1.1.1 Incident Category

Time Critical Removal Action

1.1.2 Site Description

The Site consists of an alley (owned by the City of Chicago) and a railroad spur (historically operated by Burlington Northern Santa Fe Railway [BNSF]) located in the Lower West Side (Pilsen) area of Chicago, Cook County.  The Site is in the City’s 25th Ward.  The east to west portion of the alley is approximately 460 feet (ft) long and 18 ft wide (approximately 8,280 square feet [ft²] in area) and is roughly paved with asphalt over 25% of its length from the east side.  The north to south portion of the alley is about 110 feet long.  The remaining 75% of the alley is soil.  The alley connects South Loomis Street and South Throop Street and is south of West 21^st Street and north of West Cermak Road.  The alley is bordered to the north by H. Kramer and Company (H. Kramer) and Co., the east by South Throop Street, to the south by commercial and industrial businesses, and to the west by the railroad spur and then South Loomis Street.

The railroad spur is approximately 1,120 ft long and 28,215 ft² in total area.  The railroad spur consists of an unused rail track and soil and asphalt where it is bisected by South Loomis Street.  The western portion of the railroad spur is located in the north region of a property occupied by the Benito Juarez Community Academy (Juarez), located at 1450-1510 West Cermak Road.  The railroad spur curves to the south, crosses South Loomis Street, and extends along the west boundary of H. Kramer, located at 1345 West 21^st Street. The eastern portion of the railroad spur is bordered by businesses along Loomis Street and West Cermak Road to the south.  According to a historical Sanborn fire insurance map, the railroad spur and the alley have existed since at least 1914.

The alley and railroad spur soil (surface soil and subsurface soil) generally consists of silty, clayey, sandy, and gravelly fill materials.  In the alley soil, some traces of wood chips, cinders, and pieces of glass, brick, plastic debris, and slag were observed [slag was observed in eight alley soil borings and one railroad spur soil boring].  Slag is a solid-phase waste generated by secondary lead processing.  In general, the surface and subsurface railroad soil contained more gravel than the alley soil. The western portion of the railroad spur west of Loomis street also contained vegetation (weeds) and garbage.

In addition to the information provided in the previous section. The geographical coordinates for the alley portion of the Site are 41° 51' 10.38" North latitude and 87° 39' 35.54" West longitude.  The geographical coordinates for the railroad portion of the Site are 41° 51' 13.58" North latitude and 87° 39' 41.66" West longitude. The Site is an industrial site in a residential neighborhood with a portion of it (Western Area of the Railroad Spur west of Loomis Street) located within a ¼-mile of two schools - Juarez and the Manuel Perez Jr. Elementary School (Perez).  Two City of Chicago parks are located within a ½-mile-radius of the Site, Dvorak Park and Throop Park.  

1.1.2.2 Description of Threat

EPA Removal Site Assessment analytical results document high levels of Lead in soil at or near the surface (which exceed the EPA Removal Management Level [RML] of 800 mg/kg for industrial use scenario).  Access to the Alley is unrestricted and the fence in portions of the railroad spur is inadequate to prevent trespassers.  The surface soil at the Site has the potential to migrate offsite via wind, rain, vehicular and pedestrian traffic, or manual dispersion and presents a threat of exposure to the residents and workers in the surrounding area.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

EPA conducted a removal site assessment from Dec. 2012 to 2013 in the field and found that average alley surface soil total lead was 2419 mg/kg.  Average railroad spur surface soil total lead was 4340 mg/kg. In addition to the high concentrations of total lead, two soil samples from the alley and one from the railroad spur collected from 0 to 6 inches bgs contained TCLP lead at concentrations exceeding the TCLP lead regulatory limit of 5.0 mg/L in 40 C.F.R. § 261.24(b).

2.1.1 Narrative

Responsible Parties initiated the cleanup at the Site  on 11/16/2015.  EPA OSC and EPA START oversaw the cleanup onsite at all times.  The overall goal of the removal action is to remove the threat of lead exposure to surrounding residents and workers from surface soil through: 1) removal of soil contaminated with high levels of lead above the EPA RML, and 2) placement of permanent covers at the Site.  

 
2.1.2 Response Actions to Date

The following are response actions from 12/7 to 12/11/2015. EPA OSC, START, and H. Kramer contractors [GHD (prime), RW Collins (subcontractor/soil excavation) are onsite. Response actions from 11/16 to 12/4/2015 are documented in the previous POLREPS #1,2 and 3.

The overall goals for the week were to: 1) Complete the excavation and installation of final cover in Area 1 West (area next to the high school soccer field); 2) Complete subgrading activities in Area 1 East and Area 2; 3) Complete subgrade activities in Area 10.   These goals were achieved as described in the following work.  

Monday 12/7 to Tuesday 12/8:

• GHD/RW Collins excavated soil in Area 1 West in the previous week.  EPA received final lab confirmation that the cleanup goal in Area 1 West was achieved with a total lead average lead concentration of 632 ppm. Subsequently, EPA confirmed that final gravel cover filling operations can begin for all of Area 1 West. This was completed on 12/8.  Per the Work Plan, the gravel cover consists of geoxtextile layer at the bottom of the excavation with a compacted and graded gravel cover (up to 2 feet) on top and even with the sidewalk grade next to the school soccer field (see photo).
• To ensure that the gravel fill was clean, EPA screened two gravel piles (class 6 gravel) for use as fill, prior to placement, average XRF reading for lead 64 +/- 3 ppm and 70 +/- 2 ppm. These concentrations are below EPA's residential removal management screening level.
•  GHD and RW Collins conducted additional treatment in the Area 8 West (TCLP area) since the lab results came back above the haz criteria of 5 mg/l.  Treatment consisted of mixing the soil with Free Flow 300 in the affected area (50 feet by 18 feet by 18 inches deep).
• Soil excavated from Area 1 West has been stockpiled and secured in the parking lot north of Area 1 West.
• RW Collins began grading activities in Area 1 East and Area 2    

Wednesday 12/9 to Thursday 12/10:

• After additional surveys, GHD/ RW Collins completed soil grading, geotextile fabric placement, gravel placement, and gravel grading of Area 1 East and Area 2.         
• GHD/RW Collins initiated grading work was initiated in Area 10.    

Friday, 12/7:

        -  RW Collins completed soil grading, geotextile fabric placement, gravel placement,                    and gravel grading of Area 10.

         -  All soil piles (Area 4 and parking lot north of Area 1) were secured with plastic sheeting per          routine at the end of the day.

Throughout the reporting period GHD and EPA continued to conduct air monitoring with DataRAM 4 and DustTraks for dust in air.  EPA monitored downwind with GHD.  GHD had an additional monitoring location upwind with a DustTrak. EPA conducted additional air monitoring with a PDR for dust in air the PDR held by START personnel collected dust data for continuous monitoring near work areas.  

The average PDR reading for the week is 0.0294 mg/m³ and average DataRAM 4 reading for the week is 0.0539 mg/m^3.   No action levels (for dust) were exceeded.

Note: The action levels EPA START developed for the site are 0.812 mg/m³ for Areas 8 and 9, 1.19 mg/m³ for Areas 4, 5, 6, 7, and 10, and 3.19 mg/m³ for Areas 1 and 2.)  GHD has a single action level of 0.480 mg/m³.  The off-site dust particulate action level is any sustained downwind reading of 0.150 mg/m³ above background or the upwind reading.

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

On 9/29/2015 EPA signed an Settlement Agreement and Order on Consent For Removal Action with the PRPs for the Site: H.Kramer and Company, City of Chicago, and BNSF Railway Company.

2.1.4 Progress Metrics

2.2.1 Anticipated Activities

EPA and START will continue air monitoring and oversight of response activities onsite to ensure compliance with the Administrative Settlement Agreement and Order on Consent (AOC).

2.2.1.1 Planned Response Activities

For the week of 12/14  to 12/18:

-  Recycle staged Rails

-  Properly dispose of treated soil in Area 4 and excavated soil from Area 1.

- Initiated subgrade graveling operations east of Loomis street in Areas 4,6,7,5,8&9.

2.2.1.2 Next Steps

In addition to the planned and anticipated activities, OSC will continue to work with EPA community to address concerns from the community and media as they come.

2.2.2 Issues

Weather conditions are approaching winter conditions. Appropriate measures are being taken to ensure health and safety.

2.5.1 Safety Officer

Ramon Mendoza, EPA OSC, 

Andy Krein, GHD

2.5.2 Liaison Officer

2.5.3 Information Officer and Community Relations

Philippa Cannon, EPA (PIO support)

Clarke, Rosita, EPA (Community Relation).

Leon, Heriberto, EPA

3.1 Unified Command

None

3.2 Cooperating Agencies

City Department of Transportation

Alderman Solis Office (City of Chicago)