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WRG4 Vermiculite Site

All POLREP's for this site WRG4 Vermiculite Site
Ellwood City, PA - EPA Region III
POLREP #12 - Winter Shutdown
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On-Scene Coordinator - Deborah Lindsey 4/30/2009
Time-Critical - Removal Action Pollution Report (POLREP) #12
Start Date: 7/16/2008
Pollution Report (POLREP) #12
Site Description
See previous POLREP for Site description information

Current Activities
Work at the Site was shutdown for the winter beginning the week of November 24, 2008.  Winter weather was going to limit any progress with the heavy equipment on the steep hillsides and increase the risk to site workers. Additionally, cleanup procedures would require keeping the dirt wet, which would cause icy conditions on surrounding roads and parking lots. Cleanup activities resumed the week of April 20, 2009.

The following tasks were completed during the shutdown period:

•  The Action Memorandum for the Request for Additional Funding and Exemption from the $2 Million and 12-Month Statutory Limits for a Removal Action at the WRG4 Vermiculite Site was signed on December 1, 2008.

•  OSC conducted regular visits to the Site to check on the temporary cover system, fencing and roll-offs.  No signs of individuals tampering with the roll-offs or cover system.  Minor repairs to fencing and the cover system from wind damage.

•  OSC coordinated with ERRS and Ellwood City Borough on floor repairs at the Electric Company Building from damage that occurred on November 21, 2008.

•  OSC tasked START to provide technical assistance in preparing a cover system and stabilization plan for the hillsides containing asbestos contaminated soils.  START hired a technical consultant that developed a plan that outlined the best alternatives based on site characteristics.  The draft plan was reviewed with comments, coordinated the review with the PADEP and was presented a final plan on or about March 18, 2009.  PADEP comments on the proposed plan did identify that NESHAP requires the installation of and maintenance of warning signs and fencing unless a natural barrier adequately deters access by the general public.  

•  OSC worked with the Client Services Team in Ft. Meade to receive the final data validation packages for the air samples collected during the 2008 fieldwork.  START completed the weekly summary tables and windrose diagrams to illustrate results from the air sampling program.

•  START finalized the Soil Sampling Plan and Analytical Requirements for the soil samples collected behind the building and in the adjacent ravine.  Coordinated with the Asbestos TRW Workgroup, ERT and HQ on analytical requirements for the recommended CARB 435 Method with modifications to include sample preparation per a Libby Standard Operating Procedure.  Submitted the analytical request to Client Service Team in Ft Meade on or about March 25, 2009.  

•  OSC requested technical assistance from ERT on conducting the Air Sampling Program at the Site for the upcoming fieldwork in spring of 2009.  OSC and START consolidated all the air sampling analytical data, sampling plans and location map, factsheets and DataRam summaries for ERT to review.  The OSC was notified on or about March 19, 2009 that ERT could not take the lead on performing the Air Sampling Program via their technical assistance contractor due to contract limitations.  ERT provided technical assistance in drafting a revised Air Sampling Plan including analytical requirements.  

•  OSC worked with Office of Regional Counsel on revising the Railroad Access Agreement to include both CSX Transportation and Buffalo and Pittsburgh Railroad.  The OSC compiled letters that are ready to be sent to the CSX and Buffalo and Pittsburgh requesting review and consent on the Access Agreement.

•  The OSC worked with the ERRS Response Manager on completing the Asbestos Disposal Profiles for disposal of roll-offs.  Continued to work with the RM on T&D of roll-offs.  Delays occurred due to snow and poor weather conditions at the disposal facility.  T&D of the five roll-offs occurred on 3/18/2009 and 3/19/2009.  Roll-offs were taken to EQ - Wayne Disposal, Inc located in Belleville, MI

•  The OSC coordinated/confirmed access with all property owner including Mr. Joseph Pletz-Benedict, the Pittsburgh and Lake Erie Railroad, the Moose Lodge, Wayne Township and Ellwood City Borough prior to resuming operations in the spring 2009

•  The OSC continued to work with the Agency for Toxic Substances and Disease Registry (ATSDR) on the AROA being conducted on the air sampling results from October 2008

•  The OSC worked with CIC Carrie Deitzel on a Spring Community Factsheet which was distributed at the start of the spring cleanup operations in April 2009.

•  START worked on updating the Site’s Health and Safety Plan and coordinated  equipment needs with the OSC and COOP for upcoming start of work.


Planned Removal Actions
Remobilize to the Site and implement the Soil Cover and Slope Stabilization Plan

Conduct Air Sampling and AIr Monitoring during removal activities





Next Steps
Initiate a technical evaluation of cover system alternatives and a slope stabilization plan for the remaining work at the Site.

Work with ERRS for the transportation and disposal of roll-offs currently staged at the site.

Review and update the Air Sampling requirements.

Continue to pursue Access Agreement with the Railroads


Key Issues
Continue to pursue Access Agreements with the Buffalo & Pittsburgh Railroad and CSX Transportation.