SUBJECT: Superfund Action - Economy Products Pesticide . - US EPA

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SUBJECT:Superfund Action - Economy Products PesticideContamination Site, 1126 North llth Street, OmahaNebraskaTO:Hans Crump, Acting Director (WH-548-B)Emergency Response Division - EPA/HQCLASS:EPA Region VII Superfund Site # S5 - Emergency ActionORDER #:Emergency Response Clean-up Services - 7334-07-039POLLUTANT:Multiple organochlorine pesticides as loose debris andas soil contamination. The principal components of thecontamination (toxaphene, chlordane, and methoxychlor) are allB2 human carcinogens.LOCATION: The site is located in a fully developed commercialsetting on the near north side of the City of Omaha, Nebraska.The specific address is 1126 North llth Street. Currentexposures include the employees of the adjacent business on thenorth side which is within 50 feet of the highly contaminatedsurfaces.WATER:Contamination on the site is subject to transport byprecipitation event runoff through the city storm sewers tothe Missouri River.SOURCE:The 4-story concrete and brick structure on the sitewas used as a private label pesticide formulation facility until1982 when it was abandoned by the owner following notification ofsignificant code violations by local officials. At the presenttime, the residual contamination, principally organochlorinepesticides, is present as loose debris inside the structure atlevels over 1,000 ppm and as soil contamination in the exteriorsoil on the west side of the structure at low percent levels.DATE:January 15, 1990POLREP:# 22I.SITUATION:r s.v(Unchanged from previous POLREPs)II.ACTIONS TAKEN (through 1005 January 15, 1990)A.The following is the status on the 16 exterior soilexposure units on the west side of the Economy Products'structure:S00028942SUPERFUND RECORDS

003 - Clean, no excavation or disposal necessary.955 UCL for toxaphene 5.0 mg/kg004 - Clean, no excavation or disposal necessary.95% UCL for toxaphene 22.5005 - Clean, no excavation or disposal necessary.95% UCL for toxaphene 35 mg/kg006 - Clean, no excavation or disposal necessary.95% UCL for toxaphene 38.6 mg/kg007 - Excavated to 12". Clean at 12". Disposalplanned for local landfill pending finalapproval from CWM, managers of the locallandfill.35 filled bags on hold for disposal.95 percent UCL for toxaphene at minus 12" 571 mg/kg008 - Excavated to 12". Clean at 12".materials on hold for disposal.Bagged31 filled bags on hold for disposal.95% UCL for toxaphene at minus 12" 544 mg/kg009 - Excavated to 12".34 filled bags18 bags to TWI1989.Ill111Clean at 12".excavated from this section.for disposal on December 16,Manifest # 4140116Manifest f 414011816 bags to TWI for disposal on January 5,1990.Ill Manifest # 4140117111 Manifest # 414012095% UCL for toxaphene at minus 12" 925 mg/kg010 - Documentation samples at 95% UCL for top 12"pending removal of bags stored on thissection.

011 - Documentation samples at 95% UCL for top 12"pending removal of bags stored on thissection.012 - Documentation samples at 95% UCL for top 12"pending removal of bags stored on thissection.013 - Excavated to 12". Clean at 12". Baggedmaterials onsite pending disposal arrangements at the local landfill.13 filled bags on site.95% UCL for toxaphene at minus 12" 1,741 mg/kg014 - Excavated to 12". Clean at 12". Baggedmaterials onsite pending disposal arrangements at the local landfill.50 filled bags on site95% UCL for toxaphene at minus 12" 45 mg/kg015 - Surface concentration below action level.No excavation.95% UCL for toxaphene 33.9 mg/kg016 - Surface concentration below action level.No excavation.95% UCL for toxaphene 77.4 mg/kgB.A total of 163 bags of pesticide contaminated soilwere excavated from the exterior soil unit exposure areas. Thismaterial has been staged onsite pending final disposalarrangements.C.A summary of the disposal is as follows: 34 bags from unit 009 (190,000 pounds) weresent to TWI for incineration on December 16,1989. (111. Manifest Nos. 4140116 and4140118 and on January 5, 1990, 111. ManifestsNos. 4140117 and 4140120) Copies of allmanifests will be provided to Janice Kroone,RCRA records.

11,900 gallons of contaminated liquids in thebasement were discharged to city sewers withCity of Omaha permit no. S-01001. Concentrationas discharged, measured by sample no. ZXXS5201,1.9 /ig/liter as toxaphene from Laucks TestingLaboratories, Inc. 350 gallons of deodorized kerosene were removedfrom tank "C" for recycle by Capitol Oil. 18 bags of asbestos debris (approximately200 pounds) were disposed of at the DouglasCounty Landfill. Landfill ticket #15093. 4,000 gallons of decon fluids have beendischarged to local sewers after testing.City Permit #8-01001.D.Perimeter air monitoring results returned all nondetectat 0.04 nq/vs. which is well below action level. Air monitoringcontinues on a weekly basis.E.The response manager continues to take regular sitevideo segments, and TAT reports script for the site video wascompleted as draft for review. The video will be 30 minutesmaximum.F.All analytical requirements have been completed for theoff-site disposal as solid waste of the materials from exteriorsoil sections. The State of Nebraska permit has been receivedand landfill managers have expressed verbal approval of the disposal. Completion of hard copy permits is expected this week anddisposal is expected within 10 working days.G.Carbonair subcontractor has completed treatment anddisposal of aqueous portion of liquids in structure basement andhas demobilized all equipment and contaminated carbon from thesite.III. PLANNED ACTIVITIESA.Overall plans for completion of the planned siteactivities are as follows:1.Complete abrasive blasting for decon and disposalof all metal, wood, and other debris remaining in the structurewhen removal started. All of this material is to be treated ina blasting booth constructed on the first floor. Metals are tobe wipe tested to verify decon and disposed by recycle to scrapdealer. Wood and other porous materials to be deconned anddisposed as solid waste at the local landfill.

2.Complete abrasive blasting of tool room andmaintenance area. This is the one story ground level area on thesouthwest corner of the main structure.3.Initiate removal of temporary cover from tank farmarea and abrasive blast surfaces as cover is removed. Cover wasapplied by previous removal and should not be considered contaminated. The cover material can be disposed of as solid waste orrecycled.4.Complete abrasive blasting decon of the firstfloor surfaces in the main structure.5.Conduct trial application of stabilized 35 percentH2O2 on the first floor test areas. A health and safety planmodification for this activity needs to be prepared and approvedfor this activity.6.Complete abrasive blasting of the basementsurfaces in the main structure.7.Complete off-site disposal of all materialsgenerated during removal. If delisting of KPEG treated 2,4-D and2,4,5-T is not completed by this time, these materials will betransported to storage pending approval of delisting petition.8.Complete sampling and analysis for documentationof meeting action levels.9.10.Demobilize site.Complete OSC's final report and administrativerecord.B.Activities planned for the period January 15, 1990,through January 30, 1990, are listed below in order of priority:1.Continue operation of two LTC-1060 blasters oninterior surfaces of the third floor of the main structure.2.Continue to consolidate all debris for abrasivedecon on the first floor of structure.3.Collect representative sample of oily residuefrom basement pits and submit to CWM Riverdale laboratory foranalysis to facilitate disposal.4.Obtain written status report on delisting effortfor KPEG materials drummed in the structure interior. Initialcontacts with NDEC indicate this may be a very lengthy processunless support is provided from the Regional staff.

6.Continue off-site disposal of bagged contaminatedsoil as data is received and schedules obtained with disposalsites.IV.PERSONNEL ON-SCENE (January 12, 1990)Carl Bailey , OSC/EPA/VIIRandy Davis, ERCS Response ManagerCharlotte McLain, ERCS Data ClerkLois Munnna, ERCS site safety Officer6 ERCS techniciansWells Fargo Site Security in shiftsV.Contract Costs (through January 8, 1990 billings)EMERGENCY RESPONSE CLEAN-UP SERVICES CONTRACTVI,Current Delivery Order Ceiling 1,266,497.00Actual Costs Billed on 1900-55 592,921.99Committed Costs not Billed 201,101.61Total costs 794,023.60Remaining Funds In Current Ceiling 472,473.40STATUS:Case pends.cc:David Wagoner, WSTMMorris Kay, RGADRon Ritter, CIGLRowena Michaels, PBAFJohn Anderson, FNMGChuck Hayes, NDECSara Nielsen, OS-210Martha Steincamp, CNSLDon Brunken, Omaha Fire Dept.Miriam Chesslin, DOJAl Pattavina, Omaha PublicMargaret Finney,Safety Dept.Douglas Co. Health Dept.

Contamination Site, 1126 North llth Street, Omaha Nebraska TO: Hans Crump, Acting Director (WH-548-B) Emergency Response Division - EPA/HQ CLASS: EPA Region VII Superfund Site # S5 - Emergency Action ORDER #: Emergency Response Clean-up Services - 7334-07-039 POLLUTANT:Multiple organochlorine pesticides as loose debris and as soil contamination.