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Site Number: |
10PS |
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Contract Number: |
EP-S7-13-07 |
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D.O. Number: |
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Action Memo Date: |
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Response Authority: |
CERCLA |
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Response Type: |
Emergency |
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Response Lead: |
EPA |
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Incident Category: |
Removal Action |
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NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
5/4/2016 |
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Start Date: |
5/5/2016 |
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Demob Date: |
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Completion Date: |
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CERCLIS ID: |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
OR DEQ 5/4/2016 |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Emergency Removal Action.
1.1.2 Site Description
On April 25, 2016, Lane Regional Air
Protection Agency (LRAPA) received an anonymous complaint with regards to a
demolition of a burned mobile home which was beyond repair in mid-April, 2016. The home is located in a manufactured home
park located on Edenvale Rd in Pleasant Hill, Oregon. The caller was concerned
that the structure was being demolished without an asbestos survey. LRAPA investigated the matter and located an asbestos survey
for the demolished mobile home. The asbestos survey’s results consisted of positive
presence of Chrysotile asbestos fibers in the housing materials consisting of
the demolition debris.
On April 28th, 2016, an notice of non-compliance was reported to
LRAPA from the Waste Management Division of the Lane County Department of Public Works. The notice indicated that a load of demolished, burned, mobile home material was rejected because the asbestos survey provided did not match the presented material.
This survey listed an accredited asbestos inspector from an environmental firm
performing and compiling the report. The environmental firm was contacted by
LRAPA for a copy of the original report and identified discrepancies between
the original document and document presented at the Waste Management Facility.
On April 29th 2016, LRAPA inspected the original location of
the demolished mobile home and documented part of the burned mobile home
structure still erect and extensive debris still remaining on site. An
independent asbestos sampling effort was made by LRAPA and sent to a different
accredited asbestos laboratory for analysis comprising of nine total samples of
suspect asbestos containing material (ACM). Results from these samples revealed
the presence of asbestos in each of two samples of roofing material (5% and 3%
Chrysotile asbestos), as well as each of two samples of window putty (30% and
25% Chrysotile asbestos).
LRAPA spoke with the mobile home park manager
and verified the original owner of the demolished mobile home and provided
contact information for the contracted demolition company. LRAPA was also informed that the original contractor for the demolition and
removal work was sub-contracted. Upon contacting the sub-contractor, LRAPA
learned that the demolition was performed with the sub-contractor’s
children on-site without knowledge of asbestos containing materials. The sub-contractor and his family were unprotected by personal
protective equipment (PPE) such as a respirator.
The LRAPA investigation indicates that the prime demolition contractor provided an asbestos survey report with analytical results from four samples, all negative for asbestos fiber
presence. As the structure was demolished, materials were hauled by the
sub-contractor’s (38,000 lb capacity) dump truck to the Lake County Waste
Transit Center using the asbestos survey provided by the contractor as legal
documentation of the materials presented for disposal. Using this survey, two
loads were accepted at the transfer station and were re-located to the Lane Co.
Waste Management Facility at Short Mountain, a third load was rejected at the
Waste Management Facility upon suspicion of tampering with the original
document. The sub-contractor was turned away and parked his loaded truck at his
residence. The Waste Management Facility contacted LRAPA and filed a notice of
non-compliance.
On May 2, 2016 LRAPA required the Short Mountain Landfill to hold the rejected material in the covered trailer, instructed the subcontractor not to use the truck or remove ACM materials. A Oregon State Department of Environmental Quality (OR DEQ) licensed asbestos abatement contractor covered the load at the subcontractor's home and covered a portion of the demolition debris at the mobile home park. LRAPA coordinated to have the on-site mobile home park manager spray water on the debris three times a day. The homeowner, prime contractor and subcontractor all told LRAPA they could not secure a licensed asbestos abatement contractor to conduct clean-up.
On May 3, 2016 LRAPA consulted OR DEQ and EPA Criminal Investigation Division (CID) and requested EPA Region 10 Emergency Response assistance with assessment and removal of hazardous substances. On May 4, 2016 one OSC, two Superfund Technical Assistance Response Team (START) and the Emergency and Rapid Response Services (ERRS) Removal Manager (RM) deployed to the scene.
1.1.2.1 Location
The original release occurred in a
rural residential area on Edenvale Road in Pleasant Hill, an unincorporated community in Lane County, Oregon. The site include a
partially demolished burned mobile home and surrounding demolition debris.
A load of ACM and asbestos contaminated debris is located at the subcontractor's home located in a rural area on Latham Road in Cottage Grove, Lane County, Oregon.
A trailer containing a rejected load of solid waste, ACM and asbestos contaminated debris is located at the Short Mountain Landfill, 84777 Dillard Access Road, Eugene, Lane County, Oregon, 97405.
1.1.2.2 Description of Threat
The material released is asbestos, a
CERCLA hazardous substance. The health effects of asbestos are detailed
by the ATSDR as follows:
Diseases from asbestos exposure take a long time to develop. Most cases of lung cancer
or asbestosis in asbestos workers occur 15 or more years after initial exposure
to asbestos. Tobacco smokers who have been exposed to asbestos have a "far
greater-than-additive" risk for lung cancer than do nonsmokers who have
been exposed, meaning the risk is greater than the individual risks from
asbestos and smoking added together. The time between diagnosis of mesothelioma
and the time of initial occupational exposure to asbestos commonly has been 30
years or more. Cases of mesotheliomas have been reported after household
exposure of family members of asbestos workers and in individuals without
occupational exposure who live close to asbestos mines. Significant exposure
to any type of asbestos will increase the risk of lung cancer,
mesothelioma and nonmalignant lung and pleural disorders, including
asbestosis, pleural plaques, pleural thickening, and pleural effusions. This
conclusion is based on observations of these diseases in groups of workers with
cumulative exposures ranging from about 5 to 1,200 fiber-year/mL. Such
exposures would result from 40 years of occupational exposure to air
concentrations of 0.125 to 30 fiber/mL.
The amount of asbestos released during the
demolition and fire is unknown. According to interviews with the subcontractor, ACM roofing material was cut into multiple small sections using a reciprocating saw. It is likely that the reciprocating saw released friable asbestos mixed with large volumes of sawdust which has been spread throughout the debris and ground surface. Asbestos contaminated debris is immediately adjacent to the driveway and porch of neighboring homes. The on-site mobile home park manager has witnessed cats walking through debris and neighbors entering the site to salvage debris. There is a high potential for neighbors or their pets to track friable asbestos to their homes and a risk that property owners or future residents will have ongoing exposure unless asbestos is removed.
Debris at the subcontractor's home extended above the side of the dump truck and was not completed covered with visqueen. The truck was parked adjacent to the children's swing set indicating a risk of exposure to the family. The subcontractor is not qualified to safely handle asbestos and indicated he could not hire a qualified contractor.
The rejected load at the landfill contains two to three dump truck loads of ACM and asbestos contaminated debris from the mobile home. The ACM could not be disposed of in the municipal solid waste cells per the facility permits and doing so may pose an exposure and health risk to the workers.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
EPA, and START and ERRS contractors mobilized to
the area Wednesday morning (May 4, 2016) and began work the same afternoon.
EPA met with LRAPA to obtain their investigation notes, asbestos survey results and results of bulk material samples collected by LRAPA. EPA and LRAPA interviewed the mobile home park off site manager and EPA obtained an access agreement and copies of the rental agreement with the homeowner.
EPA, LRAPA, START and ERRS personnel inspected the site and debris located at the original mobile home plot,
the sub-contractor's loaded dump truck, and Lane Co. Waste Management Facility
at Short Mountain. LRAPA personnel reviewed sampling results and identified the ACM in the debris. Visual inspection and interviews were conducted at each site, no debris was disturbed.
The rejected load at the Short Mountain Landfill was staged in a 48' long walking floor trailer with a capacity
of 20 tons or 120 cubic yards. Investigations conducted by Lane County Waste Management Division and LRAPA indicated that the ACM materials were likely in the back of the trailer. LRAPA and Lane county Waste Management Division requested EPA support to segregate and properly dispose of ACM and suspected asbestos contaminated debris.
ACM roofing material at the mobile home site was the bottom layer of roofing material. The ACM roofing material was capped by a four inch thick white closed cell foam and then another layer of roofing. During demolition all of the roofing layers were cut at one time. The sawdust containing asbestos also contains white foam material which can be easy identified visually. The foam dust can be used as a visual indicator of the extend of contamination of the friable asbestos that was released in the sawdust. The white foam dust is visible on demolition debris, under the intact mobile home floor and on the ground surface indicating where sawdust and potentially sawdust from cutting ACM roofing was deposited. To ensure removal of friable asbestos, as a precaution, EPA intends to scrape up two inches of soil where sawdust is visible. Consultation with EPA Region 10 toxicologist indicated that this approach will be a protective of human health.
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