1.1.1 Incident Category

Emergency removal action referred by the New York State Department of Environmental Conservation (NYSDEC) on July 8, 2014.

1.1.2 Site Description

The Site is the location of a defunct consumer paper products manufacturing facility.  The 4.5-acre Site is comprised of a dilapidated manufacturing facility and paper mill that operated from 1972 to 1995.  This facility manufactured consumer sanitary paper products, including facial tissue and toilet paper. The Site buildings are in a severe state of decay and previously conducted metal scrapping activities have left parts of the manufacturing building severely damaged. The Site is located in a rural area with residential properties in close proximity and the Batten Kill River running along the eastern portion of the Site property.

1.1.2.1 Location

The Site is located at 2822 NY Route 29 in Greenwich, Washington County, New York.  Greenwich is a small community approximately 25 miles northeast of Albany, New York and 25 miles east of Saratoga Springs, New York.

Site Coordinates:  43°06'34.34"N latitude, -73° 25'18.31"W longitude.

1.1.2.2 Description of Threat

There is a threat to human health posed by friable ACM present at the Site.  Friable ACM was observed in the form of thermal systems insulation (TSI) on pipes formerly used to provide steam to former plant operations.  The friable ACM was observed in deteriorating condition, hanging from pipes as well as found on the floor areas below some of the piping.  Prior metal scrapping operations and partial demolition of the Site building has left the friable ACM exposed to the elements with a potential threat for off-site release.

From August 18-20, 2014, The EPA Removal Action Branch (RAB) conducted a removal site evaluation (RSE) of the Site.  EPA observed friable ACM as well as several smaller containers (1-15 gallon) of waste that included dielectric oils and paints.  EPA observed the Site building to be in deteriorating condition and noted that part of the building had been involved with a prior demolition activity.  Prior demolition and metal scrapping activities left large portions of the western perimeter walls open, exposing much of the friable asbestos pipe insulation to the elements (i.e. wind, rain, snow). 

As part of the RSE, samples were collected from the smaller containers as well as from suspect ACM which included the deteriorating insulation on piping at the facility.  Results from the pipe insulation document the material as containing amosite and chrysotile asbestos in percentages greater than 1%, with the highest recorded levels being at 28.6% amosite and 13.3% chrysotile. Soil samples were also collected and analyzed for asbestos.  Results from the soil sampling documented asbestos in the soil at 0.25 percent.

The EPA RSE concluded that conditions at the Site meet the criteria for a removal action under CERCLA as documented in Section 300.415(b)(2) of the National Contingency.

2.1.1 Response Activities

Non-Friable Asbestos Abatement 

On 4/29/2015, the EPA OSC was on-site with a Region 2 Risk Assessor to evaluate a portion of the facility that had been part of a previous, incomplete demolition operation.  The area covers approximate 5,500 square feet and contained source ACM in the form of small, broken transite pieces, most likely left from demolition of the roof area.   

After consultation between the Risk Assessor and Removal Program, a decision was finalized on 5/29/2015 to conduct the recovery of the visible transite material and follow up with activity-based sampling to determine if an unacceptable risk exists to the public.   

On 7/16/2015 a task order was issued to the Emergency and Rapid Response Services (ERRS) contractor for the recovery, packaging and off-site disposal of transite from the facility grounds.  On 8/20/2015 the EPA ERRS contractor provided NYSDOL certified asbestos handlers along with a licensed third party monitoring firm to complete the remaining asbestos removal activities involving the recovery, packaging, and off-site shipment of transite from the grounds of the facility.  Approximately 6 cubic yards of transite material was recovered and shipped off-site.  Third party asbestos sampling results from the abatement activity were all reported as less than 0.01 f/cc, acceptable for final clearance sampling under the NYSDOL approved variance. 

Risk Assessment Sampling 

On 8/26/2015 EPA and RST3 were on-site to conduct activity-based, risk assessment sampling at and around the demolished building area.  One background area was sampled along with 5 samples collected within the approximate 5,500 square foot demo area.  The activity based sampling event was conducted to simulate a site worker in a windy environment.  RST collected samples in the demolition debris area while utilizing a 150 cfm blower to agitate the debris in the sampled area periodically throughout the day.  Samples were shipped to a NY State certified laboratory for PCM analysis.  Results from the activity-based sampling event were received on 9/3/2015.  All results from the sampling event were reported as less than or equal to 0.002 f/cc. 

Several scenarios were considered for assessing risk from asbestos under the current conditions at the Site.  The following table includes the scenarios / receptors and its associated risk screening level; 

No viable potentially responsible parties (PRPs) have been identified at this point in time.  EPA will continue to work to identify any viable PRPs.

2.1.3  Waste Disposition Table