1.1.1 Incident Category

Abandoned leather tannery.

1.1.2 Site Description

The Site is a former leather tannery that had been operating as a tannery since 1976.  In 2009 there was a series of minor fires that caused a business interruption for a few months.  In 2012, following a major downturn of military contacts, business began to suffer and the company began a gradual fiscal decline.  In 2013 the tannery closed its doors and the owner filed for Chapter 11 (reorg) bankruptcy protection.   There is no record of any actual reorganization of the business.  No property taxes have been paid since 2012, and the Site,  for all intents and purposes, appears to have been abandoned. 

1.1.2.1 Location

The Site is located in a heavily treed residential neighborhood.  It is surrounded by trees on three sides and the Cayadutta Creek, a navigable waterway of the US, borders the site on the south side of the property.  A former RR right-of-way which was converted to a bike/walking trail, also borders the Site on the south side of the property adjacent to the creek.

1.1.2.2 Description of Threat

The threat is the presence of hundreds of drums and other containers of chemicals in an abandoned tannery that has nor power or functioning fire detection/prevention system.  Some of the entrances to the premises were unlocked and vandals have overturned drums of chemicals.  A red leather dye was spilled inside the building and it has migrated outside the building and into a parking lot.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

Results of a walk-thru inspection by two OSCs in mid-July revealed the presence of hundreds of drums and other containers of chemicals.  Some were labeled as acid or corrosive, and one drum is labeled as formic acid, a CERCLA Listed Hazardous Substance.  A large AST is located behind the main building and it may contain fuel oil or process chemicals.  A small building housing a filter-press also contains drums of a corrosive liquid.

2.1.1 Narrative

2.1.2 Response Actions to Date

Current activity is in bold letters.

Two Region 2 OSCs visited the Site in mid-July and inspected the building.  Afterwards they met with City officials who agreed to lock and secure any accessible openings.  Another Site visit is planned for early August to acquire chemical samples and haz-cat some containers.  A full inventory of chemical containers will also be compiled.  The AST will be accessed to determine if it contains any oil or chemicals.

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

Two PRPs have been identified from newspaper articles and bankruptcy court filings.  One PRP may reside in Florida, and the other one may reside in Savannah GA.  Efforts are currently underway to confirm the identity/location of PRPs so that EPA can obtain written access to the Site.

2.1.4 Progress Metrics

2.2.1 Anticipated Activities

Scheduling a sampling trip to characterize the abandoned chemicals and document Site conditions.

2.2.1.1 Planned Response Activities

See above.

2.2.1.2 Next Steps

See above.

2.2.2 Issues

Obtaining written access is currently the only issue.

3.1 Unified Command

3.2 Cooperating Agencies

NYSDEC

City of Johnstown NY