The BNSF Sangamon Right of Way is located in the City of Chicago, Cook County, and runs from 16th Street south along Sangamon Street to 21st Street. The right of way between 16th and 18th street is being assessed separately and is adjacent to the National Lead Site, which is a site that was in the IEPA voluntary remediation program. The BNSF right of way is located adjacent to the City of Chicago’s right of way which includes Sangamon Street and the sidewalk that runs along the west side of the right of way.
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As part of the investigation phase of the EPA remediation project, EPA requested access to the BNSF Right of Way which borders the Loewenthal Site on the east boundary, to delineate the extent of contamination. It was agreed that on behalf of the EPA, the BNSF contractor would collect the necessary soil samples at the designated EPA sampling locations and split samples. These sampling locations are shown on Figure 1 and are designated as LM-SB-24 to LM-SB-35. The LM-series samples were collected on June 21, 2013. In addition to the EPA sampling activities, TRC collected three additional soil samples on June 21, 2013, one block north of the EPA sampling locations (north of Cullerton Street) along the BNSF ROW and east of Sangamon Street. These samples are designated as GP-1 to GP-3. The City of Chicago also owns and maintains a side walk and portions of the Sangamon right of way
Based on the results of the BNSF and EPA initial sampling, additional soil sampling was completed by BNSF on November 21, 2013 and again on October 7-8, 2014 to further evaluate lead impacts along the BNSF ROW running from 21st Street north to 16th Street, which intersects the main BNSF rail lines.
Based on the results of the soil samples collected and analyzed for total lead, 33 soil
boring locations on the BNSF ROW have total lead concentrations above 800 mg/kg, which is the above the RML for industrial and residential values. In addition, six sample locations are above the TCLP for lead of 5 mg/l, which is above the RCRA criteria and as such this material will have to be managed as a hazardous waste.
In addition to total and TCLP lead analyses, EPA analyzed one soil sample (LM-SB-24 from 2 to 3 feet below ground surface bgs) for polycyclic aromatic hydrocarbons (PAHs) analysis and one sample (LM-SB-26 from 2 to 3 feet below ground surface bgs) for volatile organic compounds VOCs) analysis. None of the Volatile or Semi Volatile analysis exceeded RML’s or IEPA TACO levels for residential or industrial values.
U.S. EPA signed an action memorandum documenting the site conditions on September 8, 2015 and began negotiations to sign a consent order with BNSF railroad to complete the removal action. The consent order with BNSF was signed on March 16, 2016. The removal action work plan which was prepared by BNSF's contractor was attached to the consent order.
The schedule as detailed in the removal action work plan will provide fencing to prevent access to high traffic areas beginning in March of 2016. The area between 16th and 18th street along the right of way will be fenced off. Topographic surveys, soil sampling to profile for disposal and request for proposals to conduct the work will be conducted in March and April of 2016.
Issuance of the contracts, permitting and revision of plans and schedules will take place in April of 2016. The removal work will initiate in May and June of 2016.