UnlMS&M
Environmental ProtBction
Ag«nsy
Office o«
Emergency and
Ronvdial Rmponsa
EPA/ROO/R03-89/073
June 1989
3EPA
Superfund
Record of Decision
Publicker/Cuyahoga Wrecking, PA
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REPORT DOCUMENTATION 1" REPORT NO. 1 ~ I. A8c1pieN'a Aca8Ion NIl.
PAGE. EPA/ROD/R03-89/073
4. TI88 and ..... 5. A8part 0.18
SUPERFUND RECORD OF DECISION 06130/89
Publicker/Cuyahoga Wrecking, PA
First Remedial Action I.
7. Authar(.) .. PIIrfonnlng OrganlDlIon IWp&. No.
g. PIIrforming Org8InIza1Ion M8m8 and AddI8u 10. ProjldlTuklWoril UnI1 No.
11. ContracqC) 01 Grant(G) NIl.
(e)
(G)
12. ~ng Orpnlullon Nama and Addreu 11. Typa 01 R~" Pariod Co.«'"
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
washington, D.C. 20460 14.
15. SUppl8m8n1aJy No..
II. Ab8lraC1 (UnlIt: 200 _Ida)
The Pub licker/Cuyahoga Wrecking site is a 37-acre, abandoned manufacturing plant in
Philadelphia, pennsylvania. A chemical company lies to the north, a marine terminal to
the south, and the Delaware River to the east. Although the immediate area surrounding
the site is primarily industrial, approximately 400,000 people live within one mile of
~ the site. From 1912 to 1985, Publicker Industries owned and operated a liquor and
industrial alcohol manufacturing plant at the site. The plant included 440 large
tanks, storage drums, product stock, chemical laboratories, reaction vessels,
production buildings, warehouses, a power plant, and several hundred miles of above-
and below-ground process lines. Petroleum was also stored o~site during the late 19705
and the early 19805. Publicker Industries discontinued operations and sold the
property in 1986. EPA evaluated site conditions in 1987 following two explosions and a
large fire. Tankers, pits/sumps, and numerous process lines were found to contain fuel
oils or other contaminated oils. EPA initiated an emergency removal action in December
1987 to stabilize the site and control the threat of additional fires and explosions.
Emergency removal activities included onsite bulking and storing of solid and liquid
waste streams; disposing of highly reactive laboratory wastes and cylinders offsite;
crushing approximately 3,100 emptied drums; wrapping overhead pipelines insulated with
(See Attached Sheet)
17. ~1 An8IyaIa .. 0.. ~
Record of Decision - Publicker/Cuyahoga Wrecking, PA
First Remedial Action
Contaminated Media: soil, gw
Key Contaminants: VOCs, other organics (PCBs, pesticides).
b. Id8nIl~T-
Co COSA 11 RaldlGrcql
18. ".III8IIIIty....... 18. SacurIty CI- (ThI8 A8part) 21. NIl. of Pagn
None 58
2D. SecurIty CI... (Thia Page) 21. Price
Nnn.,.
(4.77)
50272-101
(Sea ANSl-Z3g.18)
s..IM~Ii- on ~W...
(Formatly N11$-35)
~1 01 Commerce
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OPTIONAL FORM 272 BACK
(4-77)
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£PA/ROD/R03-89/073
Publicker/Cuyahoga Wrecking, PA
First Remedial Action
16.
Abstract (continued)
asbestos: and implementing a 24-hour fire and security watch. According to EPA
estimates, over one million gallons of bulked waste materials remain onsite stored in
dilapidated tanks and drums. Twelve waste streams have been identified, including base
neutral liquids and solids, organic liquids and solids, oxidizing liquids and solids,
water reactives, chlorides, crushed empty metal drums, and contaminated oils. This
remedial action is designed to stabilize the site and enable continued site cleanup of
soil, ground water, and asbestos. The primary contaminants of concern affecting the soil
and ground water are VOCs, and other organics including PCBs and pesticides.
The selected remedial action for this site includes offsite treatment and disposal of
the various waste streams in RCRA-permitted facilities: demolition of above-ground
process lines, with proper packaging of contaminated insulation and onsite storage
pending disposition in a subsequent remedial action; and offsite disposal of hazardous
chemicals recovered from within the lines. The estimated capital cost for this re~edial
action is $13,900,000: there are no O&M costs.
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Declaration For TIle Record Of Decision
Site NaIre and Location
Pub1icker IndUstries site
City of PhiladelIilia, PhiladelIilia Cotmty, Pennsylvania
Site Stabilization Operable unit
StatE!Te1t of Puroose
TIlis decision doc1..ment represents the selected remedial
action for this site developed in accordance with the Carpre-
hensive Environmental Resp:mse, CCJTp:!nSation am Liability
.act of 1980 (CERCIA), as azrended by the SUperfurn Anednents
and Reauthorization Act of 1986 (SMA), am to the extent
practicable, the National Contingency Plan (N:P).
Statanent of Basis
TIlis decision is based lJIX)n the administrative record
(index attached). 'I11e attached index identifies the itE!11S
which comprise the administrative record t.qX)n which the
selection of a remedial action is based.
TIle Ccmronwealth of Pennsylvania concurs with the selected
renedy. A copy of the concurrence letter is attached.
Description of the selected ReoodY
TIlis initial operable tmit was developed to protect human
health and the envirOJIlI.aat by eliminating the present threat
of fire am/or explosion as a result of known potentially
hazardous chanicals am other chemical catp:)l1l'X1s on-site.
'Ihe selected remedial action will enable the site cleanup,
which began as a ren:JVal action, to continue, utilizing
remectial ~<>::t"am fuming in place of anergerry ramval program
dollars. 8J.lked ha.zarcbJs/flanmable waste streams will be
transported off-site ani will urxiergo treatDe1t ani disposal
at permitted Resource conservation ani Recovery kt: (ICRA)
facilities.
SUbsequent investigations into other operable units ad1ressing
the soi 1, grOl.IB1 water am asbestos contamination at the
si te are forthcaning.
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'Ihe major <::aTp:>nents of the selected remedy are as follows:
.. Tr~rtation and off-site disp:>sal of the known renaining
on-site waste streams to permitted RCRA facilities.
* Daroli tion of a.OO~ade process lines that traverse the
site. This may include the recovery of unknown hazardous
chemicals and the removal of pipe insulation materials
such as asbestos-containing materials. Dismantled process
lines will renain on-site until future site remedial actions
are performed.
* Proper paCkaging of the insulation materials removed from
the process lines. Insulat ion materials, including asbestos,
will be properly stored on-site until future site remedial
actions are performed.
* 'I'ransp:>rtation and off-site disp:>sal of hazardous chemicals
recovered from within the process lines to permitted RCRA
facilities.
Declaration
The selected rarmy is protective of human health and
the envirorunent, attains Federal and State requirements
that are applicable or relevant and appropriate for this
remedial action and is cost-effective. This rarmy satisfies
the statutory preference for remedies that anploy treatment
that reduces toxicity, rrobility, or volume as a principal
el~t and utilizes pernanent solutions and alternative -
treatment (or resource recovery) technologies to the maxirrn..Irn
extent practicable.
b(Jo {81
Date
B---f3 f!~
Fdwin B. Erickson'
Regional Mninistrat~r
Region III
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Remedial Alternative Record of Decision SUmnary
Publicker Industries Site
Introduction
This initial Record of Decision (ReD) for the
Publicker Industries Site will focus on eliminating
the rrost imnediate p:7tential threats to human health anj
the envirOTlItE1t which continue to exist at the site. 'lhese
threats include pJtential fire and/or explosion fran known
pJtentially hazardoUs chemicals and other chemical cc:rrp:>urds
on-site.
This selected renec1ial action will enable EPA to
continue the cleanup which began as a rarDVal action at the
site, utilizing ranedial program furxling in place of rE!TDVal
program oollars.
A Renedial Investigation/Feasibility Study (RI/FS) of
the site is currently scheduled to begin in August 1989.
This study will identify the nature and extent of contamination
to area soils and groun::l water. Based on the data collected
during the RI, several Focused Feasibility Study (FFS)
rep:>rts may be developed to act1ress each contaminated media.
SUbsequent RCDs wi 11 be prepared to aa:!ress these issues.
Si te Location anj Description
The Publicker In:h.1stries Site is located in the
southeast p:>rtion of the City of Philadel~ia, Pennsylvania
(see Figure l). 'n1e site is bordered to the east by the
De laware River, to the oorth by the Ashlani Qlanical Coopany,
to the south by the Packer Marine Terminal and New Orleans
Cold Storage, ani to the west by Delaware AvernJ.e. '!he site
is adjacent to ani urxler the Walt Whitman Bridge which
spans the Delaware River fran Phila:1elpUa to New Jersey.
'lbe area. is primarily in:1ustriali oowever, there are
major pcpllatioo centers within one mile. In aa:lition,
there are several buSinesses (primarily food plants) ,
the Philadelprla Naval shipyard, t~ large outOOor SlX>rts
Arenas and Interstate 95 in close proximity. Center city
Philadelprla is ~tely t~ miles fran the site.
Within three-quarters of a mile are the cities of :Gloucester
and CaIrden, New Jersey.
An estimated pJpllation of 400,000 people lives within
a.wroximately one mile of the site. 'lhree scmols am t~
hospitals are located within a one and one-half mile radius
of the site.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION HI
FIGURE 1
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Publicker Industries had operated a liquor and
irxlustrial alcorol distillation process at the site until
approximately three years ago. The site is awroxi.ma.tely
37 acres in area and iocludes nearly 440 large tanks, storage
drumS, product stock, chanical laboratories, reaction vessels,
production buildings, warehouses, a pJWer plant and an
estim3.ted several h\..Irrlred miles of above- an:i belOlN-grourd
process lines. The general layout of the site an:i surrourning
area is shown on Figure 2.
Many of the existing structures have deteriorated due
to weather, fire and neglect. '!he facility has three water-
front piers that exterxi into the Delaware River.
Nineteen deep production wells (see Figure 2), ranging
in depth fran 150 to 200 feet, are rep:>rted to exist on the
site property. (011y 15 of the 19 wells have been located
fran existing site maps.) These deep wells were installed
40 to 50 years ago to supply cooling water to heavy equipnent
at the facility.
In June of 1987, the carbOn dioxide utilization IX>rtion
of the facility was destroyed in a nulti-alann fire. DJring
the fire, m..merous explosions and fire flares were rep:>rted
which led fire officials and the U.S. EmrirOlflerltal Protection
Agercy (EPA) anergercy respJnSe persormel to believe that
chanical products were still present at the facility.
An initial site inspection was coOOucted by EPA and its
~rt staff on July 9, 1987. City of Philadelphia
representatives were also on-site to inspect IX>rtions of
the facility which were rot affected by the fire. M.lnerous
spi 11 areas, ilTproper drtmt storage and leaking process lines
were observed by the inspection team. A sheen, originating
fran the site was ~ent in the waters of the Delaware
River.
Tanks, pits/5t1I'IP3, and IUJmerous process lines on-site
were fourxl to cattain fuel oils or other contaminated oils.
(Pesticides am volatile organic catp)UI'Xis rot camonly
fO\.IOO in fuel oils have been identified as cont.aminants in
sane of tbese oils.) EPA has deternUned that a major
quantity of this cattaminated oil is contained in 1.D1SOUI1d
storage vessels (leaking pipelines' am tanks), It has been
estiITated that 252,000 gallons of unsecured contaminated
oil had been previously stored on-site.
In add.i tion to these waste products, further inspections
and inventories have identified srock-sensitive an::! explosive
materials througtw:Jut the facility.
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BIGLER S1.
w
~LlO
gD
1
(-
li~
I
~
COM~~N~P;o~[OO 0 od
00 gD- 00
I - Dr
-,
I
I
WL-
- -PACKER AVE.- -
~L
I
r ---. I
f- -:. --- - - - '-, r-I
r II I
I I I I
w
-----
.
.
I PIER 103 \
~~SLlP . .-
PIER 104.
BURNED 6/26/87
fORMER SUI'>
PIER 105
SLIP
PIEH 106
.
SLIP
SLIP
PIER 108
BASIN
PIER 109
WALT WHITMAN BRIDGE
KEY
. DEEP WATER WELLS
DELAWARE
IlIVER
FIGURE 2
. Publicker Industries
..--...----.----
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TankS containing spent grain material frcm the whiskey
manufacturing operation have been detennined by EPA to contain
~rox:i11ately 70,000 gallons of reactive and flamnable layers/
~ that exhibit RCW\ hazardous waste characteristics
(i.e., ignitability, corrosivity, reactivity, EP toxicity).
These tanks contain residual grain materials collected fran
fermentation tanks and grain dryers. Analysis of these
tanks shoWs that layer's of flanma..ble (flash {X>int less than
140 degrees Fahrenheit) ard reactive materialS are present.
Site Historv
Publicker Industries, Inc. is a publicly held corporation
head:Iuartered in Greenwich, connecticut. Fran ~roxirnately
1912 to late 1985, Publicker owned anj operated a liquor anj
industrial alcohol manufacturing plant at the site. The
Publicker facility femented {X>tatoes, rrolasses, corn, am
various grains, am distilled the alcohols. '!he alcohols were
used in l'1t.merous products including whiskey, SOlvents,
cleansers, anti freeze, anj rubbing alcohol. '!he plant' 5
production peaked during Vbrld War II am again in the
19705. ruring these prosperous tines, the plant erployed
over 1,000 people. '!he site was also utilized as a petroleum
product storage facility during the late 19705 and early
19805.
Plant operations had been in decline sin:e the late
19705 arrl arploynent had decreased to 5 people before Publicker
discontinued operations in February 1986. In 1986, Publicker
sold the property to CNerland COrporation, a subsidiary of
CUyahoga Wrecking Corporation.
ruring darolition activities, tw CUyaOOga atployees
were killed by an explosion which resulted fran the cutting
of a process line with a torch. SOOrtly after this in:ident,
Overland COrporation declared banknJptcy am. aban::Ioned the
facility. '!he property is currently being aaninistered by
a banknJptcy trustee.
In J\.D1e 1987, a p)rtion of the facility was destroyed
in a nulti-alarm fire during which numeroos explosions am.
fire flareS were reported. Following the fire, EPA Emergency
RespJIlSe Personnel evaluated the site arrl determined imnediate
measures were required to control arx1 stabilize site conlitions.
Prior EPA 51 te 1'cti vi ties
Q1 5epterber 4, 1987, EPA and Publicker IrxhJstries entered
into a Consent Order urx:ler Section 106 of the Catprehensive
Envi rOll1l1e1ltal RespJnse, CC%ft:IenSa.tion anj Liability ~ (CERCIA),
as amen:ied, 42 U.S. C . section 9606. t.Jn:Ier the COnsent Order,
Publicker hired O.H. Materials of Finney, CIlio to perfonn
site stabilization measures. 'n1ese measures focused on assessing
the site am. identifYing the preserx:e and nature of hazaroous
substances at the site.
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en Deceroer 8, 1987, an EPA si te-safety coordinator
conduCted a site inspection of the facility. During this
visual inspection, it was determined that site comitions
cont inued to present threats to human health and the
envirorn.elll. An EPA. on-scene coordinator (C6C) i.rmediately
initiated a raroval action using CERCIA energency funis.
During an Emergency Raroval Action, EPA significantly
stabilized cOnditions at the site by aa:n-essing the various
fire and explosion threats. Wherever FOssible, solid and
liquid waste streams were bulked on-site an:1 stored for
future disp:>sal. Highly reactive lab wastes an:1 cylinders
were trans1X>rted off-site for disp:>sal. All materials
raroved fran the site were traJ1SFOrted to facilities regulated
under the Resource Conservation an:1 Recovery Act (RCRA) an:1
the 'Ibxic SUbstances Control Act (TSCA). Approximately
3,100 arptied drums were crushed on-site after tulking
operations were cCltlpleted. Overhead pipelines insulated
with asbestos coverings were wrapped with plastic where
necessary to abate the FOtential for the airoome release
of friable asbestos material. Asbestos droR>ings aID piles
randanly located througoout the site were bagged aID stored
on-site. Buildings which were fOtJl'}j to contain asbestos
were secured aID waITling signs FOsted. A 51..mtT\aI'Y of all
prior ~ raroval program activities are presented in Table 1.
To deter trespassing and unautOOrized entry and exit
of vehicles at the site, coocrete barriers and s:now fencing
were installed along Packer and Delaware Avenues.
Emergency raroval activities ended on DeceTIber 16,
1988, due to the lack of aaHtional furning fran the rarovaJ.
program budget. A 24-hJur site security and fire watch are
continuing to ensure safety at the site until the reredial
activities can be initiated.
On May 5, 1989, EPA proposed that the site be ad:1ed to
the National Priorities List.
Other Site lcti vi ties
In a bankruptcy court order dated July 7, 1987, FreecXrn
Savings and IDan Association was auttx>rized to sell... "all
inventory, EqUipnent and fixtures ioclOOing, without limitation,
all scrap, scrap metals, salvage, materials, tanks:, piping,
and containment stru:t:ures, prcxi.1ct.ion, transmission, storage
and handling equiprent and all items or materials created
by or raroval thereof at the fO:rm:!r Publicker In:h.1stries
Si te by private sale." en Jarwary 19, 1988, Bruga COrp:>ration
of Robbinsvi He, New Jersey p.Irchased fran FreeCt:m Savings
and IDan Association, the Stillrouse and Ethylene HyCration
Areas of the faci li ty. en June 13, 1988, Bruga COrp:>ration
entered into a consent Order lI1'X1er cm::IA section 106, 42
U.S.C. section 9606. '!he consent Order requires Bruqa to
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12.
13.
14.
Table 1
SUrnnary of Pr ior
EPA Raroval Activities
1.
All known and l.1l1kr1own laroratory containers disp:>sed of
off-site to permitted RCRA facilities.
2.
All FCB contaminated electrical equiptelt containing FCB
levels greater than 50 ~ disp:>sed of off-site to permitted
RCRA facilities. All FCB electrical equipnent containing
FCB levels less than 50 ~ are secured on-site.
3.
Gas cylinders were raroved fran site by private parties
or rem:>tely opened on-site, vented, crushed am staged
on-site.
4.
Acid liquids neutralized on-site.
Base neutral, oxidizing am organic liquids b.1lked am
stored on-site in reconditioned tanks.
5.
6.
Flanmable liquids am solids tulked/disp:>Sed of off-site to
permitted RCRA facilities.
7.
Solid waste streams bulked am secured on-site.
8.
Acid solidsdiSJX)sed of off-site to pennitted RCRA facilities.
9.
~rcury and Irercury containing catp)llDjs transp:>rted
off-site to pennitted ~ facilities.
10.
Radioacti ve laboratory catp)llDjs disp:>sed of off-site to
permitted ~ facilities.
11.
~roximately 7,000 gallons of material have been raTDVed
fran the above-9rade process lines an:l b.1lked securely
on-site.
Piles of asbestos were bagged an:l secured on-site.
arlldiDJs conta.ini.ng asbestos were bJarded-up an:l warning
signs posted. sane overhead piping wi t.h asbestos
insuJ.aticn were wrawed wi t.h plastic to prevent the
release of friable asbestos material..
A structural inspection was CorDucted on-site due to ~rker
an:l operational safety concerns.
Fuel oil an:l other contaminated oils have been tul.ked in
secure tanks on-site.
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dismantle am decontaminate, if necessary, all equipnent that
is rem:M3d fran the site. . '!his work is currently urxiervay.
01 Decaroer 8, 1988, EPA and NV\ Waremus ing, Ioc. (N:>A)
of Brooklyn, New York entered into a Consent Order LU1der CERCIA
section 106, 42 U.S.C. section 9606, whereby NV\ was granted
permission to rerove fran the site sane stainless steel
tanks and rail tank cars which N:>A owned. RE!tOval of N:>A's
property began on Decenber 9, 1988. All seven rail tank
cars have been tran.sp:>rted off-site; however, the stainless
steel tanks have not been raroved.
Extent of Contamination
'TWelve (2) waste streams have been identified on-site
to date. 'lhese include base neutral liquids anj solids,
organic liquids am solids, oxidizing liquids am
solids, water reactives, chlorides, crushed erpty Iretal
drtnns and contaminated oils. '!he various consolidated
waste streams are stored in drtnns am existing tank structures
which are in various stages of dilapidation. Sa1e of the
waste materials fran these ~ am tanks are ioccrrpatible
and, if mixed, could result in the formation of ncre dangerous
cCll1pJunds. It is estimated that over one million gallons
of bulked waste material remain on-site fran the previous
emergency rE!TOval action. Grourxi water am soils contamination
is likely. An RI/FS will be con::hrted to study these rredia am
possible remedial alternatives.
CUrrent Site Status
TIle integrity of many of the site structures is p:x>r
due to past fires am to the age of the facility. Altrough
many of the on-site waste streams have been consolidated,
the potential threat of release ranains. Figure 3 identifies
the locations of tul.k wastes arxl other waste streams on-site.
The waste streams an::l their associated volurres are sunmarized
in Table 2. '!he actual volume of the waste streams is
currently t.JI'1Ja'1c:M1, therefore, estimates have been based on
the voltme capacityand/or dimension of the containers.
'I11e wastes are present I y secured in tanks am in c1rtJnlc3:
however, the deteriorated concH tion of the structures
surrourDing the CalSOlidated wastes p:>ses a threat to these
storage vessels. Altb:Jugh taTp:>rary repairs have peen made
to and testing has been 00ne on the 35-year old storage
tanks, their structural integrity can in IX> way be certified
for any definite period of time. 'lhese risks are carpJlD'X1ed
by the corxii tion of the concrete contairment wall surrotn'Y1ing
the storage tanks. In the event of rupture or co llapse of
the storage tanks, the wall could rx>t contain a catastropuc
release. In ad:Htion, the on-site, drtm-staging area, which
is in disrepair, is emitting detectable vapors.
- 8 -
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l
U.S. EPA (
COMMAND PO~[Oo 0
BIGLER ST.
\
~
JCU ~
08' I
00 go 00
I~ IJ . D ~
- --; I
~~o
(D(f)
w
~
lua
~D
- -PACKER AVE. - -
-L L[
(-
r I ~
f-------. I
r - - - - - '-, r -I
I I I I
I I I
-
t=J
~
I
ci-
.."""",,,,,j
~
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10 r~::'03
PIER 104--.1
BURNED 6/26/87
FOllMER SUI'
PIER 105
SLIP
. PIE~~-;~~ .-- - --J
~ SLIP DELAWAflE
------------1 RIVEr-i
PIEri 101 ---1
E
PIER 108
BASIN
PIER 109
WALT ~HI~MAN BRIQ9E-
III 16 011 (contam.)
I:~~ 16 011 (non-con tam.)
~ Drum Staging Area
I~~I Drums (crushed)
eiII Sol1f1fied Spent Grain
~ Oxidizing Liquids
~ Organic Liquids
mrnrn Base Neutral Liquids
lJ Fire Extinguishers/
I Vented Cylinders
FIGURE 3
Publicker Industries
WASTE STR":AM LOCAT IONS
KEY
- .
t------f-------_. - ._-.. .- .- .-.,...
-------
Table 2
Est:i.rnated Waste Stream Volurres
waste Stream
Bulk Organic Liquids (lTtllti -phased)
Organic Solids
Bulk Oxidizing Liquids (nulti -Fi1ased)
Oxidizing Solids
Bulk Base Neutral Liquids (nulti-Fi1ase)
Base Neutral Solids
Contaminated #6 Fuel Oi 1 ani Water
Solid Site Debris (crushed E!Tpt:y Iretal
drums and protective Clothing)
FCB Contaminated Oil and Electrical Equipnent
Fuel and Lubricating Oils
Chlorides
Water Reactives
- 10 -
Estimated Volume
15~ ,815 gallons
2,500 gallons
38,845 gallons
8,845 gallons
383,810 gallons
5,865 gallons
3 ,080 gallons
20 cubic yards
320 gallons
250,000 gallons
110 gallons
85 gallons
-------
Ole to these existing site coOOitions, a 24-hour
fire am security watch is required. In the event of a
chanical release, a fire, or an unauthorized entry, the fire
watch am security measures will initially control the
situation Lmtil the awropriate- re5IX)nse inc1ividuals arrive
on the scene. '!he quick attention to an incident and the
notification of resp:mse personnel are critical.
Risk Assessrrent
DJe to the close proximity (within a one arrl one-half
mile radius) of residences, major highways, waterways,
schJols, hospitals and tran.sp:>rtation routes to the site,
any release could p:>tentially affect t:housarm of people.
'!he consolidated waste stream; currently stored on-site in
drums and in tanks include, rot are not limited to base
neutral liquids and solids, organic liquids an:l solids,
oxidizing liquids an:l solids, water reactives, chlorides,
and contaminated oils. A major release caused by the rupture
or collapse of the storage vessels on-site could force the
evacuation of large numbers of people, close cbwn tusinesses,
and affect large p:>rtions of the City of Philadel(:t1ia due
to disruption of p.tblic tran.sp:>rtation an:l major highways
(Walt Whitman Bridge, 1-76, 1-295, 1-95). Process piping that
may contain igni tible liquids an:l vap:>rs is also a major
contributing factor to site risk. A major release fram the
site could p:>ssibly affect residences as far ~y as New
Jersey, deperning on meteorologiCal conditions.
'!he threats to tnJrnan health an:l the envirorment can be
separated into four categories:
1) Fire am/or explosion associated with the hazardous waste
streams
2) '!he presence of pJtentially hazardous chanicals stored on-site
3) '!he pJtential for the migration of oils am che1ri.cal mixtures
into the Delaware River
4) VapJr emissioos fran the on-site drum-staging area, which
is in disrepair.
'!he potential threat of fire at the Publicker Site is
ext rete . '!here have been fires in the past, an:l the continuing
threat is deened to be significant by the City of Philadel-
(:t1ia Fire Marsl1al's Office. '!he facility is in very {X)Or
comition because of past fires, dalDlition on the site, neglect,
an:l vardalism. 'n1ese are all contributing factors to the
p:>ssible occurrence of future fires at the site.
- 11 -
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Many of the process and storage bui ldings contain
large aIIIJlmtS of ~ construction IT'aterials, sane of which
are over 50 years old. There are IT'aTIy spill areas of
t.IT1kI1oW11 calp)Sition, sane of which are p:)tentially ignitible.
A fire could easily cause drums staged on-site to rupture
or explode, releasing chemical contaminants into the
environment.
Description of Alternatives
Using infonnation collected by EPA OSCs am the fimings
of past and present investigations am data analyses, EPA
has developed the following three alternatives for an early
action ROD at the Publicker Industries Site. A PrQp)sed Plan,
outlining the conditions at the site am the alternatives
evaluated was issued March 1, 1989 along with the Agerry's
prop:>sed alternative. 'lhis was also plblished arxi a plblic
meeting was held March 15, 1989. Due to the unstable
nature of the site am ti1re constraints ~sed .by the
cont inued threats at the site, this PrOIX>Sed Plan am
s~rting documents in the file constitute a Focused Feasibility
Study and are the basis up:>n which this RCD is written.
'!he selected remedial action will eliminate the threat of
fire and/or explosion associated with storage tank residues,
process lines containing ignitible/ hazarCbus liquids, am
quantities of tulk hazardous chemicals stored on-site.
A ra-rajial alternative considering the continue:1 long-
tern containment of these waste streams on-site was not considered
because it is not consistent with future site ranediation
acti vi ties am does not satisfy the statutory mamate to utilize
perlT'aTIent solutions.
Alternative I - ~ 1tction
'!he rb 1tction Alternative is required by the National
Contingerry Plan (N:P) to be considered through the detailed
analysis of remedial alternatives. '!his alternative provides
a baseline carpariscm against which other renedial measures
can be CCJIII8I"ed. With this alternative, EPA \oIOUld not
irrplenent ~ aatitia1al measures to protect either tDJman
health or the envhoulle.llt fran the existing threats at the
PublicJcer Site. EKistin3 waste streams would ranain on-site
with the CDltinued threat of fire aro;or explosion due to
storage which is unsafe am inawropriate for the ".lang-term.
'Ihis alternative \oIOUld not minimize or appreciably
eliminate the p:>tential cataStropuc threat to Iunan health
am the environnelt that currently exists. In additioo,
this alternative does not satisfy the statutory mandate to
utilize permanent solutions, oor does it carply with the
statutory prefererx::e for remedial actions that rechJc:e toxicity,
rrobility, am volune. '!his alternative would allow 00
ranediation at the site until carpletian of an RIfFS report.
- 12 -
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Alternative-~ - Catpletion of Site Stabilization Activities:
Off-site Ti-eat.ment
Urxier this alternative, the cOnditions that continue to
pose the fire ani/or explosion threat at the Publicker
IIrt..1stries Site \o.UUld be eliminated. '!his action would be
the initial remedial action at the site; the first phase in
what wi 11 eventually be a Cooplete remediation of other
potential hazards (i.e., soil, ground water, asbestos).
'!he fOllowing actions are proposed to be accanplished:
* '!he transPJrtation and off-site disposal of the known
remaining on-site waste streams to permitted RCRA
facilities.
* '!he deroli tion of aOOve-grade process lines that
traverse the site. '!his may include the recovery of
t.mknown hazardous chemiCals ani the rE!YDVal of pipe
insulation materials such as asbestos--containing
materials. Dismantled process lines wi 11 remain
on-site lD1til future site ranedial actions are
perfOrmed.
* '!he proper packaging of the insulation material
reroved fran the process lines. Insulation materials,
including asbestos, will be properly packaged ani
stored on-site until future rEm3dial actions are
perfOrmed.
* '!he traI1Sp:)rtation ani off-site disposal of hazarcbus
chemicals recovered fran wi thin the process lines to
permi tted RCR1\ faci li ties.
'!he actual volune of the waste streams is presently
t.mknown ani will have to be determined during the design
period. Estimates are based on the volune capacity arxl/or
dimensions of the container. (See Table 2.)
Preliminary analytical data for the waste streams are
available. In the case of the tW.k liquids, analytical
data are not available for the tW.k VOlUl'le. 1\na.lytical data
are available, 1xJwever, for the irxlividual waste streams
that are incl1.Ded in the tul.k volUl'le. Mditional sanpling
of tulk waste volumes will be required before di5p)Sal in
order to identify the chaniCal cCJrp:>sitions. .
All waste streams will be disposed of off-site. '!he
necessary RCRA waste disp)Sal permits will be obtained by
the waste di5p)Sal contractor. '!he use of RCRA permitted
facilities depenjs upon EPA regulations pertaining to the
iooi vidual waste streams identi tied during aali tional sanpling
efforts. All lOCal, State, an:! Federal regulations that
CiR'ly to the off-site di5P'sal of the waste streams will be
- 13 -
-------
adhered to. ~is will be placed on current EPA Off-site
ctisp:>sal p:>lic ies.
Pennits will be obtained for the trarlS!XJrtation of the
waste streams to the di5p)sal facilities. Only licensed
Department of TrartSp:>rtation val
activities on-site, identification of process line contents
was lU1SUCcessful. The hazardous materials that may be fourxi
and recovered fran the process lines ITI.lSt be 5anpled,
analyzed, trarl.Sp)rted, and di5p)sed of according to the
previously stated requirements. The process lines that are
to be addressed during the recovery operations are tlx>se
Which are overhead and begin or en:l at a Wilding. Many of
the process lines are incorporated into areas of structural
concerns; therefore, other structures associated with the
process lines may need to be dem:>lished during process-line
dismantling .
During the dismantling of the process piping, pipe
insulation materials consisting of fiberglass, asbestos or
other insulating materials will be rElTDVed. It is krx:Iwn
that a portion of the insulation is asbestos; J'xJwever, the
exact c3IT'0lUlt of asbestos insulation on the process lines is
not known. The insulation material and dismantled process
piping will be stored on-site in a secured area for future
di5p)sal.
DJe to the lD1availability of detailed analytical data,
it is not p:>ssible at this time to select specific treatment
metJ'x)ds for the various on-site waste streams. '!his determina-
tion will be DBde ooce all of the tuJ.k waste volumes have
been sanpled am analyzed. However, it can be determined
at this tiDe whether a specific waste stream is amenable
to P1Ysical/chemical treatment, biological treatment, thermal
treatment or r~ling tec:hrologies. In aeXtition" certain
waste streams may also be landfilled, if allowed under the
RCRA land-ban regulations.
With the aid of EPA's TechniCal Assistarx:e Team ('00')
contractor, at least one treatment optian was selected for
each of the 12 on-site waste streams. 'lhese are SlmIrarized in
Table 3.
- 14 -
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Table 3
SUmnary of Treatment Technologies
Waste Stream
Bulk Organic Liquids (nulti-lXlaSed)
Organic Solids
Bulk Oxidizing Liquids (ITUlti -lXlaSed)
Oxidizing Solids
Bulk Base Neutral Liquids (ITUlti-lXlaSed)
Base Neutral Solids
Contaminated #6 Fuel Oil and Water
Solid Site Debris (crushed E!Tpty metal
dn..uns, protective c lathing)
FCB Contaminated Oil and Electrical
Fquipnent
Fuel and Lubricating Oils
Chlorides
Water Reacti ves
- 15 -
Treatlnent Technology
'Ihennal Treatment
Physical/01anical Treatment
'Ihermal Treatment
'Ihermal Treatment
Physical/Q1anical Treatment
'!hennal Treatment
Physical/Q1anical Treatment
Biological Treatment
'!hermal Treatment
Lan:1f ill
'!hennal Treatment
Recycle
'Ihennal Treatment
'Ihennal Treatrnent
Recycle
'Ihennal Treatment
'Ihermal Treatment
Physical/Q1enical Treatment
-------
In cases where I1'Ore than one treatIreI1t option is listed,
the waste stream may be amenable to one or rrore technologies,
depending on- the characteristics of the waste stream. If,
for exanple, a waste stream contains a large ~rcentage of
water, it may be cost-effective to treat before it is incin-
erated. In addition, if a pJrtion of a waste stream can be
recovered through a recyc ling process, the by-product may
also be thernally treated.
Final selection of technologies will be nade based on
vendor respJnses to performance specifications. Criteria to be
used in this selection include:
- compliance with their ~rmits
- Compliance with SMA and ARMs
- pennanence
- Ultimate fate of contaminants
- RedUction in volume, rrobility an:1 toxicity
- Costs
Alternative 3 - Completion of Site Stabilization Activities:
On-si te Treatlrent
'lhis alternative has the same major CC!1pJl1el1ts as and
is similar to Alternative 2, with the exception that the
treatment of the waste streams would be perforne:l on-site.
Incineration, recycling or other PlYsiCal/chetdcal and
biological treat:lnE!I1t processes would be nobilized on-site
to treat the various waste streams.
I)je to the close proximity of site structures and the
lack of available open space to nobilize several treat.rrent
processes, this alternative is not iltplanentable at this
site. In addition, the use of incineration in an area
where large volumes of ignitiblej hazarOOUs wastes are closely
stored is not a safe practice. AlSO, the operation of an
on-site incinerator would receive ~1ic OR,X>sition. Historically,
area residents have QRX)sed other projects where ~ential
impacts to air quality are likely.
For the reasons stated aOOve, this alternative will be
eliminated fran further consideration.
Cancarati ve Analysis
'!he tWO renaining alternatives 'Nere evaluated against
the following nine criteria:
l) protection to tumm1 health and the envircnnent;
2) compliance with ~licable or Relevant an:1 ~ropriate
RequirE!tSlts (~);
3) soort-tenn effectiveness;
4) long-term effectiveness;
5) reduction of toxicity, rrDbility, and volume;
6 ) inplE!TS1tabi li ty ;
7) state acceptaJX:e;
8) camuni ty acceptan:e; and
9) cost.
- 16 -
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1. Protection of Human Health and the Environment
'!he rb Action Alternative provides no protection of
either troman health or the envirornneI1t. '!he continued
threat of fire and/or explosion fran stored hazardous
wastes would still be present at the site.
The Site Stabilization Alternative will eliminate
the FOtential threats to human health and the envirornnent by
reroving and disp:>sing of the waste streams off-site. Risks
associated with fire and/or explosion would therefore be
eliminated.
2. Canpliance with ARARs
Since no site renediation will occur un:1er the ~
Action Alternative, it will not be in canpliance with
ARARs .
'!he ARARs considered for the Site Stabilization
Alternative, under this initial ratedy, are only those
which pertain to tile action being taken to eliminate the
p:>tential threat of fire an::l/or explosion, thereby protecting
ht.n'nan health and the envi ronment.
During tile rerovaJ. arx1 disp:>Sal of waste streams fran
tanks, lines an:1 vessels, am the reroval anj di5p)Sal of
drumred materials, all ARARs associated with tanks, tank
system standards anj the use am managanent of containers,
where appropriate, will be net. During these activities,
the level of air anissions will be in carpliarre with
National Air Quality Stan:lards. '!he off-site transport of
waste streams will neet all AR1\Rs associated with LOr am
RCRA requiranents. Reroval arx1 packaging of process pipe
insulation materials which contain asbestos win be han:lled
in accordance with National EhviruJ}nelrt.al StaImrds for
Hazardous Air Pollutants (NESW'). '!he 1\RMs associated with
rEmadial efforts beyond the scope of this renedial action will
be addressed in a subsequent ROO. '!he Site Stabilization
Alternative will meet those AR1\Rs identified above which
are StIIIIBI'ized in Table 4.
3. SOOrt-teIm Effectiveness
With the inplementation of the ~ k:tion A1t~mative,
the contiIUling threat of fire aOOior explosion will oot be
eliminated. 'l11e FOtential threat of such an occurren:e
contiIUles to be inp:>sed on bOth human health an1 the enviruuneht.
'!his threat will oot be abated in any form \mtil carpletion
of an RIIFS , REm:!dial Design (RD), an1 Renedial k:tion (~).
'D1e Site Stabilization Alternative will allOW
renediation of the existing threats in a 6-to 8-rrDI1th
period, with Ii ttle , if aTrf, ilrpact to hLmm health an1
the envirollment. sane mioor iJrpacts may occur dur~ inple-
- 17 -
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Action
Off-site transport
of waste streams
Rem:::>val/packaging of
asbestos wastes
Rem:::>va1 and di5p:)sal
of drums
Rem:::>val and di5p:)sal
of materialS fran
tanks, lines, and
vessels
Release of air
anissions fran drum
staging/di5p:)Sal
operations
LaOOfi 11 disposal of
waste streams
Table 4
ARAR SUntna.ry
Alt. 1
N:> Action
NA
NA
NA
NjA
NjA
NjA
- 18 -
Alt. 2
Site S~~hilization
TraI1Sp)rt of hazardous waste
streams for diSJ;Osal nust
satisfy oor regulations as
outlined in 49 C.F.R. Part 107,
sections 171.1-171.500 and
RCRA regulationc:; as outlined
in 40 C.F.R. Parts 262 and 263
TraI1Sp)rt of waste streams nust
also satisfy PN)ER's provisions
uooer HazardOus Waste Managarent.
Rules am Regulations, Section
75.263, Transp::>rters
Asbestos nust be han:iled in
accordan::e with the National
EnvirOJIIllf:lltal St.anc1ards for
HazarOOus Air Pollutants
(~) 40 C.F.R. Sections
61.140-61.156
All appropriate regulations
concerning Use and Managarent.
of Containers
40 C.F.R. sections 264.170-178
Appropriate sections of PADER' s
Section 75.265 (q), Use ani
Managenent of containers
All appropriate regulations
concerning Tank System Starmrds
40 C.F.R. $aCtions 264.190-199
Appropriate sections of PADER' s
section 75. 265 ( r), Tanks
Mrf air Emission generated by
the Ranedial k:tion will rot
exceed National An'bient Air
OJality Standards 40 C.F.R.
Part 50
RCRA Lam DispJSal Restrictions
40 C.F.R. Sections 268.1-268.50
-------
mentation of this alternative due to vap:>rs/Odors and off-
site transp;>_rtation of wastes: how'ever, these ~ will
be very snall and will be controlled am rronitored. Site
specific safety an:i health rronitoring programs will be
implaTS1ted dUring the RA..
4. Long-tenn Effectiveness
selection of the ~ Action Alternative will not eliminate
the p:>tential threat of fire am/or explosion as they will
continue to p:>se a threat to human health arx1 the environrrent.
The r-b Action Alternative may also lead to further degradation
of area groun:i water.
The Site Stabilization Alternative will provide
reliable protection of ~ health am the envirorment.
over time by eliminating hazards at the site which are ooth
current and future risks. This alternative will also allow
the long-tenn ranediation process to continue without any
ilTIninent threats to human health or investigation teams.
l>d:1i tionally, no long-tenn lIEIlaganent of the waste streams
addressed in the RCD will be required.
5. Reduction of 'Ibxicity, r-bbility, and Volurre
The r-b Action Alternative provides 00 reduction of
either toxicity, rrobility, or volurre of the waste streams
at the site.
The Site Stabilization Mternative will provide for
the total reduction in the toxicity, robility, ani volurre
of the waste streams sin:e these wastes will be either
destroYed by thennal treatment, neutralized by treatJrent,
or recycled. Residuals fran treatment/recycling processes
will be disposed of off-site. However, if lan:ifilling is
selected as a treat.nent metlxxi, the statutory requiranents
for reduction of toxicity, robility, and volurre will oot be
satisfied.
6. Implanentability
Sin:e there is nothing to inplaTSlt UIXier the ~ h::tion
Alternative, this is oot applicable to this situation.
thier the Site Stabilization Alternative, services
required for the disposal of the waste streams do .exist and
will be obtained. No technical or administrative obstacles
for inplanenting this alternati ye ~ to exist. .
7. State AcceptaOCe
'n1e catm:mwealth of Pennsylvania, DepartJtett of
EnviruJJlI~ltal Resources (DER), has reviewed the infoI1lBtion
available for this site am has concurred with this Record
of Decision (IU)). (see attached om con:urrerx=e letter).
- 19 -
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8. camuni ty AcceptanCe
A ~lic CQIII~lt period for the Prop:>sed Plan was held
fran March l, 1989 to March 30, 1989. en March 15, 1989, a
p.lblic neet.ing was held at the Winnet SOuth !'hi ladelphia
community Center to discuss ~'s preferred alternative as
described in the Proposed Plan. Area residents, local arrl State
officials that atterned the neet.ing were SURX>rtive of ~ 's
preferred alternative (i. e., Alternative 2).
At the request of Publicker In:lustries, Inc., the pJblic
conment period was extemed to May 19, 1989. Addi tional ti1re
was required by Publicker to review the project site files
and prepare CatmE!nts. CatmE!nts received during the p.Jblic
meet ing arrl the pJ.blic CQIII":lll period are presented in the
attached responsiveness sumnary.
9. Cost
The t-b Action Alternative TNCUld have 00 costs associated
with it since no Renedial Action (RA) WOUld occur until
cCl'lpletion of an RIfFS am. RD activities.
Total costs associated with the Site Stabilization
Alternative are estimated to be $13.9 million. 'Ihese costs
are capital costs for project implanentation which include
waste stream tr~rtation am disposal expenses. '!here
will be no operation and maintenarre costs associated with
t~is alternative.
selected Remadv
Based on available data and analysis conducted to date,
Alternative 2 (catpletion of Site Stabilization Activities:
Off-si te Treatment) is selected as the aR>ropriate renedy
for meeting the goals of the initial operable unit at the
Publicker lniLstries Site. '!his alternative consists of:
* Transportation and off-site disp:>Sal of the known
rEllBining an-si te waste streams to penni tted RCRA
facilities.
* DeDDlition of above-grade process lines that traverse
the site. '!his may i.nclude the recovery of '\mkr£Jwn
hazarcb.1s chenicals am the reroval of pipe insulation
materials such as asbestos~ontai.ni.ng materials.
Dismantled process lines will ranain an-site until
future ranedial actions are performed.
* Proper packaging of the insulation materials rE!lDVed
fran the process lines. Insulation materials in:l\Xlinq
asbestos, will be properly packaged an:} stored on-site
unti 1 further remedial actions are performed.
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* Transportation an:! off-site disp:>sal of hazardous
chenicals recovered fran wi thin the process lines
to permitted RCRA facilities.
This alternative will eliminate all p:>tential threats
of fire am/or explosion which negate all current and
intnediate threats to human health and the envirol1lrel1t. 'This
alternative will rerove a real arx:1 irmrinent threat to the
safety of the people of the City of Philadelphia, Pennsylvania,
and the surrourning properties.
Specific treatment technologies are not identified at this
p:>int so as not to l:imi t p:>tential viable technologies urner
ranedial action. Final selection of technologies will be made
based on vendor re5P)nses to performaI'X:e specifications.
Cri teria to be used in this selection include:
- Canpliance with their permits
- Compliance with SMA arx:1 ARARs
- Permanence
- Ultimate fate of contaminants
- Reduct ion in vo lume, robil i ty, arxi toxic i ty
- Costs
As required by section 121 of c:rncrA, as amenjed, 42 U.S.C.
Section 9621, Alternative 2 is protective of hLnnan health am
the envirornnent, reduces the toxicity, robility, arxi volume of
contamination, will attain ARARs, arxi utilizes permanent
solutions to the maxinum extent practiCable. '!his alternative
is cost-effective, achieves ilTplementable objectives am
offers an effective, iIrplanentable renedy which provides
long-term remediation by destroying or rem:wing contaminants
of concern fran the site, arxi is consistent with future site
remediation activities.
RESFUJSE CB.JE>:TIVES
The resp:>nse objectives for this operable tmit are:
.
Reduce or eliminate p)tential exp::>sure pathways by
which catt:aminants may reach JX)tential- receptors.
.
Protect the envirOllneuL fran JX)tential leaks arxi/or
catastroPlic tank failure.
.
Be cost-effective.
.
Be in carpliarx;e with the carprehensi ve Enviruullt:utal
Resp:m.se, ~tion, arxi Liability]let (CEX:IA), as
amen:1ed by the SUperfum Ansdt..e!llts am Reautb:>rization
]let (SMA),
.
Be corxhx:ted in accordan:e with the National contingerx:y
Plan (N:P-secticn 300.67~.
- 21 -
-------
*
~- in carpliance with c3R'liCable or relevant and
c3R>ropriate requiranents (ARARg).
*
Provide permaner." SOlutions to contamination problans
to the maxim..Irn Eo .c:ent practicable.
'*
Be effective over ooth the short and long-tenn.
'*
Be acceptable to State authorities am the local
Catmmity.
'*
Leave the facility in a state Con:h.Jcive to ranediation
of other areas of the site.
Schedule
Predesign sanpling and preparation of contract specifica-
tions and docurrents are estimated to take one rronth. Cb:e
the site is pramlgated on the SUperfund National Priorities
List (NPL), ranedial f\.ZOOs will becooe available to perfonn
the selected ranedial action. It is anticipated that the
selected ranedial action will take an ackiitional six to
eight ronths to cClTplete.
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PUBLICKER/CUYAHOGA WRECKING PLANT SITE
ADMINISTRATIVE RECORD FILE *
INDEX OF DOCUMENTS
FACTUAL INFORMATION/DATA
1)
Report: Preliminary Report, Environmental Evaluation,
Former Publicker Industries, Inc., Refiner, Philadel hia,
prepared by Dames & Moore, 7 21 86. P. 1-6.
2)
Region III Incident Notification Report, prepared by the Coast
Guard, 6/26/87. P. 7-7.
3) Pollution Report 11, 6/26/87. P. 8-9
4) Pollution Report '2, 7/1/87. P. 10-11.
5) Pollution Report 13, 7/7/87. P. 12-12.
6) Pollution Report #4, 7/13/87. P. 13-14.
7) Report: Publicker Industries Site, Philadelphia, PA,
Assessment Scope of Work, (no author cited), 7/14/87.
P. 15-17.
8) Pollution Report '5, 7/17/87. P. 18-19.
9) Pollution Report .6, 7/17/87. P. 20-21.
10) Pollution Report 17, 7/22/87. P. 22-23.
11) Problem Areas List, Publicker Industries Site,
Philadelphia, PA, 7/24/87. P. 24-24.
12) Pollution Report '8, 7/24/87.
13) Pollution Report '9, 7/27/87.
P. 25-27.
P. 28-29.
14) Pollution Report '10, 8/13/87.
P. 30-31.
*
Administrative Record File available 3/9/89, updated
6/22/89.
Note:
Company or organizational affiliation is identified
only when it appears in the record.
1
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15 )
16)
17)
18 )
19)
20 )
21 )
22)
23)
24 )
25 )
26)
27)
28)
29)
30)
31 )
Report: Final Progress Report for Overland Corporation
Facilit in Philadel hia, Penns lvania, prepared by
O.H. Materials Corporation, 11 12 87. P. 32-35.
Memorandum to Mr. Tom Voltaggio, U.S. EPA, re: Site
conditions and possible site visit, 12/1/87. P. 36-
36.
Pollution Report #1, 12/9/87. P. 37-38.
Pollution Report #2, 12/9/87. P. 39-40.
Pollution Report #3, 12/9/87. P. 41-42.
Pollution Report #4, 12/10/87. P. 43-46.
Pollution Report #5, 12/10/87. P. 47-50.
Pollution Report #6, 12/11/87. P. 51-52.
Pollution Report #7, 12/11/87. P. 53-55.
Pollution Report #11, 12/15/87. P. 56-59.
Report: Former Publicker Industries Site Briefing
Document, prepared by Mr. David P. Wright, 3/88.
P. 60-62.
Report: Report of Findings and Work Activities,
Federal Removal Project, Publicker Chemical Site,
Philadelphia, Pennsylvania, prepared by B.E.S.
Environmental Specialists, Inc., 9/14/88. P. 63-81.
Excerpts from the Publicker Industries Site Federal
On-Scene Coordinator's Report, (no author cited),
(undated). P. 82-86.
Report: Preliminary Operations Plans, (no author
cited), (undated). P. 87-90.
Report: Publicker Industries Site Original Tank
Assessment, (no author cited), (undated). P. 91-
115.
Background information re: Chemicals manufactured at the
Publicker Plant, (no author cited), (undated). Two maps
and three tables are attached. P. 116-121.
Publicker Industries Site, Scope of Work, (no author
cited), (undated). P. 122-127.
2
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32)
Note re: Availability of analytical data, (no author
cited), -(undated). P. 128-128.
3
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OTHER AGENCY DOCUMENTATION
1 )
Memorandum to Mr. Harry J. Cusick, City of
Philadelphia, from Mr. Roger M. Ulshafer, City of
Philadelphia, re: Fire Safety at the Publicker
Site, 12/4/87. P. 129-129.
4
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8)
9)
10)
PUBLIC PARTICIPATION
1)
.-
Handwritten meeting attendance sheet, 7/14/87. Three
business cards and a list of "RP contacts" are attached.
-P. 130-140.
2)
Newspaper article from the Philadelphia Daily News
entitled "EPA Probes Old South Philadelphia Distillery,"
by Ms. Ramona Smith, 7/24/87. P. 141-141.
3)
Indictment in the United States District Court for the
District of Maryland, United States of America v.
Cuyahoga Wrecking Corporation, Overland Corporation,
Samuel Runfola, Virgil Cummings, and Ernest Ray Martin,
10/21/87. P. 142-149.
4)
Press release from the United States Attorney for the
District of Maryland, 11/5/87. P. 150-153.
5)
Press release from the U.S. Department of Justice,
11/6/87. A document entitled "In the United States
District Court for the Eastern District of Pennsylvania,
United States of America v. Publicker Industries,
Information Count One" is attached. P. 154-156.
6)
Press release from the U.S. EPA Environmental News
entitled "EPA Takes Over Cuyahoga Wrecking Site Clean-
Up," 12/15/87. P. 157-158.
7)
Newspaper article from the Philadelphia Inquirer entitled
"EPA Team Cleaning Up Solvent Leak," by Mr. Mark
Wagenveld, Philadelphia Inquirer, 1/15/88. P. 159-159.
Press release from the U.S. EPA
entitled "EPA Seeks Comments on
Actions to Stabilize Conditions
2/27/89. P. 160-162.
Environmental News
Proposed Interim Remedial
at the Publicker Site,"
Public notice re: EPA seeks comments on proposed
remedial actions at the Publicker Industries Site,
3/1/89. P. 163-163.
Newspaper article from the Daily News entitled
"Firefighters Stem Publicker Leak," by ,Ms. Ramona Smith
and Mr. Joe O'Dowd, Philadelphia Daily News, (undated).
P. 164-164.
5
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POLICY AND GUIDANCE
1)
Memorandum to Addressees from Mr. Harris L. Crump, U.S.
EPA, re: Draft Asbestos Report, 6/20/88. P. 165-166.
2)
Memorandum to Mr. David P. Wright, U.S. EPA, and Ms. Lisa
Marie Price, U.S. EPA, from Ms. Sella M. Burchette, U.S.
EPA, re: Asbestos at the site, 7/15/88. P. 167-168.
3)
A list of General Guidance Documents, U.S. EPA,
(undated). P. 169-169.
6
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9)
DECISION DOCUMENTS
1)
Special Bulletin A from Mr. Robert E. Caron, u.S. EPA,
re: Site conditions and status, 7/9/87. P. 170-171.
2)
Special bulletin A from Mr. T. Massey, U.S. EPA, re:
Site conditions and status, 12/9/87. P. 172-173.
3)
Memorandum to Dr. J. Winston Porter, U.S. EPA, from Mr.
James M. Seif, U.S. EPA, re: Additional funding request
for the Publicker Industries Site, 12/9/87. P. 174-179.
4 )
Special Bulletin A from Mr. T. Massey, U.S. EPA, re:
Site conditions and status, 12/9/87. P. 180-181.
5)
Memorandum to Dr. J. Winston Porter, U.S. EPA, from Mr.
James M. Seif, U.S. EPA, re: Justification for
continuation of a removal action at the Publicker Site,
3/1/88. P. 182-185. A memorandum regarding an Interim
Additional Funding Request for the former Publicker
Industries site is attached.
6)
Memorandum to Dr. J. Winston Porter, U.S. EPA, from Mr.
James M. Seif, U.S. EPA, re: Publicker Industries Site
Two Million Exemption Continuation of Removal Activities,
3/23/88. P. 186-202. A memorandum regarding the Two
Million Exemption/Additional Funding Request for
CERCLA/SARA Removal Actions at the Publicker Industries
Site is attached.
7 )
Memorandum to Dr. J. Winston Porter, U.S. EPA, from Mr.
Timothy Fields, Jr., re: Region III's Two Million
Exemption and Ceiling Increase Request for Continuation
of Removal Activities for the Publicker Industries Site,
4/6/88. P. 203-206. A memorandum regarding Publicker
Industries Site Two Million Dollar Exemption addendum is
attached.
8)
Memorandum to Mr.
Marie Price, U.S.
Exemption for the
P. 207-212.
James M. Seif, U.S. EPA, from Ms. Lisa
EPA, re: Request for Twelve-Month
Publicker Industries Site, 11/17/88.
Superfund Program Fact Sheet, Proposed: Plan, prepared by
U.S. EPA Region III, 3/89. P. 213-217.
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ENFORCEMENT DOCUMENTS
1)
Chapter 11 Voluntary Petition, 1/6/87. P. 218-223. A
Corporate Resolution, A Rule 52 Affidavit, and an Order
for Retention of Attorneys for Debtor-in-Possession are
attached.
2)
Order Approving Selection of Trustee, 2/11/87. P. 224-
226. An Application for Order Approving the United
States Trustee's Appointment of a Trustee is attached.
3)
Order re: Cuyahoga Equipment Corporation, Philip B.
Schwab, Mary L. Schwab, Cuyahoga Wrecking Corporation, a
Florida Corporation, Cuyahoga Wrecking Co., Inc., an
Illinois Corporation, and Jordon & Foster Scrap
Corporation, 2/13/87. P. 227-235. Two affidavits and an
Order are attached.
4)
Stipulation and Order Modifying Stay to Permit
Foreclosure of Lien upon Property of Overland
Corporation, 7/7/87. P. 236-242.
5)
Letter to Mr. Robert Caron, U.5. EPA from Mr. Robert
Gellman, Freedom Savings, re: Permitting access to
the site, 7/10/87. P. 243-244.
6)
Order Amending February 13, 1987 Order and
Authorizing Trustee to Execute Right Of Access and
Release Agreement with Publicker Industries Inc.,
and Mortgagee, 7/23/87. P. 245-271. An Application
for Order Amending February 13, 1987 Order and
Authorizing Trustee to Execute Right of Access and
Release Agreement with Publicker Industries, Inc.
and Mortgages is attached.
7)
Letter to Mr. Martin Harrell, U.S. EPA, from Mr.
Richard A Penna, Schnader, Harrison, Segal, & Lewis,
re: Transmittal of the release agreement and the
right of access, 7/31/87. P. 272-283. The release
agreement and the right of access are attached.
Consent Agreement and Order in the Matter of:
Cuyahoga Wrecking Site and Publicker Industries,
Inc., 8/13/87. P. 284-301.
8)
9)
Letter to Mr. Martin Harrell, U.S. EPA, from Mr.
Richard A. Penna, Schnader, Harrison, Segal, &
Lewis, re: Interpretation of the Consent Order,
10/30/87. P. 302-302.
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10)
11 )
12)
13 )
14 )
15)
16)
17)
18)
19)
Letter to Mr. Martin Harrell, U.S. EPA, from Ms. Amy
R. Doberman, Schnader, Harrison, Segal, & Lewis,
re: Site assessment report, 11/2/87. P. 303-303.
Letter to Mr. Edward Fox, Carter, Ledyard, &
Milburn, from Mr. Martin Harrell, U.S. EPA, re:
Fire safety at the plant, 12/4/87. P. 304-305.
Letter to Mr. Richard A. Penna, Schnader, Harrison,
Segal & Lewis, from Mr. Martin Harrell, re: Fire
safety at the plant, 12/4/87. P. 306-307.
Letter to Mr. Martin Harrell, U..S. EPA, from Mr.
Edward M. Fox, Carter, Ledyard, & Milburn, re:
Freedom Savings and Loan Association interest in the
Publicker Site, 12/4/87. P. 308-309.
Letter to Mr. Richard Penna, Schnader, Harrison,
Segal, & Lewis, from Mr. Martin Harrell, U.S. EPA,
re: Response actions at the Cuyahoga Wrecking Site,
12/14/87. P. 310-310.
Letter to Mr. Edward Fox, Carter, Ledyard, &
Milburn, from Mr. Martin Harrell, U.S. EPA, re:
Response actions at the Cuyahoga Wrecking Site,
12/14/87. P. 311-311.
Letter to Mr. Peter Bergen, Le Boeuf, Lamb, Lerby, &
MacRae, from Mr. Martin Harrell, U.S. EPA, re:
Response actions at the site, 12/14/87. P. 312-
312.
Letter to Mr. Martin Harrell, U.S. EPA, from Mr.
Edward M. Fox, Carter, Ledyard, & Milburn, re:
EPA's response actions at the site, 12/16/87. P.
316-316.
Letter to Mr. Martin Harrell, U.S. EPA, from Mr.
G.S. Peter Bergen, Le Boeuf, Lamb, Lerby, & MacRae,
re: Control access to the site, 12/18/87. P. 317-
319. A formal response from Publicker Industries,
Inc. regarding recent letters and communication
about the site is attached. .
Letter to Mr. Richard Penna, 5chnader,Harroson,
Segal, & Lewis, from Mr. Martin Harrell, U'.5. EPA,
re: Review of the site assessment report, 1/7/88.
P. 320-320.
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20) Order re: Cuyahoga Equipment Corporation, 2/23/88.
P. 321-327. A Notice of Motion by Freedom Savings
and Loan Association to Relinquish Control of Access
to the Publicker Site and a Motion of Freedom
Savings and Loan Association to Relinquish Control
of Access to the Publicker Site are attached.
•V
21) Order Setting Hearing on Trustee's Application for
Approval of Option Agreement with Delaware Avenue
Enterprises, Inc., Regarding Priority of Overland
Corporation and Setting Procedure for Entertaining
Offers, 6/9/88. P. 328-414.
22) Order Approving Option Agreement with Delaware
Avenue Enterprises, Inc. Regarding Property of
Overland Corporation, 7/19/88. P. 415-428. A
Schedule C - Description and Recital is attached.
23) Order Granting Supplemental Approval of Option
Agreement with Delaware Avenue Enterprises, Inc.
Regarding Property of Overland Corporation As
Against Judgement Liens and Encumbrances, 8/9/88. P.
429-431.
24) Stipulation re: Cuyahoga Equipment Corporation,
9/23/88. P. 432-433.
25) Transcript of Public Meeting, 3/15/89. P. 434-488.
26) Letter to Mr. Brian Nishitani, U.S. EPA, from Mr. Barry
S. Neuman, Schnader, Harrison, Segal and Lewis, re:
Extending the period for submitting written comments on
EPA's Proposed Remedial Action, 3/20/89. P. 489-491.
27) Report: Report Of Findings And Work Activities, Federal
Removal Project, Publicker Chemical Site, Philadelphia,
Pennsylvania, prepared by B.E.S. Environmental
Specialists, Inc., 7/14/88. P. 492-507.
28) Letter to Mr. Jeffrey Winegar, U.S. EPA, from Mr. Jim
Dych, CECOS International, re: Review of the Proposed
Plans for the Proposed Remedial Actions to stabilize
conditions at the Publicker Industries Site, 3/7/89. P.
508-508.
29) Publicker Superfund Meeting Attendance List, 3/15/89.
P. 509-509.
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30)
31 )
32)
33 )
34 )
35)
36)
37)
38)
39)
Transmittal Sheet to Mr. Brian Nishitani, U.S. EPA, from
Mr. Barry Neuman, Schnader, Harrison, Segal and Lewis,
re: Transmittal of'a Freedom of Information request for
additional information on the Publicker Industries Site,
3/24/89. P. 510-517. A letter regarding the Freedom of
Information request and the Superfund Pro~ram Fact Sheet
Proposed Plan are attached. ;-
Letter to Mr. Barry S. Neuman, Schnader, Harrison, Segal
and Lewis, from Mr. Brian M. Nishitani, U.S. EPA, re:
Extension of the public comment period, 3/27/89.
P. 518-518.
Letter to AAA Warehousing Inc. from Ms. Donna M.
McCartney, U.S. EPA, re: Comments on the Proposed Plan
Fact Sheet, 3/31/89. P. 519-521.
Letter to Mr. Barry S. Neuman, Schnader, Harrison, Segal
& Lewis, from Mr. Brian M. Nishitani, U.S. EPA, re:
Extension of the public comment period, 3/31/89.
P. 522-522.
Letter to Mr. Barry S. Neuman, Schnader, Harrison, Segal
& Lewis, from Mr. Brian M. Nishitani, U.S. EPA, re: FOIA
request, 3/31/89. P. 523-523.
Letter to Ms. Donna M. McCartney, U.S. EPA, from Mr.
William Askins, Atochem, Inc., re: Comments on Proposed
Plan Fact Sheet, 4/19/89. P. 524-524.
Letter to Mr. Brian M. Nishitani, U.S. EPA, from Mr.
Barry S. Neuman, Schnader, Harrison, Segal & Lewis, re:
Request for extension of the public comment period,
4/28/89. P. 525-527.
Letter to Mr. Jeffrey B. Winegar, U.S. EPA, and
Mr. Harold Yates, U.S. EPA, from Mr. R. Scott McCay,
Texaco, Inc., re: Comments on possible company
liability, 5/1/89. P. 528-529.
Letter to Mr. Barry S. Neuman, Schnader, Harrison, Segal
& Lewis, from Mr. Brian M. Nishitani, U.S. EPA, re:
Request for extension of the public comment period,
5/1/89. P. 530-530. .
Letter to Ms. Donna M. McCartney, U.S. EPA, from Ms. Lynn
L. Zimmerman, Radian Corporation, re: Comments on
possible company liability, 5/5/89. P. 531-533.
11
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40) Letter to Mr. Jeffrey B. Winegar, U.S. EPA, from
Mr. Barry S. Neuman, Schnader, Harrison, Segal & Lewis,
re: Comments on EPA remedial actions at the site,
5/19/89. P. 534-680. The comments are attached.
41) Letter to Chester Salomon, Cuyahoga Wrecking Company and
Overland Corporation, from Mr. Stephen R. Wassersug, U.S.
EPA, re: 106(a) notice of possible liability, 5/25/89.
P. 681-683.
42) Letter to Mr. James J. Weis, Publicker Industries Inc.,
from Mr. Stephen R. Wassersug, U.S. EPA, re: 106 (a)
notice of possible liability, 5/25/89. P. 684-686.
43) Letter to AAA Warehousing, Inc. from Mr. Jeffrey B.
Winegar, U.S. EPA, re: Transmittal of list of
notification letters sent, 5/26/89. P. 687-689. The
list is attached.
44) Letter to Mr. Jeffrey B. Winegar, U.S. EPA, from
Mr. Barry S. Neuman, Schnader, Harrison, Segal 4 Lewis,
re: Cost estimates regarding on-site biological
treatment, 5/30/89. P. 690-693. A letter detailing the
costs is attached.
45) Handwritten letter to Marty [sic] from Dennis Matlock,
Weston, Inc., re: Transmittal of information regarding
the four bulk storage tanks, (undated). P. 694-729. A
handwritten memorandum detailing the tank information is
attached.
46) Report: Estimated Cost Summary, Publicker Industries,
Site Stabilization Operable Unit, prepared by Mr. Jeff
Winegar, U.S. EPA, (undated). P. 730-734.
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GENERAL GUIDANCE DOCUMENTS *
1) "Promulgation of Sites from Updates 1-4," Federal Register, dated 6/10/86.
2) "Proposal of Update 4," Federal Register, dated 9/18/85.
3) Memorandum to U. S. EPA from Mr. Gene Lucero regarding community relations
at Suoerfund Enforcement sites, dated 8/28/85.
4) Groundwater Contamination and Protection, undated by Mr. Donald V.
Feliciano on 8/28/85.
5) Memorandum to Toxic Waste Management Division Directors Regions I-X from
Mr. William Hedeman and Mr. Gene Lucero re: Policy on Floodplains and
Wetlands Assessments for CERCLA Actions, 8/6/85.
6) Guidance on Remedial Investigations under CERCLA, dated 6/85.
7) Guidance on Feasibility Studies under CERCLA, dated 6/85.
8) "Proposal of Update 3," Federal Register, dated 4/10/85.
9) Memorandum to Mr. Jack McGraw entitled "Community Relations Activites
at Superfund Sites * Interim Guidance,* dated 3/22/85.
10) "Proposal of Update 2," Federal Register, dated 10/15/84
11) EPA GroundttBter Protection Strategy, dated 9/84.
12) Memorandum to U.S. EPA from Mr. William Heckman, Jr. entitled
"Transmittal at Superfund Removal Procedures - Revision 2," dated 8/20/84.
13) "Proposal of Update 1," Federal Register, dated 9/8/83.
14) Community Relations in Superfund; A Handbook (interim version), dated
9/83.
15) "Proposal of First national Priority List," Federal Register, dated
12/30/82.
16) "ExpandBd Eligibility List," Federal Register, dated 7/23/82.
17) "Inter!* Priorities List," Federal Ragister, dated 10/23/S1.
18) Uncontrolled Hazardous Waste Site Ranking System: A User's Manual
(undated).
19) Field Standard Operating Procedures - Air Surveillance (undated).
20) Field Standard Operating Procedures - Site Safety Plan (undated).
* Located in EPA Region III office.
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RESPONSIVENESS SUMMARY
PUBLICKER INDUSTRIES SITE
RECORD OF DECISION
~he U.S. Environmental Protection Agency fEPA) must consider
~ublic comments made in response to the Proposed Pla~ for
the Completion of Site Stabilization Activities for ~he
?ublicker Industries Site, located in Philadelphia,
?e:-:nsylvania.
The pu~lic comment period for the Publicker Industries ~ite
?~oposed Plan was March 1, 1989 to May 19, 1989. During
that time, comments on the proposed plan were received from
the public through the public meeting held March 15, 1989,
at the Winnet South Philadelphia Community Center and
through written comments received at the U.S. EPA Of:ices.
The comments and responses have been organized into the
:ollowing categories: general, community relations,
2dministrative record, existing conditions, proposed
alternatives, cost estimate, and other alternatives.
GENERAL
COMMENT 1:
Comments were made commending EPA on their activities to
date and requesting EPA to supply funds and continue acti-
vities for the further protection of public health, welfare
and the environment in a safe, comprehensive, deliberate,
and expeditious manner.
RESPONSE 1:
EPA appreciates the comments from the public on the
activities to date. EPA has evaluated alternatives for the
completion of site stabilization activities designed to
further reduce public health, welfare and environmental
threats. The proposed plan addresses these alternatives and
identifies EPA's preferred alternative. Further action
requires the issuance of a Record of Decision (ROD)
regarding the proposed plan, including a responsiveness
summary addressing all public comments regarding the
proposed plan. Additional funding for the proposed plan is
needed under the Comprehensive Environmen~al Response,
Compensation, and Li~bility Act (CERCLA) remedial program,
which first requires the Publicker Industries Site to be
placed on the National Priorities List (NPL). The site was
proposed for the NPL in April 1989.
1
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COMMENT V
Comments were made that removal is onlv
many to insure safety of the public and
3ddition, it was urged that the site be
economically productive state.
the first step of
environment. Ir.
returned to an
RESPONSE 2:
The EPA concurs. Following completion of site stabilization
;ctivities, the site will undergo additional evaluation
under CERCLA. The additional evaluation is referred to as a
Remedial Investigation/Feasibility Study (RI/FS). The reme-
dial investigation will most likely focus on three major
areas of the site. The first area is the surface buildings
and the potential physical hazard to people from collapse.
Secondly, the soils at the site will be evaluated for likely
contamination from spills or leaks. Finally, the ground
water will be sampled and analyzed to determine if contami-
nants are present, and if present, to identify the potential
pathways for contaminant movement and to identify
potentially affected water bodies (Delaware River, New
Jersey aquifer). The RIfFS will evaluate these items and
more, and will propose alternatives for site management to
optimize protection of public health and welfare and the
environment. The Superfund Amendments and Reauthorization
Act (SARA) indicates a preference for permanent remedies
which allow reuse of the site. . Public meetings will be held
throughout the RIfFS to solicit public input on proposed
actions and to advise interested parties of the status of
all activities.
COMMENT 3:
Concern was raised over the lack of intervention by EPA
prior to the fire or while Publicker was operational.
RESPONSE 3:
Problems at the site existed long before people were aware
of the dangers of hazardous wastes. The EPA is only
19 years old and CERCLA was promulgated in 1980. CERCLA is
intended to give the Federal Government the authority to
clean up abandoned hazardous waste sites or to respond to
spills of hazardous substances onto land or into the air or
non-navigable waters, therefore the EPA d1d not have the
ability to intervene, under CERCLA, prior to the fire. The
Resource, Conservation and Recovery Act (RCRA), passed in
1976, gives the EPA authority to enforce environmental
standards on industries which store, treat, or dispose of
hazardous wastes at their sites to orotect human health and
the environment. The State of Pennsylvania Department of
Environmental Resources (DER) was given the authority to
enforce the RCRA requirements, and has been involved with
the site since approximately 1986. The DER conducted a
2
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coast~l ~Jy-over and inspection which lee to issuance of
violations to the si~e owners prior to the fire.
EPA shares the concerns of individuals regarding the need
for additional environmental laws to reeuce the potential
for future hazardous occurrences, such as the fire at the
Publicker Industries Site.
COMMENT 4:
A cornrnentor who ~ad visited the
the tanks again.
si7~
ear:ier wished to see
RESPONSE 4:
The EPA will be happy to take the commentor through the site
with an appointment.
COMMENT 5:
A cornrnentor wished to know if any funding would be made
avail~ble through the pennsylvania State Superfund program.
RESPONSE 5:
The State of Pennsylvania, as required by law, is
responsible for funding 10 percent of the cleanup.
Additional funding, for the publicker Industries Site,
the State has not been proposed or allocated.
from
COMMENT 6:
Concerns over provisions for public input to Superfund
decisions in the proposed National Contingency Plan (NCP) of
December 1988 were raised.
RESPONSE 6:
While EPA Region III appreciates the public reviewing the
proposed NCP, the comments need to be sent to EPA Head-
quarters in Washington D.C. The comments do not directly
apply to the Publicker site.
COMMENT 7:
A commentor states that according to EPA,.the most serious
hazards have been eliminated as a result of past activities,
yet EPA is proposing to spend another $14 million without
considering alternatives that would be significantly less
expensive and equally, if not more, protective.
3
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RESPONSE 7;
The emergency removal action conducted at the site between
December 1987 and December 1988, significantly stabilized
conditions by addressing the immediate fire and explosion
threats. The potential threat of fire continues to be
significant according to the City of Philadelphia Fire
Marshall's Office. Due to many spill areas of potentially
ignitible substances and site structures containing large
amounts of wood construction, some of which are over
50 years old, conditions that contribute to the increased
risk of future fires at the site continue to exist. A fire
could easily cause tanks and drums containing bulked waste
materials onsite to rupture or explode, releasing chemical
contaminants into the environment. Based on additional
sampling/analytical data required prior to site
stabilization design activities, treatment technologies that
are compatible with the waste streams will be assessed for
cost-effectiveness.
COMMENT 8:
A commentor supports all response actions that are necessary
and cost-effective. Nonetheless, as discussed in subsequent
comments, the commentor does not believe the record supports
the agency's current proposed actions. Present conditions
at the site are sufficiently stable to allow additional
alternatives to be assessed.
RESPONSE 8:
Conditions at the site have been significantly stabilized
when compared to site conditions prior to EPA's Emergency
Removal Program activities. Waste streams were bulked in
reconditioned tanks and in drums with the understanding that
offsite disposal of these substances would occur in the
immediate future. The bulking operation performed was
intended to be a temporary measure until additional funding
was available through the remedial program. The long-term
storage of these waste streams under present conditions was
not intended and is unsafe and inappropriate. Additional
-Iternatives were considered and are presented in the ROD.
Once the bulked wastes are removed offsite for disposal,
site entry would be permitted to perform an RI/FS to
investigate the extent of soil and ground water
contamination.
COMMENT 9:
A commentor urges EPA to use time that is available to
consider and implement actions that are environmentally
preferable, cost-effective, and otherwise consistent with
statutory and regulatory requirements.
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RESPONSE 9;
EPA has used the time period since the Emergency Removal
action to prepare a ROD which selects a remedy that
addresses the continued threat of fire and explosion. The
selected remedy meets all of the statutory mandates. It is
protective of human health and the environment, attains
Applicable or Relevant and Appropriate Requirements (ARARs),
is cost-effective, utilizes permanent solutions and
alternative treatment technologies or resource recover"
technologies to the maximum extent practicable, and has a
preference for treatment as a principal element.
COMMUNITY RELATIONS
COMMENT 1;
A question was raised as to why the public meeting was held
in the 183rd District while the Publicker Site is located in
the 184th District and why the repository, is located at the
EPA offices.
RESPONSE 1 :
The EPA examined a number of locations and conferred with
various individuals to find the most convenient and suitable
location for the meeting, and chose the Winnet South
Philadelphia Community Center. Criteria for selection
included the close proximity to the Publicker Site (approx-
imately 2 miles), adequate capacity (200 persons), and easy
access (approximately 1.25 miles from 1-95). EPA agrees to
holding another meeting at a location within the 184th
District in the future.
The repository location was selected to allow wide-spread
access to the information since there is wide-spread inter-
est in the site. The repository location also allows for
new information to be available immediately and for easy
maintenance of the information.
COMMENT 2:
A concern was raised that EPA held the public meeting to
discuss whether or not the cleanup of the site should
continue. The commentor did not want activities to stop.
RESPONSE 2:
EPA needs more money to continue the cleanup and needs to
get it from the Superfund remedial program. The reason for
the public meeting on March 15 was to streamline the admin-
istrative process required in a remedial site cleanup by
receiving the public's comments on the proposed plan. EPA
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has proposed site stabilization and is not considerir.g a no
action alternative at this time.
CO~_~ENT 3:
rl commentor asked if EPA had contacted community groups
c~ose to the site such as the Whitman Park Council and the
Pennsport Civic Association and if the groups were familiar
with ~otential hazards from the site and emergency measures.
It was further suggested to contact local, interested com-
~ur.ity groups to ~dvise them o~ ~uture public meetings 3nd
solicit suggestions on a convenient meeting place.
RESPONSE 3:
The EPA recognizes the comment. In the future, EPA will
make ~ll attempts to personally contact local groups to
advise them of upcoming meetings and entertain any and all
suggestions regarding the meeting place. EPA appreciates
receiving any names of interested local groups. The Whitman
Park Council was contacted before the March 15th meeting and
the council was in agreement with the proposed plan. EPA is
unaware with the group's familiarity with the site and upon
request, will supply all available and appropriate informa-
tion to any group.
CO~.MENT 4:
A comment was made that no notice was given about the
availability of technical assistance grants (TAG) to the
public.
RESPONSE 4:
TAGs are not available to the public until the site is on
the NPL.
ADMINISTRATIVE RECORD
COr-'1MENT 1:
Accordinq to a commentor, the following information was not
found in the administrative record:
o
Field notes
o
Backup for the costs presented at the public
meeting
o
Analytical data for the materials in the bulk
storage tanks
6
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o
--Details on the proposed action such as dismantlir.g
the piping
o
Information on the methods 0: disposal or
treatment considered for the ?roposed action
o
A discussion of whether EPA considered onsite
treatment and if so, why it was rejected
RESPONSE 1:
Field notes and backup for the costs presented at the public
meeting, which were inadvertently omitted from the
administrative record, have since been included.
Due to the vast quantity of analytical data, this
information was not included in the administrative record.
However, a reference page does exist in the record notifyin~
persons desiring to review the analytical data to contact
the Remedial Project Manager.
During this initial remedial action, all above-grade process
piping will be dismantled and stored onsite for future
disposal. As each process line is dismantled, the recovery
of its waste contents will be performed. The hazardous
materi~ls that may be found during this activity will be
sampled, analyzed, transported, and disposed of offsite.
Pipe insulation materi~ls that may contain asbestos will be
properly p~ckaged and stored at a secure onsite location for
future disposal.
Methods of offsite disposal or treatment considered for the
proposed action cannot be selected at this time due to the
unavailability of detailed analytical data. Waste streams
bulked during the emergency removal action were sampled for
compatibility prior to consolidation yet the chemical
composition of the final bulked waste and of liquids
contained within the above-grade process lines have not been
identified. Detailed sampling of the bulked materials and
the process line contents will occur prior to design of the
bulked waste materials removal and disposal and during the
process line dismantling activities, respectively. The
selection of disposal or treatment alternatives will be
based on the cost-effectiveness of the various amenable
treatment/disposal technologies to the wa.ste streams.
EPA has considered onsite treatment of the bulked and
unknown process line waste streams. However, onsite
treatment was not considered to be implementable at this
site. Due to the variety of waste streams onsite requiring
a variety of treatment technologies and the close proximity
of site structures, the lack of 3vailable open space limits
the mobilization of several treatment processes. The onsite
7
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incineration 0: many of these waste streams in an area where
hazardousJignitable wastes are stored is an unsafe practice.
Also area residents have opposed other incineration projects
due to air quality concerns.
CO~~ENT 2:
A cornmentor wishes to correct the following perceived errors.
and oversights present in the administrative record:
RESPONSE 2:
o
Publicker :ndustries is not the site owner or
operator. The property was sold more than 14
months before the fire of June 1987.
o
After the property was sold, a program to
dismantle the facilities was initiated which
involved a tragic explosion and over 140 bags of
asbestos waste. These were not the result of
Publicker activities.
o
A former contractor of Publicker's did not state
or imply to EPA that the presence of hazardous
materials represented "questionable activities" or
were "totally unrelated" to Publicker operations
as the record indicates. (A letter from the
contractor addressing this issue was provided.)
o
The record refers to a fire in 1985. Publicker is
only aware of the 1986 explosion and the 1987
fire, both of which occurred after Publicker sold
the property.
o
In the written comments, Publicker produced
numerous examples to illustrate that they have not
been recalcitrant or uncooperative as they feel
the record implies.
Although the facility was sold to Overland Corporation, a
subsidiary of CUYuhoga Wrecking Corporation in 1986, for
dpproximately 73 years the site was owned and operated by
Publicker Industries Inc. The site was therefore known to
local residents as the Publicker Industries facility. The
reference of the site by any other name would make it
unfamiliar to local residents and may be 'misleading to
others. '
The record inadvertently refers to a fire in 1985. The
reference of the fire in 1985 is incorrect and is so noted.
It is noted that the other items in this comment do not
relate to the substance of the proposed remedial action and
8
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therefore will not ~e responded to in this
summary.
responsiveness
EXIS~:NG CONDITIONS
:OMMENT 1:
A concern was raised about the air quality in the ~icinity
0f the Publicker Site.
~ESPONSE 1:
The immediate removal actions already completed by the EPA
have been designed to reduce the potential risk to public
health which includes exposure by inhalation. The proposed
plan sets forth additional steps intended to further
minimize the potential risk to public health, welfare and
the environment. The RIfFS will also identify any remaining
risk through inhalation and if the risk exists, will
identify alternatives to mitigate the risk.
COMMENT 2:
A concern was raised regarding the status and safety of some
of the 500,000 gallon tanks onsite.
RESPONSE 2:
Four onsite tanks are currently used for the temporary
storclge of 1 million gallons of hazardou~ waste. The
superstructure of the four tanks is approximately 35 years
old. Prior to the placement of any hazardous wastes in the
tanks, the tanks were tested, repaired as needed (new
floors, walls), and certified to be structurally sound by a
tank testing company. After fixing the old tanks, EPA
:illed the tanks with water and let them sit for a
determined period of time while continually monitoring for
leaks. Two other tanks at the site are used for the storage
of oil. All tanks are monitored daily for leaks by
recording levels, inspecting the surrounding area for signs
of spills and leaks, and visually inspecting the tank
exteriors for signs of leakage and/or corrosion.
COMMENT 3:
A question was asked regarding the potential for a future
catastrophe (fire, explosion, release of chemical fumes into
the air) at the site. If there is a potential, are there
some kind of emergency procedures in place for evacuation or
community notification, as well as programs in place to
inform the community of potential hazards?
9
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RESPONSE 3:
The EPA believes that there is a continued threat posed by
the Publicker Industries Site which is the reason for the
?roposed site stabilization activities. There are several
?rograms currently implemented by EPA, at the site, which
are designed to minimize potential threats. One program is
the 24-hour onsite fire watch and security patrol that has
been established to provide immediate notification in the
event of a fire, explosion, spill or breach in the site
security. Individuals assigned to the 24-hour watc~ are
trained in fire fighting and hazardous waste management pro-
cedures. Additionally, a Contingency Plan has been
developed in conjunction with the City of Philadelphia. The
Contingency Plan addresses the procedures for responding to
emergency situations at the site, identifies primary
response authority where more than one agency would respond,
identifies evacuation procedures, provides the notification
procedures (call down list) for all potential response
groups, and identifies those individuals primarily respon-
sible for all emergency response actions.
In response to community awareness, the EPA will attempt to
familiarize all interested parties with potential hazards
and in-place response plans for the site. Additionally, in
accordance with SARA Title III, EPA is required to actively
participate with the community and share all available
information on the characteristics and potential hazards
regarding the materials and activities at the site.
COMMENT 4:
A comment was made that during the removal actions, there
may have been instances where materials were bulked in such
a manner so final disposal costs will be greater than if the
wastes were not mixed. .
RESPONSE 4:
The materials bulked on the Publicker site were sampled and
analyzed for compatibility. Only compatible materials were
bulked. This is a standard and acceptable practice
performed on many sites by both industry and EPA in order to
minimize analytical, transportation, and disposal costs.
EPA has not bulked materials in such a manner as to
knowingly increase disposal costs at the Publicker site.
PROPOSED ALTERNATIVE
COMMENT 1:
A comment was made that the public has been deprived of a
meaningful opportunity to comment because the basis of and
10
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assumptions underlying EPA's proposed plan are unknown and
undeterminable.
RESPONSE 1:
As required by the NCP, a full 30-day comment period
(March 1, 1989, to March 30, 1989) was held to seek public
comment on the Proposed Plan. In addition to the 30-day
period, Publicker Industries Inc. requested and received an
extension to May 19, 1989.
Due to the continuing threat of fire and explosion at the
site, an early action to further stabilize site conditions
will be performed. Based on current analytical data
obtained during the emergency removal action, twelve (12)
waste streams have been identified. The identified waste
streams are amenable to one or more treatment/disposal
technologies which include physical/chemical treatment,
biological treatment, thermal treatment, landfilling, and
recycling. It is currently unknown, and can not be
determined at this time, the specific characteristics of the
bulked waste streams and the preferred method of
treatment/disposal. Prior to design activities, EPA will
perform detailed sampling of the waste streams to determine
the most cost-effective method of offsite
treatment/disposal.
COMMENT 2:
A commentor feels EPA has not clearly stated why immediate
measures are needed.
RESPONSE 2:
The storage of hazardous/ignitible wastes at an abandoned
facility that is located near a highly populated area which
has had a history of fire and vandalism, warrants EPA's
proposed action.
COMMENT 3:
A commentor feels EPA's proposed action, in all likelihood,
would not be cost-effective, consistent with a permanent
remedy, or consistent with the statutory preference for
onsite treatment over offsite disposal.
RESPONSE 3:
As mandated by SARA, all remedial actions must meet certain
statutory requirements. The selected initial remedial
action for the Publicker Industries site is cost-effective
11
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and is consistent with future site remedial activities. EPA
has selected offsite treatment/disposal in place of onsite
treatment because of the limited availability of open space
for treatment process mobilization, the difficulty in
operating treatment processes in an environment which stores
large quantities of hazardous/ignitable wastes, and the
likelihood of public opposition to any potential air
emission release from onsite treatment operations.
COMMENT -+:
A comment was made that the assumption made by EPA that
offsite transportation and disposal would be necessary at
some point in any future site remediation is unsupported and
unsupportable.
RESPONSE 4:
The lack of available open space for the safe operation of
treatment processes in an area where large volumes of
hazardous/ignitable wastes are stored supports the selection
of offsite treatment. Also the likelihood of public
opposition resulting from the potential of release of air
emissions by onsite treatment operations further supports
this action.
COMMENT 5:
It appears to a commentor to be appropriate to perform a
focused feasibility study for the bulk and drummed wastes
present on the site as EPA is proposing to address these
wastes with an operable unit action at the site. Operable
unit actions must be cost-effective and consistent with a
permanent remedy.
RESPONSE 5:
Due to the continued threat of fire and explosion at the
Publicker Industries site, EPA is taking this early action
to further stabilize existing site conditions. A remedial
investigation and focused feasibility study would require
approximately 12 to 18 months to complete. Current site
conditions justify EPA's immediate action. As responded to
in other comments, the selected remedial action is
cost-effective and consistent with a permanent remedy.
COMMENT 6:
A question was raised regarding the length of time it will
take to complete the site stabilization.
12
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RESPONSE 6;
EPA has completed the- emergency removal activities. All
additional work at the facility requires funding through the
CERCLA remedial program. In order to receive this funding,
the site must be placed on the NPL. The site was proposed
for the NPL in April 1989 and it is anticipated the list
will be finalized between June and August 1989. Once on the
NPL, EPA will advertise in the Commerce Business Daily for
thirty days, to solicit bids from contractors to perform the
required work, in accordance with the design plans and
specifications prepared by the EPA. Review of the bid
packages and selection of a contractor will take
approximately two months. Following the award of the
contract and robilization of the contractor, site
stabilization should be completed within approximately 6 to
8 months. In summary , the completion of the site sta-
bilization activities is anticipated within 12 to 18 months.
COMMENT 7:
A commentor wanted to know if the immediate threat of fire,
explosion, and release of chemicals would be eliminated
following completion of the site stabilization activities.
RESPONSE 7:
The EPA believes that following the completion of the site
stabilization activities, the threat to the community from
fire, explosion, and catastrophic release of chemicals will
be removed. Already, the threat to the community has been
substantially reduced.
COST ESTIMATE
COMMENT 1:
A commentor notes that the proposed plan fact sheet states
that the estimated cost of EPA's preferred alternative is
$8.5 million. However, at the public meeting, EPA said the
estimate was $13 million. EPA's written cost estimate is
for $13.9 million.
RESPONSE 1:
EPA has amended the cost estimate based on revisions made to
the proposed draft scope of work for site stabilization
design activities.
COMMENT 2;
A commentor believes EPA's cost estimate was not prepared in
accordance with good engineering practices. It did not
include a sensitivity analysis. The commentor estimates
13
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that transportation and offsite disposal of bulk tank and
drum contents should be between $1,198,000 and $3,355,000
instead of $6,816,000 as estimated by EPA. The commentor's
unit costs were obtained from vendors. The cost estimate is
presented as a range because of the lack of material
information and variations in vendor prices. Backup for the
ccmmentor's cost estimate was provided with the written
comments.
RESPONSE 2 :
The manner in which EPA's current cost estimate was prepared
is to ensure that appropriate funding would be available to
complete the site stabilization measures. A large
contingency is included in the unit pricing figures for both
transportation and treatment/disposal costs due to the
unknown chemical characteristics and volumes of the bulk
waste streams and process line contents. Also built into
the unit price figures is an allowance for any additional
unforeseen circumstances that may occur. Once additional
sampling is performed and the design finalized, the current
cost estimate will be refined.
COMMENT 3:
A comment was made that backup cost information for piping
dismantling and asbestos removal and for decanting Tank No.
238 is not available according to EPA. The commentor
believes that a cost estimate with no basis is inconsistent
with CERCLA objectives of identifying cost-effective
alternatives. Detailed comments made about the cost
estimate include:
o EPA's price for offsite disposal of bulk material
is $7/gallon for every type of bulk material. It
is unknown if this estimate is an average for all
materials. No justification for this cost is
given nor is any offsite facility or disposal
means identified. EPA said the estimate was
obtained from the Technical Assistance Team (TAT)
contractor.
o In a report prepared by B.E.S. Environmental
Specialists for EPA entitled "Report of Findings
and Work Activities-Federal Removal Project,
Publicker Chemical Site", July 1988, costs for the
disposal of the Base Neutrals and Oxidizing
Liquids are $0.1 to $0.5/gallon, not $7/gallon as
used by EPA in the proposed plan.
o EPA's price for offsite disposal of every type of
drummed materials is either $500/drum or
$1,000/drum. Again, EPA said the estimate was
14
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obtained from the TAT contractor and no
'"justification is available.
o The commentor concurs with EPA's transportation
cost estimate of S2,000 per 4,000 gallons of
bulked material. However, the commentor estimates
that the 4000 gallons equals roughly 75 drums, not
40 drums as EPA estimates. Therefore, the $2,000
transportation costs should be for 75 drums, not
40 drums.
o EPA does not include $20,000 in their cost
estimate to transport material in Bulk Storage
Tank 306.
o The commentor believes PCB solids and liquids will
be transported on one vehicle, not two as
estimated by EPA. This results in a $2,000
transportation charge for PCBs not being incurred.
RESPONSE 3;
EPA's current cost estimate will be refined once additional
information is obtained. The most appropriate,
cost-effective treatment/disposal processes will be selected
once additional sampling/analysis is performed on the waste
streams. Unit costs for transportation and
treatment/disposal expenses will be subject to current
industry market pricing.
OTHER ALTERNATIVES
COMMENT 1;
A commentor notes the costs and feasibility of particular
alternatives are sensitive to the characteristics of the
material. For all the money spent thus far, the commentor
notes that analyses to allow selection of a cost-effective
.alternative was not conducted.
RESPONSE 1:
Detailed sampling and analysis of the various onsite waste
streams will be performed prior to the selection of specific
treatment/disposal processes to ensure cost-effectiveness.
COMMENT 2;
A comment was made that the hazardous wastes in the bulk
storage tanks and drums could remain in storage until an
RI/FS is complete. Significant economies of scale could be
realized if the waste and contaminated soil are treated
15
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together._ Continued storage with the proper safety
precautions and inspections should be considered. If the
tanks were actually rebuilt to industry standards, as stated
by EPA, and if all explosive chemicals have been removed,
continued storage should be safe. The risks posed by
securely stored flammable materials is not necessarily
greater than those found at other facilities in the area.
RESPONSE 2;
The time period required to perform a RI/FS is approximately
12 to 18 months. Existing site conditions justify EPA's
immediate action. Although signficant site stabilization
measures were taken to eliminate the immediate fire and
explosion threats, the potential of future fire exists. The
safe storage of the flammable materials in the rebuilt tanks
is jeopardized by the surrounding conditions of the
facility. The facility is in very poor condition because of
past fires, demolition on the site, neglect, and vandalism.
These are all contributing factors to the possible
occurrence of future fires at the site which could ignite
the stored materials.
COMMENT 3:
A comment was made that EPA did not consider using onsite
incineration to treat the onsite wastes despite the fact
that many of the wastes present may be amenable to this
technology and the significant quantities present may result
in significant economies of scale, and despite the fact that
their contractor, B.E.S., specifically recommended that EPA
investigate onsite treatment of drummed waste "because of
the potential large cost savings". The commentor provided a
brief evaluation of the technical feasibility and cost
analysis of incineration and found it to be feasible and
less expensive ($2.67 million to $4.88 million versus $6.8
million) than EPA's estimate for offsite disposal.
RESPONSE 3:
EPA did consider the use of onsite incineration. However,
the use of incineration at the site was eliminated from
further consideration due to the unsafe operation in an
unstable area where large volumes of ignitible/hazardous
wastes are stored.
COMMENT 4:
A commentor evaluated onsite biological treatment of base
neutrals and concluded that it should have been considered.
The commentor felt they had insufficient analytical
information available to accurately evaluate biological
treatment; they estimated the needed analytical testing to
16
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seriously evaluate this alternative could be performed for
$10,000 tp $20,000. Unit costs obtained by the commentor
indicated a possible cost savings of over $1.15 million for
383,000 gallons of waste over offsite disposal.
RESPONSE 4;
Offsite biological treatment of bulked base neutral liquids
will be considered. However, it is not known at this time
whether this waste stream will be amenable to this
technology. Base neutral liquids will be sampled and
analyzed to determine if substances that may be detrimental
to biological treatment are present.
COMMENT 5:
A commentor feels that onsite oxidation of sulfur compounds
should have been considered yet they feel the opportunity to
take advantage of this technology has been lost since EPA
bulked sulfide and nonsulfide wastes together. EPA should
have explored possible means of cost savings.
RESPONSE 5:
EPA's Emergency Response Contractors operate on a time and
materials contract. Onsite treatment processes have a
potential to save costs but usually only when large
quantities of materials are being treated. This is due to
the initial overhead of setting up the process. There
existed three drums of sulfide-containing material; two of
these drums were also oxidizing liquids, the other a base
neutral liquid. Due to the small quantities of sulfides at
very low concentrations, it was deemed appropriate to bulk
these materials as oxidizing liquids and base neutral
liquids. The hazard associated with sulfides stems from the
product of their reaction with acids which produces hydrogen
sulfide. This hazard was not significant at the sulfide
concentration of 10 ppm and the threat was mitigated once
bulked.
COMMENT 6;
A commentor notes that B.E.S. suggested onsite treatment in
July 1988 so EPA has no argument that time constraints
precludes a more thorough assessment of alternatives.
RESPONSE 6:
Onsite treatment of the various waste streams was not
selected due to existing site conditions which have been
previously discussed. The selection of the proposed
17
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remedial action was not affected by any time constraint that
would have provided for a more thorough assessment of
alternatives.
alternatives.
WDR425/018
18
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L.tA
PENNSYLVANIA
DEW
.
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Post Office Box 2063
Harrisburg, Pennsylvania 17120
March 31, 1989
Deputy Secretary for
Environmental Protection
(717) 787-5028
Stephen R. Wassersug, Director
Hazardous Waste Management Division
EPA Region III
841 Chestnut Building
Philadelphia, PA 19107 .
Re: Letter of Concurrence
Publicker Industries, Record Of Decision (ROD)
Dear Mr. Wassersug:
The Record of Decision for the initial operable unit
which addresses the site stabilization and remedial removal
activities at the Publicker Industries site has been reviewed by
the Department.
The major components of the selected site
stabilization remedy include:
*
I
*
*
*
I
Transportation and disposal of the known remaining
on-site waste streams. Bulked hazardous/flammable
waste streams will be transported off-site to undergo
treatment and disposal at permitted Resource
Conservation and Recovery Act (RCRA) facilities.
Demolition of above-grade process pipe lines that
traverse the site. This may include the recovery of
unknown hazardous chemicals and the removal of pipe
insulation materials such as asbestos-containing
materials.
Proper packaging of the insulation materials removed
from the process lines. Insulation materials
including asbestos will be properly stored on-site
until future site remedial actions are performed.
Transportation and disposal of all hazardou8 chemicals
recovered from within the process lines. Bulked
hazardous/flammable waste stream8 will be transported
off-site to undergo treatment and dispo8al at
permitted Resource Conservation and Recovery Act
(RCRA) facilities.
-------
Stephen R. Wassersug, Director -2- March 31, 1989
I hereby concur with the EPA's proposed remedy with the
following conditions:
* The Department will be given the opportunity to concur
with decisions related to subsequent operable units and
the future Remedial Investigation and Feasibility Study
to identify the extent of, and future potential for,
site related contamination and remaining sources of
that contamination, and evaluate appropriate remedial
alternatives to assure compliance with DER cleanup
ARAP.s and design specific ARARs.
* EPA will assure that the Department is provided an
opportunity to fully participate in any negotiations
with responsible parties.
* The Department will be given the opportunity to concur
with decisions related to the design of the Remedial
Action, to assure compliance with DER design specific
ARARs.
* The Department will reserve our right and
responsibility to take independent enforcement actions
pursuant to state law.
* This concurrence with the selected remedial action is
not intended to provide any assurances pursuant to SARA
Section 104(c)(3).
Thank you for the opportunity to concur with this EPA
Record of Decision. If you have any questions regarding this
matter please do not hesitate to contact me.
Sincerely,
M. McClellan
Deputy Secretary
Environmental Protection
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