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Carville National Leather

All POL/SITREP's for this site Carville National Leather
Johnstown, NY - EPA Region II
POLREP #4
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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Carville National Leather - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region II

Subject: POLREP #4
Carville National Leather
A-295
Johnstown, NY
Latitude: 42.9999750 Longitude: -74.3805440


To:
From: Paul L. Kahn, On-Scene Coordinator
Date: 8/19/2016
Reporting Period:

1. Introduction
  1.1 Background
   
Site Number: A-295    Contract Number: EP-S2-15-02
D.O. Number: 045    Action Memo Date:  
Response Authority: CERCLA    Response Type: Emergency
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 8/10/2016    Start Date: 8/8/2016
Demob Date:      Completion Date:  
CERCLIS ID: NJD002193795    RCRIS ID: NYD0002840000
ERNS No.:    State Notification:
FPN#:    Reimbursable Account #:

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.  Prior to that date it was owned/operated as Knox Gelatin factory.  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 dye was spilled inside the building and it had 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 corrosive liquids.

2. Current Activities
  2.1 Operations Section
   

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.

During the week of August 15, 2016 ERRS relocated approximately 120 full/partial drums of chemicals from locations around the Site to the drum staging area.  Relocating containers will continue into next week.  Approximately 75% of all containers are unlabeled and/or unknown. 

ERRS has been directed to group together containers from various suppliers, such as Aries Chemical, Tannin Corporation, and Whtimore Chemical.   As these groupings are consolidated the OSC will contact those companies (as with Aries Chemical) to request they retrieve their products.   Every container returned to the original supplier as returned goods is one less container EPA will have to ship for disposal.  In many instances the chemicals can be re-introduced into commerce, resulting in a double positive environmental and financial benefit.

ERRS started collecting empty, and RCRA empty, containers for staging pending T & D.  Request for Proposals will be issued for T & D for these containers, with recycling and/or energy recovery the preferred disposal method. 

ERRS chemist to be on Site 8/22 to start haz-cating containers.   As the contents are identified ERRS will stage the drums by compatible groups for TCLP sampling.

ERRS remediated the extensive chemical spill caused by vandals inside the building prior to EPA involvement.  The spill was absorbed into Speedy-dri and bulked into drums pending sampling for T & D.  Trespassing into the Site seems to have been stopped; no incidents of unauthorized entry have been observed since last week. 

The pick up of returned goods by Aries Chemical (Beaver Falls, NY) was rescheduled to 8/26 as a result of a miscommunication.  Aries has assured the OSC their truck will be on Site next Friday.

OSC distributed informational flyers to residences around the Site and at the Johnstown Library.

The OSC has requested an attorney in ORC be assigned to this Site. 

 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
           
           
           


  2.2 Planning Section
   

2.2.1 Anticipated Activities

Continue crushing empty fiber drums and stacking empty poly drums for disposal.  Continue retrieving full and partial drums from around the Site and stage in main building.  Begin haz-cating and grouping by compatible waste streams.  Erect Site Sign at Knox Avenue entrance from main road.  Ship Aries Chemicals containers on 8/26.

2.2.1.1 Planned Response Activities

See above.

2.2.1.2 Next Steps

2.2.2 Issues

None

  2.3 Logistics Section
    No information available at this time.

  2.4 Finance Section
    No information available at this time.

  2.5 Other Command Staff
    No information available at this time.

3. Participating Entities
 

3.1 Unified Command

3.2 Cooperating Agencies

NYSDEC

City of Johnstown



4. Personnel On Site
 

EPA:  1 OSC

ERRS:  One Response Manager, two Techs, one Equipment Operator.

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

6. Additional sources of information
 

6.1 Internet location of additional information/report

 https://en.wikipedia.org/wiki/Tanning

6.2 Reporting Schedule

Weekly.



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


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