removal program after action report for the aaa …

REDACTED REMOVAL PROGRAM COMPREHENSIVE AFTER ACTION REPORT

FOR THE AAA ACCREDITED PEST CONTROL SITE

RUTLAND, RUTLAND COUNTY, VERMONT 19 SEPTEMBER 2013 THROUGH 16 JULY 2014

Prepared For:

U.S. Environmental Protection Agency Region I

Emergency Planning and Response Branch 5 Post Office Square, Suite 100

Boston, Massachusetts 02109-3912

CONTRACT NO. EP-S3-15-01

TDD NO. TO1-01-15-07-0042

TASK NO. 0044

DC NO. R-00814

Submitted by:

Weston Solutions, Inc. Region I

Superfund Technical Assessment and Response Team IV (START) 101 Billerica Avenue Building 5, Suite 103

North Billerica, Massachusetts 01862

June 2020

ii

TABLE OF CONTENTS Page

LIST OF APPENDICES ................................................................................................................. iii 1.0 INTRODUCTION .............................................................................................................. 1 2.0 SITE DESCRIPTION AND BACKGROUND .................................................................. 1

2.1 Summary of Site Evaluation, Findings and Conclusions........................................ 3 3.0 SUMMARY OF EPA REMOVAL ACTIONS .................................................................. 4

3.1 Organizational Structure ......................................................................................... 4 3.2 Mobilization and Site Preparation .......................................................................... 5 3.3 Summary of Removal Activities ............................................................................. 5

4.0 SUMMARY OF REMOVAL ACTION PROCESS .......................................................... 6 5.0 ESTIMATED COST OF REMOVAL ACTION ................................................................ 7 6.0 REFERENCES ................................................................................................................... 8

iii

LIST OF APPENDICES

Appendix A Figures Figure 1 - Site Location Map Figure 2A - Phase 1 Removal Properties Location Map (Redacted)Figure 2B - Phase 2 Removal Properties Location Map (Redacted)

Appendix B Removal Program After Action Report for Residential Property 1001-03 Rutland, Vermont

Appendix C Removal Program After Action Report for Residential Property 1001-04 Rutland, Vermont

Appendix D Removal Program After Action Report for Residential Property 1023-01 Rutland, Vermont

Appendix E Removal Program After Action Report for Residential Property 1009-01 Rutland, Vermont

Appendix F Removal Program After Action Report for Residential Property 1009-02 Rutland, Vermont

Appendix G Removal Program After Action Report for Residential Property 1009-03 Rutland, Vermont

Appendix H Removal Program After Action Report for Residential Property 1014-01 Rutland, Vermont

Appendix I Removal Program After Action Report for Residential Property 1000-01 Rutland, Vermont

Appendix J Removal Program After Action Report for Residential Property 1005-01 , Rutland, Vermont

Appendix K Removal Program After Action Report for Residential Property 1029-01 Granville, Vermont

Appendix L Removal Program After Action Report for Residential Property 2564-01 Shrewsbury, Vermont

Appendix M Removal Program After Action Report for Residential Property 2049-01 Manchester, Vermont

Appendix N Removal Program After Action Report for Residential Property 1037-01 Hydeville, Vermont

iv

LIST OF APPENDICES, Continued

Appendix O Removal Program After Action Report for Residential Property 1179-99 West Danby, Vermont

Appendix P Removal Program After Action Report for Residential Property 1009-04 Rutland, Vermont

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1.0 INTRODUCTION

The Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START) was tasked under Technical Direction Document (TDD) Number (No.) 01-13-09-0007 to provide technical support to U.S. Environmental Protection Agency (EPA) Region I with removal activities at the AAA Accredited Pest Control Site, located in Rutland, Rutland County, Vermont (VT) (see Appendix A, Figure 1, Site Location Map). Removal activities included the following: accessing residential properties that were approved for cleanup in the EPA Action Memorandums; removing contaminated carpet, flooring, furniture, ceiling panels, wall paneling, clothing, linens, and debris/trash from each residence for disposal; conducting efficacy sampling to determine the most effective decontamination method; conducting decontamination activities using a Sterilex® solution or a water/detergent mixture and a tap water rinse; collecting post-decontamination clearance wipe samples from each residence; conducting additional decontamination or sampling as necessary based on analysis of clearance wipe samples; conducting logbook and photodocumentation; and conducting restoration activities that included installation of new carpeting or flooring, repainting of interior walls and/or baseboard/trim, application of new wallpaper, and replacement of furniture as needed. For locations of residential removal properties, see Appendix A, Figure 2A, Phase 1 Removal Properties Location Map; and Figure 2B, Phase 2 Removal Properties Location Map.

2.0 SITE DESCRIPTION AND BACKGROUND

The AAA Accredited Pest Control Site (the site) includes residences in Rutland, Vermont (VT), and in surrounding communities. The VT Agency of Agriculture, Food, and Markets (AAFM) and Department of Health (DOH) requested EPA assistance with conducting sampling of residences where AAA Accredited Pest Control (AAA), a local exterminator, applied the pesticide chlorpyrifos in indoor settings. In May 2013, VT AAFM began investigating AAA following a complaint that a pesticide application by AAA to address a bedbug infestation had sickened a family in a treated house. VT AAFM Field Agents initiated the investigation, which included interviewing the complainant, inspecting the property, collecting photographic evidence, sampling the complainant’s home, interviewing the pesticide applicator from AAA, inspecting AAA’s records and invoices, and sampling their spray formulations and application equipment. Observations and analytical results indicated the presence of chlorpyrifos, which has been restricted for all indoor uses since 2001. In July 2013, based on the investigation, and after going through an administrative hearing process, VT AAFM suspended the company’s license to apply pesticides. The investigation continued with a review of invoices from AAA in order to prioritize treated residences requiring sampling. Based on this invoice review, sampling was conducted by VT AAFM on 10 additional residences which had been recently treated for bedbugs and/or insects by AAA, and deemed most at risk from chlorpyrifos treatment. VT DOH also evaluated the potential for public health impacts, and established levels of concern for exposure by the general population as well as for sensitive receptors. Based upon VT AAFM sampling data, VT DOH recommended that the residents of homes where these levels had been exceeded voluntarily relocate until the situation could be addressed.

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In July 2013, VT AAFM notified EPA Region 1 of the situation, and inquired about EPA’s ability to provide assistance with cleanup. Subsequently, on 3 August 2013, EPA received a letter co-signed by the Commissioner of the Vermont Department of Public Health and the Vermont Secretary of Agriculture requesting EPA’s assistance with the cleanup of contaminated homes, temporary relocation of residents, sampling and laboratory analysis, and public outreach. Based on the fact that the contamination in this case had resulted from the application of pesticides and was mostly contained within buildings, any action taken by EPA would require concurrence from the EPA Headquarters (HQ) Office of Emergency Management (OEM).

EPA Region 1 and HQ OEM consulted with the HQ Office of Pesticide Programs (OPP) regarding the development of a site-specific Removal Program Action Level (AL) for chlorpyrifos. OPP indicated that they supported an AL derived by applying an uncertainty factor to the OPP chronic exposure action level of 0.06 micrograms per square centimeter (µg/cm2). The uncertainty factor would be applied to the OPP chronic exposure action level to address the potential for higher than estimated exposures associated with the likely misapplication (i.e. off-label use) of chlorpyrifos within the residences. VT DOH initially proposed that an uncertainty factor of 180 be used; however, after VT DOH reviewed the OPP methodology and conducted discussions with EPA regarding the use of an uncertainty factor, they revised their proposal, and requested that EPA use an uncertainty factor of 10 and address only those properties with chlorpyrifos levels exceeding 0.006 µg/cm2. HQ OEM concurred with the use of the uncertainty factor of 10, resulting in a site-specific Removal Program AL of 0.006 µg/cm2 [1].

On 20 and 21 August 2013, EPA Region 1 staff and management met with State agencies in Vermont. A strategy was agreed upon to better define the overall scope of the situation, and to address how EPA’s sampling and analytical resources would be employed to augment State efforts. It was agreed that EPA could potentially address homes where the concentration of chlorpyrifos exceeded 0.006 µg/cm2. However, that determination would be made once the total number of affected residences was defined, provided that the State of Vermont committed to ensuring the cleanup of homes it had determined represent an unacceptable risk but with lesser concentrations present.

On 10 September 2013, the EPA Administrator approved EPA Region 1 support in providing assistance to the State of Vermont with the areas of data management, sampling, analysis, and outreach. On 12 September 2013, EPA, START, and a team of Regional staff supported by EPA’s Environmental Response Team (ERT) mobilized to the site. Assistance included documenting wipe samples collected by VT AAFM personnel, collecting wipe samples to confirm and characterize previous sampling results, and conducting data management, outreach efforts, and laboratory analysis. On 19 September 2013, an Action Memorandum was approved authorizing Removal Actions at up to 11 properties where analytical results indicated the presence of chlorpyrifos at levels above the site-specific Removal Program AL of 0.006 µg/cm2. The EPA Action Memorandum specified that actions would be contingent upon confirmation of the exceedance of the AL at each of the 11 properties by conducting wipe sampling. Subsequently, of the 11 homes authorized for cleanup in the September 2013 Action Memorandum, EPA confirmed that 10 met the Removal Program’s criteria to initiate a removal action. The 11th home was referred back to the state.

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In September 2013, a Sampling and Analysis Plan (SAP) was developed for the Preliminary Assessment/Site Investigation (PA/SI) characterization sampling conducted by EPA, START, and VT AAFM so that sample collection techniques, sampling media, and storage/transport of samples could be established; and to provide data that could be evaluated to determine the extent of contamination at each residence sampled and assess whether removal actions were necessary at potentially impacted properties. Samples collected during the investigation would be analyzed for the presence of elevated levels of chlorpyrifos. The PA/SI SAP was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pest Control Site, Rutland, Vermont [2]. Further, in March 2014, a SAP was finalized for the final clearance sampling to be conducted by EPA and START after removal activities were completed at each residence. The removal SAP was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont [3]. On 26 March 2014, an addendum to the Action Memorandum was approved authorizing Removal Actions at up to five additional properties. The EPA Action Memorandum addendum specified that actions would be contingent upon confirmation of the exceedance of the AL at each of the five additional properties by conducting wipe sampling. A total of 126 properties were investigated during the Site Investigation (SI) and during the Removal Action. Of the 126 properties, removal activities were conducted at 15 of the properties (see Appendix A, Figure 2A, Phase 1 Removal Properties Location Map; and Figure 2B, Phase 2 Removal Properties Location Map).

2.1 Summary of Site Evaluation, Findings and Conclusions VT AAFM began investigating AAA in May 2013 following a complaint that a pesticide application by AAA to address a bedbug infestation had sickened a family in a treated house. Samples collected by VT AAFM from the treated house in Rutland, VT indicated the presence of deltamethrin, lambda cyhalothrin, permethrin, and chlorpyrifos. Further investigations by the VT AAFM and VT DOH, and follow-up characterization sampling by EPA, indicated the potential widespread use of chlorpyrifos in indoor applications at homes in Rutland, VT and in the surrounding area. EPA, VT AAFM, and VT DOH collectively determined that EPA Removal Actions would be conducted at residences where characterization sampling indicated the presence of chlorpyrifos at levels exceeding the site-specific Removal Program AL of 0.006 µg/cm2. Further, at the conclusion of each EPA Removal Action, EPA and START would conduct post-Removal Action clearance wipe sampling of residences to document that EPA decontamination activities reduced the risk of exposure. In addition, VT AAFM would recommend and advise on owner-conducted cleanups at residences where analytical results exceeded the VT AAFM AL of 0.0004 µg/cm2. Further, VT AAFM would conduct post-cleaning sampling at residences where owner-conducted cleanups took place, to verify that a reduction in risk had been achieved.

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3.0 SUMMARY OF EPA REMOVAL ACTIONS

3.1 Organizational Structure

ORGANIZATION OF THE INVESTIGATION

Organization Representatives Responsibilities U.S. Environmental Protection Agency (EPA) Region I Emergency Planning and Response Branch (EPRB) 5 Post Office Square, Suite 100 Boston, Massachusetts 02109

Tom Condon Rich Haworth Alex Sherrin Dan Burgo Ted Bazenas Brent England

Coordinators EPA On-Scene (OSCs) responsible for the initiation, oversight, and completion of all investigation activities pursuant to the Sampling and Analysis Plan (SAP). The OSC coordinated with State and local officials.

U.S. EPA Region 1 5 Post Office Square Boston, Massachusetts 02109

Cheryl Sprague Project Manager (RPM) responsible for working with the OSCs to coordinate project scheduling, planning, and timeline management.

EPA Region I Community Involvement 5 Post Office Square, Suite 100 Boston, Massachusetts 02109

Jim Murphy Stacy Greendlinger Kelsey O’Neil Kate Melanson Jeanethe Falvey

EPA Community Involvement Coordinators (CICs) that were engaged as the liaison between EPA and property owners/tenants.

VT Agency of Agriculture, Food, and Markets (AAFM) 116 State Street Montpelier, Vermont 05620-2901

Cary Giguere Dominique Golliot Doug Johnstone David Tremblay

State representatives who assisted with the coordination of investigation activities.

VT Department of Health (DOH) 108 Cherry Street Burlington, Vermont 05402

Chris Bell Mallory Staskus Lori Cragin Linda Boccuzzo Andrew Chevrefils Sarah Vose

State representatives who assisted with the coordination of investigation activities.

Environmental Restoration, LLC. (ER) Emergency Rapid Response Services (ERRS) 627 Court Street Binghamton, New York 13901

Joe Overend Response Manager (RM) for the ERRS contractor that performed removal activities. The RM was responsible for oversight and organization of mobilization, demobilization, and waste removal activities.

Weston Solutions, Inc. (Weston) Superfund Technical Assessment and Response Team (START) 3 Riverside Drive Andover, Massachusetts 01810

Paul Callahan Bill Mahany Robert Sharp Andrew Danikas Eric Ackerman Bonnie Mace John Burton

START personnel that provided the OSCs with technical assistance, site documentation, site health and safety monitoring, data management, final clearance sampling, and draft and final report preparation.

5

ORGANIZATION OF THE INVESTIGATION

Organization Representatives Responsibilities Weston (Continued) START 3 Riverside Drive Andover, Massachusetts 01810

Stephanie Bitzas Erin Mulholland Ken Robinson Jonathan Saylor George Mavris Colin Cardin

START personnel that provided the OSCs with technical assistance, site documentation, site health and safety monitoring, data management, final clearance sampling, and draft and final report preparation.

3.2 Mobilization and Site Preparation

On 12 September 2013, the mobilization of EPA and START was initiated. On 23 September 2013, the Emergency Rapid Response Services (ERRS) Response Manager (RM) responded to the site, and met with the On-Scene Coordinator (OSC) to develop plans and initiate preparations for the upcoming residential removal/clean-up activities. The site-specific health and safety plan (HASP) was reviewed and signed by all personnel before any work commenced. In addition, emergency telephone numbers and directions to the hospital were posted. All activities were performed in appropriate personal protective equipment (PPE) in accordance with the HASP. The HASP was prepared by START personnel as a separate document, entitled Health and Safety Plan for the AAA Accredited Pest Control Site, Rutland, Vermont [4].

3.3 Summary of Removal Activities

EPA, START, and ERRS conducted trial decontamination procedures at two residences where EPA data confirmed chlorpyrifos levels exceeding the site-specific Removal Program AL. Several different decontamination procedures were used to test the efficacy of different cleaning agents on various surfaces. Pre- and post-cleaning efficacy samples were collected and delivered to the Office of Environmental Measurement and Evaluation (OEME) New England Regional Laboratory (NERL) for analysis. After the data from OEME were received and reviewed, it was determined by EPA that Sterilex® was the most effective product in removing chlorpyrifos residue and reducing the risk of exposure.

During removal activities, ERRS personnel accessed the 15 residential properties to conduct inventory of household items, to perform disposal of contaminated household items, to complete a detergent wash and water rinse of all affected areas, and to complete three applications of Sterilex® with a subsequent water rinse. After decontamination activities were completed, ERRS subcontractor personnel initiated restoration activities that included installation of new carpeting or linoleum flooring, repainting of interior walls, and varnishing or replacement of wood walls or paneling.

During removal activities, START personnel accessed the 15 residences to assist with inventory and disposal documentation, photodocumentation, and to collect final clearance wipe samples. Sampling design and wipe sampling activities conducted as part of the AAA Removal Action were conducted in accordance with the site-specific Removal Action SAP, which was approved by EPA [3].

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Clearance wipe sampling was conducted to document that an overall risk reduction had been achieved by reducing chlorpyrifos levels to below the EPA site-specific Removal Program AL of 0.006 µg/cm2. Sampling locations were based on previous characterization sample locations where analytical results exceeded the EPA site-specific Removal Program AL. If necessary, additional samples were collected at the OSC’s discretion from locations with lower but still elevated chlorpyrifos levels that were deemed to be high traffic areas or otherwise have a higher risk for exposure. Clearance sample locations were generally limited to one sample per room, but were subject to adjustment based on the above criteria. Property-specific EPA Removal Action activities are documented in the Individual Residential After Action Reports that are included as Appendices (see Appendices B through P). These Individual Residential After Action Reports were provided to the property owners for their official documentation records.

4.0 SUMMARY OF REMOVAL ACTION PROCESS

1. After characterization sampling at a residence was completed, the analytical data were reviewed to determine if an exceedance of the EPA site-specific Removal Program AL existed. If any sample location in common or living space exceeded the AL, then that residence was designated for a removal action. The extent of removal activities was determined by EPA based upon review of characterization sampling results.

2. Once removal access to the property was obtained from the property owner and tenant (if

applicable), relocation options were evaluated for the resident or residents. Community Involvement Coordinators (CICs) from EPA Community Involvement were engaged as the liaison, and the US Army Corps of Engineers (USACE) provided relocation assistance and compensation.

3. After the residence had been vacated, a complete inventory was conducted by ERRS personnel.

Monetary values for items to be disposed of were listed on a Disposition and Compensation Form. After an agreement was reached between EPA and the property owner and tenant (if applicable), both parties signed the Disposition and Compensation form, allowing removal activities to be initiated.

4. At the initiation of removal activities, all household items, furniture, possessions, and trash

were removed from the residence for storage and/or disposal. The decontamination process included a washing of walls, countertops, and appliances with a water/detergent mixture, followed by three applications of the Sterilex® decontamination solution, and was completed by a water rinse. Any carpets, underlying carpet pads, and floors were vacuumed before the carpets and/or pads were removed. Following decontamination activities, restoration activities included installation of new carpeting or flooring, repainting of interior walls, and varnishing or replacement of wood walls or paneling. Unique surfaces, such as varnished wood or paneling, were treated on a case-by-case basis; depending on the method of installation or extent of contamination, these materials were either replaced or sanded and stained/varnished. After a final walk-through upon completion of restoration, EPA and START conducted photodocumentation and clearance wipe sampling to demonstrate that a reduction in risk of chlorpyrifos exposure had been achieved. Sample locations were based on previous

7

characterization sample locations where analytical results had exceeded the EPA site-specific Removal Program AL of 0.006 µg/cm2. At the discretion of EPA, additional samples were collected from locations with lower but still elevated chlorpyrifos levels that were deemed to be high traffic areas or otherwise have a higher risk for exposure. The total clearance sample locations for each residence typically consisted of one sample per room.

5. After clearance sampling was completed, a walk-through of the residence was conducted with

the owner or tenant, EPA, START, and ERRS. Upon owner or tenant approval, ERRS personnel moved any stored items back into the residence, while START personnel verified the items on the previously signed inventory list. When all relocation activities were completed, a final cleanup letter was generated by EPA and sent to the residence owner and /or tenant.

5.0 ESTIMATED COST OF REMOVAL ACTION

EPA resources committed under this Removal Action are summarized below:

Cost Category Ceiling Costs Incurred Remainder

Regional Removal Allowance Costs

ERRS

$1,350,000 $1,006,00.00 $344,000.00

USACE IAG $550,000 $275,000 $275,000

START Contractor $611,655 $598,661 $12,994

Total Removal Project Costs $2,512,665 $1,879,661 $633,004 This accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.

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6.0 REFERENCES

1. United States Environmental Protection Agency, Office of Pesticide Programs. 2013. Human Health Risk Assessment of Vermont Chlorpyrifos Misuse Memorandum. August.

2. Weston Solutions, Region I, Superfund Technical Assessment & Response Team III. 2013.

United States Environmental Protection Agency, Region I Office of Site Remediation & Restoration, Emergency Planning & Response Branch. Sampling and Analysis Plan for the AAA Accredited Pesticides Site, Rutland, Vermont. September.


United States Environmental Protection Agency, Region I Office of Site Remediation & Restoration, Emergency Planning & Response Branch. Sampling and Analysis Plan for the AAA Accredited Pest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont. December.


Weston Solutions, Inc., Region I START Site Health and Safety Plan (HASP) for the AAA Accredited Pest Control Site, Rutland, Vermont. February.

Appendices

Appendix A

Figures

Figure 1 - Site Location Map Figure 2A - Phase 1 Removal Properties Location Map (Redacted)Figure 2B - Phase 2 Removal Properties Location Map (Redacted)

Figure 1

TO1-01-15-07-0042

B. Mahany20 February 2015B. Mahany20 February 2015

AAA Accredited Pest ControlRutland, Vermont

Site Location Map

EPA Region I Superfund Technical Assessment and

Response Team (START) IV Contract No. EP-S3-15-01

TDD Number:Created by:Created on:Modified by:Modified on:

Topos: USA Topo Maps, Copyright:© 2011 National Geographic Society, i-cubed

All other data: START

Data Sources:

E:\Vt_gis\AAA\MXD\Fig1_AAR.mxd

Site Location

0 1 20.5Miles

Appendix B

Removal Program After Action Report for Residential Property 1001-03 Rutland, Vermont

REMOVAL PROGRAM AFTER ACTION REPORT


RUTLAND, RUTLAND COUNTY, VERMONT

RESIDENTIAL PROPERTY 1001-03 RUTLAND, VERMONT

Prepared For:





TDD NO. TO1-01-15-07-0042

TASK NO. 0044

DC NO. R-00817

Submitted by:


Superfund Technical Assessment and Response Team IV (START) 101 Billerica Avenue, Building 5, Suite 103


June 2020

ii

TABLE OF CONTENTS

PAGE

LIST OF APPENDICES ................................................................................................................ iii

1.0 INTRODUCTION .............................................................................................................. 1

2.0 BACKGROUND ................................................................................................................ 1

3.0 SITE DESCRIPTION AND NARRATIVE CHRONOLOGY .......................................... 1

4.0 REFERENCES ................................................................................................................... 3

iii

LIST OF APPENDICES

Appendix A

Appendix B

Figures Figure 1 – Site Location Map (Redacted)Figure 2 – Characterization Sample Results Diagram Figure 3 – Clearance Sample Results Diagram

Tables Table 1 – Characterization Sampling Analytical Results Table 2 – Clearance Sampling Analytical Results

1

1.0 INTRODUCTION The Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START) was tasked under Technical Direction Document (TDD) Number (No.) 01-13-09-0007 to provide technical support to U.S. Environmental Protection Agency (EPA) Region I with conducting and documenting removal activities at the AAA Accredited Pest Control Site, located at various residential properties in the City of Rutland, Rutland County, Vermont (VT), and in surrounding communities. This report documents removal activities conducted under the referenced TDD, as well as preliminary assessment/site investigation (PA/SI) sampling activities conducted under TDD No. 01-13-08-0006.

2.0 BACKGROUND The AAA Accredited Pest Control Site (the site) includes residences in Rutland, Vermont (VT) and in surrounding communities where AAA Accredited Pest Control (AAA), a local exterminator, applied chlorpyrifos in indoor settings. In May 2013, VT AAFM began investigating AAA following a complaint that a pesticide application by AAA to address a bedbug infestation had sickened a family in the treated house. VT AAFM Field Agents initiated the investigation, which included interviewing the complainant, inspecting the property, collecting photographic evidence, sampling the complainant’s home, interviewing the pesticide applicator from AAA, inspecting AAA’s records and invoices, and sampling their spray formulations and application equipment. Observations and analytical results indicated the presence of chlorpyrifos, which has been restricted for all indoor uses since 2001. The investigation continued with a review of invoices from AAA, to prioritize treated properties requiring sampling. This review identified 10 additional properties deemed most at risk due to chlorpyrifos treatment for bedbugs and/or other insects. As a result, sampling was initiated at these 10 properties. During a conference call on 11 July 2013 (followed up by a letter dated 2 August 2013), the VT Agency of Agriculture, Food, and Markets (AAFM) and Department of Health (DOH) requested the assistance of EPA with cleanup of contaminated residences, sampling and analytical support, and community involvement support. On 12 September 2013, EPA and START began providing on-site assistance to VT state agencies, which included generating sample documentation for wipe samples collected by VT AAFM personnel; collecting wipe samples to confirm and characterize previous sampling results; conducting data management; performing outreach efforts; and conducting laboratory analysis. On 19 September 2013, an Action Memorandum was approved authorizing Removal Actions at up to 11 properties where analytical results indicated the presence of chlorpyrifos at levels above the EPA Site-Specific Action Level of 0.006 micrograms per square centimeter (µg/cm2). On 26 March 2014, an Addendum to the Action Memorandum was approved, authorizing Removal Actions at up to five additional properties.

3.0 SITE DESCRIPTION AND NARRATIVE CHRONOLOGY The property is a two-bedroom apartment located on the second floor of a residential apartment building in Rutland, VT (see Figure 1, Site Location Map).

2

The property was treated by AAA for bedbugs with one pesticide application. The date of application was 11 January 2013. On 18 July 2013, VT VAAFM conducted initial sampling for chlorpyrifos. Samples were analyzed at the VT State laboratory, and a maximum concentration of 0.0074 µg/cm2 was reported. This value exceeded the EPA AL of 0.006 µg/cm2. Therefore, further characterization sampling was conducted by EPA and START. On 20 September 2013, EPA and START conducted characterization sampling. A total of 14 characterization samples and one quality assurance/quality control (QA/QC) field blank sample was collected and sent to EPA’s Office of Environmental Measurement and Evaluation (OEME) New England Regional Laboratory (NERL) for analysis. The Sampling and Analysis Plan (SAP) documenting initial and characterization sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pesticides Site, Rutland, Vermont [1]. Twelve of the 14 field samples contained chlorpyrifos at concentrations exceeding the EPA AL, with a maximum detected concentration of 0.1 µg/cm2 (see Figure 2, Characterization Sample Results Diagram; and Table 1, Characterization Sampling Analytical Results). Due to the elevated levels of chlorpyrifos present, an EPA Removal Action was deemed to be warranted. The residential property was vacant prior to EPA’s arrival. Therefore, EPA, START, and EPA Emergency Rapid Response Services (ERRS) personnel tested various decontamination methods at the property, including conducting decontamination efficacy sampling on 11, 15, 22, and 23 October 2013. On 24 October 2013, EPA and ERRS began conducting test decontamination activities. All remaining household items and trash were removed from the apartment for disposal. Decontamination efforts included washing walls, countertops, appliances, and other surfaces with a water/detergent mixture; followed by six applications of the Sterilex® decontamination solution; and were completed with a water rinse. Any carpets, underlying carpet pads, and floors were vacuumed, and carpets/pads removed. Following decontamination, the owner decided to complete the clean-up on his own to allow a new tenant to move in on time; therefore, the EPA Removal Action ended prior to the completion of test cleanings. On 22 November 2013, VT AAFM conducted clearance sampling. Seven samples and one QA/QC field blank sample were collected and sent to the VT State laboratory for analysis. None of the seven field samples contained concentrations of chlorpyrifos exceeding the EPA AL (see Figure 3, Post-Cleaning Sample Results Diagram; and Table 2, Post-Cleaning Sampling Analytical Results). There was no personal property present in the apartment at the time of the EPA Removal Action. However, the personal property belonging to the tenant who was present in the residence during the pesticide application was stored in a storage locker ( Storage Locker ), which was included in the EPA Removal Action. On 3 December 2013, an inventory of all personal and household items in the associated storage locker was completed, and a Personal Property Disposition Agreement Form was signed by the previous property tenant.

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4.0 REFERENCES

1. Weston Solutions, Region I, Superfund Technical Assessment & Response Team III. United

States Environmental Protection Agency, Region I Office of Site Remediation & Restoration, Emergency Planning & Response Branch. Sampling and Analysis Plan for the AAA Accredited Pesticides Site, Rutland, Vermont. September 2013.

Appendix A

Figures

Figure 1 - Site Location Map (Redacted)Figure 2 - Characterization Sample Results Diagram

Figure 3 - Clearance Sample Results Diagram

Appendix B

Tables

Table 1 - Characterization Sampling Analytical Results Table 2 - Clearance Sampling Analytical Results

TABLE 1

CHARACTERIZATION SAMPLING ANALYTICAL RESULTSAAA ACCREDITED PEST CONTROL SITE

RESIDENTIAL PROPERTY 1001-03

RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1001-03_ CharacterizationTable.xlsx Page 1 of 1

Sample Number Sample Location Sample Description Date Sampled Chlorpyrifos (µg/cm²)

D32188 Kids Bedroom (Baseboard) Wall with Closet 9/20/2013 0.027D32189 Kids Bedroom (Closet Baseboard) Right wall of closet in kids room 9/20/2013 0.026D32190 Kids Bedroom (Wall) Upper wall 9/20/2013 0.047D32191 Living Room (Wall Middle) Middle of wall opposite entrance door 9/20/2013 0.046D32192 Living Room (Baseboard) Adjacent to kitchen entryway 9/20/2013 0.024D32193 Living Room (Wall) Adjacent to main entry door 9/20/2013 0.018D32194 Living Room (Upper Wall) Upper wall 9/20/2013 0.031D32195 Kitchen (Wall above Sink) Above kitchen sink 9/20/2013 0.047D32196 Kitchen (Floor) Adjacent to carpeted area 9/20/2013 0.005D32197 Bathroom (Wall Right of Sink) Adjacent to door 9/20/2013 0.024D32198 Bedroom (Wall) Above Vermont sample 9/20/2013 0.0067D32199 Bedroom (Window Sill) Low sill 9/20/2013 0.1D32200 Bedroom (Door) Inner side of closet door 9/20/2013 0.035D32201 Bedroom (Wall) Middle of wall 9/20/2013 0.0029D32202 Kitchen (Blank) Opened in kitchen 9/20/2013 ND (0.0004)

NOTES:

Samples analyzed by U.S. EPA Office of Environmental Measurement and Evaluation (OEME) Using EPA Region I SOP,EIASOP-LCMS$CPF.0, Chlorpyrifos in Wipes.All results in micrograms per square centimeter (µg/cm²).ND = Not Detected (reporting limit in parentheses). Bolded and light shaded results exceed the Vermont Department of Health Action Level of 0.0004 µg/cm2.Bolded and dark shaded results exceed the EPA Removal Program Action Level of 0.006 µg/cm2.

TABLE 2

CLEARANCE SAMPLING ANALYTICAL RESULTSAAA ACCREDITED PEST CONTROL SITE


RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1001-03_ _Clearance Table.xlsx Page 1 of 1


3499 Blank Field Blank 11/22/2013 ND (0.000239)4000 Bedroom #1 (North Wall) 3 Feet high, middle 11/22/2013 ND (0.000239)4001 Living Room (West Wall) 3 Feet high, middle 11/22/2013 0.0002494002 Kitchen (Wall) Behind sink 11/22/2013 ND (0.000239)4003 Kitchen (Floor) In front of stove and bathroom door 11/22/2013 0.0008324004 Living Room (Wall/Baseboard) Outside door, to left 11/22/2013 0.0003644005 Bedroom #2 (Wall/Window Frame) North wall, over heater 11/22/2013 0.0003214006 Bedroom #2 (Wall/Baseboard) Right side of bed 11/22/2013 0.000521

NOTES:


Appendix C





RESIDENTIAL PROPERTY 1001-04 , RUTLAND, VERMONT

Prepared For:





TDD NO. TO1-01-15-07-0042

TASK NO. 0044

DC NO. R-00818

Submitted by:




June 2020

ii

TABLE OF CONTENTS

PAGE


1.0 INTRODUCTION .............................................................................................................. 1

2.0 BACKGROUND ................................................................................................................ 1


4.0 REFERENCES ................................................................................................................... 4

iii

LIST OF APPENDICES

Appendix A

Appendix B



1

1.0 INTRODUCTION

The Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START) was tasked under Technical Direction Document (TDD) Number (No.) 01-13-09-0007 to provide technical support to U.S. Environmental Protection Agency (EPA) Region I with conducting and documenting removal activities at the AAA Accredited Pest Control Site, located at various residential properties in the City of Rutland, Rutland county, Vermont (VT), and in surrounding communities. This report documents removal activities conducted under the referenced TDD, as well as preliminary assessment/site (PA/SI) sampling activities conducted under TDD No. 01-13-08-0006.

2.0 BACKGROUND

The AAA Accredited Pest Control Site (the site) includes residences in Rutland, Vermont (VT) and in surrounding communities where AAA Accredited Pest Control (AAA), a local exterminator, applied chlorpyrifos in indoor settings.

In May 2013, VT AAFM began investigating AAA following a complaint that a pesticide application by AAA to address a bedbug infestation had sickened a family in the treated house. VT AAFM Field Agents initiated the investigation, which included interviewing the complainant, inspecting the property, collecting photographic evidence, sampling the complainant’s home, interviewing the pesticide applicator from AAA, inspecting AAA’s records and invoices, and sampling their spray formulations and application equipment. Observations and analytical results indicated the presence of chlorpyrifos, which has been restricted for all indoor uses since 2001. The investigation continued with a review of invoices from AAA, to prioritize treated properties requiring sampling. This review identified 10 additional properties deemed most at risk due to chlorpyrifos treatment for bedbugs and/or other insects. As a result, sampling was initiated at these 10 properties.

During a conference call on 11 July 2013 (followed up by a letter dated 2 August 2013), the VT Agency of Agriculture, Food, and Markets (AAFM) and Department of Health (DOH) requested the assistance of EPA with cleanup of contaminated residences, sampling and analytical support, and community involvement support. On 12 September 2013, EPA and START began providing on-site assistance to VT state agencies, which included generating sample documentation for wipe samples collected by VT AAFM personnel; collecting wipe samples to confirm and characterize previous sampling results; conducting data management; performing outreach efforts; and conducting laboratory analysis. On 19 September 2013, an Action Memorandum was approved authorizing Removal Actions at up to 11 properties where analytical results indicated the presence of chlorpyrifos at levels above the EPA Site-Specific Action Level of 0.006 micrograms per square centimeter (µg/cm2). On 26 March 2014, an Addendum to the Action Memorandum was approved, authorizing Removal Actions at up to five additional properties.

3.0 SITE DESCRIPTION AND NARRATIVE CHRONOLOGY

The property is a one-bedroom apartment located on the second floor of a residential apartment building in Rutland, VT (see Figure 1, Site Location Map).

2

The property was treated by AAA for bedbugs with one pesticide application. The date of application was 11 January 2013.

On 27 June 2013, VT AAFM conducted initial sampling for chlorpyrifos. Samples were analyzed at the VT State laboratory, and a maximum concentration of 0.013 µg/cm2 was reported. This value exceeded the EPA AL of 0.006 µg/cm2. Therefore, further characterization sampling was conducted by EPA and START.

On 20 September 2013, EPA and START conducted characterization sampling. A total of 15 characterization samples and one quality assurance/quality control (QA/QC) field blank sample were collected and sent to EPA’s Office of Environmental Measurement and Evaluation (OEME) New England Regional Laboratory (NERL) for analysis. The Sampling and Analysis Plan (SAP) documenting initial and characterization sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pesticides Site, Rutland, Vermont [1].

Ten of the 15 field samples contained chlorpyrifos at concentrations exceeding the EPA AL, with a maximum detected concentration of 0.051 µg/cm2 (see Figure 2, Characterization Sample Results Diagram; and Table 1, Characterization Sampling Analytical Results). Due to the high levels of chlorpyrifos present, an EPA Removal Action was deemed to be warranted.

On 21 November 2013, EPA and START conducted additional characterization sampling inside the kitchen cupboards. A total of three characterization samples and one QA/QC field blank sample were collected and sent to OEME/NERL for analysis. None of the three field samples contained chlorpyrifos at concentrations exceeding the EPA AL. In addition, an inventory of all personal and household items in the apartment was completed, and a Personal Property Disposition Agreement Form was signed by the tenant.

On 9 December 2013, EPA and the Emergency Rapid Response Services (ERRS) contractor initiated decontamination activities. All household items, furniture, possessions, and trash were removed from the apartment for storage and/or disposal. Decontamination efforts included washing walls, countertops, appliances, and other surfaces with a water/detergent mixture; followed by three applications of the Sterilex® decontamination solution; and were completed with a water rinse. Any carpets, underlying carpet pads, and floors were vacuumed, and the carpets/pads removed. Following decontamination, restoration activities included installation of new carpeting and repainting of interior walls.

On 19 December 2013, EPA and START conducted additional characterization sampling on the ceiling. A total of three characterization samples and one QA/QC field blank sample were collected and sent to OEME/NERL for analysis. None of the three field samples contained chlorpyrifos at concentrations exceeding the EPA AL.

On 6 February 2014, EPA and START conducted clearance sampling. A total of four clearance samples and one QA/QC field blank sample were collected and sent to OEME/NERL for analysis. None of the four field samples contained concentrations of chlorpyrifos exceeding the EPA AL (see Figure 3, Clearance Sample Results Diagram; and Table 2, Clearance Sampling Analytical Results).

3

The SAP documenting clearance sampling was prepared as a separate document, entitled AAA Accredited Pest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont [2].

4

4.0 REFERENCES

1. Weston Solutions, Region I, Superfund Technical Assessment & Response Team III. UnitedStates Environmental Protection Agency, Region I Office of Site Remediation & Restoration,Emergency Planning & Response Branch. Sampling and Analysis Plan for the AAA AccreditedPesticides Site, Rutland, Vermont. September 2013.

2. Weston Solutions, Region I, Superfund Technical Assessment & Response Team III. UnitedStates Environmental Protection Agency, Region I Office of Site Remediation & Restoration,Emergency Planning & Response Branch. Sampling and Analysis Plan for the AAA AccreditedPest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont.December 2013.

Appendix A

Figures



Appendix B

Tables


TABLE 1



RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1001-04_ _CharacterizationTable1.xlsx Page 1 of 1


D32203 Bedroom (Wall) Middle of wall near window. 9/20/2013 0.049D32204 Bedroom (Wall) Middle of wall near door. 9/20/2013 0.019D32205 Bedroom (Bureau Shelf) Middle of shelf next to belongings. 9/20/2013 0.051D32206 Bedroom (Wall) Upper wall. 9/20/2013 0.044D32207 Kitchen (Kickboard) Under counter on kickboard. 9/20/2013 0.0091D32208 Kitchen (Stove) Top of stove in the middle of the four burners. 9/20/2013 0.00082D32209 Kitchen (Refrigerator) Lower fourth of refrigerator. 9/20/2013 NDD32210 Kitchen (Wall) Upper wall left of counter. 9/20/2013 0.03D32211 Hallway (Carpet) Middle of pathway. 9/20/2013 0.00074D32212 Bathroom (Wall) Right of sink, lower portion of wall. 9/20/2013 0.025D32213 Living Room (Mattress) Label of the mattress. 9/20/2013 NDD32214 Living Room (Radiator) Shield of radiator. 9/20/2013 0.0023D32215 Living Room (Wall) Middle of wall. 9/20/2013 0.018D32216 Living Room (Wall) Upper wall above mattress. 9/20/2013 0.012D32217 Living Room (Baseboard) Near main entrance of apartment. 9/20/2013 0.0096D32218 Field Blank Opened in the living room. 9/20/2013 NDD32620 Field Blank Opened in the kitchen. 11/21/2013 NDD32621 Kitchen (Shelf) Cupboard above stove. 11/21/2013 0.0013D32622 Kitchen (Shelf) Cabinet below sink. 11/21/2013 0.00058D32623 Kitchen (Shelf) Cabinet below cutting board. 11/21/2013 0.0011D32732 Field Blank Opened in the living room. 12/19/2013 NDD32733 Bathroom (Ceiling) Above sink. 12/19/2013 NDD32734 Hallway (Ceiling) Bathroom side of light. 12/19/2013 0.0016D32735 Kitchen (Ceiling) Hallway side of light, included metal. 12/19/2013 0.0017

NOTES:

Bolded and light shaded results exceed the Vermont Department of Health Action Level of 0.0004 µg/cm2.

Samples analyzed by U.S. EPA Office of Environmental Measurement and Evaluation (OEME) Using EPA Region I SOP, EIASOP-LCMS$CPF.0, Chlorpyrifos in Wipes.All results in micrograms per square centimeter (µg/cm²).ND = Not Detected (reporting limit in parentheses).

Bolded and dark shaded results exceed the EPA Removal Program Action Level of 0.006 µg/cm2.

TABLE 2



RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1001-04_ ClearanceTable2.xlsx Page 1 of 1

Sample Number Sample Location Sample Description Date SampledChlorpyrifos

(µg/cm²)D32854 Field Blank Opened in Kitchen. 2/6/2014 ND (0.0004)D32855 Living Room (Wall) Above electrical outlet, chest-high. 2/6/2014 ND (0.0004)D32856 Living Room (Wall) 2 feet from corner behind TV, chest-high. 2/6/2014 ND (0.0004)D32857 Bedroom (Wall) Left of wire hanging from outlet box, waist-high. 2/6/2014 ND (0.0004)D32858 Bedroom (Wall) Left of window, chest-high. 2/6/2014 ND (0.0004)

NOTES:


Samples analyzed by U.S. EPA Office of Environmental Measurement and Evaluation (OEME) Using EPA Region I SOP,EIASOP-LCMS$CPF.0, Chlorpyrifos in Wipes.All results in micrograms per square centimeter (µg/cm²).ND = Not Detected (reporting limit in parentheses).


Appendix D






Prepared For:





TDD NO. TO1-01-15-07-0042

TASK NO. 0044

DC NO. R-00819

Submitted by:




June 2020

ii

TABLE OF CONTENTS PAGE LIST OF APPENDICES ................................................................................................................ iii 1.0 INTRODUCTION .............................................................................................................. 1 2.0 BACKGROUND ................................................................................................................... 1 3.0 SITE DESCRIPTION AND NARRATIVE CHRONOLOGY ......................................... 1 4.0 REFERENCES ................................................................................................................... 3

iii

LIST OF APPENDICES

Appendix A

Appendix B



1


2.0 BACKGROUND The AAA Accredited Pest Control Site (the site) includes residences in Rutland, Vermont (VT) and in surrounding communities where AAA Accredited Pest Control (AAA), a local exterminator, applied chlorpyrifos in indoor settings.



3.0 SITE DESCRIPTION AND NARRATIVE CHRONOLOGY The property is a three-bedroom apartment located on the third floor of a residential apartment building in Rutland, VT (see Figure 1, Site Location Map). The property was treated by AAA for bedbugs with three pesticide applications. The dates of application were 1 September 2012, 5 December 2012, and 16 February 2013.

2

On 2 August 2013, VT AAFM conducted initial sampling for chlorpyrifos. Samples were analyzed at the VT State laboratory, and a maximum concentration of 0.0091 µg/cm2 was reported. This value exceeded the EPA AL of 0.006 µg/cm2. Therefore, further characterization sampling was conducted by EPA and START. On 16 September 2013, EPA and START conducted characterization sampling. A total of 11 characterization samples and one quality assurance/quality control (QA/QC) field blank sample were collected and sent to EPA’s Office of Environmental Measurement and Evaluation (OEME) New England Regional Laboratory (NERL) for analysis. The Sampling and Analysis Plan (SAP) documenting initial and characterization sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pesticides Site, Rutland, Vermont [1]. Eight of the 11 field samples contained chlorpyrifos at concentrations exceeding the EPA AL, with a maximum detected concentration of 0.2 µg/cm2 (see Figure 2, Characterization Sample Results Diagram; and Table 1, Characterization Sampling Analytical Results). Due to the elevated levels of chlorpyrifos present, an EPA Removal Action was deemed to be warranted. EPA, START, and EPA Emergency Rapid Response Services (ERRS) personnel tested various decontamination methods at the property, including conducting decontamination efficacy sampling on 4, 7, 9, 18, and 21 October 2013. On 13 November 2013, an inventory of all personal and household items in the apartment was completed, and a Personal Property Disposition Agreement Form was signed by the property owner and tenant. On 3 December 2013, EPA and ERRS began conducting decontamination activities. All household items, furniture, possessions, and trash were removed from the apartment for storage and/or disposal. Decontamination efforts included washing walls, countertops, appliances, and other surfaces with a water/detergent mixture; followed by three applications of the Sterilex® decontamination solution; and were completed with a water rinse. Any carpets, underlying carpet pads, and floors were vacuumed, and the carpets/pads removed. Following decontamination, restoration activities included installation of new carpeting and repainting of interior walls. On 20 December 2013, EPA and START conducted clearance sampling. Twelve clearance samples and one QA/QC field blank sample were collected and sent to EPA’s OEME/NERL for analysis. None of the 12 field samples contained concentrations of chlorpyrifos exceeding the EPA AL (see Figure 3, Clearance Sample Results Diagram; and Table 2, Clearance Sampling Analytical Results). The SAP documenting clearance sampling was prepared as a separate document, entitled AAA Accredited Pest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont [2].

3

4.0 REFERENCES




States Environmental Protection Agency, Region I Office of Site Remediation & Restoration, Emergency Planning & Response Branch. Sampling and Analysis Plan for the AAA Accredited Pest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont. December 2013.

Appendix A

Figures



Appendix B

Tables


TABLE 1



RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1023-01_ _Characterization_Table1.xlsx Page 1 of 1


D32030 Living Room (Wall/Baseboard) West wall behind futon 9/16/2013 0.2D32031 Bedroom 1 (Wall/Baseboard) Behind door 9/16/2013 0.031D32032 Bedroom 1 (Wall/Baseboard) Underneath window 9/16/2013 0.048D32033 Kitchen (Floor) Linoleum left of sink 9/16/2013 0.0025D32034 Kitchen (Wall/Baseboard) East wall by back door 9/16/2013 ND (0.0004)D32035 Bedroom 2 (Wall/Baseboard) East wall, right corner 9/16/2013 0.021D32036 Bedroom 3 (Wall/Baseboard) Behind door 9/16/2013 0.014D32037 Bedroom 3 (Wall/Baseboard) Right of north window 9/16/2013 0.0061D32038 Bathroom (Wall/Baseboard) Top right of window 9/16/2013 0.044D32039 Field Blank Opened in living room 9/16/2013 ND (0.0004)D32040 Bedroom 2 (Wall) 3 feet above sample D32035 9/16/2013 0.0071D32041 Kitchen (Wall) 3 feet above sample D32034 9/16/2013 0.0058

NOTES:




TABLE 2



RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1023-01_ Clearance.xlsx Page 1 of 1


D32737 Field Blank Opened in kitchen 12/20/2013 ND (0.0004)D32738 Living Room (Wall) Below thermostat 12/20/2013 ND (0.0004)D32739 Living Room (Wall) Above outlet 12/20/2013 ND (0.0004)D32740 Bedroom #1 (Wall) Near window 12/20/2013 0.00047D32741 Bedroom #1 (Wall) Near light switch 12/20/2013 ND (0.0004)D32742 Kitchen (Floor) In front of sink 12/20/2013 0.00072D32743 Kitchen (Wall) Right of thermostat 12/20/2013 ND (0.0004)D32744 Bathroom (Floor) Between window and towel rack 12/20/2013 ND (0.0020)D32745 Bathroom (Wall) Above toilet 12/20/2013 ND (0.0004)D32746 Bedroom #2 (Wall) Right of window 12/20/2013 ND (0.0004)D32747 Bedroom #2 (Wall) Above switch 12/20/2013 ND (0.0004)D32748 Bedroom #3 (Wall and window frame) Right of window 12/20/2013 ND (0.0004)D32749 Bedroom #3 (Wall) Above outlet 12/20/2013 0.0024

NOTES:




Appendix E






Prepared For:





TDD NO. TO1-01-15-07-0042

TASK NO. 0044

DC NO. R-00820

Submitted by:




June 2020

ii

TABLE OF CONTENTS

PAGE


1.0 INTRODUCTION .............................................................................................................. 1

2.0 BACKGROUND ................................................................................................................ 1


4.0 REFERENCES ................................................................................................................... 3

iii

LIST OF APPENDICES

Appendix A

Appendix B



1

1.0 INTRODUCTION

The Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START) was tasked under Technical Direction Document (TDD) Number (No.) 01-13-09-0007 to provide technical support to U.S. Environmental Protection Agency (EPA) Region I with conducting and documenting removal activities at the AAA Accredited Pest Control Site, located at various residential properties in the City of Rutland, Rutland County, Vermont (VT), and in surrounding communities. This report documents removal activities conducted under the referenced TDD, as well as preliminary assessment/site investigation (PA/SI) sampling activities conducted under TDD No. 01-13-08-0006.

2.0 BACKGROUND





The property is a one-bedroom apartment located on the first floor of a residential apartment building on in Rutland, VT (see Figure 1, Site Location Map). The

2

property was treated by AAA for bedbugs with two pesticide applications. The dates of application were December 2011 and February 2012.

On 19 July 2013, VT AAFM conducted initial sampling for chlorpyrifos. Samples were analyzed at the VT State laboratory, and a maximum concentration of 0.09 µg/cm2 was reported. This value exceeded the EPA AL of 0.006 µg/cm2. Therefore, further characterization sampling was conducted by EPA and START.

On 3 October, 21 November 2013, and 7 January 2014, EPA and START conducted characterization sampling. A total of 24 characterization samples and three quality assurance/quality control (QA/QC) field blank samples were collected and sent to EPA’s Office of Environmental Measurement and Evaluation (OEME) New England Regional Laboratory (NERL) for analysis. The Sampling and Analysis Plan (SAP) documenting initial and characterization sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pesticides Site, Rutland, Vermont [1].

Six of the 24 field samples contained chlorpyrifos at concentrations exceeding the EPA AL, with a maximum detected concentration of 0.0954 µg/cm2 (see Figure 2, Characterization Sample Results Diagram; and Table 1, Characterization Sampling Analytical Results). Due to the high levels of chlorpyrifos present, an EPA Removal Action was deemed to be warranted.

EPA, START, and EPA Emergency Rapid Response Services (ERRS) personnel tested various decontamination methods at the property, including conducting decontamination efficacy sampling on 12 December 2013.

On 12 December 2013, an inventory of all personal and household items in the apartment was completed, and a Personal Property Disposition Agreement Form was signed by the tenant.

On 24 January 2014, EPA and ERRS began conducting decontamination activities. All household items, furniture, possessions, and trash were removed from the apartment for storage and/or disposal. Decontamination efforts included washing walls, countertops, appliances, and other surfaces with a water/detergent mixture; followed by three applications of the Sterilex® decontamination solution; and were completed with a water rinse. Any carpets, underlying carpet pads, and floors were vacuumed, and carpets/pads removed. Following decontamination, restoration activities included installation of new carpeting and repainting of interior walls.

On 19 February 2014, EPA and START conducted clearance sampling. Four clearance samples and one QA/QC field blank sample were collected and sent to EPA’s OEME/NERL for analysis. None of the four field samples contained concentrations of chlorpyrifos exceeding the EPA AL (see Figure 3, Clearance Sample Results Diagram; and Table 2, Clearance Sampling Analytical Results). The SAP documenting clearance sampling was prepared as a separate document, entitled AAA Accredited Pest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont [2].

3

4.0 REFERENCES



Appendix A

Figures



Appendix B

Tables


TABLE 1



RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1009-01_ Tables\1009-01_Characterization.xls Page 1 of 1


D32073 Field Blank Opened in living room 10/3/2013 ND (0.0004)D32074 Living Room (Lower Wall) Behind futon 10/3/2013 0.0308D32075 Living Room (Futon) On futon 10/3/2013 0.00102D32076 Living Room (Upper Wall) Behind futon 10/3/2013 0.00427D32077 Living Room (Baseboard and wall) Near heating vent 10/3/2013 0.00766D32078 Bedroom (Lower wall) Above heater 10/3/2013 0.00449D32079 Bedroom (Lower wall) Below electrical outlet 10/3/2013 0.0954D32080 Bedroom (Baseboard and wall) By door 10/3/2013 0.041D32081 Kitchen (Kickboard) Below sink 10/3/2013 0.000304D32082 Kitchen (Baseboard and wall) Behind table and chair 10/3/2013 0.0174D32083 Kitchen (Refrigerator) Side of refrigerator 10/3/2013 0.0016D32084 Bathroom (Wall) Between sink and mirror 10/3/2013 0.00375D32085 Bathroom (Wall ) Below light switch 10/3/2013 0.00939D32624 Field Blank Opened in kitchen 11/21/2013 ND (0.0004)D32625 Kitchen (Middle shelf) Above and right of stove 11/21/2013 ND (0.0004)D32626 Kitchen (Bottom shelf) Below and left of stove 11/21/2013 ND (0.0004)D32627 Kitchen (Inside door) Below sink 11/21/2013 ND (0.0004)D32628 Bedroom (Drawer Bottom) Inside toolbox 11/21/2013 ND (0.0004)D32629 Bedroom (Drawer Bottom) Inside Brown Dresser 11/21/2013 ND (0.0004)D32630 Bedroom Closet ( Wall) Left near ceiling 11/21/2013 0.005D32631 Bedroom Closet (Wall) Right near floor 11/21/2013 0.0016D32632 Living Room Closet (Wall) Right in middle of wall 11/21/2013 0.00086D32633 Bathroom (Bottom Shelf) Cabinet under sink 11/21/2013 ND (0.0004)D32761 Kitchen (Ceiling Tile) In center of room 1/7/2014 0.0025D32762 Living Room (Ceiling Tile) In center of room 1/7/2014 0.00089D32763 Bedroom (Ceiling Tile) In center of room 1/7/2014 0.0019D32764 Field Blank Opened in kitchen 1/7/2014 ND (0.0004)

NOTES:


TABLE 2



RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1009-01_ Tables\1009-01_Clearance.xls Page 1 of 1


D32859 Kitchen (Wall and baseboard) Middle part of painted north wall and baseboard 2/19/2014 ND (0.0004)D32860 Bedroom (Wall) Approximately 3 feet to the right of outlet on painted north wall 2/19/2014 ND (0.0004)D32861 Bathroom (Wall) Below light switch, painted wall 2/19/2014 ND (0.0004)D32862 Living Room (Wall) Approximately 2 feet to the right of outlet on painted west wall 2/19/2014 ND (0.0004)D32863 Field Blank Opened in kitchen 2/19/2014 ND (0.0004)

NOTES:


Appendix F






Prepared For:





TDD NO. TO1-01-15-07-0042

TASK NO. 0044

DC NO. R-00821

Submitted by:




June 2020

ii

TABLE OF CONTENTS

PAGE


1.0 INTRODUCTION .............................................................................................................. 1

2.0 BACKGROUND ................................................................................................................... 1

2.0 SITE DESCRIPTION AND NARRATIVE CHRONOLOGY ......................................... 1

3.0 REFERENCES ................................................................................................................... 3

iii

LIST OF APPENDICES

Appendix A

Appendix B



1

1.0 INTRODUCTION


2.0 BACKGROUND





The property is a two-bedroom apartment located on the first floor of a residential apartment building in Rutland, VT (see Figure 1, Site Location Map). The property was treated by AAA for bedbugs with two pesticide applications. The dates of application were December 2011 and February 2012.

2

On 19 July 2013, VT AAFM conducted initial sampling for chlorpyrifos. Samples were analyzed at the VT State laboratory, and a maximum concentration of 0.0074 µg/cm2 was reported. This value exceeded the EPA AL of 0.006 µg/cm2. Therefore, further characterization sampling was conducted by EPA and START.

On 8 October 2013, 18 November 2013, and 19 February 2014, EPA and START conducted characterization sampling. A total of 20 characterization samples and three quality assurance/quality control (QA/QC) field blank samples were collected and sent to EPA’s Office of Environmental Measurement and Evaluation (OEME) New England Regional Laboratory (NERL) for analysis. The Sampling and Analysis Plan (SAP) documenting initial and characterization sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pesticides Site, Rutland, Vermont [1].

Two of the 20 field samples contained chlorpyrifos at concentrations exceeding the EPA AL, with a maximum detected concentration of 0.0108 µg/cm2 (see Figure 2, Characterization Sample Results Diagram; and Table 1, Characterization Sampling Analytical Results). Due to the elevated levels of chlorpyrifos present, an EPA Removal Action was deemed to be warranted.

On 4 March 2014, an inventory of all personal and household items in the apartment was completed, and a Personal Property Disposition Agreement Form was signed by the tenant.

On 10 March 2014, EPA and ERRS conducted decontamination activities. All household items, furniture, possessions, and trash were removed from the apartment for storage and/or disposal. Decontamination efforts included washing walls, countertops, appliances, and other surfaces with a water/detergent mixture; followed by three applications of the Sterilex® decontamination solution; and were completed with a water rinse. Any carpets, underlying carpet pads, and floors were vacuumed, and carpets/pads and ceiling tiles removed. Following decontamination, restoration activities included installation of new carpeting and repainting of interior walls.

On 28 March 2014, EPA and START conducted clearance sampling. Four clearance samples and one QA/QC field blank sample were collected and sent to EPA’s OEME/NERL for analysis. None of the four field samples contained concentrations of chlorpyrifos exceeding the EPA AL (see Figure 3, Clearance Sample Results Diagram; and Table 2, Clearance Sampling Analytical Results). The SAP documenting clearance sampling was prepared as a separate document, entitled AAA Accredited Pest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont [2].

3

4.0 REFERENCES



Appendix A

Figures



Appendix B

Tables

Table 1 - Characterization Sampling Analytical Results Table 2 - Clearance Sampling Analytical Result

TABLE 1



RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1009-02_ _CharResultsTable.xls Page 1 of 1


D32240 Kitchen (Kickboard) Middle of counter 10/8/2013 ND (0.0004)D32241 Kitchen (Wall) Left of fridge 10/8/2013 0.00156D32242 Kitchen (Wall) Above cat dish 10/8/2013 0.0108D32243 Living Room (Wall) Behind couch 10/8/2013 0.000516D32244 Living Room (Wall) Left of TV 10/8/2013 0.00062D32245 Bedroom (Wall) Right of shelves 10/8/2013 0.00064D32246 Bedroom (Wall) Right of closet 10/8/2013 0.00208D32247 Bedroom (Wall) Behind door 10/8/2013 0.00147D32248 Bathroom (Wall) Left of toilet 10/8/2013 0.00042D32249 Bathroom (Wall) Between shelves 10/8/2013 0.000824D32250 Living Room (Wall) Behind chair 10/8/2013 0.000724D32251 Bedroom (Wall) Upper wall 10/8/2013 0.00109D32252 Kitchen (Wall) Upper wall 10/8/2013 0.00121D32253 Field Blank --- 10/8/2013 ND (0.0004)D32602 Field Blank Kitchen 11/18/2013 ND (0.0004)D32603 Kitchen (Kickboard) Stove front 11/18/2013 ND (0.0004)D32604 Kitchen (Wall) Adjacent to stove, top half 11/18/2013 0.0044D32605 Kitchen (South Wall) Above D32242, above divider 11/18/2013 0.0098D32606 Kitchen (West Wall) Opposite stove, below window 11/18/2013 0.00033D32607 Kitchen (Floor) Adjacent to table 11/18/2013 ND (0.0004)D32864 Kitchen (Cabinet) Right cabinet above sink, inside, top of cabinet 2/19/2014 ND (0.0004)D32865 Kitchen (Sink) Below sink, second cabinet to left of oven, inside, left wall 2/19/2014 ND (0.0004)D32866 Field Blank Kitchen 2/19/2014 ND (0.0004)

NOTES:


TABLE 2



RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1009-02_ _ClearanceResultsTable.xlsx Page 1 of 1


D32826 Field Blank --- 3/28/2014 ND (0.0004)D32827 Kitchen (Wall) Adjacent to D32242, cat dish area 3/28/2014 ND (0.0004)D32828 Bedroom (Wall) Adjacent to D32246, right of closet 3/28/2014 ND (0.0004)D32829 Bathroom (Wall) Adjacent to D32249, between shelves 3/28/2014 ND (0.0004)D32830 Living Room (Wall) Adjacent to D32250, behind chair 3/28/2014 ND (0.0004)

NOTES:


Appendix G

Removal Program After Action Report for Residential Property 1009-03 , Rutland, Vermont





Prepared For:





TDD NO. TO1-01-15-07-0042

TASK NO. 0044

DC NO. R-00822

Submitted by:




June 2020

ii

TABLE OF CONTENTS

PAGE


1.0 INTRODUCTION .............................................................................................................. 1

2.0 BACKGROUND ................................................................................................................... 1


3.0 REFERENCES ................................................................................................................... 3

iii

LIST OF APPENDICES

Appendix A

Appendix B



1

1.0 INTRODUCTION


2.0 BACKGROUND





The property is a two-bedroom apartment located on the second floor of a residential apartment building in Rutland, VT (see Figure 1, Site Location Map).

2

The property was treated by AAA for bedbugs with two pesticide applications. The dates of application were December 2011 and February 2012.

On 29 July and 9 August 2013, VT AAFM conducted initial sampling for chlorpyrifos. Samples were analyzed at the VT State laboratory, and a maximum concentration of 0.11 µg/cm2 was reported. This value exceeded the EPA AL of 0.006 µg/cm2. Therefore, further characterization sampling was conducted by EPA and START.

On 8 October 2013 and 7 January 2014, EPA and START conducted characterization sampling. A total of 25 characterization samples and two quality assurance/quality control (QA/QC) field blank samples were collected and sent to EPA’s Office of Environmental Measurement and Evaluation (OEME) New England Regional Laboratory (NERL) for analysis. The Sampling and Analysis Plan (SAP) documenting initial and characterization sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pesticides Site, Rutland, Vermont [1].

Eighteen of the 25 field samples contained chlorpyrifos at concentrations exceeding the EPA AL, with a maximum detected concentration of 0.121 µg/cm2 (see Figure 2, Characterization Sample Results Diagram; and Table 1, Characterization Sampling Analytical Results). Due to the elevated levels of chlorpyrifos present, an EPA Removal Action was deemed to be warranted.

On 12 December 2013, EPA, START, and EPA Emergency Rapid Response Services (ERRS) personnel tested various decontamination methods at the property, including conducting decontamination efficacy sampling. In addition, an inventory of all personal and household items in the apartment was completed, and a Personal Property Disposition Agreement Form was signed by the tenant.

On 24 January 2014, EPA and ERRS initiated decontamination activities. All household items, furniture, possessions, and trash were removed from the apartment for storage and/or disposal. Decontamination efforts included washing walls, countertops, appliances, and other surfaces with a water/detergent mixture; followed by three applications of the Sterilex decontamination solution; and were completed with a water rinse. Any carpets, underlying carpet pads, and floors were vacuumed, and carpets/pads and ceiling tiles removed. Following decontamination, restoration activities included installation of new carpeting and repainting of interior walls.

On 10 March 2014, EPA and START conducted clearance sampling. Five clearance samples and one QA/QC field blank sample were collected and sent to EPA’s OEME/NERL for analysis. None of the five field samples contained concentrations of chlorpyrifos exceeding the EPA AL (see Figure 3, Clearance Sample Results Diagram; and Table 2, Clearance Sampling Analytical Results). The SAP documenting clearance sampling was prepared as a separate document, entitled AAA Accredited Pest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont [2].

3

4.0 REFERENCES



Appendix A

Figures



Appendix B

Tables

Table 1 - Characterization Sampling Analytical Results Table 2 - Clearance Sampling Analytical Result

TABLE 1



RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1009-03_ CharResults Table.xls Page 1 of 1


D32254 Bedroom (Floor) Outside bedroom door, on linoleum 10/8/2013 0.0134D32255 Kitchen (Kickboard) Under sink 10/8/2013 0.0299D32256 Kitchen (Wall) Below window 10/8/2013 0.0263D32257 Kitchen (Wall) Above dogfood dish, next to shelves, upper wall 10/8/2013 0.0168D32258 Kitchen (Wall) Left of VT sample 10/8/2013 0.0402D32259 Living Room (Wall) Left of Couch under window 10/8/2013 0.121D32260 Living Room (Wall) Left of TV 10/8/2013 0.109D32261 Living Room (Wall) Behind chair 10/8/2013 0.0303D32262 Living Room (Wall) Right of main door 10/8/2013 0.0355D32263 Bedroom (Wall) Right of Closet 10/8/2013 0.0377D32264 Bedroom (Wall) Behind bed, left of closet 10/8/2013 0.0294D32265 Bedroom (Wall) Upper wall between windows 10/8/2013 0.0175D32266 Bedroom (Wall) Behind door, left of couch 10/8/2013 0.0267D32267 Bathroom (Wall) Behind door 10/8/2013 0.0163D32268 Bathroom (Wall) Above sink 10/8/2013 0.00787D32269 Field Blank Opened in the kitchen 10/8/2013 ND (0.0004)D32750 Kitchen (Ceiling tile) Above dining room table 1/7/2014 0.013D32751 Child's Bedroom (Ceiling tile) Center of room by side of bed 1/7/2014 0.0021D32752 Living Room (Ceiling tile) At edge of coffee table 1/7/2014 0.0028D32753 Kitchen (Inside cabinet) Middle row of shelving 1/7/2014 ND (0.0004)D32754 Kitchen (Inside cabinet) Below sink on left side of cabinet 1/7/2014 ND (0.0004)D32755 Kitchen (Inside cabinet) Above stove on right side of cabinet 1/7/2014 ND (0.0004)D32756 Child's Bedroom (Inside closet) On back wall of closet 1/7/2014 0.0055D32757 Living Room (Inside game closet) Wall on right side between shelves 1/7/2014 0.0093D32758 Bedroom (Inside closet) On the back wall of closet 1/7/2014 0.0084D32759 Bedroom (Ceiling tile) Back of room on older style tiles 1/7/2014 0.0019D32760 Field Blank Opened in the kitchen 1/7/2014 ND (0.0004)

NOTES:


TABLE 2



RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1009-03_ ClearanceResults Table.xlsx Page 1 of 1


D32820 Field Blank Opened in the kitchen 3/10/2014 ND (0.0004)D32821 Child's Bedroom (Back Wall) Inside closet 3/10/2014 ND (0.0004)D32822 Bathroom (Wall) Above Sink 3/10/2014 ND (0.0004)D32823 Bedroom (Wall) Right of Closet 3/10/2014 ND (0.0004)D32824 Living Room (Inside game closet) Wall on right side between shelves 3/10/2014 ND (0.0004)D32825 Kitchen (Kickboard) Below sink 3/10/2014 ND (0.0004)

NOTES:


Appendix H






Prepared For:





TDD NO. TO1-01-15-07-0042

TASK NO. 0044

DC NO. R-00823

Submitted by:




June 2020

ii

TABLE OF CONTENTS

PAGE


1.0 INTRODUCTION .............................................................................................................. 1

2.0 BACKGROUND ................................................................................................................ 1


4.0 REFERENCES ................................................................................................................... 3

iii

LIST OF APPENDICES

Appendix A

Appendix B



1

1.0 INTRODUCTION


2.0 BACKGROUND





The property is a two-bedroom ranch home located in Rutland, VT (see Figure 1, Site Location Map). The property was treated by AAA for bedbugs with two pesticide applications. The dates of application were 15 June 2012 and 15 January 2013.

2

On 25 June 2013, VT AAFM conducted initial sampling for chlorpyrifos. Samples were analyzed at the VT State laboratory, and a maximum concentration of 0.012 µg/cm2 was reported. This value exceeded the EPA AL of 0.006 µg/cm2. Therefore, further characterization sampling was conducted by EPA and START.

On 2 October and 22 November 2013, EPA and START conducted characterization sampling. A total of 18 characterization samples and two quality assurance/quality control (QA/QC) field blank samples were collected and sent to EPA’s Office of Environmental Measurement and Evaluation (OEME) New England Regional Laboratory (NERL) for analysis. The Sampling and Analysis Plan (SAP) documenting initial and characterization sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pesticides Site, Rutland, Vermont [1].

Five of the 20 field samples contained chlorpyrifos at concentrations exceeding the EPA AL, with a maximum detected concentration of 0.141 µg/cm2 (see Figure 2, Characterization Sample Results Diagram; and Table 1, Characterization Sampling Analytical Results). Due to the elevated levels of chlorpyrifos present, an EPA Removal Action was deemed to be warranted.

On 16 October 2013, an inventory of all personal and household items in the apartment was completed, and a Personal Property Disposition Agreement Form was signed by the tenant. On 15 January 2014, EPA and ERRS began conducting decontamination activities. All household items, furniture, possessions, and trash were removed from the apartment for storage and/or disposal. Decontamination efforts included washing walls, countertops, appliances, and other surfaces with a water/detergent mixture, followed by three applications of the Sterilex® decontamination solution, and were completed with a water rinse. Any carpets, underlying carpet pads, and floors were vacuumed, and the carpets/pads removed. Following decontamination, restoration activities included installation of new carpeting and repainting of interior walls.

On 16 January 2014, EPA, START, and EPA Emergency Rapid Response Services (ERRS) personnel tested various decontamination methods at the property, including conducting decontamination efficacy sampling.

On 27 February 2014, EPA and START conducted clearance sampling. A total of six clearance samples and one QA/QC field blank sample were collected and sent to EPA’s OEME/NERL for analysis. None of the six field samples contained concentrations of chlorpyrifos exceeding the EPA AL (see Figure 3, Clearance Sample Results Diagram; and Table 2, Clearance Sampling Analytical Results). The SAP documenting clearance sampling was prepared as a separate document, entitled AAA Accredited Pest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont [2].

3

4.0 REFERENCES



Appendix A

Figures



Appendix B

Tables


TABLE 1



RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1014-01_ _Char_ResultsTable.xlsx Page 1 of 1


D32060 Bedroom (West Wall) Behind hamper, between dressers. 10/2/2013 0.0399D32061 Office (Chair) Seat of chair. 10/2/2013 0.00201D32062 Hallway (Carpet) In front of bathroom. 10/2/2013 ND (0.0004)D32063 Kitchen (Floor) Under cabinets across from refrigerator. 10/2/2013 0.0043D32064 Bedroom (Baseboard) Left of window on North wall. 10/2/2013 0.00163D32065 Kitchen (Wall) Left of sink. 10/2/2013 0.00418D32066 Bathroom (Baseboard) Underneath window. 10/2/2013 0.141D32067 Entryway (Baseboard) Across from front door. 10/2/2013 0.00552D32068 Living Room (Wall) Left of fireplace. 10/2/2013 0.00149D32072 Field Blank Kitchen. 10/2/2013 ND (0.0004)D32234 Living Room (Chair) Back of cushion. 10/2/2013 ND (0.0004)D32235 Living Room (Wall) Underneath window, behind couch. 10/2/2013 0.026D32236 Living Room (Couch) Back of cushion. 10/2/2013 0.000482D32237 Living Room (North Wall) Left of window. 10/2/2013 0.0442D32238 Bedroom (East Wall) Left of window. 10/2/2013 0.0567D32239 Bedroom (Wall) In closet, closer to east wall. 10/2/2013 0.000342D32634 Field Blank Kitchen. 11/22/2013 ND (0.0004)D32635 Kitchen (Bottom Shelf) Cabinet right and above sink. 11/22/2013 0.00088D32636 Kitchen (Shelf) Cabinet below sink. 11/22/2013 0.0008D32637 Kitchen (Shelf) Cabinet below microwave. 11/22/2013 0.0026

NOTES:


TABLE 2



RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1014-01_ _Clearance_ResultsTable.xlsx Page 1 of 1


D32867 Kitchen (Wall Tile) Above sink, adjacent to D32065. 2/27/2014 ND (0.0004)D32868 Living Room (Wall) Adjacent to D32235. 2/27/2014 ND (0.0004)D32869 Living Room (Wall) Adjacent to D32237. 2/27/2014 ND (0.0004)D32870 Bedroom (Wall) Right of heater adjacent to D32060. 2/27/2014 ND (0.0004)D32871 Bedroom (Wall) Left of window, adjacent to D32238. 2/27/2014 ND (0.0004)D32872 Bedroom (Baseboard) Adjacent to D32066. 2/27/2014 ND (0.0004)D32873 Field Blank Kitchen. 2/27/2014 ND (0.0004)

NOTES:


Appendix I






Prepared For:





TDD NO. TO1-01-15-07-0042

TASK NO. 0044

DC NO. R-00824

Submitted by:




June 2020

ii

TABLE OF CONTENTS

PAGE


1.0 INTRODUCTION .............................................................................................................. 1

2.0 BACKGROUND ................................................................................................................... 1


4.0 REFERENCES ................................................................................................................... 3

iii

LIST OF APPENDICES

Appendix A

Appendix B



1


2.0 BACKGROUND The AAA Accredited Pest Control Site (the site) includes residences in Rutland, Vermont (VT) and in surrounding communities where AAA Accredited Pest Control (AAA), a local exterminator, applied chlorpyrifos in indoor settings. In May 2013, VT AAFM began investigating AAA following a complaint that a pesticide application by AAA to address a bedbug infestation had sickened a family in the treated house. VT AAFM Field Agents initiated the investigation, which included interviewing the complainant, inspecting the property, collecting photographic evidence, sampling the complainant’s home, interviewing the pesticide applicator from AAA, inspecting AAA’s records and invoices, and sampling their spray formulations and application equipment. Observations and analytical results indicated the presence of chlorpyrifos, which has been restricted for all indoor uses since 2001. The investigation continued with a review of invoices from AAA, to prioritize treated properties requiring sampling. This review identified 10 additional properties deemed most at risk due to chlorpyrifos treatment for bedbugs and/or other insects. As a result, sampling was initiated at these 10 properties. During a conference call on 11 July 2013 (followed up by a letter dated 2 August 2013), the VT Agency of Agriculture, Food, and Markets (AAFM) and Department of Health (DOH) requested the assistance of EPA with cleanup of contaminated residences, sampling and analytical support, and community involvement support. On 12 September 2013, EPA and START began providing on-site assistance to VT state agencies, which included generating sample documentation for wipe samples collected by VT AAFM personnel; collecting wipe samples to confirm and characterize previous sampling results; conducting data management; performing outreach efforts; and conducting laboratory analysis. On 19 September 2013, an Action Memorandum was approved authorizing Removal Actions at up to 11 properties where analytical results indicated the presence of chlorpyrifos at levels above the EPA Site-Specific Action Level of 0.006 micrograms per square centimeter (µg/cm2). On 26 March 2014, an Addendum to the Action Memorandum was approved, authorizing Removal Actions at up to five additional properties.

3.0 SITE DESCRIPTION AND NARRATIVE CHRONOLOGY The property is a one-bedroom apartment located on the first floor of a residential apartment building in Rutland, VT (see Figure 1, Site Location Map).

2

The property was treated by AAA for bedbugs with two pesticide applications. The dates of application were 24 November 2011 and 3 April 2013. On 25 June 2013 and 20 August 2013, VT AAFM conducted initial sampling for chlorpyrifos. Samples were analyzed at the VT State laboratory, and a maximum concentration of 0.39 µg/cm2 was reported. This value exceeded the EPA AL of 0.006 µg/cm2. Therefore, further characterization sampling was conducted by EPA and START. On 16 September 2013, EPA and START conducted characterization sampling. A total of 14 characterization samples and one quality assurance/quality control (QA/QC) field blank sample were collected and sent to the EPA Office of Environmental Measurement and Evaluation (OEME) New England Regional Laboratory (NERL) for analysis. The Sampling and Analysis Plan (SAP) documenting initial and characterization sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pesticides Site, Rutland, Vermont [1]. Thirteen of the 14 field samples contained chlorpyrifos at concentrations exceeding the EPA AL, with a maximum detected concentration of 0.20 µg/cm2 (see Figure 2, Characterization Sample Results Diagram; and Table 1, Characterization Sampling Analytical Results). Due to the elevated levels of chlorpyrifos present, an EPA Removal Action was deemed to be warranted. EPA, START, and EPA Emergency Rapid Response Services (ERRS) personnel tested various decontamination methods at the property, including efficacy sampling on 20 and 21 November 2013; 4, 11 and 13 December 2013; and 8 and 9 January 2014. On 14 November 2013, an inventory of all personal and household items in the apartment was completed, and a Personal Property Disposition Agreement Form was signed by the property owner. On 21 November 2013, EPA and ERRS conducted decontamination activities. All household items, furniture, possessions, and trash were removed from the apartment for storage and/or disposal. Decontamination efforts included washing walls, countertops, appliances, and other surfaces with a water/detergent mixture; followed by three applications of the Sterilex® decontamination solution; and were completed with a water rinse. Any carpets, underlying carpet pads, and floors were vacuumed, and the carpets/pads and drop ceiling tiles removed. Following decontamination, restoration activities included installation of new carpeting and repainting of interior walls. On 3 March 2014, EPA and START conducted clearance sampling. A total of four clearance samples and one QA/QC field blank sample were collected and sent to EPA’s OEME/NERL for analysis. None of the four field samples contained concentrations of chlorpyrifos exceeding the EPA AL (see Figure 3, Clearance Sample Results Diagram; and Table 2, Clearance Sampling Analytical Results). The SAP documenting clearance sampling was prepared as a separate document, entitled AAA Accredited Pest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont [2].

3

4.0 REFERENCES





Appendix A

Figures



Appendix B

Tables


TABLE 1



RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1000-01_ _Characterization Table 1.xlsx Page 1 of 1


D32010 Bedroom (Wall) Lower wall by foot of bed. 9/16/2013 0.09D32011 Bedroom (Upper Wall) Adjacent to head of bed. 9/16/2013 0.083D32012 Bedroom (Upper Wall) Above closet. 9/16/2013 0.099D32013 Bedroom (Ceiling) Above foot of bed. 9/16/2013 0.061D32014 Bathroom (Upper Wall) Above toilet. 9/16/2013 0.11D32015 Bedroom (Floor) In front of closet. 9/16/2013 0.085D32016 Living Room (Floor) Adjacent to entryway and table. 9/16/2013 0.20D32017 Living Room (Upper Wall) Adjacent to bedroom and kitchen entryway. 9/16/2013 0.054D32018 Living Room (Wall at waist level) Above dining table. 9/16/2013 0.058D32019 Living Room (Recliner) Headrest of recliner. 9/16/2013 0.0009D32020 Living Room (Ceiling) Center of room. 9/16/2013 0.023D32021 Kitchen (Upper Wall) Adjacent to refrigerator. 9/16/2013 0.022D32022 Kitchen (Floor) In front of refrigerator. 9/16/2013 0.0172D32023 Kitchen (Ceiling) Above sink. 9/16/2013 0.029D32024 Field Blank Field Blank 9/16/2013 ND

NOTES:




TABLE 2



RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1000-01_ Clearance Table 2.xlsx Page 1 of 1


D32814 Kitchen (Field Blank) Field Blank 3/3/2014 ND (0.0004)D32815 Kitchen (Slanted Ceiling) Above the sink. 3/3/2014 ND (0.0004)D32816 Bathroom (Upper Wall) Above the toilet. 3/3/2014 ND (0.0004)D32817 Bedroom (Wall) Above the closet. 3/3/2014 ND (0.0004)D32818 Living Room (Floor) Left of the entry door, to the right of the electrical outlet. 3/3/2014 ND (0.0004)

NOTES:




Appendix J






Prepared For:





TDD NO. TO1-01-15-07-0042

TASK NO. 0044

DC NO. R-00825

Submitted by:




June 2020

ii

TABLE OF CONTENTS

PAGE


1.0 INTRODUCTION .............................................................................................................. 1

2.0 BACKGROUND ................................................................................................................... 1


4.0 REFERENCES ................................................................................................................... 3

iii

LIST OF APPENDICES

Appendix A

Appendix B

Figures Figure 1 - Site Location Map (Redacted)Figures 2A and 2B - Characterization Sample Results Diagrams Figures 3A and 3B - Clearance Sample Results Diagrams

Tables Table 1 - Characterization Sampling Analytical Results Table 2 - Clearance Sampling Analytical Results

1

1.0 INTRODUCTION


2.0 BACKGROUND





The property is a two-floor residential building in Rutland, VT (see Figure 1, Site Location Map). The property was treated by AAA for bedbugs with one pesticide application. The date of application was 29 April 2013.

2

On 8 May and 28 June 2013, VT AAFM conducted initial sampling for chlorpyrifos. Samples were analyzed at the VT State laboratory, and a maximum concentration of 3.9934 µg/cm2 was reported. This value exceeded the EPA AL of 0.006 µg/cm2. Therefore, further characterization sampling was conducted by EPA and START.

On 17 September 2013, EPA and START conducted characterization sampling. A total of 31 characterization and two quality assurance/quality control (QA/QC) field blank samples were collected from the first and second floors of the residence, and were sent to EPA’s Office of Environmental Measurement and Evaluation (OEME) New England Regional Laboratory (NERL) for analysis. The Sampling and Analysis Plan (SAP) documenting initial and characterization sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pesticides Site, Rutland, Vermont [1].

Twenty-six of the 31 field samples contained chlorpyrifos at concentrations exceeding the EPA AL, with a maximum detected concentration of 0.79 µg/cm2 (see Figures 2A and 2B, First and Second Floor Characterization Sample Results Diagrams; and Table 1, Characterization Sampling Analytical Results). Due to the elevated levels of chlorpyrifos present, an EPA Removal Action was deemed to be warranted.

In addition, on 5 December 2013, EPA and START conducted characterization sampling of the basement and first floor heating vents. A total of 19 characterization samples and one QA/QC field blank sample were collected and sent to NERL for analysis. However, none of the 19 field samples contained chlorpyrifos at concentrations exceeding the EPA AL. Therefore, the basement was not included in the EPA removal action on this residential property.

On 1 November, 5 through 7 November 2013, and 22 and 23 January 2014, an inventory of all personal and household items in the home was conducted. On 26 February, and 19 and 25 March 2014, the Personal Property Disposition Agreement Form(s) were signed by the property owner(s).

On 27 March 2014, EPA and ERRS began conducting decontamination activities. All household items, furniture, possessions, and trash were removed from the unit for storage and/or disposal. Decontamination efforts included washing walls, countertops, appliances, and other surfaces with a water/detergent mixture; followed by three applications of the Sterilex® decontamination solution; and were completed with a water rinse. Any carpets, underlying carpet pads, and floors were vacuumed, and carpets/pads removed. Following decontamination, restoration activities included installation of new carpeting and repainting of interior walls.

On 16 May 2014, EPA and START conducted characterization sampling. A total of 24 clearance samples and two QA/QC field blank samples were sent to OEME/NERL for analysis. None of the 24 field samples contained concentrations of chlorpyrifos exceeding the EPA AL (see Figures 3A and 3B, First and Second Floor Clearance Sample Results Diagrams; and Table 2, Clearance Sampling Analytical Results). The SAP documenting clearance sampling was prepared as a separate document, entitled AAA Accredited Pest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont [2].

3

4.0 REFERENCES



Appendix A

Figures

Figure 1 - Site Location Map (Redacted)Figures 2A and 2B - Characterization Sample Results Diagrams

Figures 3A and 3B - Clearance Sample Results Diagrams

Appendix B

Tables


TABLE 1



RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1005-01_ _CharacterizationResultsTable.xlsx Page 1 of 1


D32155 1st Floor Living Room (Dresser) Top of dresser, co-located with Vermont sample. 9/17/2013 0.79D32156 1st Floor Bedroom #1 (Dresser) Top of dresser, co-located with Vermont sample. 9/17/2013 0.02D32157 1st Floor Bedroom #4 (Window) South window, co-located with Vermont sample. 9/17/2013 0.00099D32158 2nd Floor Kitchen (Tote) Top of tote, co-located with Vermont sample. 9/17/2013 0.0034D32159 2nd Floor Bedroom #5 (Wall) West Wall and baseboard. 9/17/2013 0.088D32160 2nd Floor Bedroom #5 (Wall) South Wall and baseboard. 9/17/2013 0.015D32161 Field Blank Opened on 2nd floor. 9/17/2013 0.00036D32162 2nd Floor Bathroom (Floor) East side, on floor. 9/17/2013 0.066D32163 2nd Floor Exercise Room (Wall) West Wall near outlet. 9/17/2013 0.048D32164 2nd Floor Living Room (Wall) East Wall and baseboard, between doors. 9/17/2013 0.038D32165 2nd Floor Kitchen (Floor) Southwest corner, on floor. 9/17/2013 0.07D32166 2nd Floor Kitchen (Stove) Top of stove. 9/17/2013 0.092D32167 2nd Floor Bedroom #6 (Wall) North wall heater and baseboard. 9/17/2013 0.029D32168 2nd Floor Bedroom #6 (Bed) Mattress label. 9/17/2013 0.046D32169 2nd Floor Bathroom (Window) East window sill. 9/17/2013 0.099D32170 2nd Floor Bathroom (Wall) South wall in closet, near baseboard. 9/17/2013 0.014D32171 1st Floor Bedroom #4 (Bed) Bedframe. 9/17/2013 0.0041D32172 1st Floor Bathroom (Wall) North Wall. 9/17/2013 0.039D32173 1st Floor Bedroom #3 (Floor) Center of east wall, on floor. 9/17/2013 0.54D32174 1st Floor Kitchen (Wall) Wall behind refrigerator. 9/17/2013 0.18D32175 1st Floor Kitchen (Stove) On top of stove. 9/17/2013 0.031D32176 1st Floor Living Room (Piano) Side of piano. 9/17/2013 0.039D32177 1st Floor Bedroom #2 (Floor) Floor behind mattress by heating vent on west wall. 9/17/2013 0.027D32178 1st Floor Bedroom #2 (Floor) Southeast corner, floor and wallboard. 9/17/2013 0.11D32179 1st Floor Bedroom #2 (Mattress) Mattress label. 9/17/2013 0.014D32180 1st Floor Bedroom #1 (Wall) Center of north wall and baseboard. 9/17/2013 0.03D32181 Field Blank Opened on 1st floor. 9/17/2013 ND (0.0004)D32182 1st Floor Bathroom (Wall) Center of west wall and baseboard. 9/17/2013 0.085D32183 1st Floor Kitchen Hall (Wall) Upper east wall. 9/17/2013 0.19D32184 1st Floor Main Entrance (Floor) Floor behind door on east wall. 9/17/2013 0.055D32185 1st Floor Bathroom (Sink) Front of sink, previously cleaned. 9/17/2013 ND (0.0004)D32186 1st Floor Kitchen (Appliance) Front of refrigerator, previously cleaned. 9/17/2013 0.0069D32187 2nd Floor Kitchen (Counter) Counter top, previously cleaned. 9/17/2013 0.005

NOTES:


TABLE 2



RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1005-01_ _ClearanceResultsTable.xlsx Page 1 of 1


D32960 Field Blank Opened on 2nd floor. 5/16/2014 ND (0.0004)D32961 2nd Floor Bathroom (Wall) North wall near baseboard. 5/16/2014 ND (0.0004)D32962 2nd Floor Bedroom #5 (Wall) North wall near baseboard. 5/16/2014 ND (0.0004)D32963 2nd Floor Exercise Room (Wall) South wall mid-level, right of outlet. 5/16/2014 ND (0.0004)D32964 2nd Floor Exercise Room (Wall) North wall near baseboard. 5/16/2014 ND (0.0004)D32965 2nd Floor Entry Area (Wall) South wall near door, above baseboard. 5/16/2014 ND (0.0004)D32966 2nd Floor Entry Area (Beam) Beam on west wall between Exercise Room and Kitchen, 6" from floor. 5/16/2014 ND (0.0004)D32967 2nd Floor Kitchen (Cabinet) Inside south wall cabinet, left-hand side. 5/16/2014 ND (0.0004)D32968 2nd Floor Kitchen (Wall) East wall near baseboard. 5/16/2014 ND (0.0004)D32969 2nd Floor Bedroom #6 (Wall) North wall, below window to right, above baseboard heater. 5/16/2014 ND (0.0004)D32970 2nd Floor Bathroom (Window) North window sill. 5/16/2014 ND (0.0004)D32971 2nd Floor Bathroom (Wall) South wall in closet, near baseboard. 5/16/2014 ND (0.0004)D32972 2nd Floor Entry Area (Wall) East Wall above baseboard, between doors. 5/16/2014 ND (0.0004)D32973 Field Blank Opened on 1st floor. 5/16/2014 ND (0.0004)D32974 1st Floor Bathroom (Wall) East wall below window, near baseboard. 5/16/2014 ND (0.0004)D32975 1st Floor Bedroom #4 (Wall) North wall near outlet above baseboard. 5/16/2014 ND (0.0004)D32976 1st Floor Bedroom #3 (Wall) South wall near outlet above baseboard. 5/16/2014 ND (0.0004)D32977 1st Floor Bedroom #3 (Wall) North wall near outlet above baseboard. 5/16/2014 ND (0.0004)D32978 1st Floor Bedroom #2 (Wall) South wall near corner of open closet, 12" above baseboard. 5/16/2014 ND (0.0004)D32979 1st Floor Bedroom #1 (Wall) South wall, right of light switch. 5/16/2014 ND (0.0004)D32980 1st Floor Bedroom #1 (Wall) North wall, left of outlet. 5/16/2014 ND (0.0004)D32981 1st Floor Living Room (Wall) North wall between bedroom #1 and bathroom. 5/16/2014 ND (0.0004)D32982 1st Floor Bathroom (Wall) North wall below window, just above baseboard. 5/16/2014 ND (0.0004)D32983 1st Floor Living Room (Wall) East wall, left of door on wood baseboard. 5/16/2014 ND (0.0004)D32984 1st Floor Kitchen (Wall) Left of west wall outlet, mid-wall, next to bedroom #3 door frame. 5/16/2014 ND (0.0004)D32985 1st Floor Kitchen (Wall) South wall, right of left-hand outlet, mid-wall. 5/16/2014 ND (0.0004)

NOTES:


Appendix K

Removal Program After Action Report for Residential Property 1029-01 Granville, Vermont




RESIDENTIAL PROPERTY 1029-01 GRANVILLE, VERMONT

Prepared For:





TDD NO. TO1-01-15-07-0042

TASK NO. 0044

DC NO. R-00826

Submitted by:




June 2020

ii

TABLE OF CONTENTS

PAGE


1.0 INTRODUCTION .............................................................................................................. 1

2.0 BACKGROUND ................................................................................................................ 1


4.0 REFERENCES ................................................................................................................... 3

iii

LIST OF APPENDICES

Appendix A

Appendix B

Figures Figure 1 - Site Location Map (Redacted)Figure 2 - Characterization Sample Results Diagram - First Floor Figure 3 - Characterization Sample Results Diagram - Second Floor Figure 4 - Characterization Sample Results Diagram - Jacuzzi/Sun Room Figure 4A - Characterization Sample Results Diagram - Basement Figure 5 - Clearance Sample Results Diagram - First Floor Figure 6 - Clearance Sample Results Diagram - Second Floor Figure 7 - Clearance Sample Results Diagram - Jacuzzi/Sun Room

Tables Table 1 - Characterization Sampling Analytical Results Table 2 - Clearance Sampling Analytical Results

1

1.0 INTRODUCTION


2.0 BACKGROUND





The property is a seven-bedroom, two-story home located in Granville, VT (see Figure 1, Site Location Map). The property was treated by AAA for cluster flies with one pesticide application. The date of application was 2 April 2013.

2

On 29 July 2013, VT AAFM conducted initial sampling for chlorpyrifos. Samples were analyzed at the VT State laboratory, and a maximum concentration of 0.17 µg/cm2 was reported. This value exceeded the EPA AL of 0.006 µg/cm2. Therefore, further characterization sampling by EPA and START was conducted.

On 13 September, 18 and 29 October, and 5 November 2013, EPA and START conducted characterization sampling. A total of 110 characterization samples and five quality assurance/quality control (QA/QC) field blank samples were collected and sent to EPA’s Office of Environmental Measurement and Evaluation (OEME) New England Regional Laboratory (NERL) for analysis. The Sampling and Analysis Plan (SAP) documenting initial and characterization sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pesticides Site, Rutland, Vermont [1].

There were 49 field samples containing chlorpyrifos at concentrations exceeding the EPA AL, with a maximum detected concentration of 1.6 µg/cm2 (see Figure 2, Clearance Sample Results Diagram - First Floor; Figure 3, Clearance Sample Results Diagram - Second Floor; Figure 4, ClearanceSample Results Diagram - Jacuzzi/Sun Room; Figure 4A, Characterization Sample Results Diagram- Basement; and Table 1, Characterization Sampling Analytical Results). Due to the elevated levelsof chlorpyrifos present, an EPA Removal Action was deemed to be warranted.

On 26 March 2014, an inventory of all personal and household items in the unit was completed, and a Personal Property Disposition Agreement Form was signed by the tenant.

On 2 April 2014, EPA and the Emergency Rapid Response Services (ERRS) contractor began conducting decontamination activities. All household items, furniture, possessions, and trash were removed from the unit for storage and/or disposal. Decontamination efforts included washing walls, windows, countertops, appliances, and other surfaces with a water/detergent mixture; followed by three applications of the Sterilex® decontamination solution; and were completed with a water rinse. Any carpets, underlying carpet pads, pine wood paneling, and floors were vacuumed, and the carpets/pads removed. Following decontamination, restoration activities included installation of new carpeting, pine wood paneling, and repainting of interior walls.

On 30 May 2014, EPA and START conducted clearance sampling. Fifteen clearance samples and two QA/QC field blank samples were collected and sent to EPA’s OEME/NERL for analysis. None of the 15 field samples contained chlorpyrifos at concentrations exceeding the EPA AL (see Figure 5, Clearance Sample Results Diagram - First Floor; Figure 6, Clearance Sample Results Diagram - Second Floor; Figure 7, Clearance Sample Results Diagram - Jacuzzi/Sun Room; and Table 2, Clearance Sampling Analytical Results). The SAP documenting clearance sampling was prepared as a separate document, entitled AAA Accredited Pest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont [2].

3

4.0 REFERENCES



Appendix A

Figures

Figure 1 - Site Location Map (Redacted)Figure 2 - Characterization Sample Results Diagram - First Floor Figure 3 - Characterization Sample Results Diagram - Second Floor Figure 4 - Characterization Sample Results Diagram - Jacuzzi/Sun Room Figure 4A - Characterization Sample Results Diagram - Basement Figure 5 - Clearance Sample Results Diagram - First Floor Figure 6 - Clearance Sample Results Diagram - Second Floor Figure 7 - Clearance Sample Results Diagram - Jacuzzi/Sun Room

Appendix B

Tables


TABLE 1



GRANVILLE, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1029-01_ \1029-01_CharacterizationResultsTable1.xlsx Page 1 of 4


D32000 Bathroom (First Floor, off of Sunroom) Baseboard/Wall. 9/13/2013 0.071D32001 Sunroom Wall above small window to the right. 9/13/2013 0.006D32002 Sunroom Jacuzzi Deck. 9/13/2013 0.03D32003 Sunroom Wall by Screen Door. 9/13/2013 0.0051D32004 Sunroom Wall behind TV. 9/13/2013 0.0096D32005 Kitchen Floor. 9/13/2013 0.02D32006 Dining Room Floor. 9/13/2013 0.031D32007 Basement Stairs to basement. 9/13/2013 0.011D32008 Basement Beneath Jacuzzi on 2x4 support wood. 9/13/2013 1.6D32009 Field Blank 9/13/2013 ND (0.0004)D32344 Bedroom #1 (Second Floor) Window Sill. 10/18/2013 0.00467D32345 Bedroom #1 (Second Floor) Door Sill. 10/18/2013 0.0012D32346 Bedroom #2 (Second Floor) Window Sill. 10/18/2013 0.00321D32347 Bedroom #2 (Second Floor) Door Sill. 10/18/2013 0.01D32348 Bedroom #3 (Second Floor) Window Sill. 10/18/2013 0.0037D32349 Bedroom #3 (Second Floor) Door Sill. 10/18/2013 ND (0.0004)D32350 Staircase from Living Room 10th Step up from bottom. 10/18/2013 0.006D32351 Staircase from Living Room 2nd Step up from bottom. 10/18/2013 0.0052D32352 Bathroom (Second Floor) Window Sill. 10/18/2013 0.0051D32353 Bathroom (Second Floor) Heating Vent. 10/18/2013 0.00073D32354 Bedroom #4 (Second Floor) Window Sill. 10/18/2013 0.0042D32355 Bedroom #5 (Second Floor) Window Sill. 10/18/2013 0.0051D32356 Staircase from Den Bottom Step. 10/18/2013 0.0062D32357 Staircase from Den Landing Step. 10/18/2013 0.0014D32358 Staircase from Den Top Step. 10/18/2013 0.0043D32359 Den Wall, left of staircase, near floor. 10/18/2013 0.017D32360 Den Wood Paneling, wall above bench seat. 10/18/2013 0.023D32361 Den Top of Door Frame. 10/18/2013 0.0011D32362 Den Door Sill. 10/18/2013 0.00026D32363 Bedroom #6 (First Floor) Window Sill. 10/18/2013 0.0067D32364 Bedroom #6 (First Floor) Heating Vent. 10/18/2013 0.0017D32365 Basement Floor, near staircase. 10/18/2013 0.00068

TABLE 1



GRANVILLE, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1029-01_ Granville\Tables\1029-01_CharacterizationResultsTable1.xlsx Page 2 of 4


D32366 Basement Floor, middle of basement. 10/18/2013 0.0002D32367 Basement Floor, near Jacuzzi. 10/18/2013 0.0053D32368 Basement Side of Jacuzzi. 10/18/2013 0.138D32369 Basement Corner of Jacuzzi. 10/18/2013 0.056D32370 Basement Joist supporting Jacuzzi. 10/18/2013 0.0183D32371 Basement Joist supporting Jacuzzi. 10/18/2013 0.057D32372 Basement Wood 2x4 in access way. 10/18/2013 0.82D32373 Bedroom #7 (First Floor) Window Sill. 10/18/2013 0.0037D32374 Bedroom #7 (First Floor) Baseboard. 10/18/2013 0.0084D32375 Mudroom Door Sill. 10/18/2013 0.00021D32376 Mudroom Floor, under carpet. 10/18/2013 ND (0.0004)D32377 Mudroom Wall. 10/18/2013 0.00025D32378 Mudroom Window Sill. 10/18/2013 0.00024D32379 Kitchen Floor, by doorway to Dining Room. 10/18/2013 0.0094D32380 Kitchen Floor, in front of stove. 10/18/2013 0.013D32381 Kitchen Floor, middle of Kitchen. 10/18/2013 0.017D32382 Kitchen Floor, by doorway to Den. 10/18/2013 0.024D32383 Kitchen Window Sill, window near stove. 10/18/2013 0.029D32384 Kitchen Wall, above dishwasher, below cabinets. 10/18/2013 0.034D32385 Kitchen Wall, above door to Sunroom. 10/18/2013 0.021D32386 Kitchen Window Sill, window near Sunroom. 10/18/2013 0.012D32387 Kitchen Wall, middle of wall, adjacent to stove. 10/18/2013 0.017D32388 Dining Room Wall, between windows, on level with bottom of windows. 10/18/2013 0.032D32389 Dining Room Floor, below sample D32388. 10/18/2013 0.015D32420 Dining Room Floor, near heating vent. 10/18/2013 0.00078D32421 Dining Room Floor, by doorway to Living Room. 10/18/2013 0.019D32422 Dining Room Floor, by doorway to Mudroom. 10/18/2013 0.011D32423 Dining Room Floor, by doorway to Bedroom #6. 10/18/2013 0.0043D32424 Field Blank 10/18/2013 ND (0.0004)D32425 Field Blank 10/18/2013 ND (0.0004)

TABLE 1



GRANVILLE, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1029-01_ _Granville\Tables\1029-01_CharacterizationResultsTable1.xlsx Page 3 of 4


D32514 Sunroom Wall above east window, upper left. 10/29/2013 0.02D32515 Sunroom East window, middle of plastic frame. 10/29/2013 0.0011D32516 Sunroom East window, bottom sill, right-hand panel. 10/29/2013 0.0075D32517 Sunroom East window, right-hand frame, plastic. 10/29/2013 0.002D32518 Sunroom South window, left-hand frame plastic. 10/29/2013 0.0015D32519 Sunroom Wall above south window, upper left. 10/29/2013 0.0026D32520 Sunroom South window, bottom sill, center. 10/29/2013 0.0021D32521 Sunroom West wall, left of door. 10/29/2013 0.002D32522 Sunroom North wall, baseboard right of bathroom. 10/29/2013 0.0029D32523 Sunroom West wall, under towel rack. 10/29/2013 0.0018D32524 Sunroom North wall, above mirror. 10/29/2013 0.0012D32525 Sunroom North wall, below mirror. 10/29/2013 0.005D32526 Sunroom Top of bathroom, above north wall. 10/29/2013 0.0094D32527 Sunroom Window sill of east window, bottom sill. 10/29/2013 0.025D32528 Bathroom (First Floor) West wall, above hook. 10/29/2013 0.026D32529 Bathroom (First Floor) North wall, above toilet. 10/29/2013 0.022D32530 Bathroom (First Floor) Baseboard below tub. 10/29/2013 0.07D32531 Sunroom Baseboard under Jacuzzi, west side. 10/29/2013 0.021D32532 Field Blank 10/29/2013 ND (0.0004)D32478 Kitchen Middle shelf, cabinet left of sink. 11/5/2013 ND (0.0004)D32479 Kitchen Middle shelf, cabinet nearest den door. 11/5/2013 0.00022D32400 Kitchen Wall adjacent to stove, inside cabinet. 11/5/2013 ND (0.0004)D32401 Laundry Closet Dryer door. 11/5/2013 0.0041D32402 Kitchen Top of microwave. 11/5/2013 0.15D32403 Dining Room Shelf underneath southwest corner of table. 11/5/2013 0.034D32404 Den Third stair. 11/5/2013 0.0054D32405 Den Second stair. 11/5/2013 0.0015D32406 Den Fireplace. 11/5/2013 0.002D32407 Den Ceiling crossbeam, side nearest Kitchen. 11/5/2013 ND (0.0004)D32408 Den Door Frame, above Door. 11/5/2013 0.0033D32409 Den Leg of table. 11/5/2013 0.0062D32410 Bedroom 2 Wall near ceiling. 11/5/2013 0.002D32411 Bedroom 2 Wall, below center of bed. 11/5/2013 0.0023

TABLE 1



GRANVILLE, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1029-01_ Granville\Tables\1029-01_CharacterizationResultsTable1.xlsx Page 4 of 4


D32412 Bedroom 2 Back of closet. 11/5/2013 0.00041D32413 Bedroom 2 Dresser, top left corner. 11/5/2013 0.0036D32414 Staircase Wood Frame, wall above seventh step. 11/5/2013 0.0064D32415 Hallway Mirror. 11/5/2013 ND (0.0004)D32416 Hallway In-Wall Storage. 11/5/2013 0.00032D32417 Living Room South window sill. 11/5/2013 0.0043D32418 Living Room West window sill. 11/5/2013 0.001842D32419 Living Room Entertainment system. 11/5/2013 0.00093D32540 Living Room West wall in southwest corner. 11/5/2013 0.00054D32541 Living Room Table leg. 11/5/2013 0.0047D32542 Bedroom 7 Closet, south wall. 11/5/2013 0.0036D32543 Bedroom 7 End table. 11/5/2013 ND (0.0004)D32544 Bedroom 7 North wall, upper northwest corner. 11/5/2013 0.011D32545 Bedroom 6 Closet door frame. 11/5/2013 0.0045D32546 Bedroom 6 South wall, below tennis picture. 11/5/2013 0.01D32547 Bedroom 6 North window frame. 11/5/2013 0.0089D32548 Dining Room Mirror. 11/5/2013 ND (0.0004)D32549 Dining Room Wall, right of door, above closet. 11/5/2013 0.012D32550 Bathroom South wall, near west wall. 11/5/2013 0.0026D32551 Field Blank 11/5/2013 ND (0.0004)

NOTES:Samples analyzed by U.S. EPA Office of Environmental Measurement and Evaluation (OEME) Using EPA Region I SOP,EIASOP-LCMS$CPF.0, Chlorpyrifos in Wipes.All results in micrograms per square centimeter (µg/cm²).ND = Not Detected (reporting limit in parentheses).

Bolded and dark shaded results exceed the EPA Removal Program Action Level of 0.006 µg/cm2.Bolded and light shaded results exceed the Vermont Department of Health Action Level of 0.0004 µg/cm2.

TABLE 2



GRANVILLE, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\1029-01_ Granville\Tables\1029-01_ClearanceResultsTable2.xlsx Page 1 of 1


D32986 Living Room South window sill. 5/30/2014 0.0012D32987 Dining Room Wall, between windows. 5/30/2014 ND (0.0004)D32988 Kitchen Wall, above microwave. 5/30/2014 ND (0.0004)D32989 Bedroom #7 (First Floor) Wall, north wall, upper northwest corner. 5/30/2014 ND (0.0004)D32990 Bedroom #6 (First Floor) Wall, south wall, lower right corner. 5/30/2014 ND (0.0004)D32991 Den stairs Step, bottom step. 5/30/2014 ND (0.0004)D32992 Bedroom #5 (Second Floor) Window sill. 5/30/2014 ND (0.0004)D32993 Bedroom #4 (Second Floor) Window sill. 5/30/2014 ND (0.0004)D32994 Bathroom (Second Floor) Window sill. 5/30/2014 ND (0.0004)D32995 Bedroom #2 (Second Floor) Door frame, lower right door frame. 5/30/2014 ND (0.0004)D32996 Bedroom #1 (Second Floor) Window sill. 5/30/2014 ND (0.0004)D32997 Bedroom #3 (Second Floor ) Window sill. 5/30/2014 ND (0.0004)D32998 Living Room Stairs Step, 10th step from bottom. 5/30/2014 ND (0.0004)D32999 Living Room Stairs Wall, paneling on wall next to steps (10th). 5/30/2014 ND (0.0004)D33000 Sunroom Vanity, bottom front drawer on vanity. 5/30/2014 ND (0.0004)D33001 Kitchen (First Floor) Blank. 5/30/2014 ND (0.0004)D33002 Hallway (Second Floor) Blank. 5/30/2014 ND (0.0004)

NOTES:



Appendix L

Removal Program After Action Report for Residential Property 2564-01 Shrewsbury, Vermont




RESIDENTIAL PROPERTY 2564-01 SHREWSBURY, VERMONT

Prepared For:





TDD NO. TO1-01-15-07-0042

TASK NO. 0044

DC NO. R-00832

Submitted by:




June 2020

ii

TABLE OF CONTENTS

PAGE


1.0 INTRODUCTION .............................................................................................................. 1

2.0 BACKGROUND ................................................................................................................... 1


4.0 REFERENCES ................................................................................................................... 3

iii

LIST OF APPENDICES

Appendix A

Appendix B



1

1.0 INTRODUCTION


2.0 BACKGROUND





The property is a three-bedroom, two-story cabin located in Shrewsbury, VT (see Figure 1, Site Location Map). The property was treated by AAA for ants with one pesticide application. The date of application was 1 June 2011.

2

On 14 October 2013, VT AAFM conducted initial sampling for chlorpyrifos. Samples were analyzed at the VT State laboratory, and a maximum concentration of 0.0874 µg/cm2 was reported. This value exceeded the EPA AL of 0.006 µg/cm2. Therefore, further characterization sampling by EPA and START was conducted.

On 24 October 2013, EPA and START conducted characterization sampling. A total of seven characterization samples and one quality assurance/quality control (QA/QC) field blank sample were collected and sent to EPA’s Office of Environmental Measurement and Evaluation (OEME) New England Regional Laboratory (NERL) for analysis. The Sampling and Analysis Plan (SAP) documenting initial and characterization sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pesticides Site, Rutland, Vermont [1].

Three of the seven field samples contained chlorpyrifos at concentrations exceeding the EPA AL, with a maximum detected concentration of 0.12 µg/cm2 (see Figure 2, Characterization Sample Results Diagram; and Table 1, Characterization Sampling Analytical Results). Due to the elevated levels of chlorpyrifos present, an EPA Removal Action was deemed to be warranted.

Decontamination activities were conducted from 5 through 7 May 2014. Decontamination efforts included washing walls and other surfaces with a water/detergent mixture, followed by three applications of the Sterilex® decontamination solution, and were completed with a water rinse.

On 9 May 2014, EPA and START conducted clearance sampling. A total of four clearance samples and one QA/QC field blank sample were collected and sent to EPA’s OEME/NERL for analysis. None of the four field samples contained chlorpyrifos at concentrations exceeding the EPA AL (see Figure 3, Clearance Sample Results Diagram; and Table 2, Clearance Sampling Analytical Results). The SAP documenting clearance sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont [2].

3

4.0 REFERENCES



Appendix A

Figures



Appendix B

Tables


TABLE 1



SHREWSBURY, VERMONT

2564-01_ CharacterizationResultTable1.xlsx Page 1 of 1


D32470 Field Blank Field Blank. 10/24/2013 ND (0.0004)D32471 Living Room Southwest Corner Wall. 10/24/2013 0.12D32472 Living Room South Wall, West Above Window. 10/24/2013 0.0033D32473 Living Room West Wall, Above Southwest Corner. 10/24/2013 0.0096D32474 Living Room South Wall, Ceiling Above Window. 10/24/2013 0.0006D32475 Living Room South Wall, East Above Window. 10/24/2013 ND (0.0004)D32476 Living Room Southwest Corner. 10/24/2013 0.0063D32477 Living Room Wall Above Fireplace. 10/24/2013 ND (0.0004)

NOTES:


TABLE 2



SHREWSBURY, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\Phase 2\2564-01_ _ClearanceResultTable.xlsx Page 1 of 1


D32838 Field Blank Opened in Living Room. 5/9/2014 ND (0.004)D32839 Living Room (South Wall) SW corner next to baseboard, adjacent to D32476. 5/9/2014 ND (0.004)D32900 Living Room (South Wall) Above window, adjacent to D32475. 5/9/2014 ND (0.004)D32901 Living Room (West Wall) SW corner near roof start, adjacent to D32471. 5/9/2014 ND (0.004)D32902 Living Room (West Wall) 1st beam up from roof start, adjacent to D32473. 5/9/2014 ND (0.004)

NOTES:


Appendix M

Removal Program After Action Report for Residential Property 2049-01 Manchester, Vermont




RESIDENTIAL PROPERTY 2049-01 MANCHESTER, VERMONT

Prepared For:





TDD NO. TO1-01-15-07-0042

TASK NO. 0044

DC NO. R-00831

Submitted by:




June 2020

ii

TABLE OF CONTENTS

PAGE


1.0 INTRODUCTION .............................................................................................................. 1

2.0 BACKGROUND ................................................................................................................... 1


4.0 REFERENCES ................................................................................................................... 3

iii

LIST OF APPENDICES

Appendix A

Appendix B



1

1.0 INTRODUCTION


2.0 BACKGROUND





The property is a two-bedroom mobile home located in Manchester, VT (see Figure 1, Site Location Map). The property was treated by AAA for bedbugs with two pesticide applications. The dates of application were 21 July 2010 and 18 October 2010.

2

On 9 September 2013, VT AAFM conducted initial sampling for chlorpyrifos. Samples were analyzed at the VT State laboratory, and a maximum concentration of 0.0598 µg/cm2 was reported. This value exceeded the EPA AL of 0.006 µg/cm2. Therefore, further characterization sampling by EPA and START was conducted.

On 26 September 2013, EPA and START conducted characterization sampling. A total of 18 characterization samples and one quality assurance/quality control (QA/QC) field blank sample were collected and sent to EPA’s Office of Environmental Measurement and Evaluation (OEME) New England Regional Laboratory (NERL) for analysis. The Sampling and Analysis Plan (SAP) documenting initial and characterization sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pesticides Site, Rutland, Vermont [1].

Five of the 18 field samples contained chlorpyrifos at concentrations exceeding the EPA AL, with a maximum detected concentration of 1.7 µg/cm2 (see Figure 2, Characterization Sample Results Diagram; and Table 1, Characterization Sampling Analytical Results). Due to the elevated levels of chlorpyrifos present, an EPA Removal Action was deemed to be warranted.

On 7 May 2014, an inventory of all personal and household items in the mobile home unit was completed, and a Personal Property Disposition Agreement Form was signed by the property owner. On 22 May 2014, EPA and the Emergency Rapid Response Services (ERRS) contractor began conducting decontamination activities. All household items, furniture, possessions, and trash were removed from the unit for storage and/or disposal. Decontamination efforts included washing walls, countertops, appliances, and other surfaces with a water/detergent mixture; followed by three applications of the Sterilex® decontamination solution; and were completed with a water rinse. Any carpets, underlying carpet pads, and floors were vacuumed, and the carpets/pads removed. Following decontamination, restoration activities included installation of new carpeting and repainting of interior walls.

On 17 June 2014, EPA and START conducted clearance sampling. A total of six clearance samples and one QA/QC field blank sample were collected and sent to EPA’s OEME/NERL for analysis. None of the six field samples contained chlorpyrifos at concentrations exceeding the EPA AL (see Figure 3, Clearance Sample Results Diagram; and Table 2, Clearance Sampling Analytical Results). The SAP documenting clearance sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont [2].

3

4.0 REFERENCES



Appendix A

Figures



Appendix B

Tables


TABLE 1



MANCHESTER, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\Phase 2\2049-01_ _Characterization Results Table1.xlsx Page 1 of 1


D32025 Bedroom 1 (Wall) Heating duct on north wall, right of window. 9/26/2013 0.0138D32026 Bedroom 1 (Wall) West wall, behind bed. 9/26/2013 0.0014D32027 Bedroom 1 (Wall) East wall, above corner shelf. 9/26/2013 ND (0.0004)D32028 Bedroom 1 (Floor) Closet floor, close to south window. 9/26/2013 0.059D32029 Bathroom (Wall) Above sink. 9/26/2013 0.0068D32042 Bathroom (Wall) Behind toilet. 9/26/2013 0.058D32043 Mudroom (Wall) Next to socket near door. 9/26/2013 ND (0.0004)D32044 Hallway (Wall) Heating duct under window. 9/26/2013 0.0013D32045 Bedroom 2 (Wall) South wall, heating duct right of window. 9/26/2013 0.0036D32046 Bedroom 2 (Wall) East wall, behind bed. 9/26/2013 0.0019D32047 Field Blank Opened in hallway. 9/26/2013 ND (0.0004)D32048 Kitchen (Kickboard) Underneath sink. 9/26/2013 0.00078D32049 Kitchen (Wall) North wall, left of built-in cabinet. 9/26/2013 ND (0.0004)D32050 Living Room (Wall) North wall, behind sofa. 9/26/2013 ND (0.0004)D32051 Living Room (Wall) East wall, under window. 9/26/2013 0.00036D32052 Living Room (Wall) South wall, heating duct under window. 9/26/2013 0.0019D32053 Porch (Vinyl Siding) Under windows. 9/26/2013 ND (0.0004)D32054 Hallway (Wall) Left of bedroom #1 door. 9/26/2013 0.0013D32055 Bedroom 1 (Floor) Under rug along north wall, left of door. 9/26/2013 1.7

NOTES:



TABLE 2



MANCHESTER, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\Phase 2\2049-01_ 2049-01_Clearance Results Table2.xlsx Page 1 of 1


D32907 Field Blank Opened in living room. 6/17/2014 ND (0.0004)D32908 Living Room (Wall) South wall below window, adjacent to D32052. 6/17/2014 ND (0.0004)D32909 Kitchen (Kickboard) Below sink, adjacent to D32048. 6/17/2014 ND (0.0004)D32910 Bedroom 2 (Wall) Below window, adjacent to D32045. 6/17/2014 ND (0.0004)D32911 Bathroom (Wall) Above toilet, adjacent to D32042. 6/17/2014 ND (0.0004)D32912 Bedroom 1 (Wall) Below window, adjacent to D32025. 6/17/2014 ND (0.0004)D32913 Bedroom 1 (Wall) Closet wall, left of phone jack, adjacent to D32028. 6/17/2014 ND (0.0004)

NOTES:



Appendix N

Removal Program After Action Report for Residential Property 1037-01 Hydeville, Vermont




RESIDENTIAL PROPERTY 1037-01 HYDEVILLE, VERMONT

Prepared For:





TDD NO. TO1-01-15-07-0042

TASK NO. 0044

DC NO. R-00829

Submitted by:




June 2020

ii

TABLE OF CONTENTS

PAGE


1.0 INTRODUCTION .............................................................................................................. 1

2.0 BACKGROUND ................................................................................................................ 1


4.0 REFERENCES ................................................................................................................... 3

iii

LIST OF APPENDICES

Appendix A

Appendix B

Figures Figure 1 – Site Location Map (Redacted)Figure 2 – Characterization Sample Results Diagram, First Floor Figure 3 – Characterization Sample Results Diagram,

Second Floor Figure 4 – Clearance Sample Results Diagram, First Floor Figure 5 – Clearance Sample Results Diagram, Second Floor


1

1.0 INTRODUCTION


2.0 BACKGROUND





The property is a two-bedroom home located at Hydeville, VT (see Figure 1, Site Location Map). The property was treated by AAA for fleas with one pesticide application. The date of application was 29 December 2011.

2

On 16 October 2013, VT AAFM conducted initial sampling for chlorpyrifos. Samples were analyzed at the VT State laboratory, and a maximum concentration of 0.3703 µg/cm2 was reported. This value exceeded the EPA AL of 0.006 µg/cm2. Therefore, further characterization sampling by EPA and START was conducted.

On 30 October 2013, EPA and START conducted characterization sampling. A total of 16 characterization samples and one quality assurance/quality control (QA/QC) field blank sample were collected and sent to EPA’s Office of Environmental Measurement and Evaluation (OEME) New England Regional Laboratory (NERL) for analysis. The Sampling and Analysis Plan (SAP) documenting initial and characterization sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pesticides Site, Rutland, Vermont [1].

All 16 of the field samples contained concentrations of chlorpyrifos exceeding the EPA AL, with a maximum detected concentration of 1.21 µg/cm2 (see Figures 2 and 3, Characterization Sample Results Diagrams, First Floor and Second Floor, respectively; and Table 1, Characterization Sampling Analytical Results). Due to the elevated levels of chlorpyrifos present, an EPA Removal Action was deemed to be warranted.

On 6 May 2014, an inventory of all personal and household items in the unit was completed, and a Personal Property Disposition Agreement Form was signed by the property owner.

On 14 May 2014, EPA and the Emergency Rapid Response Services (ERRS) contractor began conducting decontamination activities. All household items, furniture, possessions, and trash were removed from the unit for storage and/or disposal. Decontamination efforts included washing walls, countertops, appliances, and other surfaces with a water/detergent mixture; followed by three applications of the Sterilex® decontamination solution; and were completed with a water rinse. Any carpets, underlying carpet pads, and floors were vacuumed, and the carpets/pads removed. Following decontamination, restoration activities included installation of new carpeting and repainting of interior walls.

On 25 June, 2 July, and 11 July 2014, EPA and START conducted clearance sampling. A total of nine clearance samples and one QA/QC field blank sample were collected and sent to EPA’s OEME/NERL for analysis. None of the nine field samples contained chlorpyrifos at concentrations exceeding the EPA AL (see Figures 4 and 5, Clearance Sample Results Diagrams, First Floor and Second Floor, respectively; and Table 2, Clearance Sampling Analytical Results). The SAP documenting clearance sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont [2].

3

4.0 REFERENCES



Appendix A

Figures

Figure 1 - Site Location Map (Redacted)Figure 2 - Characterization Sample Results Diagram, First Floor

Figure 3 – Characterization Sample Results Diagram, Second Floor Figure 4 – Clearance Sample Results Diagram, First Floor

Figure 5 – Clearance Sample Results Diagram, Second Floor

Appendix B

Tables


TABLE 1

AAA ACCREDITED PEST CONTROL SITECHARACTERIZATION SAMPLING ANALYTICAL RESULTS


HYDEVILLE, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\Phase 2\1037-01_ _Hydeville_CharacterizationResultsTable1.xlsx Page 1 of 1


D32572 Kitchen (Baseboard) Under sink, collected in same location as VT sample 2103. 10/30/2013 0.025D32573 Kitchen (Baseboard) Left of dishwasher. 10/30/2013 0.033D32574 Dining Room (Wall/Baseboard) West wall, right of grandfather clock. 10/30/2013 0.138D32575 Dining Room (Floor) In front of grandfather clock. 10/30/2013 1.21D32576 Living Room (Wall) Above closet door in entrance between living room and kitchen. 10/30/2013 0.057D32577 Living Room (Wall/Baseboard) West wall, around outlet. Left of built-in cabinet. 10/30/2013 0.269D32578 Living Room (Wall/Baseboard) South wall, left of door. 10/30/2013 0.365D32579 Bathroom (Wall/Baseboard) First floor, right of toilet. 10/30/2013 0.246D32581 Bedroom (Wall/Baseboard) South wall, middle. 10/30/2013 0.115D32582 Bedroom (Wall) East wall, right of closet area. 10/30/2013 0.028D32583 Bathroom (Wall) Second floor, west wall, between bathtub and toilet. 10/30/2013 0.056D32584 Green Room (Wall) North wall, left of door. 10/30/2013 0.028D32585 Green Room (Wall) East wall, right of window. 10/30/2013 0.039D32586 Office (Wall/Baseboard) North wall, below gun rack. 10/30/2013 0.201D32587 Office (Wall) West wall, above comptuer desk. 10/30/2013 0.0084D32588 Stairway (Wall/Moulding) Left of small divider. 10/30/2013 0.072D32589 Field Blank Opened in dining room. 10/30/2013 ND (0.0004)

NOTES:



TABLE 2



HYDEVILLE, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\Phase 2\1037-01_ _Hydeville_ClearanceResultsTable2.xlsx Page 1 of 1


D32914 Field Blank Opened in kitchen. 6/25/2014 ND (0.0004)D32925 Kitchen (Kickboard) Left of dishwasher, adjacent to D32573. 7/2/2014 ND (0.0004)D32916 Dining Room (Floor) In front of grandfather clock, adjacent to D32575. 6/25/2014 ND (0.0004)D32917 Living Room (Wall) South Wall, left of front door adjacent to D32578. 6/25/2014 ND (0.0004)D32932 Bathroom (Wall/Baseboard) First floor, right of toilet, adjacent to D32579. 7/11/2014 ND (0.0004)D32919 Bathroom (Wall) Second floor, between bathtub and toilet, adjacent to D32583. 6/25/2014 ND (0.0004)D32920 Stairway (Wall/Moulding) Left of divider, adjacent to D32588. 6/25/2014 ND (0.0004)D32921 Bedroom (Wall/Baseboard) South wall, adjacent to D32581. 6/25/2014 ND (0.0004)D32922 Office (Wall/Baseboard) North wall below gun rack, adjacent to D32586. 6/25/2014 ND (0.0004)D32923 Green Room (Wall) East Wall, right of window, adjacent to D32585. 6/25/2014 ND (0.0004)

NOTES:



Appendix O

Removal Program After Action Report for Residential Property West Danby, Vermont




RESIDENTIAL PROPERTY 1179-99 WEST DANBY, VERMONT

Prepared For:





TDD NO. TO1-01-15-07-0042

TASK NO. 0044

DC NO. R-00830

Submitted by:




June 2020

ii

TABLE OF CONTENTS

PAGE


1.0 INTRODUCTION .............................................................................................................. 1

2.0 BACKGROUND ................................................................................................................... 1


4.0 REFERENCES ................................................................................................................... 3

iii

LIST OF APPENDICES

Appendix A

Appendix B

Figures Figure 1 – Site Location Map (Redacted)Figure 2 – Characterization Sample Results Diagram, First Floor Figure 3 – Characterization Sample Results Diagram,

Second Floor Figure 4 – Clearance Sample Results Diagram, Second Floor


1


2.0 BACKGROUND The AAA Accredited Pest Control Site (the site) includes residences in Rutland, Vermont (VT) and in surrounding communities where AAA Accredited Pest Control (AAA), a local exterminator, applied chlorpyrifos in indoor settings.



3.0 SITE DESCRIPTION AND NARRATIVE CHRONOLOGY The property is a four-bedroom home located West Danby, VT (see Figure 1, Site Location Map). The property was treated by AAA for cluster flies with one pesticide application. The date of application was 7 November 2012.

2

On 25 October 2013, VT AAFM conducted initial sampling for chlorpyrifos. Samples were analyzed at the VT State laboratory, and a maximum concentration of 0.0103 µg/cm2 was reported. This value exceeded the EPA AL of 0.006 µg/cm2. Therefore, further characterization sampling by EPA and START was conducted. On 13 November 2013, EPA and START conducted characterization sampling. A total of 19 characterization samples and one quality assurance/quality control (QA/QC) field blank sample were collected and sent to EPA’s Office of Environmental Measurement and Evaluation (OEME) New England Regional Laboratory (NERL) for analysis. The Sampling and Analysis Plan (SAP) documenting initial and characterization sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pesticides Site, Rutland, Vermont [1]. Nine of the 19 field samples contained chlorpyrifos at concentrations exceeding the EPA AL, with a maximum detected concentration of 0.053 µg/cm2 (see Figure 2, Characterization Sample Results Diagram; and Table 1, Characterization Sampling Analytical Results). All samples that exceeded the EPA AL were located on the second floor of the residence. Due to the elevated levels of chlorpyrifos present, an EPA Removal Action on the second floor was deemed to be warranted. On 21 May 2014, an inventory of all personal and household items on the second floor of the unit was completed, and a Personal Property Disposition Agreement Form was signed by the property owner. On 3 June 2014, EPA and the Emergency Rapid Response Services (ERRS) contractor began conducting decontamination activities. All household items, furniture, possessions, and trash were removed from the second floor of the unit for storage and/or disposal. Decontamination efforts included washing walls, countertops, appliances, and other surfaces with a water/detergent mixture; followed by three applications of the Sterilex® decontamination solution; and were completed with a water rinse. Any carpets, underlying carpet pads, and floors were vacuumed, and the carpets/pads removed. Following decontamination, restoration activities included installation of new carpeting applying a new coat of polyurethane to the hardwood floors, and repainting of interior walls. On 9 July 2014, EPA and START conducted final clearance sampling. A total of four clearance samples and one QA/QC field blank sample were collected and sent to EPA’s OEME/NERL for analysis. None of the four field samples contained chlorpyrifos at concentrations exceeding the EPA AL (see Figure 3, Clearance Sample Results Diagram; and Table 2, Clearance Sampling Analytical Results). The SAP documenting clearance sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont [2].

3

4.0 REFERENCES 1. Weston Solutions, Region I, Superfund Technical Assessment & Response Team III. United




Appendix A

Figures

Figure 1 - Site Location Map (Redacted)Figure 2 - Characterization Sample Results Diagram, First Floor

Figure 3 - Characterization Sample Results Diagram, Second Floor Figure 4 - Clearance Sample Results Diagram, Second Floor

D32562

0·0007 Master Bedroom

Master Bathroom

Mud Room

CHLORPYRIFOS ACTION LEVELS:

VERMONT LEVEL OF CONCERN 0.0004

EPA ACTION LEVEL0.006

A

NOT DETECTED

(ND)

I B C I C

0.004

D

0.04

Living Room

WEST DANBY, VERMONT

Characterization Sampling

First Floor

Porch

Dining Room

Kitchen

TV

Room

D32600

0.0018 •

c::::::J

L'.:] •• •

D32569 •

0.0038

LEGEND

Window

Door

Sample below EPA and VT Action Level

Sample above VT Action Level of 0.0004

Sample above EPA Action Level of 0.006 Note: All chlorpyrifos results are reported in micrograms per square centimeter (µg/cm2).

AAA Accredited Pest Control Site EPA Region I

NOTE: ORA WING NOT TO SCALE

TDD: TOl-01-15-07-0042

�-Author: ST ART Region 1

Superfund Technical Assessment and

Date: February 2018 Response Team (START) IV

Contract No. EP-S3-15-01

Figure 2 Characterization Sample Results Diagram, First Floor

Property ID: 1179-99

West Danby, Vermont

D32564 0.00039

•

D32565 0.0013

Loft


VERMONT LEVEL

OF CONCERN 0.0004

A

NOT DETECTED

(ND)

I B

0.004


C I C D

0.04

WEST DANBY, VERMONT

Characterization Sampling

Second Floor

D32561 • 0.0052 Bedroom

2

D32552 0.05

Bedroom

4

Bathroom 03255

D32553..._ 0.0076

..._ D32560 0.018

D32559 0.0076

....

..._ 0.053 D32554

0.035

D32558 0.045

....

Bedroom

3

D32557 0.017

D32556 0.032 ..._

LEGEND

c:::::::::J Window

L] Door

Note: All chlorpyrifos results are reported in micrograms per square centimeter (µg/cm2).

•

•

.&



Sample above EPA Action Level of 0.006

TDD: TOl-01-15-07-0042 Author: ST ART Region 1 Date: February 2018

AAA Accredited Pest Control Site

Figure 3 Characterization Sample Results Diagram, Second Floor


West Danby, Vermont



NOTE: DRAWING NOT TO SCALE

�.

I Loft


VERMONT LEVEL OF CONCERN 0.0004

A

NOT DETECTED

(ND)

B

0.004


C C

I •

ID32928

1 ND

D

0.04

WEST DANBY, VERMONT

Clearance Sampling

Second Floor

-

�-D

Bathroom

['\ c_

Bedroom

4

-

Bedroom

2

·ID329301ND

(1

\_j Bedroom

3

·10�29

1

LEGEND

c::::::J Window

LJ Door

• • ...



Sample above EPA Action Level of 0.006

Note: All chlorpyrifos results are reported in micrograms per square centimeter (µg/cm2).

TDD: TOl-01-15-07-0042 Author: ST ART Region 1 Date: February 2018

AAA Accredited Pest Control Site

Figure 4 Clearance Sample Results Diagram, Second Floor


West Danby, Vermont



NOTE: DRAWING NOT TO SCALE

�.

Appendix B

Tables


TABLE 1

CHARACTERIZATION SAMPLING ANALYTICAL RESULTS AAA ACCREDITED PEST CONTROL SITE


WEST DANBY, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\Phase 2\1179-99_ _CharacterizationResultsTable1.xlsx Page 1 of 1


D32552 Bedroom 2 (Wall) Right window frame and wall. 11/13/2013 0.05D32553 Bedroom 2 (Window) Window sill, center. 11/13/2013 0.0076D32554 Bedroom 2 (Wall) Behind table. 11/13/2013 0.035D32555 Bedroom 2 (Wall) Under light switch. 11/13/2013 0.053D32556 Bedroom 3 (Wall/Baseboard) Under window between beds. 11/13/2013 0.032D32557 Bedroom 3 (Window) Window sill, facing driveway. 11/13/2013 0.017D32558 Bedroom 3 (Wall) Door frame and wall, left of switch. 11/13/2013 0.045D32559 Bedroom 4 (Window) Frame, left of window facing driveway. 11/13/2013 0.0076D32560 Bedroom 4 (Wall) Left of bed under window. 11/13/2013 0.018D32561 Bathroom (Floor) Left of toilet. 11/13/2013 0.0052D32562 Master Bedroom (Wall) Right window, under center. 11/13/2013 0.0007D32563 Master Bedroom (Wall) Wall and frame, center of door. 11/13/2013 0.0012D32564 Loft (Window) Window frame, under right window in built-in shelf. 11/13/2013 0.00039D32565 Loft (Wall) Right of window facing backyard. 11/13/2013 0.0013D32566 Living Room (Door) Door frame, left of door by stairs. 11/13/2013 0.0018D32567 Front Door (Wall/Sill) Window sill and wall, right of door. 11/13/2013 0.0012D32568 Kitchen (Counter) Backsplash behind toaster, right of window. 11/13/2013 ND (0.0004)D32569 TV Room (Wall) Right of window on north wall. 11/13/2013 0.0038D32600 TV Room (Wall) Wall and sill, right window by front entrance, below center. 11/13/2013 0.0018D32601 Field Blank Opened in living room. 11/13/2013 ND (0.0004)

NOTES:



TABLE 2

CLEARANCE SAMPLING ANALYTICAL RESULTS AAA ACCREDITED PEST CONTROL SITE


WEST DANBY, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\Phase 2\1179-99_ _ClearanceResultsTable2.xlsx Page 1 of 1


D32926 Field Blank Opened in bathroom. 7/9/2014 ND (0.0004)D32927 Bathroom (Floor) Left of toilet. 7/9/2014 ND (0.0004)D32928 Bedroom 4 (Wall) Left of bed under window. 7/9/2014 ND (0.0004)D32929 Bedroom 3 (Wall) Doorframe and wall, left of light switch. 7/9/2014 ND (0.0004)D32930 Bedroom 2 (Wall) Under light switch. 7/9/2014 ND (0.0004)

NOTES:



Appendix P






Prepared For:





TDD NO. TO1-01-15-07-0042

TASK NO. 0044

DC NO. R-00828

Submitted by:




June 2020

ii

TABLE OF CONTENTS

PAGE


1.0 INTRODUCTION .............................................................................................................. 1

2.0 BACKGROUND ................................................................................................................... 1


4.0 REFERENCES ................................................................................................................... 3

iii

LIST OF APPENDICES

Appendix A

Appendix B

Figures Figure 1 – Site Location Map (Redacted)Figure 2 – Clearance Sample Results Diagram

Tables Table 1 – Initial Sampling Analytical Results Table 2 – Clearance Sampling Analytical Results

1

1.0 INTRODUCTION


2.0 BACKGROUND





The property is a two-bedroom apartment located in Rutland, VT (see Figure 1, Site Location Map). The property was treated by AAA for bedbugs with two pesticide applications. The dates of application were 12 February 2013 and 11 December 2013.

2

On 29 July and 19 August 2013, VT AAFM conducted initial sampling for chlorpyrifos. Samples were analyzed at the VT State laboratory, and a maximum concentration of 0.0303 µg/cm2 was reported. This value exceeded the EPA AL of 0.006 µg/cm2. Therefore, further characterization sampling by EPA and START was deemed to be warranted. However, subsequent to the final sampling event conducted by VT AAFM on 19 August 2013, the landlord refurbished the apartment. The actions taken by the landlord were consistent with the cleanup guidance developed by the State of Vermont for homeowners. As such, EPA prepared to conduct clearance sampling to determine whether the landlord’s actions were effective in reducing the risk posed by residual chlorpyrifos. On 16 April 2014, EPA and START conducted clearance sampling. A total of three clearance samples and one QA/QC field blank sample were collected and sent to EPA’s OEME/NERL for analysis. None of the three field samples contained chlorpyrifos at concentrations exceeding the EPA AL, and no further action by EPA was warranted (see Figure 2, Clearance Sample Results Diagram; and Table 2, Clearance Sampling Analytical Results). The SAP documenting clearance sampling was prepared as a separate document, entitled Sampling and Analysis Plan for the AAA Accredited Pest Control Removal Action Sites, Post-Removal Action Clearance Sampling, Rutland, Vermont [2].

3

4.0 REFERENCES



Appendix A Figures

Figure 1 - Site Location Map (Redacted)Figure 2 - Clearance Sample Results Diagram

Appendix B

Tables

Table 1 - Initial Sampling Analytical Results Table 2 - Clearance Sampling Analytical Results

TABLE 1

INITIAL SAMPLING ANALYTICAL RESULTSAAA ACCREDITED PEST CONTROL SITE


RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\Phase 2\1009-04_ _Characterization_VTInitial.xlsx Page 1 of 1


11C 3938 Field Blank --- 8/19/2013 ND (0.0003)11C 3939 Wall/Baseboard Master bedroom closet 8/19/2013 0.030311C 3940 Wall/Baseboard Kids bedroom closet 8/19/2013 0.000311C 3941 Baseboard heater Kids bedroom 8/19/2013 ND (0.0003)

3072913-10 Field Blank --- 7/29/2013 ND (0.0003)3072913-11 Wall/Baseboard Bedroom, behind door 7/29/2013 0.000383072913-12 Wall/Baseboard Living room, behind couch 7/29/2013 ND (0.0003)3072913-13 Shelf Kitchen, behind shelves 7/29/2013 ND (0.0003)

NOTES:

Samples analyzed by State of Vermont Department of Health Laboratory.All results in micrograms per square centimeter (µg/cm²).ND = Not Detected (reporting limit in parentheses). Bolded and light shaded results exceed the Vermont Department of Health Action Level of 0.0004 µg/cm2.Bolded and dark shaded results exceed the EPA Removal Program Action Level of 0.006 µg/cm2.

TABLE 2



RUTLAND, VERMONT

R:\TO1_15070042\Property Folders-Updated_START4\Phase 2\1009-04_ 1009-04_Clearance.xls Page 1 of 1


D32834 Field Blank Opened in kitchen 4/16/2014 ND (0.0004)D32835 Bedroom (Closet) South wall of closet 4/16/2014 ND (0.0004)D32836 Bedroom (Closet) South wall, east of closet door 4/16/2014 ND (0.0004)D32837 Bedroom (Closet) South wall, west of closet door 4/16/2014 ND (0.0004)

NOTES:



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