CONSOLIDATED IRON AND METAL
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Consolidated Iron and Metal Company’s scrap metal processing and storage operations began in the mid-1950s and continued at the site until the facility's closure in 1999. Facility operations led to soil contamination. Contaminants include volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), pesticides, polychlorinated biphenyls (PCBs) and metals.
The Consolidated Iron and Metal site is an inactive car and scrap metal junk yard located at the foot of Washington Street in the City of Newburgh, Orange County, New York. The facility occupies 7 acres of land bordering the Hudson River in a mixed industrial, commercial, and residential area. The site is bounded by a boat marina and restaurant to the north, Conrail railroad tracks and South Water Street to the west, a wastewater treatment plant to the south, and the Hudson River to the east. Before EPA conducted a clearing operation at the site in 2003, the Consolidated Iron facility consisted of tire and scrap metal piles throughout the southern portion of the site; a smelter, a compactor, and a metal shear along the western portion of the site; and an office, scale, and garage located in the northern portion of the site. Scrap metal processing and storage operations took place at the site for approximately 40 years, during which time various types of scrap metal were received, including whole automobiles, automobile engines, transmissions, and batteries, keypunch machines, computer parts, white goods (appliances), and transformers. The smelter, which operated between 1975 and 1995, was used primarily to melt aluminum transmissions to produce a reusable aluminum product. Other materials were also smelted, resulting in a lead-contaminated ash/slag by-product. Other operations included sorting ferrous and non-ferrous metal scrap for recycling, baling and shearing large pieces of metal, including whole cars, into smaller pieces for transport, and flattening of cars. From 1997 to 1999, the New York State Department of Environmental Conservation (NYSDEC) conducted several inspections at the facility. NYSDEC observed oil and other waste liquids on the facility soils and storm water being discharged into the Hudson River from the northeast corner of the property without appropriate testing or permits. In 1999, the New York State Attorney General filed a lawsuit against the company for environmental law violations, resulting in the company ceasing operations. Following a preliminary study of the site by EPA in 1999, the site was placed on the National Priorities List (NPL) in June 2001.
Site Responsibility: This site is being addressed through Federal actions. EPA’s efforts at the site are coordinated with NYSDEC and the New York State Department of Health (NYSDOH) in planning future activities.
What Has Been Done to Clean Up the Site?
In July 2009, EPA contractors began excavating, disposing, and backfilling operations at the site. Operations finished in August 2010. About 117,000 tons of contaminated soil has been removed from the site and replaced with clean fill. In addition to the work performed on the site, at the request of the NYSDOH, EPA removed soils just beyond the north and south property boundaries to a depth of approximately two feet (where not hindered by utilities) and backfilled with clean fill. This was done to ensure that any contaminated soil that may have migrated beyond the site property was also mitigated.EPA has completed the site’s final Remedial Action Report and the City of Newburgh has prepared a SMP, approved in June 2014, to allow for future use and redevelopment of the site. As part of the SMP, the site is regularly inspected and the groundwater is sampled periodically to ensure that the site remedy continues to function as designed and constructed. Additionally, the ROD called for the following with respect to institutional controls: imposition of institutional controls in the form of an environmental easement and/or restrictive covenant that will at a minimum require: (a) restricting any excavation below the soil cover’s demarcation layer of generally six feet (deeper in some areas of the site and shallower in others) unless the excavation activities are in compliance with an EPA-approved SMP; (b) restricting new construction at the site unless an evaluation of the potential for vapor intrusion is conducted and mitigation, if necessary, is performed in compliance with an EPA-approved SMP; and (c) restricting the use of groundwater as a source of potable or process water unless groundwater quality standards are met. The restrictions are memorialized in an environmental easement filed with the Orange County Clerk on September 11, 2012.
What Is the Current Site Status?
EPA conducted a remedial investigation and feasibility study of the site from 2004-2005. A Record of Decision (ROD) was signed by EPA in October 2006 which selected the site remedy and established remedial action objectives for the protection of human health and the environment. The site remedy essentially required the removal of contaminated soils from the site to a depth of approximately six feet, allowing for commercial redevelopment of the site, and to monitor groundwater quality following the soil removal to ensure that the quality improves over time. The site remedy also calls for institutional controls in the form of an environmental easement to be placed on the site property and periodic reviews to be conducted by EPA to ensure that the remedy remains protective of public health and the environment.
From September through November 2008, EPA conducted certain preparatory activities at the site to facilitate the remedial construction. These activities included the demolition and removal of the garage, the demolition and removal of the remaining building foundations, the removal of scrap metal and debris, and the dismantling and removal of a truck frame and metal barges from the shoreline of the site. Excavations were backfilled with clean material and boulders were placed to restore the shoreline.
Following the preparatory activities, construction of the remedial action commenced on July 6, 2009. The work was divided into two phases: Phase One involved the excavation and off-site disposal of 60,000 tons of site soils across the southern half of the site to a depth of six feet and backfilling with clean fill. Phase Two involved the excavation and off-site disposal of approximately 30,000 tons of PCB and VOC impacted soils to the water table and the excavation and off-site disposal of remaining site soils, approximately 27,000 tons, covering the northern third of the site to a depth of six feet and backfilling with clean fill. Phase One was completed in October 2009 and Phase Two was completed in August 2010.
Soil excavation and transport was carried out using clean-diesel equipment in accordance with the EPA Region 2 Clean and Green policy. Backfilling was performed concurrently with the excavation, maintaining an adequate buffer zone to avoid cross contamination. Backfill material was tested for suitability before placement, meeting the guidelines set by NYSDEC for restricted residential use and the remediation goal values required by the ROD. Prior to placement of the backfill, the base of the excavation was sampled on a 50-foot grid to characterize and document the soil remaining on site; samples were analyzed for VOCs, SVOCs, PCBs, and metals. Geotextile fabric was then placed to demarcate the interface between potentially contaminated soil and clean backfill material. Following reaching final grade with backfill soil, the entire site was covered with a minimum of six inches of topsoil and hydroseeded to provide a vegetative cover to ensure dust and erosion control.
Excavation, transport and backfilling were conducted from July 2009 through August 2010 with little work stoppage for weather. Surveying was performed during the entire operation by a New York State licensed surveyor for documentation purposes and to ensure that lift layer depths were accurate. Dust suppression and air monitoring were routinely performed in accordance with design specifications.
EPA conducted a pre-final inspection with NYSDEC at the site on June 9, 2010, and following the completion of punch list items, a final inspection of the site was completed on August 18, 2010. EPA completed its Remedial Action Report, documenting all the remedial activities conducted at the site, in March 2012. The City of Newburgh, as current property owner, is responsible for management of the site in accordance with the site management plan (SMP) developed for post-remediation uses of the site. The SMP was completed in June 2014. Site management responsibilities will be transferred to any future site owner. EPA conducted its first five-year review of the site in July 2014 and concluded that the remedy remains protective of public health and the environment. The next five-year review will be completed by December 2018. The site was delisted from the NPL in December 2014 following EPA’s determination that the implemented remedy achieved the degree of cleanup specified in the ROD for all pathways of exposure. The remedy, remedial action objectives, and associated cleanup goals are consistent with agency policy and guidance. No further Superfund response action is needed to protect human health and the environment.
EPA continues to work with the City of Newburgh in its efforts to carry out operation, maintenance, and monitoring activities in accordance with the Site Management Plan.