In a classic case of cooperation between field and staff personnel, a hidden danger was uncovered at an old factory in a rowhouse community in Philadelphia. Alert members of an engine company provided a valuable lead to fire department hazardous materials specialists that a potential hazard existed in their response area at a site containing many old and dangerous toxic chemicals. In this case, persistent detective work by many trained firefighters paid off.
The Philadelphia Fire Department formed a specialized unit known as the Hazardous Materials Administrative Unit (HMAU) in 1988, in large part as a result of Superfund Amendments and Reauthorization Act (SARA) Title III community right-to-know legislation. One of the HMAU's many duties is to follow up leads based on chemical inventory forms known as "Tier IIs," required to be filed annually with the local fire department. The forms let fire departments throughout the country identify facilities that contain hazardous chemicals. Because the HMAU had asked field companies for lists of any facilities in their response districts that may contain chemicals and thus be possible Tier II filers, it received a peculiar lead.
Engine 29, first-due engine company in "Fishtown," an aging bedroom community near the Delaware River, notified the HMAU of an old four-story factory that appeared to be vacant. The company had listed the building in its "Vital Building Information" (VBI) book as containing chemicals but hadn't been able to gain access for some time. (VBIs are carried by every engine company and list buildings in their districts that contain sprinklers, standpipe systems, or unusual or noteworthy hazards.)
HMAU inspectors visited the location but could not gain entry. Although an interior light was lit, numerous doorbell rings and knocks went unanswered. During several more HMAU visits to survey the location, neighbors were interviewed and said a small chemical company, consisting of two employees, still operated in the building. The owner had purchased an adjoining rowhouse and made this the main entrance, sealing off the "factory" doors and breaking through the adjoining bearing wall, thus giving the building the appearance of being empty.
Neighbors gave the HMAU's telephone number to the owner and told him of the unit's interest. HMAU members eventually spoke with the owner by telephone and scheduled an appointment to inspect his business. He assured the HMAU that most of the chemicals involved in his business were non-hazardous but the unit members told him they wanted to verify what was there and whether proper precautions were being taken to handle any possibly hazardous materials.
A tour of the site revealed that the overall seriousness of the violations involving the deteriorating building and its contents were beyond the scope of the HMAU's local jurisdiction. Major violations and dangerous conditions were found:
- Every floor in the old brick building contained hazardous materials stored in drums, carboys, bags or tanks. In most cases, the old containers were deteriorating, leaking or at best unlabeled. Stored in the dark, dank basement were ancient wooden "acid" drums that dated back 50 years. Some drums were thought to be empty but there was no way of verifying this or even ascertaining proper identification.
- Not only was there no containment to prevent hazardous materials from entering drains, there was no protection to keep incompatible materials from contacting one another. The owner was asked whether he had a required discharge permit from the water department for industrial waste and for being a hazardous waste generator. The answer was no, even though the need for both was obvious.
- The general condition of the building and its floors was poor. Some "fire doors" were inoperable and, in fact, one came crashing down when inspectors attempted to slide it open. There were many large cracks in the plastic ceilings and evidence of roof leakage near some chemicals. Signs of charring indicated a previous fire and some structural members were in questionable condition. Contents of many of the leaking containers had permeated the wooden floors, which caused deterioration and even holes in many spots.
- The second floor housed old "Alpha Labs" (labs storing jars of chemicals in alphabetical order, rather than by hazard class). This leads to incompatible storage, which could cause a reaction/ fire if chemicals contacted one another. There were many "unknowns" in the labs that could have included outdated chemicals that decomposed over time, creating problems for anyone touching the jars. In general, these labs were in poor condition and had the potential for injuring unsuspecting people.
- There were no hazmat training records for the only employee, as required by the Occupational Safety and Health Administration (OSHA), and it was obvious he was unaware of the hazards to which he was potentially being exposed.
- Numerous "Extremely Hazardous Substances" were discovered throughout the premises, including formaldehyde, phenol, sulfuric acid and potassium cyanide. There was no record of any Tier II or SARA Title III compliance.
- The building's sprinkler system had not been certified and there was no fire alarm system.
After informing the owner of the numerous violations that existed, the HMAU contacted the many multi-jurisdictional enforcing agents that had possible concerns here. (This is a standard procedure on the part of the HMAU, due to its role with the Environmental Crimes Task Force). A follow-up inspection was conducted the next day by representatives of 12 government agencies, including the Environmental Protection Agency (EPA). A memo was faxed immediately to the fire department's field forces, informing them of the numerous dangerous conditions present and recommending that an exterior attack be considered in the event of any emergency response to a fire at this location. Also, the local police district was notified to keep surveillance on this property.
The follow-up inspection led the EPA's on-scene coordinator to say, "This facility has the potential to be on par with some of the worst Superfund sites that this city has ever seen." The agency representatives found more "hidden" dangers:
- Another hidden lab was found on one of the upper floors that contained many more "unknowns," some in poor condition, even to the point of crystallization (some chemicals can become shock sensitive and explosive when they reach this state).
- There were unprotected open vats into which an unsuspecting firefighter could fall under dark, smoky conditions.
- Deteriorating drums of sodium fluoride (used for rat poison) were found in another hidden room. Much of the product had been released from the containers.
- There were possible asbestos problems.
- Containers marked "Dioxin" had been sitting for some time.
The owner contended that his current operations dealt mostly with non-hazardous substances that were contained on the first floor. He stated that the rest of the building's contents were from a prior business (in which he was employed as a chemist), and that he did not use these other parts of the building. He left the other floors alone, eventually hoping to gain from the building's sale if casino gambling came to fruition along Philadelphia's waterfront.
An immediate "Cease Operations" order was placed on this business by members of the Department of Licenses & Inspections, the city's enforcing agent for fire code violations, for the many unsafe conditions present. In addition, the EPA gave the owner the opportunity to "clean up" his entire operations, under the agency's supervision. Because he was unable to afford the cost of this work estimated to be in the millions of dollars the EPA took over the site, utilizing its contractors and taking legal action to recover its expenses. This is known as "Superfunding." (The EPA was especially concerned because there is an elementary school directly behind this facility and officials wanted to be sure children were not exposed to improper or haphazard cleanup operations.) Approximately 285 drums of assorted hazardous waste materials, including many Extremely Hazardous Substances, were transported in overpacking to treatment and disposal facilities. The remaining assets were staged on the third floor and were turned back over to the potential responsible party (PRP). The city's Department of Licenses & Inspections dealt with the building and fire code issues.
In summary, without a close working relationship between field and staff personnel, this problem might not have been discovered. It is felt that if this business had continued to operate unattended, a calamity would eventually befall this facility someone would have been injured or a fire might have resulted through improper handling of dangerous chemicals or the lack of attention to safety precautions. Civilians and firefighters could have become victims of exposure to the many toxic substances released from this site.
If any "ghost" buildings like this exist in your community, it would be wise to determine whether there are any "hidden" dangers. They're still out there!
Stephen T. Roth is a lieutenant and 24-year veteran of the Philadelphia Fire Department, assigned to the Hazardous Material Administrative Unit. He has attended and instructed many National Fire Academy hazmat courses and is NFA-certified as an instructor in Hazmat Incident Management. Roth has an associate's degree in fire science from the Community College of Philadelphia and is studying for a baccalaureate in the same field at Holy Family College.
