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In this section, PADOH outlines the recommendations made in PADOH/ATSDR's August 1996 HC and follows them immediately with a description of the site cleanup activities that Ogden has undertaken pursuant to HSCA.

Recommendation 1. Raze the ruins of the burned-out factory to eliminate the many physical hazards present. Repair and maintain the security fence to reduce the chance of trespassing.
Action 1. Ogden evaluated the structural integrity of nine ceramic manufacturing buildings at the site. As a result, they demolished seven of the nine buildings in October and November 1996, leaving only Buildings 4 and 5 (Appendix A, Figure 3) (2). That action eliminated almost all of the physical hazards. They also repaired the security fence, thus reducing the chance of trespassing (2). Ogden has proposed to empty and backfill the water-filled pits (3).

Recommendation 2. Correct the raw sewage problem in Falls Creek Borough by constructing a PADEP-approved sewage collection system. In the interim, advise parents to instruct their children to stay away from the affected areas.
Action 2. Falls Creek Borough has approved the construction of a sanitary sewer system. Construction is slated to begin in October 1998, and will continue for about six months until the sewerage system is completed (4). Residents can then begin the required lateral connections and, as a result, the raw sewage flowing onto the site should come to an end. PADOH developed and distributed 130 copies of community fact sheets alerting residents and their health care providers to avoid the wetlands and the public health hazard it poses to the community. In addition, two articles were published in the local newspaper and a public availability session was held for interested residents (Appendix C).

Recommendation 3. Place warning signs around the areas of elevated lead contamination in wetlands sediments stating that the areas present a health hazard for lead.
Action 3. No one has placed any warning signs around the wetland to deter trespassers from entering those areas (5). However, Ogden will conduct a focused feasibility study on the sludge in the wetland area (Operable Unit No. 2 - OU2). Ogden will provide PADEP with a final report in about January 1999, that will contain selected remedial alternatives for OU2 using overall protection of human health as one of the prime criteria (3).

Recommendation 4. Sample on-site groundwater annually for VOCs and lead.
Action 4. Ogden has identified site-wide groundwater as a separate unit, Operable Unit No. 3 (OU3). Ogden will determine if the migration pathway from groundwater (OU3) is complete to surface water in the wetlands area (OU2) and will report their findings in a Final Site Characterization Report Addendum in about February 1999 (3).

Recommendation 5. Sample surface waters annually for lead in the unnamed tributary to Wolf Run, which drains the former lagoon and runs through the wetland. Lead could be leaching into surface waters and/or groundwater from contaminated sediments.
Action 5. Ogden has proposed a baseline ecological risk assessment in the wetlands and streams adjacent to the site. Ogden's time line for completing that work shows that it will be finished by October 1998 (3).

Recommendation 6. Collect wipe samples randomly from the surfaces of discarded china in the china waste piles and analyze for lead.
Action 6. Ogden collected samples from the china waste piles and analyzed them for lead. Appendix A, Figure 4 shows the points (labeled CG-1 through CG-6) where they took the samples. Appendix B, Table 1 shows the results of analyses. None of the samples met USEPA's definition of lead-bearing hazardous waste (2). Although the samples were not wipe samples, Ogden has proposed a plan to design a residual waste cover for the china waste piles (3). The cover will prevent the piles from being a future public health concern.

Recommendation 7. Collect surface soil samples (0-3 inches) from the soccer field and analyze for lead.
Action 7. USEPA reported in an internal memorandum that Weston, Inc., conducted soil sampling at unspecified depths on the ballfield infield. USEPA reported further that the analytical results for that sample showed lead to be present at a level of 25 milligrams per kilogram (mg/kg) (6), which is not a level of concern. Ogden collected samples from the ballfield and analyzed them for lead. Appendix A, Figure 4 shows the points (labeled PGA-1 through PGA-10) where they took the samples. Appendix B, Table 1 shows the results of analyses. None of the samples met USEPA's definition of lead-bearing hazardous waste. Field investigators reported that no china waste was present at sample points PGA-4 through PGA-9 (2). Investigators did not report the depth of sampling in the ballfield and did not distinguish between the ballfield and soccer field. PADEP's laboratory did not analyze for total lead at the four points where china waste was present (PGA-1 through PGA-3 and PGA-10), but rather analyzed them using the toxicity characteristic leaching procedure (TCLP) and the synthetic precipitation leaching procedure (SPLP) (2). PADOH, in a conservative approach, believes that a data gap for lead in the playground still exists.

Recommendation 8. Sample the fluid, if present, in the on-site transformer for polychlorinated biphenyls (PCBs).
Action 8. Ogden sampled the contents of the pole-mounted electric power transformer. PADEP's laboratory in Harrisburg analyzed the sample for PCBs. The results of sampling showed no PCBs above the detection limits (2). The above discussion shows that, except for soil samples in the 0-3 inch zone of the playground, all of the recommendations in PADOH/ATSDR's August 1996 HC have been addressed in the ongoing HSCA activities at the site.

Children's Health

As part of the ATSDR Child Health Initiative, public health activities give special consideration to sensitive sub-populations such as children. PADOH feels that children are not being exposed to site-related contaminants at levels considered harmful to human health. However, until the raw sewage problem is completely eliminated, children in the area may come in contact with pathogenic organisms carried in the raw sewage onto the site.

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