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, 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

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

The Responsible Parties initiated the cleanup at the Site  on 11/16/2015.  EPA OSC and EPA START oversaw the cleanup onsite. 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

Response actions taken from 11/16 to 12/30/2015 are summarized as follows: High levels of lead contaminated soil  (above the hazardous waste characteristic) were excavated, treated (to non-hazardous waste)  and disposed offsite at a permitted landfill in Areas 4 and 8. In addition, low levels of lead contaminated soil (non-hazardous) were excavated and disposed offsite at a permitted landfill. Solid waste, vegetation, most rail ties and rail were also removed.  All areas were graded with gravel cover with an underlying geotextile fabric for preparation for asphalt, except for Area 1 west where a final gravel cover was completed. Since the Asphalt plants closed in November, work crews temporarily demobed on 12/30/2015, with plans to return in April 2016.

Response actions were taken from April 1 to July 6, 2016 and Documented in previous POLREPs 1-6. In summary, except fo the western portion of Area 1, (which was covered with an eathen cap) an engineered asphalt cover was installed and completed in Eastern portion of Area 1, 2, 4,5,6,7,8,9, and 10. The primary cap construction crews have de-mobilized from the Site.

A repair crew from the City of Chicago returned on August 22, 2016 to repair the NE corner of Area 5. 

H. Kramer contractors (GHD) completed the final survey of the Site in Sept. 2016.

GHD submitted its Draft Removal Completion Report (Dec. 6, 2016) which documented work conducted. EPA Reviewed and after addressing the EPA comments, the document went final and was approved and finalized April 6, 2017.

A final inspection of the engineered covers was conducted by the EPA OSC on April 12, 2018. No damage was observed and the Covers are in good condition. Photos are attached to this report.

2.1.2.1   Post Closure Removal Site Control -  Sept 2016 to April 2018 :

During this period the responsible parties to the EPA Settlement and Agreement on Consent (AOC)drafted plans for post closure removal site controls for EPA review and concurrence. The controls were developed to meet the requirements under the AOC to ensure that the cover systems installed are maintained.  Extended time was was granted by the EPA OSC since the controls require entering into environmental covenants which require review and signatures from multiple parties such as the Illinois EPA , Cook County, US EPA, responsible parties and the City of Chicago.

Overall, there are Environmental Convenants were signed by US EPA for : 1) Area 10  (August 18, 2017) ; 2) Areas 4 &6, (April 20, 2017); 3) Area 2 (April 5, 2018). 

On January 12, 2018, the City of Chicago Dept. of Transportation Commissioner signed a letter (to the USEPA) committing the City to implement post removal site controls for the unparceled city owned properties for Areas 1,5,7,8&9.

2.1.2.2  - Notice of Completion -   On Feb 20, 2018, EPA OSC sent an final letter to GHD/Project Coordinator : Notice of Completion of Work for the Pilsen Soil Operable Unit 1Railroad Spur and Alley Site.

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

On 9/29/2015 EPA signed an Settlement Agreement and Order on Consent (AOC) For Removal Action with the PRPs for the Site: H.Kramer and Company, City of Chicago, and BNSF Railway Company. Response Actions described in this report were taken in accordance with the AOC.

2.1.4 Progress Metrics

The following Solid Wastes were transported and disposed off-site (Completed by July 2016)

2.2.1 Anticipated Activities

All Site work has been completed.

2.2.1.1 Planned Response Activities

None.  

2.2.1.2 Next Steps

None 

2.2.2 Issues

 
None

2.5.1 Safety Officer

Ramon Mendoza, EPA OSC, 

Walt Pochron, GHD, Project Manager

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 (Community Relation).

 Muhtsun, Ruth (Community Relation).

3.1 Unified Command

None

3.2 Cooperating Agencies

City of Chicago Department of Transportation
City of Chicago Department of Health
Chicago Public Schools
Agency for Toxic Substances and Disease Registry
Alderman Solis Office (City of Chicago)