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Caswell, Strauss & Co., Inc. - 1660 Oak Tree Road

All POL/SITREP's for this site Caswell, Strauss & Co., Inc. - 1660 Oak Tree Road
Edison, NJ - EPA Region II
POLREP #1
Initial
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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Caswell, Strauss & Co., Inc. - 1660 Oak Tree Road - Removal Polrep
Initial Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region II

Subject: POLREP #1
Initial
Caswell, Strauss & Co., Inc. - 1660 Oak Tree Road
A296
Edison, NJ
Latitude: 40.5727545 Longitude: -74.3431445


To: Judith Enck, EPA
Lisa Plevin, EPA
Tim Grier, USEPA Headquarters 5202G
Joe Rotola, USEPA Region 02
Elias Rodriguez, USEPA Region 02, PAD
Doug Kodama, USEPA Region 2 ERRD
Beckett Grealish, USEPA Region 2, ERRD, RAB
Dan Harkay, USEPA, Region 02, ERRD-RAB
Jay Elliot, Edison Health Department
Wanda Ayala, EPA
Michael Fiore, EPA-R2-OIG
William Reilly, EPA-R2-ORC
George Zachos, USEPA Region 2 ERRD
Fred Mumford, NJDEP

From: Kelli Lucarino, On-Scene Coordinator
Date: 10/19/2012
Reporting Period: 10/15/2012 to 10/19/2012

1. Introduction
  1.1 Background
   
Site Number: A296    Contract Number:  
D.O. Number:      Action Memo Date:  
Response Authority: CERCLA    Response Type: PRP Oversight
Response Lead: PRP    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 10/15/2012    Start Date: 10/15/2012
Demob Date:      Completion Date:  
CERCLIS ID: NJC200400968    RCRIS ID:
ERNS No.:    State Notification:
FPN#:    Reimbursable Account #:

1.1.1 Incident Category

The property is a commercial property owned by Extra Space Properties Thirty Six, LLC and utilized as a self storage facility by Extra Space Storage.

1.1.2 Site Description

The Site presently consists of approximately 4.65 acres of land located within a tract, identified in the Edison Tax Map as Block 546-1, Lot 39A in Edison Township, Middlesex County, New Jersey. 

1.1.2.1 Location

The Site is within the footprint of land that was once owned by Caswell, Strauss & Co., Inc. prior to 1959.  At various times from the 1940s to 1959, Caswell carried out a lead smelting operation on the land it owned including the Site. 

The Site is situated in a suburban area characterized by residential, commercial retail and office development and vacant land and is improved with a 30-year-old, 93,875 SF, 1,024-unil self-storage facility.  Site improvements include 10 separate one and two story buildings and ancillary site work. Two of these 10 buildings were built in 1998/99. The buildings are of slab-on-grade construction, and the superstructures of the older buildings are a composite of structural steel and masonry bearing walls. The two newer buildings are built entirely of light gauge steel.

1.1.2.2 Description of Threat

Lead is a cumulative poison where increasing amounts can build up in the body eventually reaching a point where symptoms and disability occur. Particularly sensitive populations include children and pregnant women, because of the fetal transfer of lead. Cognitive deficits are associated with fetal and childhood exposure to lead. An increase in blood pressure is the most sensitive adverse health effect from lead exposure in adults. Effects of kidney, nervous system, and heme-forming elements are associated with increasing blood lead concentrations, both in children and adults. Other symptoms include decreased physical fitness, fatigue, sleep disturbance, aching bones, abdominal pains and decreased appetite.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

The Site was referred to the Environmental Protection Agency by the New Jersey Department of Environmental Protection in November 2011. The referral letter is included in Appendix B. Between January and May, 2012, EPA collected soil samples from a total of 29 residential properties located on Hilltop Road, Libby Court and Henry Street. The analytical results identified lead in concentrations greater than the EPA residential screening level of 400 parts per million at twelve of the 29 properties sampled. The properties where lead was identified have at least one quadrant or drip line location with lead greater than the action level of 400 ppm. From the twelve properties, the results for lead in quadrant surface samples ranged from 34 ppm to 5,610 ppm. Samples collected from below the surface (6” – 12”) ranged from 13 ppm to 5,320 ppm. The concentration of lead in samples collected from depths below one foot ranged from 7.7 ppm to 10,100 ppm. Drip line samples ranged from 11.6 ppm to 2,670 ppm.

 

In addition to the residential properties, the EPA collected soil samples from two commercial properties located within the historic footprint of the former Caswell, Strauss & Company, Inc. property at

1660 and 1670 Oak Tree Road and one commercial property located adjacent to this property at

1680 Oak Tree Road. Analytical results identified lead in concentrations greater than the EPA commercial screening level of 800 ppm on all three properties. Lead was detected in concentrations ranging from 12 ppm to 61,100 ppm on the 1660 Oak Tree Road property and from 1.0 ppm to

175,000 ppm on the 1680 Oak Tree Road Property.

 

Given the topography of the Site and the natural and manmade drainage pathways, surface water runoff from the Extra Space Storage property (1660 Oak Tree Road) drains directly onto the adjacent lots to the north, east and west. The highest lead concentrations were found at 2” – 6” below ground surface depth at the Extra Space Storage property and in an area immediately adjacent to the fence line on the Air Products property (1680 Oak Tree Road).

 

During the sampling event, the EPA observed surface water runoff from the Extra Space Storage property draining and pooling on the neighboring properties. Based upon the sampling conducted by the EPA, surface water runoff containing lead contaminated soils is believed to have migrated from the Extra Space property onto the adjacent commercial and residential areas.

2. Current Activities
  2.1 Operations Section
    2.1.1 Narrative

2.1.2 Response Actions to Date

Activities conducted during this reporting period include:

Contractors and subcontractors for Extra Space mobilized personnel and equipment to the site.

Clearing of vegetation in the areas of concern was conducted.

The removal of the existing fence was initiated along with installation of a temporary fence.

Excavation of contaminated soil in the northwest corner of the property was completed.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

 

A CERCLA Settlement Agreement and Order on Consent for Removal Action was signed on July 25, 2012 by the property owner of 1660 Oak Tree Road for work to be conducted on their property. The work includes implementation of measures to eliminate direct contact with lead contaminated surface soils and to prevent the migration of lead contaminated soil via surface runoff and air currents to any lands adjacent to the property, design and construction of surface water runoff control measures to prevent surface water runoff from the property from migrating onto adjacent properties, post-excavation sampling, site restoration, and maintenance activities as needed.

2.1.4 Progress Metrics

Waste Stream Medium Quantity Manifest # Treatment Disposal
           
           
           


  2.2 Planning Section
    2.2.1 Anticipated Activities

Extra Space will continue to conduct excavation of certain areas, capping of areas, installing a retaining wall and fence and site restoration activities.

2.2.1.1 Planned Response Activities

The site has been divided into six areas of concern as outlined in the Remedial Action Plan submitted and approved by EPA.  Extra Space will continue to implement the remedies outlined in the RAP for the identified areas of concern.

2.2.1.2 Next Steps

The site has been divided into six areas of concern as outlined in the Remedial Action Plan submitted and approved by EPA.  Extra Space will continue to implement the remedies outlined in the RAP for the identified areas of concern.

2.2.2 Issues

No issues were encountered during this reporting period.

  2.3 Logistics Section
    Not applicable

  2.4 Finance Section
    2.4.1 Narrative

The work is being conducted by the PRP under an AOC with the EPA.

  2.5 Other Command Staff
    2.5.1 Safety Officer

No safety issues were encountered during this reporting period.

2.5.2 Liaison Officer

Not applicable.

2.5.3 Information Officer

A photographer for USA Today was on site on 10/17/12 taking photographs and videos of activities.

3. Participating Entities
  3.1 Unified Command

3.2 Cooperating Agencies

USEPA

4. Personnel On Site
  1 - EPA OSC
3 - Environ personnel

5. Definition of Terms
  No information available at this time.

6. Additional sources of information
  No information available at this time.

7. Situational Reference Materials
  No information available at this time.

POLREP #1 Last Updated 10/19/2012