United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-91/114
June 1991
Superfund
Record of Decision
Publicker/Cuyahoga
Wrecking Plant, PA
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50272-101
REPOpr DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R03-91/114
3. Recipient1* Acceuion No.
4. Tide and Subtitle
""PERFUND RECORD OF DECISION
>licker/Cuyahoga Wrecking Plant, PA
__cond Remedial Action
5. Report Data
06/28/91
7. Authors)
8. Performing Organization Rept No.
8. Performing Organization Nun* and Addre**
10. Project!Mk/Work Unit No.
11. Contracted or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Nam* and Addre**
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 2046'0
IX Type o< Report & Period Covered
800/000
14.
15. Suppletnentiry NotM
16. Abstract (Limit: 200 word*)
The 37-acre Publicker/Cuyahoga Wrecking Plant site is a former liquor and industrial
alcohol distillery in Philadelphia, Philadelphia County, Pennsylvania. Surrounding
land use is primarily industrial, with 400,000 people living within a 1-mile radius of
the site. From 1912 until 1986 when the plant closed, alcohol distilling operations
^re conducted onsite. From the 1970s to 1980s, the site was also used as a petroleum
id chemical storage facility, which utilized 440 large above-ground tanks, stored
chemicals, chemical laboratories, reaction vessels, production buildings, warehouses, a
power plant, and several hundred miles of above-ground process lines, many of which
were wrapped with asbestos insulation. In 1987 a CO2 utilization area was destroyed in
an onsite fire, which was accompanied by numerous explosions. Subsequent onsite
inspections by EPA and the State identified leaking tanks, pits, and process lines
containing fuel oil, and shock-sensitive explosive materials, and 7,000 gallons of
reactive and flammable materials in fermentation tanks and grain dryers. In 1987, EPA
stabilized the site by bulking flammable and explosive materials onsite for future
disposal, disposing of highly reactive laboratory wastes and cylinders offsite,
crushing 3,100 empty drums, wrapping overhead asbestos-covered process lines with
(See Attached Page)
17. Document Analysi* a, Descriptor*
Record of Decision - Publicker/Cuyahoga Wrecking Plant, PA
Second Remedial Action
Contaminated Medium: debris
Key Contaminants: inorganics (asbestos)
b. tdentifierc/Open-Ended Term*
c. COSATI fieW/Group
liability Statement
It. Security Clau (This Report)
None
20. Security Clau (This Page)
None
21. No. of Page*
30
22. Price
(See ANSI-Z39.18)
See Intlructiona on Reverse
Or IIUNAL rUHM 2f2 (4-/7)
(Formerly NT1S-35)
Department of Commerce
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EPA/ROD/R03-91/114
• 4
Publicker/Cuyahoga Wrecking Plant, PA
Second Remedial Action
ract (Continued)
plastic, and bagging and storing loose asbestos materials onsite. A 1989 Record of
Decision (ROD) addressed Operable Unit 1 (OU1) and provided for offsite treatment and
disposal of hazardous waste streams and chemicals recovered from within the process
Mnes, demolition of the above-ground process lines, and packaging and onsite storage of
asbestos and other insulation materials. This ROD addresses a portion of OU2,
specifically the bulked asbestos stored onsite, any remaining asbestos material attached
to overhead exterior pipelines, and a pile of asbestos debris near a loading pier. A
subsequent ROD will address onsite soil and ground water contamination. The primary
contaminant of concern present as debris is asbestos, an inorganic.
The selected remedial action for this site includes removing approximately 150 cubic
yards of asbestos from overhead extraction pipes and placing this material in plastic
bags; staging this material, along with 6 cubic yards of asbestos from near a loading
pier and 1,100 cubic yards of bagged asbestos from previous removal and remedial actions/-
and disposing of the staged asbestos offsite. The estimated present worth cost for this
remedial action is $293,420. There are no O&M costs associated with this remedial
action.
PERFORMANCE STANDARDS OR GOALS: All bulked and remaining loose asbestos material will be
removed from the site. No specific cleanup standard for asbestos was provided.
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RECORD O? DECISION
PUBLICKER INDUSTRIES SITE
DECLARATION
SITE NAME AND LOCATION
Publicker Industries Site
City Of Philadelphia, Philadelphia County, Pennsylvania
STATEMENT O? BASIS AND PURPOSE
This decision document presents the selected remedial action for
the second operable unit (OU-2) for the Publicker Industries Site
in Philadelphia, PA, which was chosen in accordance with the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP).
This decision is based upon the Administrative Record for the
site (index attached).
The Commonwealth of Pennsylvania agrees with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THB SELECTED REMEDY
This early final remedial action, which is the second operable
unit (OU-2) for the site, addresses a principal threat at the
site by removing bulked asbestos and other asbestos-containing
material to an offsite disposal facility. ^
A Remedial Investigation/Feasibility Study (RI/FS) is currently
under way for the soil and ground water. When the RI/FS is
completed another decision will be made for the soil and ground
water operable unit.
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The selected remedy includes the following major components:
* Removal of remaining asbestos from piping staged
throughout the site; placement in secure packaging
(plastic bags); and staging and preparation for
transport and disposal
* Collection of all asbestos waste previously packaged
and staged at the site; repackaging it if necessary;
and preparation for transport and disposal
* Transportation of all asbestos wastes to a permitted
offsite disposal facility (landfill).
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment or resource
recovery technologies to the maximum extent practicable for this
site. However, because treatment of the asbestos materials at
the site was not found to be the best alternative, the statutory
preference for treatment has not been met but a permanent remedy
for the site has still been selected.
Because this remedy will not result in hazardous substances
onsite above health-based levels, the five-year review will not
apply to this action.
/"- Edwin B. Erickson Date
Regional Administrator
Region III
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Remedial Alternative Record of Decision Summary
Publicker Industries Site
Site Name. Location and Description
The Publicker Industries Site is located in the southeastern
portion of the City of Philadelphia, Pennsylvania (see Figure 1).
The Site is bordered to the east by the Delaware River, to the
north by the Ashland Chemical Company, to the south by the Packer
Marine Terminal and New Orleans Cold Storage, and to the west by
Delaware Avenue. The Site is adjacent to and under the Walt
Whitman Bridge which spans the Delaware River from Philadelphia
to New Jersey.
The Site is located within the Atlantic Coastal Plain Province.
The Site is underlain by Holocene age sediments, the Pleistocene
age Trenton Gravel, and the Cretaceous age Potomac-Raritan-
Magothy (PRM) formations.
Two types of aquifers have been identified at the Site: an
unconfined aquifer consisting of Holocene sediments and the
Trenton Gravel; and a confined aquifer consisting of various sand
units in the PRM. Neither aquifer apparently is used as a public
source of water in Pennsylvania, however, the confined aquifer(s)
are used extensively for water supply in New Jersey. Both
aquifers are presumably being recharged to some limited extent
from precipitation at the Site.
The area is primarily industrial; however, there are major
population centers within one mile. In addition, there are
several businesses (primarily food plants), the Philadelphia
Naval shipyard, two large outdoor Sports Arenas and Interstate 95
nearby (See Figure 2). Center city Philadelphia is approximately
two miles from the Site. Within three-quarters of a mile are the
cities of Gloucester and Camden, New Jersey.
An estimated population of 400,000 people lives within
approximately one mile of the Site. Three schools and two
hospitals are located within a one and one-half mile radius of
the Site.
Publicker Industries had operated a liquor and industrial alcohol
distillation process at the Site until approximately 1986. The
Site is approximately 37 acres in area and included nearly 440
large tanks, storage drums, product stock,
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chemical laboratories, reaction vessels, production buildings,
warehouses, a power plant and an estimated several hundred miles
of above-ground process lines. Many of the above-ground process
lines were formally wrapped with asbestos insulation. The
general layout of the Site and surrounding area is shown on
Figure 2.
Many of the existing structures have deteriorated due to weather,
fire and neglect. The facility has three water-front piers that
extend into the Delaware River.
Nineteen deep production wells (See Figure 2), ranging in depth
from 150 to 200 feet, are reported to exist on the Site property.
(Only 15 of the 19 wells have been located from existing Site
maps.) These deep wells were installed 40 to 50 years ago to
supply cooling water to heavy equipment at the facility.
Site History and Enforcement Activities
Site History
Publicker Industries, Inc. is a publicly held corporation
headquartered in Old Greenwich, Connecticut. From approximately
1912 to late 1985, Publicker owned and operated a liquor and
industrial alcohol manufacturing plant at the Site. The
Publicker facility fermented potatoes, molasses, corn, and
various grains, and distilled the alcohols. The alcohols were
used in numerous products including whiskey, solvents, cleansers,
antifreeze, and rubbing alcohol. The plant's production peaked
during World War II and again in the 1970s. During these times,
the plant employed over 1,000 people. The Site also was utilized
as a petroleum and chemical storage facility during the late
1970s and early 1980s.
Plant operations had been in decline since the late 1970s and
employment had decreased to 5 people before Publicker
discontinued operations in February 1986. In 1986, Publicker
sold the property to Overland Corporation, a subsidiary of
Cuyahoga Wrecking Corporation.
During demolition activities, two Cuyahoga employees were killed
by an explosion that resulted from the cutting of a process line
with a torch. Shortly after this incident, Overland Corporation
declared bankruptcy and abandoned the facility. The property is
administered by a bankruptcy trustee.
In June of 1987, the carbon dioxide utilization portion of the
facility was destroyed in a multi-alarm fire. During the fire,
numerous explosions and fire flares were reported which led fire
officials and the U.S. Environmental Protection Agency (EPA)
emergency response personnel to believe that chemical products
were still present at the facility.
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An initial Site inspection was conducted by EPA and its support
staff on July 9, 1987. City of Philadelphia representatives were
also onsite to inspect portions of the facility that were not
affected by the fire. Numerous spill areas, improper drum
storage and leaking process lines were observed by the inspection
team. A sheen, originating from the Site was apparent in the
waters of the Delaware River.
Tanks, pits/sumps, and numerous process lines onsite were found
to contain fuel oils or other contaminated oils. (Pesticides and
volatile organic compounds not commonly found in fuel oils have
been identified as contaminants in some of these oils.) EPA has
determined that a major quantity of this contaminated oil is
contained in unsound storage vessels (leaking pipelines and
tanks). It has been estimated that 252,000 gallons of unsecured
contaminated oil had been previously stored onsite.
In addition to these waste products, further inspections and
inventories identified shock-sensitive and explosive materials
throughout the facility.
Tanks containing spent grain material from the whiskey
manufacturing operation were determined by EPA to contain
approximately 70,000 gallons of reactive and flammable layers/
phases that exhibit characteristic RCHA wastes. These tanks
contain residual grain materials collected from fermentation
tanks and grain dryers. Analysis of these tanks shows that
layers of flammable (flash point less than 140 degrees
Fahrenheit) and reactive materials are present.
As determined by analysis conducted in 1989, asbestos-containing
materials are ubiquitous at the Site, particularly in relation to
building materials and piping insulation. Approximately 1,200 to
1,300 cubic yards of asbestos waste exists at the Site. Most of
this waste was originally piping insulation, and was previously
removed from above-ground piping that was dismantled during the
period 1988-1990 by EPA Emergency Response/Removal contractors.
A large portion of the asbestos waste is currently secured and
staged in bags in several locations at the Site. A small amount,
however, remains attached to and exposed on piping throughout the
Site. i
The integrity of many of the Site structures is poor due to past
fires, neglect, and the age of the facility. Although much of
the asbestos was consolidated during the removal action, the
potential threat of release remains.
Due to these Site conditions, a 24-hour fire and security watch
was instituted. Despite this full Site security and the fence
surrounding the Site, vandals were trespassing.
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Figure 2
GENtRAL SITE LOCATION MAP
PUBLICKER SITE
SOURCE: USGS QUAORANGLE-PHILAOELPHI A
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On December 8, 1987, an EPA site-safety coordinator conducted a
Site inspection of the facility. During this visual inspection,
it was determined that Site conditions continued to present
threats to human health and the environment. An EPA on-scene
coordinator (OSC) immediately initiated a removal action using
CERCLA emergency funds.
During the Emergency Removal Action, EPA significantly stabilized
conditions at the Site by addressing the various fire and
explosion threats. Wherever possible, solid and liquid waste
streams were bulked onsite and stored for future disposal.
Highly reactive lab wastes and cylinders were transported offsite
for disposal. All materials removed from the Site were
transported to facilities regulated under the Resource
Conservation and Recovery Act (RCRA) and the Toxic Substances
Control Act (TSCA). Approximately 3,100 emptied drums were
crushed onsite after bulking operations were completed. Overhead
pipelines insulated with asbestos coverings were wrapped with
plastic where necessary to abate the potential for the airborne
release of friable asbestos material. Asbestos droppings and
piles randomly located throughout the Site were bagged and stored
onsite. Buildings which were found to contain asbestos were
secured and warning signs posted. This bulked asbestos and the
remaining asbestos coverings on the exterior overhead pipelines
is what this ROD addresses.
To deter trespassing and unauthorized entry and exit of vehicles
at the Site, concrete barriers and snow fencing were installed
along Packer and Delaware Avenues. This has slowed scavengers,
but has not stopped them. EPA notified the Philadelphia police
Department that the Agency would be withdrawing site security at
the completion of the action for OU-1. The Philadelphia Police
Department planned to increase surveillance of the Site.
Emergency removal activities ended on December 16, 1988.
On May 5, 1989, the Site was proposed on the National Priorities
List (NPL). In October 1989, the Site was finalized on the NPL
A ROD for OU 1 was signed on June 30, 1989, for offsite treatment
and disposal in RCRA permitted facilities of the various waste
streams and hazardous chemicals recovered from within the process
lines. The ROD also authorized demolition of above-grade process
lines that traverse the Site (including the removal of asbestos-
containing materials); packaging of the insulation materials
removed from the process lines (including asbestos); and storage
of this asbestos. EPA discontinued the 24-hour fire and security
watch after the Site was stabilized as a result of OU 1 remedial
actions. Before the Site security watch was pulled, EPA ensured
that the asbestos was bagged and secured in a building and
staging areas.
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Enforcement Activities
On September 4, 1987, EPA and Publicker Industries entered into a
Consent Order under Section 106 of CERCLA, as amended, 42 U.S.C.
Section 9606. Under the Consent Order, Publicker hired O.K.
Materials of Findley Ohio to perform site stabilization measures.
These measures focused on assessing the Site and identifying the
presence and nature of hazardous substances at the Site.
On June 13, 1988, Bruga Corporation (Bruga) entered into a.
Consent Order under CERCLA Section 106, 42 U.S.C. Section 9606.
The Consent Order required Bruga to dismantle and decontaminate,
if necessary, all equipment that was removed from the Site. This
work has been completed.
On December 8, 1988, EPA and AAA Warehousing, Inc. (AAA) of
Brooklyn, New York entered into a Consent Order under CERCLA
Section 106, 42 U.S.C. Section 9606, whereby AAA was granted
permission to remove from the Site some stainless steel tanks and
rail tank cars which AAA owned. Removal of AAA's property began
December 9, 1988. All seven rail tank cars have been transported
offsite; however, the stainless steel tanks have not been
removed.
Highlights of Community Participation
The public participation requirements of CERCLA Sections
113(k)(2)(B)(i-v) and 117 42 U.S.C. Sections 9613(k)(2)(B)(i-v)
and 9617 have been met by the following activities.
The notice of availability for the Administrative Record was
published on February 4, 1991 and April 5, 1991 in the
Philadelphia Daily News. The Focused Feasibility Study (FFS) and
Proposed Plan for the Publicker Site were released to the public
on April 29, 1991. The notice of availability for the FFS and
proposed plan was also published in the Philadelphia Daily News
on April 29, 1991. These documents were made available to the
public in both the administrative record and the information
repository maintained at:
US E.P.A.
841 Chestnut Building
Philadelphia, PA 19107
(215)597-3037
A public comment period was held from April 29, 1991 to May 28,
1991. There was a request for a time extension to this comment
period. The public comment period was extended to June 11, 1991.
There was little public interest in the proposed plan and there
was no request for a public meeting. A response to the comments
received during this period is included in the Responsiveness
Summary, which is part of this ROD. This ROD presents the
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3
selected remedial action for the Publicker Site, chosen in
accordance with CERCLA, as amended by SARA and, to the extent
practicable, the NCP. The decision for this Site is based on the
Administrative Record.
Scope and Role of Operable Unit
As previously mentioned, Emergency Removal activities were
conducted beginning in December 1987, to stabilize various fire
and explosion threats at the Site.
On June 30, 1989, the ROD for the first OU was signed. As
previously mentioned, the ROD was for offsite treatment and
disposal in RCRA permitted facilities of the various waste
streams and hazardous chemicals, recovered from within the
process lines. That ROD also authorized demolition of above-
grade process lines that traverse the Site (including the removal
of asbestos-containing materials); packaging of the insulation
materials removed from the process lines (including asbestos);
and storage of this asbestos.
This ROD for OU-2 will address the asbestos materials that were
bagged, staged, and covered resulting from the prior EPA removal
actions or from remedial actions associated with the
implementation of the June 30, 1989 ROD. This asbestos is
considered a principal threat at this Site because it is a highly
mobile, highly toxic material.
Only the currently staged asbestos and the exposed asbestos on
pipes that are staged on the ground throughout the Site, will be
addressed in this remedial action. The asbestos associated with
the integral parts of the buildings (i.e., in the walls and
ceilings) will be addressed in a subsequent actions. In
addition, an RI/FS is currently under way for the soil and
groundwater.
Summary of Site Characteristics
As mentioned above, asbestos-containing materials (asbestos is a
carcinogen) are ubiquitous at the Site, particularly in relation
to building materials and piping insulation.
Samples of the fiberous materials were taken by EPA and sent to
the Electron-Microscopy Service Laboratories Inc. that showed
asbestos was present.
Most of the asbestos waste being addressed in this action is
related to the previous site response actions. The initial EPA
emergency removal implemented from December 1987 to December 1988
included asbestos-related actions. In compliance with the Site
stabilization of the 1989 ROD, the liquid contents of an
extensive above-ground process line network were removed by EPA
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remedial action subcontractors. The dismantling of the above-
ground piping systems at the Site resulted in the generation of
friable asbestos wastes, which formerly surrounded the pipelines
as insulation materials. The majority of the asbestos material
was bagged by the remedial action subcontractors and stored
onsite. The total volume of bagged asbestos wastes that were
stored resulting from the removal and remedial actions is
estimated at 1,100 cubic yards. Some piping-related asbestos was
not bagged; some asbestos was left intact on some of the
dismantled piping and covered with plastic.
Approximately 150 cubic yards of asbestos material was estimated
to remain intact around sections of piping located throughout the
Site. The protective plastic coverings that were placed on these
pipes during the previous actions have become loose, or have
blown or have been torn from the piping. Consequently, most of
the asbestos material remaining on these pipes is not secured.
In addition, numerous sections of asbestos-covered pipe
(approximately 500 lineal feet) were not covered with plastic.
A pile of debris of approximately six cubic yards in volume,
located adjacent to Pier 104, was identified as consisting of 50-
Ib. bags of "pure asbestos". Tarps covering one building that
was believed to be used as one of the staging areas for the
bagged asbestos have been vandalized, thus this asbestos is not
completely secured.
The total estimated volume of asbestos waste to be addressed by
this operable unit is 1,200 to 1,300 cubic yards.
Once exposed to the elements, asbestos materials may migrate from
their original locations via several pathways. The primary
pathway of migration for friable asbestos is air (wind) as
emissions, followed by transport in surface water as runoff, and
transport in groundwater via surface infiltration and
percolation. The fibrous nature of asbestos creates a high
length-to-width ratio, which results in a relatively great
surface area. This characteristic potentially enables asbestos
to be transported in wind or water to potentially great
distances, and may create a wide dispersion area. Additionally,
asbestos is relatively chemically inert, thus it does not readily
decompose into benign constituents.
The populations that could be exposed to the asbestos onsite or
migrating from the Site are Site trespassers and the nearby
surrounding populations. The environmental areas that could be
exposed are the Delaware River and the surrounding soils, surface
water, and groundwater.
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10
Summary of Site Risks
This remedial action is an early final action The risk
assessment is qualitative and does not attempt to assess all
environmental concerns and potential exposure pathways associated
with the entire Site. Therefore any residual risk at the Site
may be addressed in a later action.
Asbestos is identified as a Class A carcinogen, which means that
it is a known human carcinogen. It is also an animal carcinogen.
Exposure limits for airborne asbestos have been determined by the
National Institute for Occupational Safety and Health (NIOSH) and
are regulated through the Occupational Safety and Health Act
(OSHA) for occupational exposure, based upon an 8-hour Time
Weighted Average (TWA) workday. The most recent NIOSH (1988)
recommended exposure limits (REL) for asbestos is 0.1 fibers per
cubic centimeter (fibers/cc), for fibers greater than 5 microns
(urn) in length. The OSHA Permissible Exposure Limit (PEL) TWA is
0.2 fibers/cc, with an action level set at 0.1 fiber/cc, and a 30
minute excursion limit of 1 fiber/cc (OSHA, 29 C.F.R. Sections
1910.1001, and 1926.58).
Ingestion of asbestos in drinking water is regulated directly
under the Safe Drinking Water Act. The Maximum Contaminant Level
and the Maximum Contaminant Level Goal (MCLG) are both 7 x 10-6
fibers per liter. A fiber is defined as 10 microns in length or
longer (January 30, 1991 56 Fed. Reg. 3526). Ingestion of
asbestos via surface water and organisms is regulated under the
Clean Water Act. The ambient water quality criterion (AWQC) for
asbestos is 3 x 10-4 fibers per liter.
Due to the widespread occurrence of uncontained asbestos
materials observed on the Site, it is possible that asbestos has
been and continues to be entrained in air and dispersed over some
area. The potential for exposure exists due to: this potential
for widespread occurrence; the ability of asbestos to be
transported to potentially great distances via air or water; the
carcinogenic nature of asbestos; the frequent presence of
trespassers at the Site; and the dense populations centers nearby
the Site. Furthermore, if there were to be another fire,
releases of asbestos to the air would likely occur. The threat
of fire exists because of the vandals trespassing onsite. <,
Primary potential exposure pathways to humans and terrestrial and
aquatic organisms (environmental receptors) to asbestos at the
Site include:
o Inhalation of airborne emissions (wind); and
o Direct contact with concentrated asbestos wastes.
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11
Secondary potential exposure pathways of human and terrestrial
and aquatic organisms include:
o Ingestion of surface water runoff (Delaware River);
o Ingestion of shallow groundwater discharging to surface
water courses (Delaware River); and
o Ingestion by consumption of contaminated groundwater.
Receptors via inhalation, direct contact, and ingestion of both
surface water and groundwater are primarily humans, but may
include terrestrial organisms on and in the shallow Site soils,
and aquatic organisms in the Delaware River. The area over which
asbestos contamination from the Site potentially exists is not
known.
The probability of the secondary potential pathways as
significant routes of exposure is generally expected to be
minimal because there is little or no evidence that asbestos
migrates downward or laterally through the soil (USEPA,
Enforcement Approach to Asbestos Site Cleanup, in Proceedings of
the Sixth National Conference of Management of Hazardous Waste
Sites. The Hazardous Materials Control Research Institute, Silver
Spring, MD (November 1985)). There is no evidence that asbestos
is migrating to the river and it is unlikely that this would
occur because asbestos adsorbs to sediments and therefore does
not migrate through water. Additionally, exposure via these
secondary pathways is unlikely since ingestion of surface water
and groundwater in the vicinity of the Site is unlikely by
humans, therefore exposure via inhalation and direct contact are
the most likely. However, these pathways are considered because
of the public water obtained from wells across the Delaware River
from the Publicker Site. Therefore, the risks associated with
the ingestion of contaminated water are believed to be
significantly less than those associated with airborne emissions.
Abatement of asbestos waste is required to restrict offsite
migration of asbestos and reduce the immediate and potential
threat to human health posed by uncontrolled releases.
Containment of asbestos, will prevent further degradation of
loose piping insulation and reduce future releases. Asbestos
control will minimize current and potential future releases by
Site workers during Site demolition activities.
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected in this ROD, amy present an imminent and substantial
endangerment to public health, welfare, or, the environment.
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12
Description of Alternatives
Alternative 1 - No Action
Estimated Capital Cost: $0
Estimated 0 & M Costs: $0
Estimated Present Worth: $0
Estimated Implementation Time: None
The No Action Alternative is required by the National Contingency
Plan (NCP) to be considered through the detailed analysis of
remedial alternatives. This alternative provides a baseline
comparison to the other remedial alternatives. Under the No
Action alternative, EPA would not implement any measures to
protect either human health or the environment from the existing
threats at the Site.
Under this alternative no action would be taken to remediate the
estimated 1,200 to 1,300 cubic yards of asbestos materials. The
Site would continue to be accessible to trespassers, and
uncontained asbestos would continue to pose a risk to humans and
terrestrial and aquatic organisms through the primary and
secondary exposure pathways: inhalation, direct contact, and
ingestion.
Alternative 2 - Upgraded Site Security (Full-Time)
Estimated Capital Cost: $37,330
Estimated O & M Costs: $356,400 for 3 years
Estimated Present Worth: $393,732
Estimated Implementation Time: 3 months
Under this alternative, Site security would be upgraded to limit
further access to the Site. Upgrading Site security would
include the upgrading of the Site perimeter fence and the
stationing of a continuous security force at the Site. The
asbestos waste staging areas would be made more secure.
The estimated 1,200 to 1,300 cubic yards of asbestos waste would
remain onsite at the end of three years. Although the risks
associated with the asbestos waste would still exist at current
levels, Site access would be limited under this alternative, (it
would be more difficult for trespassers to gain Site access.
Consequently there would be some reduction in the human health
exposure potential at the Site, i.e., some of the risk from
inhalation and dermal contact would be reduced.
There are no Applicable or Relevant and Appropriate Requirements
(ARARs) associated with this alternative.
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13
Alternative 3 - Source Reduction and Offsite Disposal
Estimated Capital Cost: $293,420
Estimated O & M Costs: $0
Estimated Present Worth: $293,420
Estimated Implementation Time: 5 months
This alternative consists of: the removal of asbestos from
piping scattered throughout the Site, placement in secure
packaging (plastic bags), and staging and preparation for .
transport and offsite disposal; collection of all asbestos waste
previously packaged and staged at the Site, repackaging if
necessary, and preparation for transportation and offsite
disposal; and transportation of the estimated 1,200 to 1,300
cubic yards of asbestos wastes to a permitted offsite disposal
facility (landfill).
This alternative will comply with all ARARs. Because removal of
asbestos would occur, the National Emission Standard for
Hazardous Air Pollutants (NESHAPs) for asbestos under the Clean
Air Act will be met. These requirements are relevant and
appropriate to this alternative because they cover situations
similar to those of the alternative. The Pennsylvania
regulations regarding disposal of residual wastes in a municipal
facility, areas prohibited for land disposal, and the
requirements for storage and containment during offsite actions
are applicable because they regulate how the alternative will be
implemented.
Summary of the Comparative Analysis of Alternatives
The NCP requires an evaluation of all the alternatives against
the Nine Evaluation Criteria. Alternatives 1, 2 and 3 were
evaluated against these criteria to summarize the relative
performance of these alternatives against each other. The Nine
Evaluation Criteria are:
Threshold Criteria (i.e. criteria that must be met)
o Overall protection of human health and the environment
(addresses whether a remedy provides adequate
protection and describes how risks are eliminated,
reduced, or controlled)
o Compliance with applicable or relevant and appropriate
requirements (addresses whether a remedy will meet all
of the applicable or relevant and appropriate
requirements. These requirements must be promulgated
federal or state environmental regulations.)
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14
Primary Balancing Criteria
o Long-term effectiveness and permanence1 (refers to the
ability of a remedy to maintain reliable protection of
human health and the environment over time once cleanup
goals are achieved)
o Reduction of toxicity, mobility, or volume through
treatment (refers to the anticipated performance of the
treatment technologies a remedy may employ)
o Short-term effectiveness (addresses the period of time
needed to achieve protection and any adverse impacts on
human health and the environment that may be posed
during the construction and implementation period until
cleanup goals are achieved)
o Implementability (refers to the technical and
administrative feasibility of a remedy, including the
availability of materials and services needed to
implement a particular option)
o Cost (includes the estimated capital, operation and
maintenance costs)
Modifying Criteria
o State/Support Agency Acceptance (indicates whether,
based on its review of the backup documents and
Proposed Plan, the State concurs with the remedy)
o Community Acceptance (whether or not the public
supports the decision to take a particular action)
1. Overall Protection of Human Health and the Environment
The Source Reduction and Offsite Disposal Alternative
(Alternative 3) will substantially reduce the magnitude of risk
to human health and the environment by reducing the amount of
asbestos onsite. This alternative will eliminate the risk
associated with the release of the previously staged asbestos
into the environment at the Site, as well as control the future
release of the asbestos generated from the Site into the
environment at the offsite disposal facility. The inhalation and
direct contact pathways for human and environmental exposure
would be eliminated because the asbestos would be removed from
the Site. The ingestion of the surface water runoff; the
ingestion of shallow groundwater discharging to surface water
courses; and the ingestion by consumption of contaminated
groundwater by humans and environmental receptors would be
largely eliminated because the source of the asbestos
contamination would be removed. There may be small amounts of
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15
asbestos remaining in the soil, groundwater, and surface water.
As previously mentioned, these media are undergoing an RI/FS at
the current time.
The Upgraded Site Security Alternative (Alternative 2) would
reduce some of the potential for human exposure to asbestos waste
at the Site, however human health and environmental threats would
persist. This alternative does not mitigate the migration
potential of the asbestos in air or surface water. Therefore,
the exposure pathways (inhalation, dermal contact, surface water
ingestion, and ingestion by consumption of groundwater) for all
receptors would be not be addressed.
The No Action Alternative (Alternative 1) provides no protection
of either human health or the environment. All exposure
pathways, and therefore the risk, would not be eliminated.
Because the No Action alternative is not protective, it is not
discussed further.
2. Compliance with ARARs
Alternative 3 would comply with all Federal and State ARARs.
There are no ARARs pertinent to Alternative 2.
Neither asbestos, nor asbestos-like material is regulated under
the Resource Conservation and Recovery Act (RCRA), therefore the
Land Disposal Restrictions are not ARAR.
3. Long-Term Effectiveness and Permanence
Since Alternative 3 includes source-reduction and offsite
disposal there should be little to no residual risk at the Site,
for asbestos wastes, once the alternative is implemented and
completed. This alternative would not require any long-term
management or monitoring requirements at the Site, because the
waste is being disposed of offsite. Once the asbestos has been
removed from the Site, this alternative would maintain reliable
protection of human health and the environment on the Site and in
the Site's surrounding areas. Substantial uncertainties have not
been identified regarding land disposal of asbestos wastes that
would require special long-term considerations.
Alternative 2 would not address the asbestos waste at the Site.
Consequently, the asbestos would continue to migrate to the air,
surface water, and groundwater and therefore remain a threat the
human health and the environment. The risk to the human and
environmental receptors after the remedy is implemented would not
change from the current risk at the Site. There would be some
risk reduction to trespassers.
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16
4. Reduction of Toxicity, Mobility, or Volume Through Treatment
Neither Alternative 2, nor Alternative 3 reduces the toxicity,
mobility, or volume of the asbestos waste through treatment.
Currently there is no known treatment or resource recovery
technology that can address asbestos.
5. Short-Term Effectiveness
During the previous asbestos handling and removal activities
under the Emergency Removal program at the Site, the results of
air monitoring indicated there were no short-term public health
concerns associated with the release of the asbestos at the Site.
Since Alternative 3 is similar to the original asbestos handling
activities, EPA believes that the short-term human health and
environmental effects will be negligible, provided that all
activities are conducted according to the asbestos removal
procedures and regulations.
There would be no short-term effects on human health or the
environment as the result of implementing Alternative 2 because
this alternative does not consist of disturbing or causing
contact with the asbestos waste.
6. Implementability •
For Alternative 3, removal and packaging of the asbestos from
piping, the collection of previously packaged asbestos wastes,
and the transportation and disposal of asbestos wastes would rely
on standard asbestos abatement practices, which are proven to be
reliable methods for addressing asbestos problems. There are
adequate equipment and contractor capabilities available to
implement this alternative, on a competitive basis.
Additionally, there are permitted disposal facilities in
southeastern Pennsylvania that have the capabilities and capacity
to accept the type and volume of asbestos waste to be removed
from the Site. Technical or administrative problems that could
lead to scheduling delays with this alternative are unlikely.
Alternative 2 would not be complicated to implement. Upgrading
perimeter fencing and providing for Site security personnel are
widely used and are a reliable means for increasing Site ^
security. In addition, security personnel have been previously
assigned at the Site. However, considering the Site location,
size and condition, and based on previous Site experience,
completely preventing unauthorized access or trespassing would
still be difficult.
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17
7. Cost
The estimated costs for Alternative 2 are:
Capital Cost: $37,330
0 & M Costs: $356,400 for 3 years
Present Worth: $332,773
The estimated costs for Alternative 3 are:
Capital Cost: $293,420
O & M Costs: $0
Present Worth: $293,420
8. State/Support Agency Acceptance
The Commonwealth of Pennsylvania agrees with the selected remedy.
9. Community Acceptance
Public interest at the Site has been minimal. No public meeting
was requested. Comments were received from the public during the
public comment period and are addressed in the Responsiveness
Summary.
The Selected Remedy
The selected remedy for the Site for OU2 is Alternative 3, Source
Reduction and Offsite Disposal. The selected remedy consists of
the removal of asbestos from piping scattered throughout the
Site, placement in secure packaging (plastic bags), and staging
and preparation for transport and offsite disposal; collection of
all asbestos waste previously packaged and staged at the Site,
repackaging if necessary, and preparation for transportation and
offsite disposal; and transportation of the estimated 1,200 to
1,300 cubic yards of asbestos wastes to a permitted offsite
disposal facility (landfill).
The estimated costs for the selected remedy are:
Capital Cost: $293,420 <
O & M Costs: $0
Present Worth: $293,420
The estimated implementation time for the selected remedy is five
months.
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13
Statutory Determinations
Protection of Hunan Health and the Environment
The selected remedy will eliminate the risJc associated with the
release of the previously staged asbestos into the environment at
the Site, as well as control the future release of the asbestos
waste generated from the Site into the environment at the offsite
disposal facility. The inhalation and direct contact pathways
for human and environmental exposure would be eliminated because
the asbestos would be removed from the Site. The ingestion of
surface water runoff; the ingestion of shallow groundwater
discharging to surface water courses; and the ingestion by
consumption of contaminated groundwater would be largely
eliminated because the source of the asbestos contamination would
be removed. There may be small amounts of asbestos remaining in
the soil, groundwater, and surface water. As previously
mentioned, these media are undergoing an RI/FS at the current
time.
There are no unacceptable short-term risks or cross-media impacts
that will be caused by implementation of the remedy.
Compliance with ARARs
The selected remedy will comply with all the following ARARs and
the To Be Considereds (TBCs).
Chemical-Specific ARARs
Clean Air Act, National Emission Standard for Hazardous Air
Pollutants (NESHAPs) - Section 112 of the Clean Air Act.
(Federal).
40 C.F.R. Section 61.146 - Standard for demolition and
renovation: Notification requirements
40 C.F.R. Section 61.147 - Standard for demolition and
renovation: Procedures for asbestos emission control
40 C.F.R. Section 61.152 - Standard for waste disposal
for manufacturing, demolition, renovation, spraying and
fabricating operations
These requirements are relevant and appropriate to the
selected remedy.
Location-Specific ARARs
None
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19
Action-Specific ARARs
Regulations promulgated in Pennsylvania Bulletin, Vol. 20,
No. 8, Part II, the Environmental Quality Board Proposed
Residual Waste Management (February 24, 1990) (State).
These requirements are applicable.
Chapter 271 - Disposal of residual wastes in a
municipal facility.
Chapter 291 - Areas prohibited for land disposal'
Chapter 299 - Requirements for storage and containment
during transport for offsite actions
TBCs
Asbestos Control Regulations, Philadelphia Board of Public
Health, Air Management Services, Chapter 6-600, Title 6,
Health code of the Philadelphia code (Local).
Standards for asbestos control. This TBC is used
because of the asbestos removal activities that will
occur.
Cost-Effectiveness
EPA believes that since this remedy will eliminate the risks to
human health and the environment at an estimated cost of
$293,420, the selected remedy provides an overall effectiveness
proportionate to its costs, such that it represents a reasonable
value for the money that will be spent.
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Practicable fMEPl
EPA believes that the selected remedy provides the best balance
of tradeoffs among the alternatives with respect to the nine
evaluation criteria, especially the five primary balancing
criteria. The most important of these five criteria in
distinguishing between the remedial alternatives that were^
considered at this Site in making the decision to select the
Source Reduction and Offsite Disposal alternative was Long-Term
Effectiveness and Permanence. Alternative 2 is not effective in
the long term, because the asbestos waste would remain onsite and
continue to migrate to the air, surface water, and groundwater.
The selected remedy utilizes permanent solutions and treatment
(or resource recovery) technologies to the maximum extent
practicable. Currently there is no known treatment or resource
recovery technology that controls asbestos, therefore treatment
of asbestos at the Site is impracticable.
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20
Preference for Treatment as a Principal Element
i
Because there is no known permanent treatment or resource
recovery technology that could effectively address the asbestos,
and, thus treatment has not been selected as part of this remedy,
the preference for treatment as a principal element is not
satisfied by the selected remedy.
Documentation of Significant Changes
The selected remedy, Source Reduction and Offsite Disposal, was
the Preferred Alternative was identified in the Proposed Plan.
There have been no significant changes to the preferred
alternative.
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PUBLICKER/CUYAHCGA WRECKING PLANT OU2
ADMINISTRATIVE RECORD FILE » *»
INDEX OF DOCUMENTS
III . REMEDIAL RESPONSE PLANNING
1. Report: Revised Draft Work Plan, Volume I, Rer.edial
Investigation/Feasibility Study Publicker Industries
Site, Philadelphia, Pennsylvania, crepared bv Tetra
Tech, Inc., 3/90. ?. 300001-300124.
2. Report: Preliminary Health Assessment for Publicker
Industries, prepared by the Agency for Toxic
Substances and Disease Registry, 9/12/90.
?. 300126-300138.
3. Report: Focused Feasibility Study Report, Asbestos
Removal Operable Unit, 4/91. P. 300139-300195. A
transmittai letter is attached.
4. U.S. EPA Proposed Plan, Publicker Industries/
Cuyahoga Wrecking Site, 4/91. P. 300196-300205.
* Administrative Record File available 12/12/90, updated
4/26/91.
** Additional information pertaining to Publicker/Cuyahoga
OU2 can be found in the Administrative Record File for
Publicker/Cuyahoga OU1.
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COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Lee Park, Suite £010
555 North Lane
Conshohocken, PA 19428
215-332-6012
June 28, 1991
Mr. Edwin a. 2rickaon
Regional Administrator
U.S. EPA Region III
841 Chestnut Building
Philadelphia, PA 19107
Ra: Letter of Concurrence
Publicker Industries Superfund Site
. City of Philadelphia
Racord of Decioion (ROD)
Operable Unit #2, Asbestos Removal
Dear Mr. Erickson:
Tha Record of Decision, concerning the specific actions to be taken
at the Publicker Industries Superfund Site, haa bean reviewed by the
Department.
Tha major components of the selected final remedy for tha Asbestos
Removal, Operable Unit #2, includei
* Removal of remaining asbestos from piping staged throughout
tha site; placement in secure packaging /plastic bags);
staging and preparation for transport and disposal.
* Collection of all asbestos waste previously packaged and
staged at the site; repackaging it if necessary; and
preparation for transport and disposal,
* Transportation of all collectable asbestos waste directly to
an approved and permitted off-site disposal facility
(landfill).
I hereby concur with the EPA'a proposed actions, with the following
conditions:
* The Department will be given the opportunity to concur with
future decisions concerning subsequent actions relative to tht
contaminated Ground Water ar.d Soil Operable Units, and to
evaluate appropriate remedial alternatives to ensure
compliance with Pennsylvania ARAR's.
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Mr. Edwin B. Erickson
June 28, 1991
-2-
* It is understood that EPA is not waiving Pennsylvania ARAR'a
for any final remedy at thia time.
* 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 Actions, to
ensure compliance with Pennsylvania cleanup ARAR's and design
specific ARAR'a,
* The Department's position is that its design standards are
ARARs pursuant to CERCLA Section 121 as amended by SARA, and
will reserve our right to enforce those design standards.
* The Department will reserve the 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 CERCLA Section
104(c)(3) as amended by SARA.
Thank you for the opportunity to concur with this EPA Record of
Decision.
If you have any additional questions in this matter, please feel free
to contact me.
Very truly yours/
Leon T. ^fonshor
Regional Director
cc: Office of Environmental Protection
Mr. Snyder
Ma. Hoffman •
Mr. Lynn
Mr. Danyliw
Mr. Cole
Mr, Matlock
Mr. Becker
Mr. Olewiler
Mr. Miller
Re (G) LB817
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RESPONSIVENESS SUMMARY
PUBLICKER INDUSTRIES SITE
JUNE 1991
During the public comment period from 4/29/91 to 6/11/91 no
comments were received from the public. One set of comments were
received from a Potentially Responsible Party. Due to the
brevity of these comments they are addressed individually below.
COMMENT: The uncontained asbestos wastes does not constitute a
risk because there is no evidence of releases; therefore the
statement that the site "poses a substantial risk to human health
and the environment" should be deleted.
RESPONSE: Sampling results collected during the Removal Actions
in 1989 indicate that asbestos waste is present at the site. The
potential for releases to the environment ,therefore, does exist.
Some of the materials are known to be uncontained and there are
still some human activities on the property. Consequently, the
asbestos could be disturbed or even removed from the site, and
EPA has determined that a substantial risk is present.
COMMENT: The Focused Feasibility Study (FFS) states that "No
definitive risks can be determined for the likely exposure of the
public to asbestos at the site.1* The commentor feels that this
is contradictory to the Agency position that there is a
substantial risk.
RESPONSE: The statement is intended to describe the present
risks from the uncontained asbestos on the site but does not
describe the potential for releases and exposures if someone
should enter the site (such as trespassers) and disturb the
material or remove it from the site. The only reasonable and
conservative way to protect the public is to remove and properly
dispose of the materials.
COMMENT: Since there is no release of asbestos from the site,
Alternative 3 will not reduce the magnitude or eliminate the
risks.
RESPONSE: Once again, the potential for release is a real risk
associated with the uncontained materials and bagged asbestos.
Alternative 3 will reduce and eliminate the risks. v
COMMENT: Since there is no releases occurring and the site, the
possibility of the occurrence of a release which exceeds the
Clean Air Act is unlikely during periods of little or no
activity.
RESPONSE: The potential still exists when the materials are
uncontained on the site. Unauthorized activities may occur and
release could exceed the Clean Air Act limits.
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COMMENT: The public acceptance of the proposed alternative
because of the substantial reduction in the risk is misleading
because there is no current human exposure and the risks have not
been quantified.
RESPONSE: The potential for releases is real and the public has
been very concerned about protection of their community and
individual health of the residents.
COMMENT: The FFS contained only limited information about the
groundwater aquifers at the site and any assessment of the
transport of asbestos in the groundwater and surface waters is
inadequate to assess the likelihood of exposure.
RESPONSE: EPA agrees that the groundwater and surface water
pathways are not defined and are probably not a potential pathway
for transport of the asbestos. These pathways were considered
because of the public water obtained from wells across the
Delaware River.
COMMENT: Based on the fate and transport properties of asbestos
it is unlikely that asbestos fibers could migrate to the deeper
aquifers and beneath the river to reach the wells across the
Delaware River from the site.
RESPONSE: EPA agrees with this comment.
COMMENT: The statement that, "Quantitative data do not exist to
document levels of asbestos exposure associated with releases
from the Publicker site" is incorrect and the Agency should have
used the OSC's report that no airborne asbestos above permissible
limits was detected during site activities.
RESPONSE: Since the asbestos materials are present and exposed
to the surface at the site, the potential for release is the
risk. Since there are trespassers on the property the
possibility of a release does exist, even though EPA does not
have documentation of concentration measurements of any releases.
COMMENT: A statement in the risk assessment comparing ingestion
of asbestos-contaminated groundwater to airborne emissions is
misleading since there is no evidence of contaminated
groundwater.
RESPONSE: The statement only compares the relative risk add was
not intended to presume contamination of groundwater is present.
COMMENT: A statement that containment of the asbestos will
reduce further releases is also misleading because no current
releases have been documented.
RESPONSE: The possibility of a release is real and containment
and proper disposal will certainly reduce the possibility of any
releases.
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COMMENT: The FFS does not document that asbestos is really
present at the site and the Administrative Record does not
contain this information either.
RESPONSE: The analysis for asbestos was conducted as part of the
Removal Activities. The fibrous materials were sent to Electron-
Microscopy Service Laboratories Inc. (EMSL) for analysis and the
documentation received by EPA was Dated December 29, 1989. This
documentation will be added to the final revision of the FFS and
will subsequently become part of the Administrative Record.
COMMENT: The FFS does not clearly describe the compliance'with
ARARS for the alternatives evaluated.
RESPONSE: The ARARS that must be evaluated are outlined in the
current Record of Decision and are explained within this
document. Some clarification will be added to the final version
of the FFS.
COMMENT: The FFS incorrectly identifies requirements of the
Philadelphia Code as an ARAR.
RESPONSE: The Philadelphia Code requirements are now listed as
"To Be Considereds".
COMMENT: ARARs are generally categorized as being chemical-,
location-; or action-specific. The FFS does not identify these
categories in tabular form.
RESPONSE: The Record of Decision clarifies these categories and
revisions will be made when finalizing the FFS.
COMMENT: The FFS does not address regulations regarding
demolition activities when asbestos is present.
RESPONSE: The ARARs for demolition have been included in the
Record of Decision and will be added to the final revision of the
FFS.
COMMENT: The FFS defines the scope of the asbestos operable unit
for the site as only the staged and exposed asbestos present on
the ground throughout the site. No rationale was provided for
leaving other suspected asbestos on the site. In addition^this
limited action is not cost effective.
RESPONSE: This remedial action is not intended to address all
the asbestos which is an integral part of the structure of the
buildings. That will be addressed by EPA if and when the
buildings are demolished as part of Superfund response
activities. This operable unit will provide the assurance that
none of the uncontained materials will be released or transport?
from the site which will affect the public health or the
environment. Increasing the scope of this operable unit to
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include building demolition is not warranted and would not be
cost effective at this -time.
COMMENT: The FFS does not set forth specific numerical goals or
acceptable levels for each exposure route.
RESPONSE: Since this not the final remedy for the entire site
the risk assessment for this early action ROD is qualitative and
does not attempt to assess all environmental concerns and
potential exposure pathways.
COMMENT: The FFS report covers the short-term effectiveness
criterion but does not address the subcriteria for short-term
effectiveness.
RESPONSE: The subcriteria are addressed in the Record of
Decision.
COMMENT: The FFS report erroneously states that below-ground
process lines are present at the Publicker site.
RESPONSE: The Record of Decision addresses this issue and the
final revision of the FFS will be corrected.
COMMENT: The FFS should not have evaluated the State and
Community acceptance criterion.
RESPONSE: Based on previous meetings with the community and
discussions with the State, EPA' felt that the acceptance
described in the FFS was accurate. In addition the State has
agreed in writing with this statement.
COMMENT: The present worth calculations in the FFS for
Alternative 2 are incorrect.
RESPONSE: This correction was made in the Record of Decision and
will be included in the final revision of the FFS.
COMMENT: The Proposed Plan refers to other asbestos materials
inside the buildings and that will be further evaluated during
subsequent activities planned at the site. However, the RI/FS
work plans do not address asbestos.
RESPONSE: This statement was made to provide the public with
clear notice that the asbestos which is an integral part or the
buildings was not included in this remedy selection. Subsequent
activities may address asbestos materials inside the buildings,
although no activities are currently planned.
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