United States Environmental Protection Agency
Region IV
POLLUTION REPORT

Subject: 

Site background and enforcement information can be found on Pollution Reports #1, #2, and #3.

On November 5, 2007, HEPACO continued excavation activities on residential properties.  Excavation continued on the following grid locations:  G9, H9, H10, I9, J9, L9, and M9.

On November 6, HEPACO began clearing and grubbing on the residential properties 2117 and 2129 South Main Street.  Excavation continued on the following grid locations: I10, L5, M5, N1 and N5.

From November 7 to November 9, HEPACO continued excavation on the following grid locations: N4, N5, O5, N6, N7, N8, N9, J10, I10, K10, M10, N10, H11, M11, N11, I11, J11, K11, L11, H12, I12, and K12.  By November 9, approximately 250 cubic yards of soil had been excavated, mixed with TSP, and stockpiled.  A composite sample was collected and sent off-site for analysis.

On November 12, confirmation samples for grids D10, G9, H9, and C8 returned analytical results for lead that exceeded screening levels although XRF readings had indicated that samples from these grids were below cleanup levels.  An additional 6” was excavated from the four grid locations and new samples were sent off-site for analysis.

From November 13 to November 16, HEPACO continued excavation on the following grid locations: M13, L13, H13, K13, I13, J13, H14, L14, M14, K14, I14, J14, K15, L15, J15, L22, K22, H15, and I15.

START Malone was on-Site during the weeks of November 5 and November 12.  OSC Huyser requested that START collect split samples from approximately 1/3 to 1/4 of the confirmation samples collected from grid locations on the IMACO property, approximately 1/2 of the grid locations from adjacent properties, and all of the grid locations in the back yard of 2117 South Main Street.  Between November 5 and 12, START collected 8 confirmation samples and 19 split confirmation samples (plus 2 duplicate samples).  Analytical results have been received for 17 of the samples, and 9 of those were received before HEPACO’s analytical results were returned.  HEPACO and START both have data for the grid locations where the 8 non-split confirmation samples were collected.  In 3 of the 8 grids, HEPACO’s sample results exceed screening levels requiring further excavation, but START’s sample results exceed the screening level in only 1 of those 3 grids.  There was no grid where START’s results exceed the screening level when HEPACO’s did not.

START Malone will remain on-Site and continue to collect split confirmation samples from approximately 1/4 to 1/8 of the grid locations on the IMACO lot until it is determined that the split sampling data obtained by START demonstrates sufficient reliability in the data collected by HEPACO.


CLEARED GRIDS:
- G9 at 18 inches (November 5)
- J9 at 18 inches (November 5)
- H10 at 18 inches (November 5)
- H9 at 6 inches (November 5)
- K9 at 6 inches (November 5)
- M9 at 6 inches (November 5)
- I9 at 6 inches (November 5)
- M5 at 6 inches (November 6)
- N1 at 6 inches (November 6)
- N4 at 6 inches (November 7)
- N5 at 6 inches (November 7)
- N6 at 6 inches (November 7)
- N7 at 6 inches (November 7)
- N8 at 6 inches (November 7)
- N9 at 6 inches (November 7)
- O5 at 18 inches (November 7)
- J10 at 6 inches (November 8)
- K10 at 6 inches (November 8)
- L10 at 6 inches (November 8)
- M10 at 6 inches (November 8)
- N10 at 6 inches (November 8)
- M11 at 6 inches (November 8)
- N11 at 6 inches (November 8)
- K11 at 6 inches (November 8)
- L11 at 6 inches (November 8)
- I10 at 12 inches (November 8)
- H11 at 12 inches (November 8)
- I11 at 12 inches (November 8)
- J11 at 12 inches (November 8)
- I12 at 6 inches (November 9)
- J12 at 6 inches (November 9)
- K12 at 6 inches (November 9)
- H12 at 12 inches (November 9)
- K12 at 12 inches (November 12)
- L12 at 6 inches (November 12)
- M12 at 6 inches (November 12)
- L13 at 6 inches (November 13)
- K13 at 6 inches (November 13)
- M13 at 12 inches (November 13)
- H13 at 24 inches (November 13)
- L14 at 6 inches (November 14)
- K14 at 6 inches (November 14)
- I13 at 12 inches (November 14)
- J13 at 12 inches (November 14)
- K14B at 12 inches (November 14)
- L14B at 12 inches (November 14)
- M14B at 12 inches (November 14)
- H14 at 18 inches (November 14)
- J14B at 12 inches (November 15)
- K15 at 12 inches (November 15)
- L15 at 12 inches (November 15)
- J15 at 12 inches (November 15)
- I14 at 18 inches (November 15)
- H15 at 24 inches (November 16)
- I15 at 18 inches (November 16)

- Sampling to determine the aerial and vertical extent of contamination on-site and on adjacent properties (COMPLETE)

- All soils and sediments on-site and on adjacent properties which are contaminated above RALs shall be excavated (ONGOING)

- All waste streams shall be disposed of by appropriate measures as determined by the disposal profile (ONGOING)

- Restore areas which are disturbed by the removal action to their pre-removal state to the maximum extent practicable

Loading and transport off-site for disposal of the first stockpile will begin by November 26 or 27 pending the return of TCLP analytical results.  The second stockpile will be sampled during the week of November 26 for TCLP analysis.

On November 20, START reported that large portions of slag debris were spotted underneath the south west corner of the building located at 2100 Sunnyside Avenue.  Excavation was conducted earlier in the week on the property at grid locations L22, K22, and J22 which are located at the north west corner of the same building.  START will collect XRF data from the slag debris to determine if it contains high levels of lead.  The building is constructed on cinder-block columns that are several feet high in some locations.