1.1.1 Incident Category
Emergency removal action, referred by the New York State Department of Environmental Conservation (NYSDEC) on June 27, 2013.

1.1.2 Site Description
The former Jones & Laughlin Ore Company property is a 54-acre iron ore processing facility that ceased operations in the late 1970’s. The “Site”, as referred by the NYSDEC, consists of a 36 acre portion of the property that includes several deteriorating buildings.

The Site was part of a former ore processing facility in which operations shutdown in 1978. Since that time one private entity, Dongrove Holdings, has held title to the property with its primary use being building demolition and metal scrapping in the early 1990s. At some point in the early 1990s, Dongrove Holdings abandoned the property leaving many of the Site buildings in a deteriorated condition.  Since that time, additional unauthorized access and vandalism has occurred at the Site.  Due to years of neglect and acts of vandalism and/or unauthorized scrapping of Site metals, most of the Site buildings are in a severe state of deterioration.  Deteriorated or collapsed roofing on some buildings have also caused additional weather damage to internal building materials such as plaster walls and ceilings.

Portions of the site are wooded and overgrown with the Little River flowing from east to west through the central portion of the site. A former 2.5-mile long, 200 feet deep, strip mine (Benson Mines) has flooded and now forms an approximate 300 acre lake along the site’s northern border.

1.1.2.1 Location
The Site is located at 4669 State Route 3, Clifton, NY (St. Lawrence County), at the intersection of State Highway 3 and County Route 50.

Latitude: 44.1676820 / Longitude: -74.9952508

1.1.2.2 Description of Threat
There is a threat to human health posed by friable ACM and mercury containing devices present at the Site. Friable ACM was observed in decaying bags and lying on the ground in several areas of the Site. Mercury containing devices were found in decaying condition and mixed within debris of deteriorating building materials. Disturbance of these materials would result in a direct contact threat.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

On June 27, 2013, the NYSDEC referred the Site to EPA to assess and consider the Site for a removal action to address CERCLA hazardous substance that are present and pose a potential threat of direct contact to human health. EPA reviewed the NYSDEC’s request along with associated assessment reports and conducted two site inspections on July 15, 2014 and July 31, 2014. During the Site inspections EPA observed friable asbestos containing materials (ACM) in decaying bags in one building as well as friable ACM pipe insulation laying on the floors of other buildings on the Site. EPA also observed mercury containing devices (i.e. switches and components) within two Site buildings. These devices were in decaying condition and posed a potential threat of release. Along with the friable ACM and mercury devices, approximately 1 dozen small storage containers and drums of unknown material were observed at the Site.

An EPA review of the NYSDEC assessment reports along with observations made during the EPA Site inspections concluded that conditions at the Site meet the criteria for a removal action under CERCLA as documented in Section 300.415(b)(2) of the National Contingency Plan.

RESPONSE ACTIVITIES

Asbestos and Mercury Waste

The EPA Emergency and Rapid Response Services (ERRS) contractor completed the off-site shipment of asbestos and mercury waste on 10/17/14.  Five cubic yards of asbestos were shipped off-site along with one 55 gallon drum of mercury contaminated debris and one 55 gallon drum of mercury containing devices.  A listing of disposal locations can be found in the waste disposition table at the end of this section.

Drum/Container Waste

The wastes identified in 15 on-site drums were haz-catted on 9/18/14 and bulked successfully during the week of 9/22/14.  Drum wastes were bulked based on their hazard classifications.  Bulked wastes were sampled on 10/7/14 with samples submitted to a NELAP certified laboratory for waste characterization analysis.

Waste characterization analysis for the drum waste was received on 10/27/14.  An RFQ for the transportation and disposal (T&D) was finalized and put on the street 10/29/14.  Bids were received and evaluated during the week of 11/4/14 with the T&D bid being awarded on 11/7/14.  Waste profiles and shipping papers were prepared during the week of 11/10/14 and all drum wastes were shipped off-site on 11/17/14.

The drum waste included RCRA hazardous wastes, ignitable (D001), as well as non-RCRA regulated wastes including corrosive solids (basic), corrosive solids (acidic), and neutral solids.  A listing of disposal locations can be found in the waste disposition table at the end of this section.

As of November 18, 2014, all generated waste has been shipped off-site and all the EPA ERRS and Removal Support Team (RST) contract resources utilized for this action have been demobilized from the Site.

ASSESSMENT ACTIVITIES

On September 16-17, 2014, the EPA RST contractor collected a total of 41 bulk material samples from 23 distinct locations.  The bulk samples were submitted to a NYS ELAP accredited laboratory for asbestos analysis by NY ELAP 198.1 method.  The samples were collected from suspect ACM with the primary focus being on plaster materials within Site buildings.  Plaster samples (ceiling and wall) were collected from buildings 2, 3, 7, 8, 9, 12, and 23.  In most cases, samples were collected from both the scratch coat and finish coat of the plaster area.  Ten of the plaster material samples, from five distinct locations, were reported as positive for asbestos (chrysotile).  The results ranged from 10.81% to 23.53%.  All ten samples were collected from ceiling plaster material.  The samples testing positive for asbestos were collected in buildings 2, 3, and 7. 

Seven bulk samples, from six distinct locations, were collected from building 8.  All building 8 samples were reported as non-detect for asbestos.  Only areas on the first floor were sampled due to the poor integrity of the building structure.  Samples were collected from areas where plaster was still in-tact on walls and ceilings as well as from plaster materials that were believed to have fallen off of walls and ceilings.  While the samples were all reported as non-detect, Suspect ACM material was observed in the basement of this building in the form of thermal systems insulation (TSI) on old piping.

Assessment sampling activities for ACM was not intended to fully characterize the Site buildings in terms of all ACM but rather to augment some of the previous sampling activities conducted under NYSDEC contracted work.  While much of the sampled material was reported as non-detect, data exists from past NYSDEC reports that indicates the presence of ACM within some of the Site buildings.  EPA is currently reviewing the most recent assessment data and data reported in NYSDEC reports related to friable asbestos containing materials.

On September 16, 2014, the EPA RST contractor collect a total of five chip samples from oil-stained wood-block flooring within building 12.  These samples were collected from four distinct locations.  Chip samples were collected from the oil-stained lens of wood-blocks found in the building.  The samples were analyzed for target compound list (TCL) polychlorinated hydrocarbons (PCBs) via EPA method SW846 8082.  Three of the five samples (including 1 duplicate) were reported as containing Aroclor 1254 with results ranging from 1.9(J) mg/kg to 19.1(J) mg/kg.  Three of the four locations sampled reported results as containing PCBs.

ENFORCEMENT ACTIVITIES

No viable potentially responsible parties (PRPs) have been identified at this point in time.  EPA will continue to work to identify any viable PRPs.

WASTE DISPOSITION TABLE

Planned Response Activities
There are no further planned response actions at this time.

Issues

There are no issues to report.

* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.