1.1.1 Incident Category

Abandoned leather tannery.

1.1.2 Site Description

The Site is a former family-owned leather tannery that had been operating as such since 1976.  Eighty percent of its business was contracts with the Dept. of Defense.  Prior to that it was owned/operated as Knox Gelatin factory.  In 2009 Carville Leather experienced a series of minor fires that caused brief business interruption.  In 2012, following a major downturn of military contacts, business began to suffer and the company began a rapid fiscal decline.  In 2013 the tannery closed its doors and the owner filed for Chapter 11 (reorg) bankruptcy protection, but there is no record of any actual reorganization of the business.  No property taxes have been paid since 2012, and the Site appears, for all intents and purposes, to have been abandoned by its owners.

1.1.2.1 Location

The Site is located in a heavily treed, partial 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 accessed the building and overturned drums of chemicals.  A red dye was spilled inside the building and it 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.

2.1.1 Narrative

2.1.2 Response Actions to Date 

The crew and all rental equipment was demobilized on 1/26.  Dye-stained trash was bulked into drum liners and placed in a triple lined trash roll-off.  Disposal occurred on 1/27 at the Fulton County landfill.

All response activities as specified in the Scope of Work in the Action Memo have been completed.

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.  Access to the Site was granted verbally to both the OSC and EPA Site attorney.  The OSC obtained a copy of the current property deed from the Fulton County Clerk and has given copies to the EPA attorney.

2.1.4 Progress Metrics

2.2.1 Anticipated Activities.

Send notification to the NYSDEC and local authorities reporting this new release and how it was mitigated.

2.2.1.1 Planned Response Activities

None

2.2.1.2 Next Steps

None

2.2.2 Issues

None.