U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
New Method Cleaners - Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region II
|
|
Subject:
|
POLREP #2
Removal of Containers Completed
New Method Cleaners
A22D
Trenton, NJ
Latitude: 40.2303436 Longitude: -74.7744914
|
|
To:
|
|
|
From:
|
Keith Glenn, OSC/Environmental Scientist
|
|
Date:
|
8/15/2013
|
|
Reporting Period:
|
June 22, 2013 through August 7, 2013
|
|
1. Introduction
|
|
|
1.1 Background
|
|
|
|
|
Site Number: |
A22D |
|
Contract Number: |
S2-10-03 |
|
D.O. Number: |
|
|
Action Memo Date: |
6/18/2013 |
|
Response Authority: |
CERCLA |
|
Response Type: |
Emergency |
|
Response Lead: |
EPA |
|
Incident Category: |
Removal Action |
|
NPL Status: |
Non NPL |
|
Operable Unit: |
|
|
Mobilization Date: |
6/18/2013 |
|
Start Date: |
6/18/2013 |
|
Demob Date: |
|
|
Completion Date: |
8/7/2013 |
|
CERCLIS ID: |
NJN000206585 |
|
RCRIS ID: |
|
|
ERNS No.: |
|
|
State Notification: |
|
|
FPN#: |
|
|
Reimbursable Account #: |
|
1.1.1 Incident Category
Emergency Response action taken to address containers that are leaking, bulging, and/or compromised due to rust, missing lids, and disturbance.
1.1.2 Site Description
The City of Trenton and the New Jersey Department of Environmental Protection (“NJDEP”) requested the United States Environmental Protection Agency (“EPA”) to conduct a removal assessment of the New Methods Cleaners, Inc. Site. Initial EPA requests were received in June 2006 from NJDEP case managers. EPA received additional verbal and email requests from the City of Trenton in August 2012. On March 27, 2013 the Region received a formal request from NJDEP for a removal action consideration under CERCLA.
On April 1, 2013 the Removal Action Branch commenced operations of a removal assessment at the Site and surrounding properties. As part of these operations, hazardous characteristics (“HAZCAT”) techniques were conducted on the contents of various containers located inside the facility as well as outside. Numerous containers, a majority of which were 55-gallon drums, were found to be compromised. Drums were noted to be leaking, rusted, and/or bulging. Several containers had been removed of their tops and contents voided, suspected to the ground or the nearby surface water stream. Approximately 30 containers of unknown contents and without labels were found outside of the structures. Two (2) 275-gallon totes associated with a defunct groundwater treatment plant were found inside the building containing unknown liquids. In attempts to identify characteristics of material, nineteen (19) containers were opened and aliquots of the contents were used for HAZCAT purposes. In addition, two (2) containers were sampled via laboratory analysis for volatile organic compounds (“VOCs”).
During the RSE and following HAZCAT of material, efforts were made to temporarily stabilize the containers that were leaking. Drums that were lying on their sides were up-righted and placed in the same area with the other containers. Temporary lids were placed on open-top containers to prevent rain from intruding on the material. Holes located on the sides were patched with sorbent cloths and secured as best as practical. A temporary berm was placed around the bulk of the containers to prevent any potential migration of contents. Although not permanent measures, these activities were done until sufficient analytical data could be received from samples collected of several containers. Such data was received in June 2013.
On June 18, 2013 EPA received a letter from the property owner indicating that no actions would be conducted on the part of the owners. EPA requested, and received, funding for performing an emergency removal action of the containers containing hazardous substances. A verbal approval for the allocation of $75,000 was given on June 18, 2013.
1.1.2.1 Location
The New Methods Site is located at 310 Prospect Street, Trenton, Mercer County, New Jersey. It is bordered to the north and east by Prospect Street, to the south by East Stuyvesant Avenue, and the west by a vacant lot and stream. The 1.9 acre property includes a 4,200 square-foot structure that currently houses the Bell Boy Cleaners and an unused area. The area is primarily residential with light commercial areas to the south and east. Adjacent to the stream is a paving company that has been in operation since 1948, Barrett Paving. Vacant lands and Power Magnetics, Inc, a company that constructs magnetic and voltage equipment for utilities since 1968, are located to the west. Although no residential properties are located on East Stuyvesant Avenue, the residential properties that line Rutherford Avenue provide access to this southern boundary. Located across the street from the Site is a Senior Citizen Center and Community Recreational Hall that is utilized by area children.
1.1.2.2 Description of Threat
Actual releases of hazardous substances from onsite containers have been documented. The HAZCAT operation indicated container contents are highly flammable, containing chlorinated compounds, and/or with high alkalinity. Samples were collected from two containers and analyzed for VOCs. Results were received in June 2013 and indicated the presence of dichloroethene, trichloroethene, and tetrachloroethene. Labels on several containers included the following: isopropyl alcohol, methyl alcohol, and staticol (a trade name product with glycol ethers). Containers were found to be compromised with contents spilled onto the ground, near a surface water creek, and throughout the rear of the subject property. Several containers were also found to be bulging, rusted out, and free of sealed tops presenting a hazard to human health and the environment. Heavy rains have also been causing overtopping conditions of several drums that are void of covers, causing additional spills onto the soil.
The hazardous substances listed below were observed to be present at the Site during the removal site evaluation in April 2013.
|
Compound
|
Statutory Source for a Hazardous Substance |
|
311(b)(2) CWA
|
307(a)CWA
|
112 CAA
|
3001 RCRA
|
|
1,2-Dichloroethene
|
|
X
|
|
X
|
|
Trichloroethene
|
X
|
X
|
X
|
X
|
|
Tetrachloroethene
|
|
X
|
X
|
X
|
|
Methyl Alcohol
|
|
|
X
|
X
|
|
Staticol (trade name with glycol ethers)
|
|
|
X
|
|
The following hazardous substances are unlisted hazardous wastes with characteristics designated as a hazardous substance under Resource Conservation and Recovery Act (“RCRA”) §3001. This material was analyzed through field instrumentation that gives the hazard characteristic of the substance.
· Approximately 6 containers of flammable liquids;
· Approximately 1 drum of high alkalinity;
· Approximately 2 containers indicating the presence of chlorides, a corrosive;
· Approximately 20 containers of unknown contents.
The mechanisms for releases to the environment are from poor handling practices and storage of materials due to abandonment. Along with poor housekeeping, most containers are located in an unsecured location and exposed to adverse weather elements. Human contact and interference with the containers is evident as several empty containers are located along the surface water creek and used as tables, chairs, and toilets. Common routes of exposure to these materials include dermal contact, ingestion, and inhalation.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
Analytical results indicate that chlorinated solvents are present in the compromised containers. Refer to the 1.1.2 for additional information.
|
|
2. Current Activities
|
|
|
2.1 Operations Section
|
|
|
|
2.1.1 Narrative
Following HAZCAT of material and sample analysis of several containers, a representative of Selesnick Property LLC was contacted. Michael Selesnick was given a Notice of Federal Interest dated June 4, 2013 identifying the containers, contents of such, and the poor conditions that are leading to an active release. The notice, sent via certified mail, gave the property owner until June 18, 2013 to respond with availability to perform the stability, cleanup, and removal of materials. On June 18, 2013 EPA received a letter from Mr. Selesnick indicating that he does not own the property, conveying no action to be taken on behalf of Mr. Selesnick or Selesnick Property LLC.
2.1.2 Response Actions to Date
The ERRS contractor was identified and activated on June 18, 2013. The following day, all parties met at the facility to commence stabilization activities. Significant overgrowth around several containers was removed and an inventory of containers was conducted. Several drums were found to have broken through previous temporary measures designed to prevent further migration. Those conditions were addressed. Plans were formulated for over-packing containers, content transfer, and bulking like materials.
On June 19, 2013 all containers located outside were secured in over-pack drums. The highly flammable material located in tanks associated with an old dry cleaning unit were evacuated using pumps. This material was transferred to three 55-gallon drums and remains secured inside the facility. The material located in 275-gallon totes associated with the former pump and treatment unit was transferred into five 55-gallon drums and secured inside the facility until disposal.
Samples were collected from each container. All like materials, based on HAZCAT results, generated composite samples for bulked materials. Samples were sent to laboratories on approximately June 24, 2013. On July 5, 2013 all analytical results were sent to the ERRS contractor. Following review of data, a bid request was generated for the transportation and disposal of materials. The subcontract was awarded in late July 2013.
On August 7, 2013 all containers were labeled for transport. Freehold Cartage arrived at the New Method Cleaners Site and all containers were loaded into a box trailer. Containers were sent to EQ, Michigan Waste Disposal, and Wayne for appropriate disposal of container content. All RCRA empty containers were also removed and disposed of.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Following HAZCAT of material and sample analysis of several containers, a representative of Selesnick Property LLC was contacted. Michael Selesnick was given a Notice of Federal Interest dated June 4, 2013 identifying the containers, the contents of such, and the poor conditions that are leading to an active release. The notice, sent via certified mail, gave the property owner until June 18, 2013 to respond with availability to perform the stability, cleanup, and removal of materials. On June 18, 2013 EPA received a letter from Mr. Selesnick indicating that he does not own the property, conveying no action to be taken.
Mr. Selesnick continues to state that his company, Selesnick Property LLC, is no longer in existence. The company has not paid taxes on the Site property since 2008. As such, Mr. Selesnick claims that he no longer owns the land and is therefore not responsible for the conditions presented at the Site.
2.1.4 Progress Metrics
The following table will be completed following the analysis of samples collected to finalize the waste streams associated with the New Method Cleaners Site.
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| F002, N.O.S. |
Solid |
770g |
011149413 JJK |
|
Wayne |
| F002, N.O.S. |
Liquid |
195g |
011149411 JJK |
|
EQ |
| F002, N.O.S. |
Liquid |
55g |
011149412 JJK |
|
Michigan |
| F002, N.O.S. |
Liquid |
330g |
011149410 JJK |
|
EQ |
| D007, D008, D0039, D0049 |
Liquid |
55g |
011149410 JJK |
|
EQ |
| 021L |
Liquid |
165g |
011149410 JJK |
|
EQ |
|
|
|
2.2 Planning Section
|
|
|
|
2.2.1 Anticipated Activities
All material has been removed from the Site. No additional anticipated activities are expected.
2.2.1.1 Planned Response Activities
The removal action authorized by the Action Memo has been completed. No additional response activities are planned.
2.2.1.2 Next Steps
Track the disposal of material.
2.2.2 Issues
None to report.
|
|
|
2.3 Logistics Section
|
|
|
|
ERRS and Region 2 are dealing with any logistical issues or concerns.
|
|
|
2.4 Finance Section
|
|
|
|
No information available at this time.
|
|
|
2.5 Other Command Staff
|
|
|
|
2.5.1 Safety Officer
Safety is being provided by the ERRS contractor and the OSC.
2.5.2 Liaison Officer
The Liaison Officer is not activated for this removal action.
2.5.3 Information Officer
The information officer is not activated for this removal action.
|
|
3. Participating Entities
|
|
|
3.1 Unified Command
UC is not necessary for this response.
3.2 Cooperating Agencies
NJDEP and the City of Trenton has been working with EPA on this project.
|
|
4. Personnel On Site
|
|
|
All personnel departed the site following activities on August 7, 2013:
1 EPA OSC
2 ERRS
1 Subcontractor (Freehold Cartage)
|
|
5. Definition of Terms
|
|
|
Definition of Terms
Assisting and Cooperating Agencies - Agencies who are assisting the EPA response, but are not a part of Unified Command.
E Goods - Electronic machines which contain hazardous components. Emergency Response - any activity undertaken by the Operations Section which mitigated an immediate threat to human health or the environment.
FRP - Facility Response Plan. Under the Clean Water Act, as amended by the Oil Pollution Act, a plan for responding, to the maximum extent practicable, to a worst case discharge, and to a substantial threat of such a discharge, of oil. Required by certain facilities that store and use large quantities of oil.
Household Hazardous Waste - Small quantity waste from households that contain corrosive, toxic, ignitable, or reactive ingredients is hazardous. This includes pesticides, paint, solvents, etc.
Hazardous Debris - Debris which contains compounds that make it inappropriate for municipal landfill disposal
Monitoring - Using equipment which will give limited real-time information about constituents in environmental media. This method is used most often for air and water testing.
RCRA - Resource Conservation and Recovery Act.
RMP- Risk Management Plan. Under the Clean Air Act, certain facilities with large quantities of toxic potentially air born chemicals whose releases may impact human populations are required to submit to EPA a plan for hazard assessment, prevention, and emergency response.
Sampling -The process of taking environmental media for analysis at a laboratory of its constituents. These tests may require multiple days to complete, but test for a wider array of constituents than monitors.
Small Container - any container with a potential capacity of less than 5 gallons.
TRI - Toxic Release Inventory - A publicly available EPA database that contains information on toxic chemical releases and other waste management activities reported annually by certain covered industry groups as well as federal facilities. This inventory was established under the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) and expanded by the Pollution Prevention Act of 1990.
Unified Command - A structure based on the Incident Command System (ICS) that brings together the Incident Commanders of all major organizations involved in the incident in order to coordinate an effective response, while at the same time allowing each to carry out their own jurisdictional, legal, and functional responsibilities.
White Goods - Large home electronics such as refrigerators, washing machines, and dryers.
WW - Wastewater Treatment Facilities
|
|
6. Additional sources of information
|
|
|
6.1 Internet location of additional information/report
www.epaosc.org/NewMethodCleaners
6.2 Reporting Schedule
A final POLREP will be generated following the completion of 1900-55s.
|
|
7. Situational Reference Materials
|
|
|
No information available at this time.
|
|
|
