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Hamburg Residential Lead Site

All POL/SITREP's for this site Hamburg Residential Lead Site
Hamburg, PA - EPA Region III
POLREP #7
Requested remainder of project ceiling plus contingency funding
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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Hamburg Residential Lead Site - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region III

Subject: POLREP #7
Requested remainder of project ceiling plus contingency funding
Hamburg Residential Lead Site
A3XU
Hamburg, PA
Latitude: 40.5678350 Longitude: -75.9803390


To:
From: Todd Richardson, On Scene Coordinator
Date: 7/18/2014
Reporting Period: 6/30/2014 - 7/11/2014

1. Introduction
  1.1 Background
   
Site Number: A3XU    Contract Number:  
D.O. Number:      Action Memo Date: 4/10/2014
Response Authority: CERCLA    Response Type: Time-Critical
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 4/15/2014    Start Date: 4/10/2014
Demob Date:      Completion Date:  
CERCLIS ID:    RCRIS ID:
ERNS No.:    State Notification:
FPN#:    Reimbursable Account #:

1.1.1 Incident Category
Time Critical Removal Action
1.1.2 Site Description
This Site was originally brought to the attention of EPA  Remedial Project Manager (RPM) for the Price Battery Remedial Site, by the property owner, in 2012.  At that time the property owner was inquiring about how to handle and/or dispose of soil containing battery fragments, as he was planning a home renovation project.  The RPM relayed the property owner’s concern to EPA OSC Richardson, requesting assistance from the Removal Program in assessing areas of concern at the property.
In September, 2013, EPA, along with a START contractor, met with the homeowner at the Site property.  At this time a removal assessment was conducted, confirming the reported battery fragments in the surface soil, in several locations around the property.  During the removal assessment, approximately 25 randomly selected X-ray Fluorescence (XRF) screening locations on the property, were screened for lead.  Fourteen of these locations revealed lead concentrations ranging from 648 to 31,600ppm (exceeding the established residential risk based screening/action level concentration of 572 ppm, used at the Price Battery, and Hamburg Lead Sites). 

 
1.1.2.1 Location
The –Hamburg Residential Lead Site, located on 6th St, in Hamburg, Windsor Township, Berks County, PA, is owned by a residential property owner.  The approximate 1.5 acre property consists of a roughly 2,000 square foot house, two car garage,  gravel driveway, vegetable garden (40’x40’), children’s play area, and a firewood shed, and dog and chicken pens.  The Property is adjoined by other residential properties, and a partially wooded property owned by the Hamburg Gun Club. 

1.1.2.2 Description of Threat
   The Site is a residential property.  Battery casings were observed in bare soil and sampling results indicate elevated lead concentrations. 

Section 300.415 of the NCP lists factors to be considered in determining the appropriateness of a Removal Action.  Paragraphs (b)(2)(i), (iv), (v), and (vii) of Section 300.415 directly apply as follows to the conditions as they exist at the Site.

 

A.    300.415 (b)(2)(i)           Actual or potential exposure to nearby human populations,

animals, or the food chain from hazardous substances or

pollutants or contaminants;

 

Lead-contaminated soil and soil containing lead-contaminated materials are located at the Site.  Battery casings are exposed at the surface.  Contact with the soil or waste material and subsequent incidental ingestion of contaminated soil pose a significant threat to human health of nearby populations. 

 

In the absence of cleanup activities, the Site poses a potential direct contact threat to human receptors (residents).  Incidental ingestion of lead in the soil or sediment at the Site may result in increased blood lead levels.  Lead is known to adversely affect the central nervous system.

 

B.     300.415 (b)(2)(iv)        High levels of hazardous substances or pollutants or contaminants

in soils largely at or near the surface, that may migrate;

 

            The hazardous substances located in the soils at the Site include lead contaminated, exposed surface soil on a residential property.  While vegetation is generally heavy, bare soil can be observed in several areas.   There is a potential for migration due to runoff and erosion from the slope. 

 

C.     300.415 (b)(2)(v)        Weather conditions that may cause hazardous substances or

pollutants or contaminants to migrate or be released;

 

                  The exposed surface soils are susceptible to erosion by wind and precipitation.  Due to the steep slope, runoff during rain events may cause the migration of hazardous substances to the marshy area that is down gradient of contaminated areas. 

 

D.    300.415 (b)(2)(vii)       The availability of other appropriate Federal or State response

                                     mechanisms to respond to the release;

 

                        The PADEP has requested EPA assistance with the Site due to inability to fund the action at this time.  No other federal or state response mechanisms are currently available to perform the actions necessary to mitigate the threats to public health and the environment presented by the release or threatened release of hazardous substances at the Site.

1.1.2.3  Preliminary Removal Assessment/Removal Site Inspection Results
The removal site evaluation revealed battery casings and elevated concentrations of lead in the surface soils. Lead is a hazardous substance as defined in Section 101 (14) of the Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended (CERCLA), 42 U.S.C. § 9601 (14) and is listed as such in 40 C.F.R. § 302.4. As previously mentioned, XRF data revealed lead concentrations as high as 31,600 ppm in the exposed surface soils in several areas that were screened during the September 2013 removal assessment. There were also visible battery fragments observed in multiple areas that were not screened using an XRF. At similar Sites in the Berks County area, where fill material containing battery fragments have been identified, lead concentrations in soils have been as high as 300,000 ppm. As part of recent comprehensive extent of contamination survey, surface and subsurface soil samples are being analyzed to determine the full extent of lead contamination. The total quantity of lead-contaminated soil and waste at the Site is currently unknown.

2. Current Activities
  2.1 Operations Section
    2.1.1 Narrative
During this reporting period ERRS continued excavating on the North side of property.  They also completed excavation around the north side of the house (foundation wall).  Immediately following excavation, backfill (from clean excavated area on site) was placed and compacted around the foundation wall.  START processed confirmation samples (dried, sieved, and packaged in XRF cups) from the gun club property, and form the south and southwest  half of the property.  Numerous dump truck loads of soil exceeding 5,000 ppm were staged seperately as potentially hazardous.  This was done to prevent the entire excavated soil pile from testing as hazardous (requiring haz waste disposal).
2.1.2 Response Actions to Date
Removal Assessment Screening
Extent of Contamination Investigation (Test Pitting)
Began excavation removal activities
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

2.1.4 Progress Metrics

Waste Stream Medium Quantity Manifest # Treatment Disposal
           
           
           


  2.2 Planning Section
    2.2.1 Anticipated Activities
Excavation of areas with lead concentrations exceeding 572 to an approximate depth opf 24".

2.2.1.1 Planned Response Activities

Begin excavaton activities.

2.2.1.2 Next Steps
Continue excavaton/backfill activities.

2.2.2 Issues

On 7/2/14 EPA recieved a 85% funding letter from WRS.  This letter stated that 85% of the funding available in the existing Task Order (TO) had been expended.  OSC Richardson therefore requeseted that the  remainder of the Action Memo Project Ceiling, plus most of the contingency be added to the ERRS TO.  On 7/10/14, the ERRS TO was modified, placing an additional $285,000 into the available ERRS budget. 
Also, based on a larger volume of soil excavated (adjoining properties), and extremely high lead concentrations (as high as 160,000ppm - high probability for requiring hazardous waste disposal), the anticipated disposal and labor costs will likely be higher than the project ceiling.  Therefore, OSC Richardson is drafting a request for additional funding to complete the necessary Site work. 


  2.3 Logistics Section
    No information available at this time.

  2.4 Finance Section
    No information available at this time.

  2.5 Other Command Staff
    No information available at this time.

3. Participating Entities
  3.1 Unified Command

3.2 Cooperating Agencies
US EPA Region III and PADEP

4. Personnel On Site
  US EPA, Region III
START - Weston Solutions
ERRS - WRS

5. Definition of Terms
  No information available at this time.

6. Additional sources of information
  No information available at this time.

7. Situational Reference Materials
  No information available at this time.