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Several rooms in the southern part of the complex were filled with car and truck tire. In somerooms they were piled to the ceiling, and the total is estimated to be approximately 500,000. Aformer tenant that had conducted a plastics recycling operation in the north part of the complexleft a large amount of baled plastics in the building when they vacated the area. MDCH staffobserved several 55 gallon drums in a section of the complex they could not enter during theirvisit to the property. There was trash of various sorts in most of the buildings, including glassfrom broken windows, capacitor casings, bird droppings, and litter from trespassers. Much of thecomplex had no internal lighting at the time of the MDCH visit, and many of the windows hadbeen boarded over. Large sections of the interior of the complex were either dimly lit or entirelyin darkness though it was broad daylight outside.

The MDEQ collected 9 paint chip samples from the Packard Plant buildings during the BFRA. All the paint samples contained lead, from 625 to 69,100 parts per million (ppm) (2). This isconsistent with the age of the buildings. There is no data available on lead contamination in airand other environmental media in the complex. Intact leaded paint poses little risk of humanexposure. However, the paint in the buildings is peeling, which increases the likelihood of humanexposure to the lead it contains. In addition, certain methods for removal of the paint duringrehabilitation of the structures or for demolition might release paint particle dust, which might becarried through the air into the workers' breathing space or to nearby residents.

The MDEQ collected 22 samples of floor and ceiling tile and insulation from the Packard Plantbuildings for asbestos analysis during the BFRA. The results of this sampling ranges from nodetectable asbestos (less than 1%) to 40% asbestos (2). From a visual inspection of the buildings,MDEQ staff concluded that the amount of asbestos-containing material on the property exceededthe standards set under the U.S. Environmental Protection Agency (U.S. EPA)'s NationalEmission Standards for Hazardous Air Pollutants (NESHAP), Asbestos Revision,1 which requiresremoval of the asbestos-containing material before or during demolition of the building. TheNESHAP regulations also specify the removal techniques that are to be used to minimize releaseof asbestos and human exposure to the materials. Again, this is to be expected given the age ofthe buildings. There is no data on asbestos concentrations in the air or free on the surfaces, andthere is little likelihood of human exposure from intact, properly-installed asbestos-containing tilesor insulation. Wear and weathering might release asbestos fibers from the tiles or insulation. Unless proper techniques are used for removal or encapsulation, as specified under the NESHAPregulations, removal of the asbestos-containing materials or demolition of the structures mightalso release asbestos fibers into the atmosphere.

MDEQ staff collected two samples of oil from the capacitor casings found in the complex, todetermine whether the oil contained polychlorinated biphenyls (PCBs). One sample contained 3.9ppm PCBs (estimated value), the other none (detection limit 5 ppm) (2).

MDEQ staff collected three samples of soil from an area where transformers had been located, todetermine whether the transformers might have leaked PCB-containing oil onto the ground. Analysis for selected metals and PCBs showed that these samples contained lead above theMDEQ Generic Clean-up Criteria for Industrial, Commercial, and Residential Use (Table 1) (2, 3,4). The PCB concentrations were below the MDEQ Industrial, Commercial, and ResidentialCriteria. The lead concentrations were within the range typically found in urban areas,particularly near buildings the age of the Packard Plant complex. During this era, lead wascommonly used in paints and automotive gasoline (5).

Table 1. Concentrations of chemicals found in soil from a transformer location on the Packard Plant, July 1997.

Bird droppings, as are present in some areas of the complex, might contain the vectors for variousdiseases, such as psittacosis. Brief and occasional exposure to the droppings generally poses littlehazard of contracting the diseases, though prolonged and frequent close contact increases the risk(6, 7).

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