1.1.1 Incident Category

The Lower Darby Creek Area - Clearview Landfill Site Operable Unit 01 (Residential Area) is the location of a release of hazardous substances in soils within a residential neighborhood.  A Removal Action will address certain contaminated residential soils posing an unacceptable risk to human health.

1.1.2 Site Description

The LDCA Site includes two landfills: 1) the Clearview Landfill and 2) the Folcroft Landfill and Annex.  The Clearview Landfill is located along the eastern bank of both Darby Creek and Cobbs Creek, near the intersection of 83^rd Street and Buist Avenue.  The footprint of Clearview Landfill is much larger than the area now subject to a Removal Action and lies primarily within Darby Township, Delaware County, PA, but partially within the limits of the City of Philadelphia.  OU1 includes the Clearview Landfill, the Eastwick Regional Park (a/k/a “City Park” or “Park”) which abuts the eastern limits of the present-day landfill footprint, and a portion of the Eastwick neighborhood (a residential area) located generally east of the present-day landfill area and the Park.  The Removal Action involves the removal of soil from the residential area of Philadelphia once within the footprint of the landfill and then staging of that soil on a portion of the landfill located in adjacent Delaware County.  A Remedial Action will be conducted in the future to address those aspects of the Site not addressed by the Removal Action.

NOTE:  A Removal Action was previously conducted in a different area of the Clearview Landfill between November 2011 and September 2012 relating to the removal of PCBs-contaminated soil from the Southern Industrial Area of the Clearview Landfill.  See POLREPs 01 through 23 relating to that response action.  Since the present Removal Action in the residential area relates to PAHs in an entirely separate area of the former landfill, this Removal Action will be documented in a new series of POLREPs beginning herein.

1.1.2.1 Location

The Removal Action involves the removal of soil from residential properties in the Eastwick neighborhood of Philadelphia and storage of that soil upon a portion of the Clearview Landfill in Darby Township.  The locations of individual homes will not be reported in this POLREP.

1.1.2.2 Description of Threat

A group of compounds called polycyclic aromatic hydrocarbons (PAHs) present the majority of the threat posed by the Site.  Benzo[a]pyrene (B[a]P) is the primary risk driver among the detected PAH compounds.   Elevated concentrations of B[a]P and other PAHs are detected in soils within the residential properties of Eastwick neighborhood and adjacent City Park.   The levels of PAHs pose an unacceptable risk to residential human receptors (residents of the Eastwick neighborhood exposed to contaminated soils).  Elevated lead concentrations are also found within the PAH-contaminated soils.  Incidental ingestion of lead in the soil may also result in increased blood lead levels.  Lead is known to adversely affect the central nervous system.  The threats are more fully described in the July 21, 2016 Action Memorandum.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

The Site is an NPL Site.  The RPM for the Site and the OSC relied upon existing soil sample information (e.g., data collected during remedial investigation or preliminary design activities) and newly collected soil analytical results to comprise a Removal Site Evaluation (RSE).  The RSE indicated that elevated levels of hazardous substances are located in residential soils within the OU1 Residential Soil Area.  The hazardous substances are present at levels which pose an unacceptable excess cancer risk to exposed human receptors. 

The maximum concentration of PAHs in the surface (0 to 12 inches) soil of the residential properties in the Eastwick neighborhood are 118 mg/kg (ppm or parts per million).  The maximum concentration of B[a]P within these soils is 8.6 mg/kg which is well above the 1x10^-4 excess cancer risk level for this compound.  Elevated PAH concentrations are also found in subsurface soils well above the 1x10^-4 excess cancer risk level.  Based upon on-scene observation, some of the contaminated soils are poorly vegetated or mixed into garden or play areas allowing an increased chance of unacceptable exposure to elevated PAHs.  Elevated lead is also found in a limited area of the Eastwick neighborhood.  The area of elevated lead contamination is believed to exist within the area of elevated PAHs contamination described above.

The removal site evaluation ad threats posed are more fully described in the July 21, 2016 Action Memorandum.

2.1.1 Narrative

An Action Memorandum approving response actions to address the contaminated soil in the residential Eastwick neighborhood was signed July 21, 2016.  The RPM conducted several outreach sessions to inform the residents and community groups about the Removal Action.  EPA also mailed information to residents of the community.  The RPM also gained access from and discussed response actions with residents and property owners to be directly affected by the Removal Action.

The OSC and RPM first convened with ERRS (ER) and START (Weston) contractors on the Site on August 8, 2016 (Mobilization Date).  This meeting and subsequent meetings were conducted to assure a proper plan of action and that proper personnel, equipment, and materials could be identified to implement the response action.  Between 8/8/2016 and 9/6/2016, the OSC and RPM continued preparation activities inclusive of coordination with residents and contractors and development of air monitoring and other actions to enhance safety in the community during the Removal Action.

2.1.2 Response Actions to Date

On September 6, ERRS contractor personnel mobilized to the Site.  The initial on-site activities began 9/7/2016.

ERRS contractors began to prepare the Site for Removal Actions by clearing trees and brush from an area to be used to set up a Command Post, equipment staging, material staging.  This area is located near the intersection of 83rd Street and Buist.  The trees were cut and moved to the edge of the cleared area.  Chipping activities were also initiated.  During these actions, a minor amount of debris (e.g., concrete, tires, etc.) was also dislodged.  The area was leveled, a fabric was laid and the area upon which the Command Post will sit was stoned.

ERRS began to prepare an accessway from the Command Post area to the area of the landfill upon which the contaminated soil will be staged.  The accessway courses immediately behind or near the residential properties subject to the Removal Action in order the facilitate the removal and transportation of the contaminated soil away from the residences.  The soil staging area is near the top of the landfill.  The initial construction of the access road involved the removal of trees and brush and debris and was completed 9/9/16.

Dust suppression was provided by spraying water from a "water buffalo" dragged around the work area.  Water is obtained from a hydrant under permit.

The START contractor conducted air monitoring using Dust Trak units to monitor dust levels upwind and downwind of the work area.  The initial actions indicate that dust suppression will be necessary throughout the action.  The soil is very fine and dry and easily went airborne when travelled.  Arrangements were made to obtain additional air monitors and to cover accessway with stone.  The soils near the residences will be wetted until covered.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

Activity related to identification of PRPs is still ongoing. 

2.1.4 Progress Metrics

2.2.1 Planned Response Activities Next Period

Complete setup of Command Post with mobilization of trailers and generator.

Complete accessway to soil staging area; cover with stone.

Initiate construction of soil staging area on Clearview Landfill.

Expand dust monitoring setup and establish data management.

Remove trees from residential properties to facilitate removal of contaminated soil.

Continue coordination with residents.

2.2.2 Issues

Extensive coordination with residents will be required before soil removal in yards.

2.4.1 Narrative

A Removal Action Project Ceiling of $3,152,379 was approved for OU1 by EPA Region III on April 12, 2012.  Of this amount, $2,799,948 was from the Regional Removal Allowance.  An additional $2,092,762 is necessary to raise the Removal Action Project Ceiling to $5,245,141, of which $4,718,806 are from the Regional Removal Allowance.   The funding is necessary to mitigate the threats identified in the July 21 Action Memorandum.

The costs associated with the Removal Action completed in September 2012 are documented in POLREP 23 and Final for that response action.

This POLREP will begin to track and identify costs solely relating to this Removal Action addressing the contaminated soils in Eastwick neighborhood.

Costs associated with removal site evaluation is not included.

* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.