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.
On 8/4/2016 the OSC and a team of ERT/SERAS contractor personnel mobilized to the Site and haz-cated 21 drums of chemicals with the following results:
1 pH 1 RCRA D002 Corrosive Waste
1 pH 2 RCRA D002 Corrosive Waste
1 PCBs > 50 ppm TOSCA regulated
3 highly flammable/ignitable
1 aluminum sulfate is a CERCLA listed Hazardous Substance
1 chlorinated toluene is a CERCLA listed Hazardous Substance
1 kerosene/water combo
Drum labels indicate the presence of, among other chemicals, sodium hydroxide, sulfuric acid, formic acid, nitric acid and "oil processing leather".
A rough drum count was made as follows: Totes: 4 with a total of 1,000 gals; 55-gallon: 70 full/partial, 1 drum over-pressurized & 1 drum under-pressurized. 30-gallon: 50; 5 gallon: 70, 1 container may have crystals around the bung. In addition to the chemical containers there are two ASTs, one inside and one outside, that may contain product. There may also be a chlorine gas source in the former WWTP.
There are 22 drums of mostly dye pigment that were overturned by vandals and spilled inside the main building. Most of this material is puddled on the first floor of the building, although a red dye had migrated from the building into the parking lot.
Also on 8/4/2016, verbal authorization to initiate a removal action at this site and contractor funding was given to the OSC.
On 8/10 ERRS and the OSC mobilized to the Site to initiate the removal action. ERRS cleared weeds and underbrush from the perimeter of the building and strung barrier fence parallel to the jogging trail that runs along the west side of the main building. On 8/11 ERRS prepared a drum staging area in the main building. The OSC contacted Aeries Chemical Co., Beaver Falls, NY and the company agreed to pick up all of their unused chemicals on an as-found basis. The OSC had ERRS relocate one drum of NaOH, an empty chemical tote and one 55-gallon drum of Aeries anti-floc agent from the WWTP to the staging area. ERRS also moved two other Aeries totes totaling almost 400 gallons of NaOH to the storage area. Tentative pick up date for these chemicals is 8/19.
On 8/11 the office and crew trailers were set up and connected to the generator.
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.
The OSC obtained a copy of the current property deed from the Fulton County Clerk.
2.1.4 Progress Metrics
Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
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