1.1.1 Incident Category
This incident is a Time-Critical Removal of CERCLA hazardous substance: asbestos.

1.1.2 Site Description

The Delancey-Houghton Elementary School is a partially demolished school with no roof, windows, doors or interior walls.  The school was opened in 1947 with 171 students and expanded to add a library, multi-purpose room, and kitchen in 1950. A new elementary school was constructed at a different location in town sometime in the early 2000s, and it is not clear when the Delancey-Houghton Elementary School closed. Evidence suggests that the Site was purchased from the Soap Lake School District prior to demolition work and the new owners subsequently flied for Chapter 7 bankruptcy in 2012. Based on aerial photography, it appears that demolition of the building began sometime between 2009 and 2011. It is unknown when demolition activities ceased. According to the Grant County Assessor's office, the parcels were transferred to Grant County Tax Title in 2013.

1.1.2.1 Location
The Site is located in a residential neighborhood at the comer of Fourth Avenue Southeast and Cannas Street South, in Soap Lake, Grant County, Washington. The precise location is 47.385857 North Latitude; 119.485848 West Longitude.

1.1.2.2 Description of Threat

Asbestos containing material (ACM) and asbestos contaminated debris may release asbestos fibers when disturbed. Future site workers, trespassers, and homeless people using the site for shelter may inhale asbestos fibers. Continued exposure can increase the number of fibers that remain in the lungs. Fiber embedded in lung tissue over time may cause lung disease, including asbestosis, lung cancer, and mesothelioma.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

On December 14, 2015, the EPA and Superfund Technical Assessment and Response Team (START) conducted a removal assessment of the Site. The school is divided into three wings. The original school building forms the east wing of the school, which has standing walls with no roof, windows, doors or interior walls; two-thirds of the area is a soil crawlspace and the other one-third is a basement with concrete floor. The basement floor is covered with approximately six inches of demolition debris and trash dumped from off-site. The basement boiler room retains a concrete ceiling. The central wing is completely demolished with the foundation remaining and vegetated soil throughout. The west wing was a gymnasium and auditorium with no doors or windows and fire-damaged floors, walls and ceiling. The school is currently abandoned with no physical barriers to entry. The Site is apparently used as shelter by homeless people; children reportedly play at the Site, and it may be subject to illegal dumping. The Site has residences across the street on two sides; the nearest house is approximately 150 feet away. Homeless people were observed on the Site the morning of the assessment and the anonymous complaint indicates that the Site is an attractive nuisance for children. There was evidence on-site of recent graffiti and the Soap Lake City Supervisor described a recent fire in the boiler room which was likely caused by homeless people who created a fire for warmth.

Twenty-three samples of suspected ACM were collected by START. Analytical results indicated that corrugated "air-cell" type Thermal System Insulation (TSI) in the basement boiler room contained 55 percent chrysotile asbestos and a pile of insulation and other demolition debris north of the school contained less than 1 percent Actinolite asbestos and 20 percent vermiculite. The vermiculite is assumed to be from Libby, Montana, and is likely to contain additional asbestos which is difficult to detect in vermiculite. The west wing was only partially assessed; a fire had caused structural damage that resulted in a high worker safety risk. The asbestos survey in this wing was limited to the three building entries and stairwells. A visual inspection from the exterior indicated that the majority of unassessed materials were composed of wood. Two drums and one bucket of unknown materials were assessed. One drum and the bucket were determined to be non-hazardous; however, one drum was identified as containing waste oil.

• 2.1.1 Narrative
  EPA, START and ERRS contractors arrived on site on June 27, 2016 to remove asbestos containing materials and debris that is likely to be contaminated by asbestos.
  

2.1.2 Response Actions to Date

See Initial POLREP for operations completed in prior reporting period

6/29/2016

• Approximately six feet of suspected ACM pipe wrap was removed from crawl space by certified asbestos workers then double wrapped, labeled and staged for disposal
• Removed remaining demolition debris from basement approximately 40 cubic yards
• Began removal of soil from boiler room, removed approximately 6 cubic yards. Samples from activity based sampling were overloaded with dust and could not be analyzed therefore all soil and debris will be removed. 
• Asbestos and nuisance dust was controlled through continuous application of water
• Conducted personal air sampling for asbestos for worker health and safety
• Conducted perimeter air monitoring for nuisance dust and perimeter sampling for asbestos

6/30/2016

• Removed approximately 5 cubic yards of vermiculite mineral wool insulation mixed with demolition debris
• Completed removal of soil and debris from boiler room for approximate total of 8 cubic yards
• Began removal of residual contamination by washing surfaces then removed wash water using vacuum
• Screened concrete floor paint for lead with XRF per City of Soap Lake Request. All results were non-detect for lead.
• Asbestos and nuisance dust was controlled through continuous application of water
• Conducted personal air sampling for asbestos for worker health and safety
• Conducted perimeter air monitoring for nuisance dust and perimeter sampling for asbestos

 7/1/2016

• Completed removal of residual contamination by washing surfaces then removed wash water using vacuum
• Completed loading of staged debris into roll off boxes
• Monitored loading operations for particulate and perimeter sampling for asbestos
• Transported waste off-site for disposal at Off-site Rule Certified facility
• Documented post clean-up site conditions with photographs
• Collected asbestos samples from air in basement to document clean-up of residual contamination
• Decontaminated and demobilized equipment
• Demobilized all personnel from site

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Potentially responsible parties have been identified. EPA will determine the appropriate enforcement action upon completion of clean-up activities.

2.1.4 Progress Metrics

ACM pipe wrap had been moved since assessment occurred. Assessment results indicated that a majority of pipe wrap in the building was below detection limits for asbestos however, the appearance of both ACM and non-ACM air cell pipe wrap was indistinguishable. Because ACM pipe wrap could not be identified by location or appearance, all pipe wrap was assumed to be ACM.

2.2.1 Anticipated Activities

2.2.1.1 Planned Response Activities

No additional response activities are anticipated.

2.2.1.2 Next Steps

Asbestos sample results from air in basement will be reviewed to confirm effective clean-up.

2.2.2 Issues

All Issues have been addressed.

2.5.1 Safety Officer
All entries into the school basement were conducted in level C PPE. Daily health and safety meetings occurred prior to operations; additional health and safety meetings were held when operations changed throughout the day.

2.5.2 Liaison Officer
The OSC coordinated all liaison activities.

2.5.3 Information Officer

The site was visited by ifiberone.com on June 27, 2016. Additional inquiries were coordinated with the Public Information Officer in the regional office however, no other reporters visited the site.

3.1 Unified Command
EPA is the lead agency.

3.2 Cooperating Agencies

Washington Department of Ecology removed a drum of waste oil from the site one week prior to EPA operations.

Grant County Health District provided a public health notice in April 2016. The notice included signs and a fact sheet developed jointly with EPA. The notice informed residents of the health risk and advised them to avoid entering the site. Fact sheets in Spanish, Russian and Ukrainian were posted on-site and distributed electronically and through a press release.

All personnel have been demobilized from the site. During this reporting period staffing included: 

EPA - 1

START - 2

ERRS - 5

Asbestos Containing Material (ACM) - any material containing more than 1% asbestos as determined by approved laboratory methods