truck.   The pit had been previously discovered beneath a steel plate in the hollow grind room.  A total of 400 gallons of liquid oil and 1,500 gallons of sludge were recovered from the pit.

All remaining oil and hazardous wastes, with the exception of one unknown drum,  were shipped off-site for disposal on December 8 and 9, 2004.  The 1,900 gallons of oil and sludge were shipped via railcar for recycling to Ecological Systems, Inc. in Indianapolis, Indiana.  The 6 drums of hardening salts and 1 drum of TCE contaminated wastes were shipped to the CWM facility in Model City, New York.  Three drums of PPE and oil absorbent wastes, generated during site cleanup activities, were shipped to the Safety-Kleen facility in Smithfield, Kentucky.  The final unknown drum was identified as a non-RCRA hazardous polishing compound and was shipped for disposal to the Safety-Kleen facility in Hebron, Ohio on January 6, 2005.

A Problem was encountered when CWM rejected the 6 drums of hardening salts upon receipt at their Model City, New York facility on December 8, 2004.  The drums had been screened at the facility prior to acceptance and had shown low levels of radioactivity at the drum surface.  Although the levels were extremely low, the drums were rejected and returned to the site pending investigation.

On January 12, 2005, EPA OSCs visited the site to investigate the presence of raiological contamination in the 6 drums of hardening salts.  Low level readings of radioactivity were found on the outside of the drums at 13 uR/hour above background.  Readings obtained from the open drums directly above the waste were between 30 -36 uR/hr.  These levels are not considered to present a health hazard.  Screening with the SAM 935, an instrument capable of identifying radio-isotopes, indicated that the source was most likely potassium 40, a naturally occuring isotope that is not regulated for shipping or disposal.   A sample was sent for confirmatory radio-isotope analysis to the EPA National Air and Radiation Environmental Laboratory (NAREL) in Montgomery, Alabama.

NAREL confirmed naturally occurring potassium 40 as the source of radiological contamination in the hardening salts.  Since potassium 40 does not present a health hazard at the levels encountered and is not a regulated waste, the CWM facility in Model City, New York was permitted to accept the wastel.  The 6 drums were shipped to CWM in Model City on May 9, 2005 for ultimate disposal.  This represented the final shipment of wastes required under the scope of the AOC.

Note:  $25,000 of the extramural contingency was reallocated to RST contract costs for this Removal Action.  $10,000 from the extramural contingency was also reallocated for Atlantic Strike Team (USCG) costs.

Planned Removal Actions
It should be noted that soil samples were collected in May 2004 from two outdoor areas of concern where drums with reported minor leaks were stored and had potentially impacted the soils. The impacted soils had been excavated by others prior to EPA’s involvement, were staged in the courtyard on a concrete pad and later disposed of under the AOC. The soil samples collected in May 2004 indicated that the soils immediately impacted by the leaking drums had been effectively excavated. However, elevated levels of chromium and lead were detected. These contaminants may have been in the metallic form, since metal shavings and small bits of metal scrap are present throughout the site. The scope of the AOC had been limited to the removal of wastes and soils immediately impacted by the leaking drums in these two areas of concern. Further investigation of site-wide contamination is outside of the scope of the AOC and will be conducted by parties other than the PRPs named in the AOC. Work under the intended scope of the AOC is therefore complete.

Next Steps
The current property owner initiated a Phase II environmental site assessment (ESA) in August 2004 and has released the investigation report to the EPA. The ESA included a limited asbestos survey, soil borings/sampling and ground water sampling. EPA will evaluate the report to determine the need for further investigation, the eligibility for further Removal Action under CERCLA or for possible referral back to the State of New York for remediation.

Disposition Of Wastes

Waste Stream	Quantity	Manifest #	Disposal Facility
Oil/Water (Non-RCRA Waste)	2,700 gallons	NA	Booth Oil Facility 60 Katerine Street Buffalo, NY 14210
Waste Oil (Non-RCRA Waste)	2,113	NA	Booth Oil Facility 60 Katerine Street Buffalo, NY 14210
Oil Sludge (Non-RCRA Waste)	443 gallons	NA	Booth Oil Facility 60 Katerine Street Buffalo, NY 14210
Oil/Water (Non-RCRA Waste)	430 gallons/ ~3,600 lbs	NYC-7409158	Safety-Kleen Systems,Inc. 3700 LaGrange Road Smithfield, KY 40068
TCE (Waste Toxic Liquids, Organic, N.O.S.)	17 drums, ~ 5,750 lbs.	NYC-7173753	Safety-Kleen Systems,Inc. 3700 LaGrange Road Smithfield, KY 40068
TCE/Chromium (Hazardous Waste, Liquid, N.O.S.)	18 drums, ~5,900 lbs	NYC-7173753	Safety-Kleen Systems,Inc. 3700 LaGrange Road Smithfield, KY 40068
TCE	10 Gallons	NYG-344889	CWM Chemical Services, LLC 1550 Balmer Road Model City, New York
Waste Paint Related Material	2 drums, ~840 lbs	Various	Safety-Kleen Systems,Inc. 3700 LaGrange Road Smithfield, KY 40068
Corrosive Liquids (RCRA Hazardous)	12 drums, ~ 4,200 lbs	NYC-7409158	Safety-Kleen Systems,Inc. 3700 LaGrange Road Smithfield, KY 40068
Non- RCRA Regulated Wastes (various)	36 drums, 15,410 lbs.	NA	Safety-Kleen Systems,Inc. 3700 LaGrange Road Smithfield, KY 40068
RCRA Empty Drums	65	Bill of Lading No. 74321	Vexor Technology, Inc. 955 W. Smith Street Medina, OH
Non-RCRA Solids (Soil, Grinding Swarf and plastic debris)	13,140 lbs.	Non-Haz Waste Manifest No. 87654	CID landfill 1080 Olean Road Chaffee, NY 14030
Waste Aerosols, Flammable	1 drum, ~ 50 lbs.	NYG 3449835	CWM Chemical Services, LLC 1550 Balmer Road Model City, NY 14107
Hazardous Waste Solid, N.O.S. (Furnace Media)	16 drums, ~4,800 lbs.	NYG 3449835	CWM Chemical Services, LLC 1550 Balmer Road Model City, NY 14107
NON-RCRA Waste Water	1 drum, ~ 15 gallons	NYG 3449835	CWM Chemical Services, LLC 1550 Balmer Road Model City, NY 14107
Non-RCRA Solids (Hardening Salts)	6 drums	NYG 3449835 (rejected); Non-Haz Man. 87412 (re-shipment)	CWM Chemical Services, LLC 1550 Balmer Road Model City, NY 14107
Non-RCRA Solids (polishing compound)	1 drum, ~400 lbs.	Bill of Lading No.19686	Safety-Kleen Systems 581 Milliken Dr. SE Hebron, Ohio 43025
Non-RCRA Liquds/Sludges (Waste Oil/sludge)	1,900 gallons	NA	Ecological Systems, Inc. 4910 West 86th Street Indianapolis, IN 46268