In 2011, EPA removed asbestos-contaminated soil from several properties in and around Orofino and combined that soil with the existing asbestos-contaminated soil at the First Baptist Church (FBC), creating a repository. The asbestos-contaminated soil repository is behind a gravity-based retaining wall. The retaining wall is located along the north and west boundaries of the FBC's parking area. The repository consists of two areas, including an asphalt parking area and a vegetated dry retention area. Work on the retaining wall and repository was completed by EPA in 2012.
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In 2014, representatives from the FBC notified EPA about several issues related to the integrity of the repository cap. Specifically, areas of the asphalt parking area were settling, and vegetation had not been well established in the dry retention basin.
Following the notification of these issues by the FBC to EPA, EPA's Superfund Technical Assessment and Response Team (START) contractor investigated the site in March 2014 and collected samples of the dry retention basin topsoil for soils testing. In August 2014, EPA returned to the site with its Emergency and Rapid Response Services (ERRS) and START contractors and met with representatives of the FBC to further assess these issues. Based on these March and August 2014 site inspections, EPA identified the following problems:
· The settled areas of the asphalt allowed water and sediment to puddle near the engineered retaining wall;
· Surface water did not drain properly from the asphalt parking lot through the dry retention basin and into the dry well;
· Following hydroseeding in October 2012, a grass cover had never been established, and the dry retention basin was only sparsely vegetated; and
· The steep slopes at the northeastern of the retaining wall did not provide convenient access to the lower sections of the wall for maintenance and repair activities.
. The steep slopes along the asphalt at the southwest of the retaining wall were not graded, and represented a liability issue since people or vehicles could drive off the edge or get hurt. In addition, soil was eroding along the steep edge and out from under the asphalt, and, if not addressed could expose asbestos-contaminated soil.