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Duracell Inc. Site
(Former Mallory Battery Factory Site)
NYSDEC Site No. 360011, Sleepy Hollow, New York
The Gillette Company
For periods between 1944 and 1984, a battery manufacturing facility operated at the corner of Elm Street and Andrews Lane in Sleepy Hollow, New York. The facility was originally operated by P.R. Mallory. Duracell began operations at the site in 1979, and the site was closed in 1984. This property, which is now a municipal parking lot, is currently owned by the Village of Sleepy Hollow.
Duracell completed several cleanup actions at the site between 1988 and 1994. Factory buildings were demolished and impacted soil was removed from the site and from several properties directly adjacent to the factory. As a result of these efforts, the site was “de-listed” from New York State’s Registry of Inactive Hazardous Waste Disposal Sites in 1994 after meeting the cleanup goals that were developed at that time for the site by the New York State Department of Environmental Conservation (NYSDEC) in consultation with the New York State Department of Health (NYSDOH).
In late 2008, a soil sample was collected and analyzed for metals from a residential property near the former facility. The sample exhibited levels in excess of the 2006 NYSDEC-recommended soil cleanup objective (SCO) for mercury in a residential setting. As a result, the NYSDEC performed an assessment in May of 2009 by collecting additional soil samples in the area to provide a better understanding of the conditions surrounding the site. This assessment found lead and mercury levels on numerous properties above the 2006 NYSDEC SCOs for these constituents in a residential setting.
The Gillette Company (Gillette), which acquired Duracell, executed an Order on Consent with the NYSDEC in December of 2009 to develop and implement a remedial investigation for the site at the direction of the NYSDEC. The purpose of the investigation was to evaluate both on-site and off-site conditions that might have resulted from operations at the former battery plant site.
Phase I Remedial Investigation
Between September and December 2010, Gillette collected and analyzed over 1,600 soil samples from 146 properties in the vicinity of the Site at the direction of the NYSDEC in accordance with an approved Phase I Remedial Investigation Work Plan (August 2010).
A summary of the sample results was prepared and approved by the NYSDEC, and indicates inorganic mercury concentrations range from not detected to 180 parts per million, with the highest mercury concentrations found closer to the Site. Lead was also detected in soils, however, concentrations of lead increased with distance from the Site. A review of historical records and the sampling results from the remedial investigation indicate that historic fill, which was used to level or create land for development, was deposited in the site area prior to operations at the former battery plant. This material contained mercury and lead.
Site- Specific Soil Cleanup Objective for Inorganic Mercury
A cleanup level for inorganic mercury in soil was approved by the NYSDEC in consultation with the NYSDOH and serves as the Site-Specific Soil Cleanup Objective (the remedial goal) for the project. For the residential areas adjacent to the Duracell Inc. Site, a remedial goal of 4.8 mg/kg (or parts per million) has been developed for inorganic mercury in soil. This goal has been evaluated and deemed protective of public health and the environment by the NYSDEC and the NYSDOH based on consideration of potential exposures through ingestion of soil, dust and homegrown fruits and vegetables. The NYSDEC has determined that lead in the area’s soil is not attributable to operations at the former battery plant, and Gillette is not responsible for cleaning up this material. For additional information about lead, please contact the NYSDEC and/or NYSDOH (see links to contact page above).
Interim Remedial Measures
Gillette prepared an Interim Remedial Measures (IRM) Work Plan to remove soil from select properties in the vicinity of the Site that contain mercury concentrations greater than the remedial goal established for the Site. Implementation of the approved IRM Work Plan is expected to result in the removal of soil from properties that contain mercury levels exceeding the remedial goal. The cleanup will protect human health by minimizing the potential for exposure to affected soil.
The NYSDEC approved the IRM Work Plan in April 2012. Upon this approval, Gillette prepared the necessary design plans and specifications for the work. This included taking photographs of each property in its current state and collecting survey information; developing plans that are applicable to all properties (Health and Safety Plan, Storm Water Pollution Prevention Plan, Community Air Monitoring Plan, and Transportation Plan); and developing property-specific drawings showing excavation, backfill and restoration plans for the first group of IRM properties.
Following NYSDEC approval of all plans and property-specific drawings, Gillette began meeting with each property owner to discuss the work being proposed for their property (the remediation plan), as well as the planned restoration (the restoration plan). Ultimately, each owner signed an access and remediation/restoration agreement for their property before work began.
Once agreements from the property owners were obtained, the final plans were provided to the Village of Sleepy Hollow for review and approval. The Village’s approval was necessary prior to issuing a building permit for the work.
Remediation Work Initiated in August 2012
Remediation work at select properties was initiated in August 2012. AECOM, an environmental engineering firm working for Gillette, provides oversight for the work performed by VIASANT, an environmental services contractor.
The first task completed at each property is to mark underground utilities as well as the construction area. The “work area” (the zone where the excavation occurred) is then cordoned off, and cleared of materials and debris. This includes plants and trees, and small structures.
Next, soil is excavated, containerized, and transported off-site to an approved disposal facility. Confirmation samples are collected and analyzed to verify that the remedial goal is met for each property. If the remedial goal is not achieved, additional soil is removed. Once all sample results confirm that the remedial goal is met, the excavated areas are backfilled with clean soil and the properties are restored as near as possible to their pre-work condition.
Excavation and remediation work is occurring in groups of properties to minimize disruption to the community. We are working diligently to complete work at each property as quickly as possible -- the time spent working at each property varies depending on the size of the excavation and items needing to be removed and replaced.
Working from the spring through the late fall, we believe it will take more than one year to complete the approximately 80 properties requiring cleanup.
Progress of IRM
From September through December 2012 Gillette completed IRMs at seven properties. From March through December 2013, IRMs were completed at an additional 34 properties.
The IRM work schedule for the specific property groupings is dependent on many factors, including obtaining agreement from property owners, New York State Department of Environmental Conservation (NYSDEC) approval of all plans, as well as permit approvals from the Village of Sleepy Hollow. Gillette continues to work diligently to put all of these pieces into place for each property in order to safely and efficiently complete the required remediation and restoration.
Safety Measures During Remediation Work
Cleanup activities are being conducted under the direction of the NYSDEC in a manner that is protective of public health and safety and in accordance with the approved site-specific health and safety plan. For example, the work areas are surrounded with temporary construction fencing, and one field staff member is dedicated to site safety -- including preventing unauthorized individuals from entering the work areas. In addition, silt fencing and/or straw bales are placed around the excavation areas to prevent migration of contaminated soils during remedial activities or rain events.
A community air monitoring program, which was reviewed and approved by the NYSDEC in consultation with the NYSDOH, is implemented during the entire cleanup process. Dust levels are monitored continuously during cleanup operations and measures are taken, as necessary, to minimize the amount of fugitive dust (e.g., washing or wetting down the work area and equipment with water, and applying spray-mulch to exposed soil).
Phase II Remedial Investigation
A second phase of soil sampling has been conducted. This phase, called the Phase II Remedial Investigation, included soil sampling on a small number of additional properties near the Site. These properties were within the Phase I area or selected based on the Phase I results of adjacent properties.
A Phase II Data Summary report was submitted for approval by the NYSDEC. Once approved, the report will be available in the public document repositories listed below.