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BACKGROUND AND SITUATION:
On December 2, 2003 a WVDEP inspector conducted a Compliance Schedule Evaluation (follow-up) of the former Old Athens Turnpike property in downtown Princeton, Mercer County, WV. Previous industrial waste disposal activity on the property has already been documented as the source of lead contamination of the soil in this residential area. S. S. Belcher, a salvage company, operated on adjacent property from the 1920s through 1990 on property leased from Norfolk Southern Railroad. Clean up of lead contamination on the Norfolk Southern property, resulting from S. S. Belcher's battery scrapping operation, has long been complete and the groundwater monitoring wells closed. The administrative order, however, remains open since 1) the contamination has involved both properties and originated from a single source and 2) since lead contamination in the surface soils on the Old Athens Turnpike has potential to impact the downgradient Norfolk Southern property. WVDEP collected two composite soil samples during the inspection. Analytical results for soil samples indicated lead concentrations of 3,380 mg/Kg and 151,000 mg/Kg total lead. The samples were also analyzed for TCLP lead. TCLP lead concentrations were 3.6 mg/L and 780 mg/L, respectively.
On January 9, 2007, WVDEP requested that the US Environmental Protection Agency Region 3 conduct a removal assessment and possible removal action at the site. OSC Kelly reviewed the history and data submitted by WVDEP and determined that further assessment was necessary at the Site. However, it is unclear who "owns" the property. WVDEP documented that the West Virginia Department of Highways (WV-DOH) owns the property. However, the WV-DOH denies ownership.
On March 28, 2007, OSC Kelly, along with EPA START personnel performed a sampling event of homes adjacent to the Old Athens Turnpike. The OSC obtained access from five residents. START utilized the X-Ray Fluorescence (XRF) unit to perform in-situ screening of the residents’ backyards. The XRF results indicated lead concentrations from Non-Detect to a high of 307 parts per million (ppm). One surface soil sample was collected from each backyard at the location where the highest level of lead was detected with the XRF unit. The six soil samples collected (five residential properties sampled plus one duplicate) were analyzed for metals, volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and pesticides. Analytical results for metals indicated no analyte concentrations that exceeded EPA Regional screening levels for residential soils. The highest observed lead concentration was 266 mg/kg. Analytical results for SVOCs indicated a five polycyclic aromatic hydrocarbons (PAHs) that exceeded Regional Screening levels, including: benzo(a)anthracene (in one sample); benzo(b)fluoranthene (two samples); benzo(a)pyrene (two samples); indeno(1,2,3-cd)pyrene(one sample); and dibenzo(a,h)anthracene(one sample). Analytical results for pesticides analysis indicated very low concentrations of a number of pesticides but all results were less than Regional Screening levels.
OSC Kelly and the Office of Regional Counsel (ORC) obtained court-ordered access to the Old Athens Turnpike Site and on August 20, 2008 OSC Kelly and START conducted a removal site evaluation sampling event at the Site. Initially, the OSC and START conducted a reconnaissance of the Site and identified 15 sampling locations. Battery casing debris was observed in a number of areas. EPA conducted in situ (non-intrusive) soil screening using a field portable X-Ray Fluorescence (XRF) instrument. The XRF screening was conducted at the 15 identified locations across the Site to help identify areas with high lead concentrations. XRF results indicated lead concentrations in soil ranging from 11.8 milligrams per kilogram (mg/kg) to 25,300 mg/kg. EPA and START collected 18 soils samples from the screened locations, including one subsurface sample and two duplicate soil samples. Most samples were collected at depth intervals between the surface and four (4) inches below ground surface (bgs). One subsurface sample was collected from six (6) to nine (9) inches bgs. The soil samples were shipped to an EPA-assigned laboratory to be analyzed for Target Analyte List (TAL) metals by the EPA Contract Laboratory Program (CLP) Statement of Work (SOW) ILM05.4 Inductively Coupled Plasma - Atomic Emission Spectroscopy (ICP-AES). Laboratory analytical results indicated high concentrations of lead throughout the Site. Soil lead concentrations ranged from 57.5 mg/kg to 131,000 mg/kg. Only three (3) samples had lead concentrations less than 400 mg/kg, a typical action level for residential soils. Additionally, analytical results for two soil samples had significantly elevated arsenic concentrations of 163 and 164 mg/kg. There are no fences or obstructions to restrict access to the sight and visible evidence of trespassing was observed during the sampling event.
OSC Kelly is preparing an Action Memorandum to obtain funding to conduct a removal action at the Site.
A survey will be conducted to identify Site property boundaries. After the survey has been completed, OSC Kelly will initiate legal action to obtain access to the property to conduct a removal action.
The Site has significant concentrations of lead throughout the Site. There are no restrictions to accessing the Site. Visible indications of trespassing was observed at the Site during the sampling event, including a trail used by ATVs.
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