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

ERRS contractors continued to prepare the Site for Removal Actions.  Construction of the area to be used for Command Post, equipment staging, material staging was completed.  This area is located near the intersection of 83rd Street and Buist.  Trees and brush were cut and most have been chipped.  Chipping activities continue.  The area was leveled, a fabric was laid and the area upon which the Command Post will sit was stoned.  EPA and ERRS trailers arrived on 9/12/16.  Electric generator was also hooked up the week of 9/12/16.

ERRS completed the 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.  Clean stone was placed on the accessway and rolled.  This work was completed by 9/20/16.  The soil staging area on the landfill was bermed and covered with fabric to manage stormwater.  Accessway terminates inside this disposal area.  Once soil staging begins, soil will be covered at the end of each work day.  Silt fencing and high visibility fencing were installed along the accessway where needed, to manage potential stormwater and minimize potential public access through the adjacent Eastwick Park.  Fencing between the accessway and yards was removed on 9/22/16.  Large trees in front and back yards of homes to be addressed in near future along Buist Avenue were removed by ERRS.  

Dust suppression is being provided by spraying water from a water truck. Water is obtained from a hydrant under permit.  Portions of the accessway which had not yet been stoned were also watered over the weekend of 9/10/16.  

Soil samples for clean backfill and topsoil were collected by START contractor on 9/16/19 and 9/19/19, respectively, with results being provided within 48 hours from the laboratory.  Sample results indicated that both sources were acceptable. There were no exceedances of site-specific soil cleanup levels established in the OU1 Record of Decisions.  The backfill and topsoil also meet criteria to be considered to be clean fill under the Pennsylvania Management of Fill policy.

The START contractor conducted air monitoring using Dust Trak units to monitor dust levels upwind and downwind of the work area.  Data from the Dust Trak units is being uploaded in real-time to the the EPA ERT VIPER website.  Total Dust Action Limits that are protective for residents and workers have been established in the HASP.  The VIPER website has been set to provide alerts to EPA and START personnel when dust levels reach certain thresholds prior to hitting Total Dust Action Limits.  This will facilitate any additional dust suppression activities.  Air monitoring data indicates that dust suppression will be necessary throughout the action.  The soil is very fine and dry and easily went airborne when travelled.  During residential excavations, dedicated ERRS personnnel will be conducting dust suppression activities.  

The EPA Remedial Project Manager (RPM) and START contractor met with the property owner representatives and tenants of the first four yards to be addressed.  Inventory was taken of all items to be removed prior to excavation.  A restoration plan and the expectations for the work to be performed was developed and agreed to by EPA, property owners and tenants.  The RPM has explained to the property owners and tenants the process that will be followed during  yard excavation and restoration.  Although dust suppression will be ongoing, EPA has recommended that all doors and windows remain closed during excavation to minimize any dust entering the homes and to dampen any loud noises.  Excavation of the first yards will start on 9/26/16.  Three to four yards will be addressed the first week, depending on the pace of progress.  The current plan is to complete restoration of yards within 5 days.

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

Initiate excavation of contaminated soils from residential yards.

Backfill excavated yards with clean soil and restore surface vegetation.

Continue dust suppression.

Continue air monitoring upwind and downwind of work areas.  

Remove additional trees from yards to be addressed in coming weeks.

Conduct surveys and inventories of next set of yards to be addressed.

Continue coordination with residents.

2.2.2 Issues

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