Polution Situation Report

U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
FMO Pesticide Site - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region III

Subject:

POLREP #17
Ongoing removal action
FMO Pesticide Site
A3PZ
Orefield, PA
Latitude: 40.6322715 Longitude: -75.6149893

To:

Gerald Heston, US EPA Region III
Jeff Bartlett, North Whitehall Township
Dennis Carney, EPA Region III
Linda Marzulli, EPA Region III

From:

Ruth Scharr, Federal On-Scene Coordinator

Date:

7/27/2011

Reporting Period:

7/17/2011 through 7/24/2011

1. Introduction

1.1 Background

Site Number:	A3PZ	Contract Number:
D.O. Number:		Action Memo Date:	9/1/2010
Response Authority:	CERCLA	Response Type:	Time-Critical
Response Lead:	EPA	Incident Category:	Removal Action
NPL Status:	Non NPL	Operable Unit:
Mobilization Date:	7/1/2010	Start Date:	9/17/2010
Demob Date:		Completion Date:
CERCLIS ID:	PAN000306719	RCRIS ID:
ERNS No.:		State Notification:
FPN#:		Reimbursable Account #:

1.1.1 Incident Category

Time-Critical Removal

1.1.2 Site Description

The Site is characterized as a time-critical removal. The Site includes land that was used formerly for the commercial growing and harvesting of fruit from orchard trees and are currently zoned for residential or public use primarily in North Whitehall Township, PA. Lead arsenate pesticide was historically used for several decades at the Site until its use was banned in 1988 by EPA. Elevated levels of arsenic and lead have been detected in surface soil samples on residential parcels and in public use areas. The FMO Pesticide Action Memo was submitted by the OSC and signed on September 1, 2010 approving a Removal Action which addresses contamination at residential parcels.

1.1.2.1 Location

The site is located in the Orefield/Schnecksville area of North Whitehall Township, Lehigh County, Pennsylvania

1.1.2.2 Description of Threat

Incidental ingestion of lead and arsenic through direct contact with contaminated soil, or ingestion of contaminants from small particles that have been aerosolized from the disturbance of soil.

2. Current Activities

2.1 Operations Section

2.1.1 Narrative

2.1.2 Response Actions to Date

Excavation at the next residence began this week. Since it was determined to be more cost effective,the garden area was excavated to a depth of 18 inches below ground surface rather than installing raised garden beds. A barrier was placed at the 18 inch depth at the base of the garden area.
Many trees with shallow roots exist in the yards of this property. Due to the presence of surface roots and many shallow roots in the areas of the back yard being excavated, much of the back yard was hand dug to avoid damaging the root systems. These areas were back filled prior to completing the entire back yard excavation to avoid over exposure to the excessive heat. These areas will be seeded rather than sodded because of the many surface roots. The toddler play area at the residence was also excavated to a maximum depth of six inches below ground surface. Samples were collected from the base of each excavation proir to back filling. The areas were back filled with certified clean topsoil. No significantly elevated dust concentrations were identified downwind of or within the work area at either residence. A total of one rolloff was used for excavation activities conducted this week.

ERRS continues to water the sod each day at properties identified by EPA. Sod is watered in early morning and later evening to avoid burning. Sod was not watered if it rained.

A total of 58 rolloffs containing an estimated 928 tons of soil have been shipped offsite for disposal as non-hazardous waste. Three rolloffs are currently staged onsite; two containing soil, one containing PPE.

2.2 Planning Section

2.2.1 Anticipated Activities

The property owner that had cancelled for the week of July 11, has requested to be rescheduled for September. Phase II results were received for five properties sampled last month; two of these properties have been offered a removal action. At this time removal actions are planned for 21 properties. Removal activities have been completed at 13 properties.

Next week, excavation and back filling activities will continue in the backyard at the residence started this week. The excavation crew will demobe after this yard is completed. Due to excessive heat last week, sod was not installed at the small back yard area of the previous residence to be excavated. Sod will be installed at that residence next week.

Property specific work plans for residences requiring soil excavation will continue to be prepared. EPA will be meeting and scheduling with residents where removal activities may take place. At times scheduled between the resident and EPA, excavation of properties will occur, samples will be collected, backfill installed, and sod installed.

Air monitoring will continue to be conducted during excavation activities to ensure contaminated soil is not being spread to areas outside of each work zone and appropriate levels of personal protective equipment are being utilized by site workers.

Samples will be shipped to an offsite laboratory for Post-Excavation activities. For the newly added removal action properties, Extent of Contamination samples will be collected and shipped off-site to a laboratory for analysis. This will provide quicker results and enable the action to be taken this year. Phase II samples will be collected at one additional property. These samples will be shipped for offsite analysis.
ERRS will continue to excavate, dispose of soils, restore yards, and water sod.

EPA will prepare closeout letters for those properties where we have received validated data for post-excavation sampling. Letters will include maps showing where EPA excavated and restored the property and a table of post excavation sampling results. Post-excavation walkthroughs are being scheduled at residences at which excavation activities have been completed.

2.2.1.2 Next Steps


2.2.2 Issues

        The lack of rain and severe heat has complicated the restoration of properties.  Sod installation has been delayed at times. Sod watering has been increased because during the period of initial rooting (approximatley 3 weeks), adequate irrigation should be applied to maintain moisture in the upper five inches of soil at all times to promote root growth. The properties being restored rely on private wells for their water source. Because of the lack of rain, and the use of private wells, the property owners are unable to take over the watering of the lawn after the three week stablization period.  Their wells do not have enough capacity to supply the thousands of gallons of water that are needed to ensure the soil moisture is maintained to a depth of one to two inches after the sod's stablization period.   Because of the hot,dry weather, EPA is watering lawns twice a day for fours weeks, and at least once a day after that to avoid sod failure. The result is that we have reached the limit on the number of homes that can be watered effectively within the watering window of early morning and after dusk. Therefore, the excavation activies will be shut down temporarily. The OSC plans to remobe the excavation crew the week of August 21, 2011.

2.3 Logistics Section