EPA Superfund
Record of Decision:
PB96-963918
EPA/ROD/R03-96/239
April 1997
Publicker Industries Inc.,
Operable Unit 3, Philadelphia, PA
12/28/1995
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DECLARATION FOR TKS RECORD OP DECISION
Publicker Industries Site
Operable Unit #3
Philadelphia, Pennsylvania
This decision document presents the selected remedial action
for Operablej%Unit #3 of the Publicker Industries Site (the Site) ,
in Philadelphia, Pennsylvania, which was chosen in accordance with
the requirements of the Comprehensive Environmental Response,
Compensation, 'and Liability Act of 19.80 (CERCLA) , as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA)
and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This decision document explains the
factual and legal basis for selecting tha remedy for this.Site.
This decision is based on the Administrative Record for this Site.
The Pennsylvania Department of Environmental Protection has
concurred with the selected remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from
this 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 the Selected Remedy
This Operable Unit is the-third of three operable units for
the Site. Operable Unit #1 provided for Site Stabilization and
consisted of transportation and off-Site disposal of known waste
streams, demolition of above-grade process lines,,and
transportation and off-Site disposal of wastes-discovered in
above-grade process^'lines. Operable Unit #2 addressed the
abatement and off-Sff'e disposal of asbestos that "had covered the
above ground process lines drained during Operable Unit #1. The
remediation under Operable Units tfl and #2 has been completed.
This Operable Unit is the final one planned for the Site. It
addresses the remaining contamination. The major components of
the selected remedy include the followinc:
• Abandonment of on-Site ground water veils;
• Removal, treatment, and off-Site disposal of liquids and
sediments in contaminated electric utilities;
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• Removal, treatment, and off-Site disposal of liquids and
sedimencs in contaminated stormwater trenches and utilities;
• Removal, treatment and off-Site disposal of miscellaneous
wastes.
Additionally, should excavation be conducted by current or
future owners or occupants where such activities are not
specifically a part of the above selected remedy, those excavation
activities shall be monitored.
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, and it satisfies
the statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element.
Because this remedy will result in hazardous substances
remaining on Site above health-based levels, a review will be
conducted within five years after commencement of remedial action
to ensure that the remedy continues to provide adequate protection
of human health and the environment.
Thomas C. Volt
Hazardous Waste
ictor
it Division
Date
EPA Region 2^-S
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DECISION SUMMARY FOR THE RECORD OP DECISION
1. s
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alcohol, methanol, methyl ethyl ketone, and methyl isobutyl
ketone.
Plant operations were discontinued in February 1986 and,
later that year, Publicker Industries sold the property to the
Overland Corporation. Overland Corporation declared bankruptcy
and abandoned the Site in November 1986 following an explosion at
the Site that killed two Cuyahoga Wrecking Corporation (Overland
Corporation's parent corporation) demolition workers.
A detailed chronology of Site history is given in Table i.
PREVIOUS INVESTIGATIONS
In addition to the extensive EPA removal and related
characterization activities at the Site, there have been several
other environmental investigations conducted at or near the Site
prior to and concurrent with the RI/FS that have generated
environmental data relevant to the Site. These have included the
following major investigations:
• Preliminary Report - Environmental Evaluation, Former
Publicker Industries, Inc. Refinery, by Dames and Moore -
July 1986
• Relation of Ground Water Quality to Land Use in Philadelphia,
PA and Camden, NJ, Area, United States Geological Survey
Water Resources Investigation Report 88-4211, Blickwell and
Wood, 1989.
• Site Inspection Report, by Pennsylvania Department of
Environmental Resources, Bureau of Waste Management - June
1989
• Site Analysis - Publicker Industries Site, by USEPA EMSL -
October 1990
• Results of An Investigation at the Site of a Proposed Access
Roadway - Publicker Industries Site (Summary Only), by
Woodward Clyde Consultants - February 1991
• Results of Environmental and Geotechnical Investigations at•
the Site of a Proposed Free-standing Sign - Publicker
Industries Site, by Woodward Clyde Consultants - April 1991
• Soil and Groundwater Subsurface Investigation Report, Ashland
Chemical, Inc., by Environmental Strategies Corporation - May
1991
• Publicker Industries Sampling Event - Summary Report and Data
Tables, Weston Technical Assistance Team (TAT) - May 1994
A brief summary of the findings and major conclusions for
each of these reports is in the Remedial Investigation Report.
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3 . Highlights of Coappmiifcy Participation
The RI/FS Report and the Proposed Plan for the Publicker
Industries Site, Operable Unit #3 were released to the public for
comment on June 2, 1995. These two documents were made available
to the public in both the Administrative Record and an information
repository maintained at the EPA Docket Room in Region 3. The
notice of availability for these two documents was published in
the Philadelphia Daily News and the South Philadelphia Review
Chronicle on June 2, 1995. An extension request was received on
June 27, 1995, and the extension notice was published in the two
newspapers listed above. A public comment period on the documencs
was held from June 2, 1995 to August 2, 1995. In addition, a
public meeting was held on June 20, 1995. At this meeting,
representatives from EPA and the Pennsylvania Department of
Environmental Resources, (now the Pennsylvania Department of
Environmental Protection), answered questions about conditions at
the Site and the remedial alternatives under consideration. A
response to the comments received during this period is included
in the Responsiveness Summary, which is part of this ROD.
Site Strategy
As with many Superfund sites, the problems at the Publicker
Industries Site have been complex. As a result, EPA organized the
work into a removal action and three remedial operable units.
These are:
• Removal Action
• Operable Unit #1 Site Stabilization
• Operable Unit #2 Asbestos Remediation.
• Operable Unit #3 Soil andj3round Water
This ROD addresses the remedial action for Operable Unit #3
at the Site.
The Removal Action, and Remedial Actions for Operable Units
#1 and #2 are described in the Chronology (Table 1),.and have been
completed.
The Remedial Action for Operable Unit #3 described in this ;
ROD addresses the remaining threats at the Site.
5 • SumMrv of Site Characteristics
Results from the Remedial Investigation (RI), including
physical and chemical results, combined with information from
previous studies, were used to delineate the nature and extent of
contamination at the Site.
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SOIL VAPOR INVESTIGATION
A soil vapor survey was performed during November 1991 to
investigate the shallow subsurface for the presence and extent of
volatile organic contaminants and for the optimal location of
subsequent soil samples. Two suites of analyses were performed on
each soil vapor sample collected. One suite was analyzed for
eleven common hydrocarbons or their degradation products, and the
other suite analyzed for benzene, toluene, ethylbenzene, and
xylenes (BTEX) compounds. The results of the soil vapor survey
indicated several notable "hot spots" of high organic vapor
content at the Site. However, most of the Site is relatively free
of measurable organic vapors in the subsurface. Of the 119 vapor
points sampled, 23 locations were reported to contain BTEX
compounds, as analyzed by flame ionization detector (FID) methods,
in the shallow subsurface (two to four foot depths) at
concentrations greater than 1 microgram per liter (ug/1) Total
FID. The locations with Total FID values above 10 ug/1 are shown
on Figure 3, with the concentrations contoured for illustration.
Benzene and Total FID Volatiles were unusually high at sampling
point 14, with reported concentrations of 25,610 ug/1 and 32,870
ug/1, respectively. Only one other location, point 15 with a
total FID value of 1,221 ug/1, was indicated to contain .
concentrations of either individual or total FID volatile organic
compounds above 1,000 ug/1.
The sampling points of maximum concentration were different
for most of the BTEX compounds; benzene was highest at point 14
(25,610 ug/1), toluene and total xylenes were highest at point 46
(34 and 213 ug/1, respectively), and ethylbenzene was highest at
point 44 (364 ug/1).
SURFACE SOIL INVESTIGATION
Primary Soil Sampling
Samples of the surface soils were collected from 30 locations
both on and off (but near) the Site. The 30 locations were
selected on the combined basis of sorl vapor survey data and
observed field conditions (e.g., stained soil areas) to provide
adequate Site-wide characterization. Three off-Site, background
surface soil samples were collected. Each surface soil location '
was sampled for three different aspects: asbestos content,
chemical characterization via Target Compound List and Target
Analyte List (TCL/TAL) analyses, and dioxin/dibenzofurans. A
summary of the analyses of each of the three aspects is presented
below. :
Asbestos Sampling Results
Asbestos is present at trace concentrations (less than 1%
asbestos out of total volume sample) throughout the Site.
Concentrations of asbestos greater than 1% were detected only at
locations south of Packer Avenue. Only two locations, stations 26
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and 27, were reported to contain asbestos at concentrations of 1%
total asbestos or greater; location 26 containing 3% total
chrysotile and amosite, and location 27 containing 1% total
chrysotile. Both of these locations lie to the south of Packer
Avenue, and were sampled to provide Site characterization. None
of the surface soil samples collected from the vicinity of known
asbestos staging areas on the Site had asbestos concentrations
above 1% total asbestos.
Target Compound List and Target Analyte List (TCL/TAL) Results
The magnitude and extent of chemical contamination in the
surface soils were assessed by submitting the soil samples for
chemical analyses of the full TCL/TAL parameters. The results of
the analyses are summarized in Table 2 for volatile organic
compounds, total semi-volatile organic compounds, total polycyclic
aromatic hydrocarbons (PAHs); both carcinogenic and non-
carcinogenic, total benzo-a-pyrene equivalent, total pesticides,
and total polychlorinated biphenyls (PCBs).
Volatile Organic Compounds - With the exception of one sample
station, volatile organic compounds are not present in the surface
soils at the Site. Location 10 was the only location where
volatile organic compounds were detected in significant
concentrations, with toluene (1,100J ug/kg) and total xylenes
(14,OOOJ ug/kg) reported. "J" values indicate that the analyte is
present, but the reported value may not be accurate or precise.
Semi-Volatile Organic Compounds - Many semi-volatile organic
compounds were detected in the surface soils at the Site. As
shown in Table 2, the Polycyclic Aromatic Hydrocarbons (PAHs)
comprise the majority of the semi-volatile organic compounds
present. Pesticides and PCBs were also reported at some sample
locations.
Polycyclic Aromatic Hydrocarbons (PAHs) - PAHs were detected at
all sampling locations including the background stations, ranging
in concentration from 1,467 ug/kg at station 11 to 524,000 ug/kg
at station 30. No pattern of PAH distribution over the Site is
evident, except that high concentrations are noted at locations
associated with prior spills or waste, including apparent spill •
locations (SS-30), and tank containment locations (SS-07, SS-15).
The background levels were 14,776 ug/kg, 3,570 ug/kg, and 33,270
ug/kg at locations 25, 28 and 29, respectively. The highest
levels of PAHs occurred at locations 15, 24, and 30. Only the
highest two reported detections (stations 24 and 30) have
concentrations that exceed three times the highest background
concentration. Based on the information collected, there appears
to be no pattern to the concentrations of PAH compounds detected
at the Site.
Pesticides - Low concentrations of pesticide compounds are present
at nearly all locations throughout the Site and background
locations. Thirteen different pesticide compounds were reported
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to be detected at the Site, all at J-qualified concentrations.
"J" values indicate that the analyte is present, but the reported
value may not be accurate or precise. Most of the thirty surface
soil samples contain one or more pesticide compounds. As with the
PAHs, no specific pattern of pesticide distribution can be
identified except that the compounds are present sporadically
across the Site. The pesticides endrin, ketone and 4'4-DDE were
present most frequently, with each reported at 10 different
sampling locations. Only one pesticide, dieldrin, at location 16
(360J ug/kg), was present at a concentration above 150 ug/kg; four
locations had single pesticides at concentrations above 50 ug/kg,
but the majority of detections were at levels below 10 ug/kg per
pesticide compound.
The highest total pesticide levels were found at station 16,
and the second highest were at station 29, which was one of the
three designated background locations. Pesticides were not
detected at stations 03, 13, 17, 21, 28, and 30. In general, the
results indicate that pesticide compounds were used extensively
throughout the Site.
Polychlorinated Biphenyls (PCBs) - PCBs are present in the surface
soil at approximately one-half of the locations sampled, including
background locations. These compounds were detected near all
former transformer locations, and some spill and random locations.
Two types of PCBs were reported from sixteen locations at the
Site, including two of the three background stations. Each
location where PCBs were detected contained either Aroclor 1254 or
Aroclor 1260, but not both. PCB compounds were detected at all
sample stations located near former transformer areas, at some
sample stations located near spill or soil gas "hot spot" areas,
and at some random and background sample stations.
Inorganic Elements - Although present at most locations, most
inorganic elements detected are not present at concentrations of
potential human health concern. Only lead appears to be present
at concentrations of potential concern over a widespread area of
the Site. In addition, several "hot spot" locations exist with
high concentrations of certain elements. A summary of the
frequency and range of concentrations of inorganic elements
detected in the surface soils at the Site is presented in Table 3.
Oioxin Soil Sampling
Low concentrations of dioxin/furans are present at most
locations at the Site and at off-site background locations. These
compounds appear to be present at locations of apparent past
spills or waste activities. Soil samples were collected from 12
specific and' random locations at the Site and analyzed for total
tetra- through octa-chlorinated dibenzo-p-dioxins and
dibenzofurans. Results are summarized in Table 4, and total
toxicity equivalent concentrations (TE) of 2,3,7,8-TCDD for each
sample location are illustrated on Figure 4.
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Asbestos Ash Sampling
Asbestos sampling was conducted to evaluate the presence of
asbestos in the ash present in the buildings destroyed in the
April 1992 fire at the Site.
The results of the ash sampling are depicted on Figure 5.
The ash generated and deposited at the Site'as a result of the
April 1992 fire does not contain asbestos. However, ash collected
specifically from the remains of the asbestos material stored at
the Site does contain asbestos. Asbestos was detected only in the
ash sample (AS-01 - 40-60% chrysotile, 10-30% amosite) collected
directly from the remains of the asbestos waste staging area; no
asbestos was detected at the other three ash sampling locations.
These results indicate that the asbestos previously staged in the
building probably did not become airborne or spread throughout the
area as a result of the fire.
SUBSURFACE SOIL INVESTIGATION
Samples of the subsurface soils were collected from 20 boring
locations on and off (but near) the Site. The 20 boring locations
were selected on the combined basis of soil vapor 'survey data,
observed field conditions (e.g., stained soil areas), and the need
to provide adequate site-wide characterization. Two off-Site,
background boring locations (borings 8 and 14) were included in
the sampling program.
Two samples were collected from each borehole. One sample
was collected from the zone just above the encountered water table
(typically a very shallow depth at the Site), and the other sample
was collected from a deeper depth zone.
The results of the analyses are summarized in Table S for
volatile organic compounds, total semi-volatile organic compounds,
total PAHs (both carcinogenic and non-carcinogenic), total benzo-
a-pyrene equivalent, total pesticides, and total PCBs.
Volatile Organic Compounds - Volatile organic compounds are not
prevalent throughout the subsurface soils at the Site. However,
two distinct source areas (one located in the northeastern portion
of the Site and one located in the former solvent storage area
located in the central portion of the Site), were identified with
high concentrations of volatile organic compounds in the
subsurface.
At boring location 1, benzene was detected at a concentration
of 1,400 ug/kg in the shallow sample (1-3.5 feet) and 1,300,000
ug/kg in the deep sample (3.5 - 5.0 feet). These data indicate a
substantial "hot spot" at this location, the source and vertical
and horizontal extent of which are not delineated.
Boring location 11 generally corresponds with the former
solvent storage area. Volatile organic compounds, including
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toluene, chlorobenzene, ethylbenzene, and xylenes were detected in
both the shallow (l to 3 feet) and deep sample (7 to 9 feet).
Total volatile organic compounds were detected at concentrations
of 250,000 ug/kg in the shallow sample, and 34,800 ug/kg in the
deep sample. The distribution of volatile organic compounds in
the subsurface at the Site seems to indicate discrete localized
source (spill) areas.
Semi-Volatile Organic Compounds - Many semi-volatile organic
compounds were reported to be present in the subsurface soils at
the Site. As shown in Table 5, the Polycyclic Aromatic
Hydrocarbons (PAHs) comprise the majority of the semi-volatile
organic compounds present, and will be the focus of the discussion
below. Pesticides and PCBs were also reported at some sample
locations, as summarized below. .
Polycyclic Aromatic Hydrocarbons - PAH compounds, including
carcinogenic and non-carcinogenic compounds are present in the
subsurface throughout the entire Site and background locations.
Highest subsurface soil PAH concentrations are noted in a
widespread area encompassing the northern portion of the Site, and
minor "hot spot" locations in the southern portion of the Site.
The highest PAH compound concentrations noted may be indicative of
the presence of light non-aqueous phase liquids (LNAPL), probably
petroleum in nature. The source of the PAH compounds is likely
related to previous releases from any of the large number of tanks
located in the northern portion of the Site.
Pesticides - Very low concentrations of pesticide compounds are
present in the subsurface soils at the Site, generally at or near
the sample quantitation limit. However, one "hot spot" location
of pesticides in the subsurface at the former solvent storage area
was discovered, with pesticides detected to a depth of 5 feet.
Polychlorinated Biphenyls (PCBs) - PCBs are not present in the
subsurface soil at the Site, with the exception of low
concentrations detected at a shallow depth at two unrelated
locations. PCBs were detected in only two boring samples, BOR-02A
and BOR-05A, at concentrations of 710 ug/kg and 430 ug/kg,
respectively. Aroclor-1254 was the only PCS detected at these
shallow boring locations.
Inorganic Elements - Although present at most locations, most
inorganic elements detected in the subsurface are within a rather
limited concentration range. However, anomalies in subsurface
arsenic, lead, and mercury concentrations (relative to the rest of
the Site) were noted at two locations (1 and 17). A summary of
the frequency and range of concentrations of inorganic elements
detected in the subsurface soils at the Site is presented in Table
6.
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GROUND WATER INVESTIGATION
Site Geology/Hydrogeology
Site-specific activities to further evaluate the Site geology
and hydrogeology included borehole geophysical logging, water
level measurements, and ground water flow direction and velocity
determinations.
The elevation of the piezometric surface was measured in
fourteen monitoring/former production wells on the Site from late
1990 to late 1992. The water level measurements were collected in
three different aquifers. From February 22, 1991 through March
28, 1991, continuous water-level recorders were placed in four
former production wells by the United States Geologic Survey
(USGS) to evaluate the tidal influence of the Delaware River on
ground water levels in the lower two aquifers. The uppermost
aquifer is the unconfined water table aquifer located within
alluvium and Site fill material. A confined aquifer is located
within the Trenton Gravel and the upper sand unit of the Potomac-
Raritan-Magothy (PRM) Group. The third aquifer of interest is
also under confined conditions and is located within the lower
sand unit of the PRM Group. Pertinent information regarding these
wells is summarized in Table 7.
In the alluvial water table aquifer, the fluctuations are
caused by direct exchange of water between the river and the
aquifer, at least for a distance of a few hundred horizontal feet.
In the lower two aquifers, the water level fluctuations are caused
by changes in hydraulic pressure as a result of changes in
loading. The fluctuations in the lower two confined aquifers have
been observed almost one mile from the Delaware River.
Ground water flow direction in each of the three aquifers was
determined by contouring the water level data collected on various
dates. The ground water flow direction in each aquifer was
consistent for each measurement date and does not appear to be
influenced by the tidal cycle in the Delaware River.
On the contrary, ground water flow direction is influenced by
pumping of the various aquifers. Pumping of the PRM-Lower Sand .
aquifer in New Jersey produces, southeasterly horizontal flow
beneath the Site.
The pumping also influences the ground water flow direction
in the Trenton Gravel/PRM-Upper Sand aquifer. Because of pumping
in the PRM-Lower Sand aquifer, the Delaware River "loses" water to
the Trenton Gravel/PRM-Upper Sand aquifer. Logically, this should
result in a westerly flow of ground water in this aquifer.
However, ground water in this aquifer appears to flow into a
trough that lies perpendicular to the Delaware River. In this
case, ground water flow appears to be influenced by the thickness
of the Trenton Gravel (above the middle clay unit), as the
thickest portions of the Trenton Gravel correspond to the deepest
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portions of the trough apparently influencing ground water flow
direction.
In the alluvial aquifer, the horizontal ground water flow
direction is to the northwest, away from the Delaware River. It
should be noted that during the time active pumping occurred on
the Site (until approximately 1980), a localized cone of
depression in the water table aquifer was centered near the Site.
Monitoring Well Sampling
The ground water investigation at the Site included on-site
monitoring and former production well sampling and off-site
monitoring and former production well sampling (Figure 6). Two
complete rounds of ground water sampling of the twelve on-site
wells (MW-2, MW-4, MW-9, MW-10, MW-11, PH-408, PH-411, PH-415,
PH-416, PH-417, PH-419, and PH-420) and five off-site wells
(Packer-Shallow, Packer-Deep, PH-750, PH-751, and PH-752), were
conducted during February and November 1991. In addition, several
QA/QC samples were collected during each sampling event.
All ground water samples collected from monitoring and former
production wells were analyzed for general water chemistry and TCL
and TAL (total and dissolved metals) parameters. A summary of the
results are presented in Tables 8 and 9.
Off-Site Ground Water Quality
There are five well locations considered background sampling
stations. Of these five wells PH-750 (lower sand), PH-751 (upper
sand), and PH-752 (upper sand) are off-Site sampling locations and
are considered to be hydrologically upgradient of the Site (i.e.,
not impacted by any Site activities). The other two wells,
Packer-Shallow (alluvium) and Packer-Deep (Trenton Gravel), are
likely situated upgradient or sidegradient of most portions of the
Site where waste activities were noted in the past.
With the exception of lower sand well PH-750, the off-site
wells contain little to no organic compounds. However, well PH-
750, which was designated as a background well, contains numerous
volatile organic compounds. Numerous inorganic elements are also
present in the off-site wells. Elements detected at
concentrations of potential concern include arsenic, barium, and
manganese. In the off-site wells, only volatile organic compounds
were detected in both rounds of ground .water sampling. Two semi-
volatile compounds (4-methylphenol [4J ug/1 - Packer-D] and phenol
[5J ug/1 - PH-751 and PH-752]) were detected in the off-site
wells, but no pesticides and PCBs were detected in any of the
samples.
There are a variety of inorganic elements present in the off-
site wells. Inorganic elements present at concentrations of
potential, concern in filtered samples, based solely on a general
comparison to human health risk screening data criteria (EPA,
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1993), include arsenic (Packer-S; 23.8 ug/1), barium (Packer-D;
699 ug/1), and manganese (all off-site wells; range from 256 ug/1
to 2,640 ug/1).
On-Site Ground Water Quality
There are three separate distinct aquifers at the Site: an
alluvial/fill aquifer, the Trenton Gravel/PRM Upper Sand aquifer,
and the PRM Lower Sand aquifer.
Alluvial Aquifer - There are a variety of inorganic elements
present.in the alluvial aquifer. Inorganic elements present at
concentrations of potential concern in dissolved (filtered)
samples, based solely on a general comparison to human health risk
screening data criteria, include arsenic, barium, and manganese.
However, the manganese and barium concentrations present are
within background concentrations.
Trenton Gravel/Upper Sand Aquifer - There were few to no organic
compounds detected in the Trenton Gravel/Upper Sand aquifer.
However, there are numerous inorganic elements present. Elements
detected at concentrations of potential concern include manganese
only, although high manganese concentrations are a natural feature
of this aquifer.
Only relatively low concentrations of volatile organic
compounds were detected in the Trenton Gravel/Upper Sand aquifer
during the first sampling round. No volatile organic compounds,
pesticides, or PCS compounds were detected in the second sampling
round, although low concentrations of selected semi-volatile
compounds were detected.
. There are a variety of inorganic elements present in the
Trenton Gravel/Upper Sand aquifer. Inorganic elements present at
concentrations of potential concern in dissolved (filtered) •
samples, based solely on a general comparison to human health risk
screening data criteria, include manganese. However, high
concentrations of iron and manganese are a natural feature of this
aquifer.
Lower Sand Aquifer - There were numerous volatile organic
compounds present in the lower sand aquifer at the Site, however;
this is a background condition and does not appear related to
contamination, at the Site. There are numerous inorganic elements
present in this aquifer as well, with manganese present at
concentrations of potential concern, although this also appears to
be a background condition of this aquifer. The PRM Lower Sand
aquifer contains the greatest number and highest concentrations of
organic compounds on the Site. With the exception of a single
finding of bis(2-ethylhexyl)phthalate (6.4J ug/1) in the round 2
sample from well PH-408, the only other compounds detected in this
aquifer were volatile organic compounds.
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A comparison of Che off-sice and on-site water qualicy of Che
PRM Lower Sand aquifer indicaces Chat relacively similar compounds
and concentrations are present in Che aquifer both on-site and
hydrologically upgradient off-site locations. The results of this
comparison supplement'che geologic evidence (i.e., isolation of
che lower sand from che concaminanCs at the Site by a thick [50-60
feet chick] layer of confining clay) that supports the observation
that the source of organic compounds detected in the lower sand
aquifer at the Site is likely not related to contaminants at the
Site (i.e., the compounds detected in the lower sand aquifer are
not typically present in the shallow aquifer or soil at the Site).
Rather, the presence of organic compounds in the lower sand
appears to be a result of contamination of the aquifer from
sources west (upgradient) of the Site. Migration of contaminants
to the Site from areas west of the Site is promoted by the
continued pumping of the PRM Lower Sand aquifer in New Jersey,
which substantially has lowered the potentiometric surface of this
aquifer.
There are a variety of inorganic elements present in the PRM
Lower Sand aquifer. Inorganic elements present at concentrations
of potential concern in dissolved (filtered) samples, based solely
on a general comparison to human health risk screening data
criteria (EPA, 1993), include manganese (PH-408 - 459 ug/1; PH-417
- 809 ug/1; PH-419 - 696 ug/1; and PH-420 - 654 ug/1). However,
high iron and manganese concentrations are a common background
condition of this aquifer because o'f changes in hydrogeochemistry
as a result of contamination of this aquifer over the last 50
years.
UNDERGROUND LINE INVESTIGATION
Line Location Activities
The primary objective of line location activities was to
assess the possible presence of buried process lines at the Site
and to identify potential conduits for contaminant migration in
the subsurface at the Site.
Two approaches were used to assess the location and type of
utilities and subsurface lines: (1) inventorying historic Plant
and utility plans, and (2) performing field reconnaissance to
identify existing utilities and locations. To accurately account
for the numerous underground utilities throughout this large
Plant, the Site was divided into eight .zones.
As shown in Table 10, there are several types of below ground
lines at the Site, including primarily sanitary sewer lines
(Figure 7), storm sewer lines and surface drainage trenches
(Figure 8), underground electric lines (Figure 9), and various
types of water lines and other apparent subsurface process-type
lines. No underground storage tanks were identified. The
subsurface lines that could be reasonably differentiated and
identified at the Site are .depicted on the noted figures. The
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city water and sanitary sewer lines are Site-related. Most of che
lines appear to be in poor condition and do not appear to be
usable. For example, many of the stormwater trenches, drains, and
sewers are filled with debris and other material.
Several types of subsurface process-type lines, including
molasses, spent mash, and fuel lines, were identified on
historical Plant plans. However, because these lines often were
shown to terminate inside of dilapidated buildings, it was very
difficult to locate process lines in the field, even with a plan
showing the approximate location of the feature.
In general, there appears to be a limited number of process
lines which travel for short distances below grade at the Site.
Specific subsurface process pipe lines investigated are described
below and are depicted on Figure 10:
• Approximately 155-foot section of a 12-inch diameter molasses
line was identified from the historic Plant/utility plans.
This 12-inch diameter line terminates near the old boiler
house. Multiple efforts to locate this line in the field
were unsuccessful and it is possible that this line was
removed.
• A fuel line connecting the Site with the old fuel depot on
the west side of Delaware Avenue (now Christopher Columbus
Boulevard) was identified on Plant/utility plans. This line
originates between Drum Dryer Buildings No. 1 and No. 2. in
the southern portion of the Site, but a surface expression of
this line or termination of the line could not be identified.
• Plans indicate a number of subsurface well water lines
existed in support of on-site wells. In general, the
subsurface well water lines identified on the Plant plans
travel for only short distances.
An extensive network of subsurface lines, including sanitary
and storm sewers, electrical conduits, water lines, and some
process lines exist at the Site. Many of these lines are in poor
condition.
Surface Water/Sediment Sampling
Surface water and sediment samples were collected from the
surface and subsurface features (i.e., .surface trenches and
subsurface lines - Figure 11) throughout the Site, which features
did not appear to contain oily substances. (Samples collected
from areas heavily contaminated with petroleum were designated as
"waste samples," the results of which are discussed in
Miscellaneous Wastes.) The purpose of this sampling was to
evaluate the extent of contamination in these features
(specifically surface water runoff) throughout the Site. A
description of the features sampled as part of this effort is
provided in Table 11.
13
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The magnitude and extent of chemical contamination in the
surface water and sediments were assessed by submitting the
samples for chemical analyses of the full Target Compound List and
Target Analyte List parameters. The results of the analyses
follow.
Surface Water Data
The results of the surface water (stormwater/runoff) sampling
are summarized in Table 12 for volatile organic compounds, total
semi-volatile organic compounds, total PAHs (both carcinogenic and
non-carcinogenic), total benzo-a-pyrene equivalent, total
pesticides, and total PCBs. With the exception of two sample
stations situated near the former solvent storage area located
near-Locations LIQ-01 and LIQ-02, volatile organic compounds are
not present in the surface water (stormwater/runoff) at the Site.
Volatile Organic Compounds - Locations LIQ-01 and LIQ-02 were the
only locations with detection of significant levels volatile
organic compounds, with benzene (490 ug/1), 4-methyl-2-pentanone
(2400 ug/1), and toluene (730 ug/1) reported in sample LIQ-01 and
2-butanone (5,500 ug/1) and 4-methyl-2-pentanone (490 ug/1)
reported in sample LIQ-02.
The samples collected from stations LIQ-01 and LIQ-02 were
collected from drop inlets situated in the vicinity of the former
solvent storage area.
Semi-Volatile Organic Compounds - Low concentrations of semi-
volatile compounds, including carcinogenic and non-carcinogenic
PAH compounds, are present in the surface water
(stormwater/runoff) at the Site. Higher concentrations of these
compounds are found at sample stations located near the former
solvent storage area. Semi-volatile organic compounds were
reported to be present in nearly all of the surface water
(stormwater/runoff) samples (with the exception of stations LIQ-03
and LIQ-09) collected at the Site. With the exception of the
total semi-volatile organic compound concentrations detected at
stations LIQ-01 and LIQ-02, most semi-volatile organic compounds
are present at relatively low, J-qualified concentrations at most
stations.
Pesticides.- Low concentrations of pesticide compounds were
present at two surface water sample stations. Pesticide
compounds, however, are not generally prevalent in the surface
water (stormwater/runof f) at the Site.
Polychlorinated. Biphenyls (PCBs) - No PCBs were reported in the
surface water (stormwater/runoff) samples collected at the Site.
Inorganic Elements - Most inorganic elements are present in the
surface water (stormwater/runoff) at the Site. Copper, iron,
lead, manganese, and zinc are present at all sample stations at
concentrations of potential environmental concern. In addition,
14
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cadmium, mercury, silver, and vanadium are present at specific
locations also at concentrations of potential environmental
concern. The source of the inorganic elements is likely runoff
from the extensive amount of metal debris at the Site and
concentrations of metals in the surface soils at the Site. A
summary of the frequency and range of concentrations of inorganic
elements detected in the surface water (stormwater/runoff) at the
Site is presented in Table 13.
Sediment Data
The results of the sediment sampling are summarized in Table
14 for volatile organic compounds, total semi-volatile organic
compounds, total PAHs (both carcinogenic and non-carcinogenic),
total benzo-a-pyrene equivalent, total pesticides, and total PCBs.
Volatile Organic Compounds - With the exception of two sample
stations, one of which is situated near the former solvent storage
area, volatile organic compounds are not present in the sediment
at the Site. However, volatile organic compounds were found at
high concentrations at those two locations. Locations SED-02 and
SED-03 were the only locations with significant concentrations of
volatile organic compounds, with 2-butanone (25,000 ug/kg)
reported in sample SED-02, and chioromethane (990J ug/kg),
bromortiethane (2100J ug/kg) , benzene (1500J ug/kg) , ethylbenzene
(17,OOOJ ug/kg), and xylenes (17,OOOJ ug/kg) reported in sample
SED-03.
Semi-Volatile Organic Compounds - Semi-volatile organic compounds
were reported to be present in all sediment samples collected at
the Site. As shown in Table 14, the Polycyclic Aromatic
Hydrocarbons (PAHs) comprise the majority of the semi-volatile
organics present.
Polycyclic Aromatic Hydrocarbons - PAH compounds, including
carcinogenic and non-carcinogenic compounds are present in all
sediment samples collected. The presence of the PAH compounds is
probably a result of direct spills into the Site drainage system
or transport of surface soil material into the drainage system via
runoff.
Pesticides - Low concentrations of pesticide compounds are present
at most of the sediment sample stations at the Site. However,
pesticides are not generally prevalent in the sediments.
Pol/chlorinated Biphenyls (PCBs) - Low concentrations of PCBs are
present at most of the sediment sample stations at the Site.
Low concentrations of PCBs were reported in all sediment samples
with the exception of sample SED-12. Arochlor 1254 is the most
prevalent PCS detected (6 locations), ranging in concentration
from 150 ug/kg (SED-01) to 2,600 ug/kg (SED-08).
Inorganic Elements - Most inorganic elements are present in the
sediment at the Site. Arsenic and lead are present at certain
15
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sample stations at concentrations of potential environmental
concern. The source of the inorganics is likely runoff from the
surface soil and debris at the Site. The inorganic sediment
results are summarized on Table 15.
Waste Sampling
Sampling was conducted to evaluate substances identified in
the underground features at the Site as "high concentration or
oily" waste type materials, based solely on field characteri-
zation and observations (i.e., high organic vapor readings,
apparent free oil product, unknown waste materials, etc.). In
addition to the substances identified in the underground features,
other types of waste, including substances located in three drums
of unknown origin (note that only two drums could be accessed for
sampling) and a substance leaking from a storage sphere at the
Site, were identified for further characterization.
Liquid and/or solid (multi-matrix) samples were collected
from 10 locations at the Site in January 1992 (Figure 12). The
results of the waste sampling are summarized in Table 16 for
volatile organic compounds, total semi-volatile organic compounds,
total PAHs • (both carcinogenic and non-carcinogenic), total benzo-
a-pyrene equivalent, total pesticides, and total PCBs. A summary
of the frequency and range of detects of inorganics is presented
in Table 17. A general description of the findings follows.
Drum Samples (Stations HC-01, HC-02) - The drums contain numerous
organic compounds and metals, although based on the analytical
data, the exact contents of the drums cannot be determined. Of
the two drums sampled, one drum contains almost a nearly pure
organic substance, whereas the other drum contains both organic
compounds and metals.
Hortonsphere Sample (Stations HC-03) - The liquid draining from
the Hortonsphere at the time'of sampling cannot be identified
based on the laboratory results. The sample collected from the
Hortonsphere was clear and amber colored, and was 'more viscous
than water but less viscous than oil, and had no obvious odor.
No TCL compounds were detected in the sample from the
Hortonsphere, and only one unknown semi-volatile Tentatively
Identified Compound (TIC) was detected at a concentration of 1,940
mg/kg. The liquid draining from the sphere contains relatively
high concentrations of arsenic (101 ug/1), iron (75,500 ug/1),
lead (18 ug/1), manganese (553 ug/1), and zinc (646 ug/1). No
other metals were detected.
Electrical Utilities (Stations HC-04, HC-05, HC-OB, HC-Q9, HC-10)
- The oily waste samples collected from the electrical utility
areas contain low levels of TCL compounds and numerous inorganic
elements. It is presumed that the major constituents of the oily
waste are non-TCL list organic compounds.
IS
-------
Stormwater Utilities (Stations HC-06, HC-07) - Samples HC-06 and
HC-07 were collected from shallow stormwater trenches within the
Hortonsphere farm in the southeastern portion of the Site. The
shallow trenches within the Hortonsphere farm are contaminated
with a variety of inorganic elements. Several inorganic elements,
including antimony, beryllium, lead, and mercury are present at
concentrations of potential environmental concern in these
trenches. Given that the liquid originating from the Hortonsphere
did not contain numerous metals, the source of the metals in the
sediment and runoff in the drainage trench is likely related to
leaching from metal debris located in the area or from spills of
unknown materials in this area.
Line Contamination Assessment
Based on the laboratory results and the field reconnaissance
of the subsurface features, the majority of contamination appears
centered around two areas of the Site. The discussion below
describes the specific utilities impacted and the nature of
contamination, and provides an estimate of the contaminant volume.
Sanitary Sewer Utilities
Only a limited inspection of sanitary utilities was performed
during the RI. No samples of fluids/sediment found in sanitary
sewers were collected. Site reconnaissance was limited to key
manholes at major intersections of the sanitary sewer lines. The
length of sanitary sewers impacted by Site activities is difficult
to ascertain. A light sheen was observed on liquid surfaces in
some manholes which may be due to organic decomposition. Although
there is no current activity on the Site, flow was observed in the
sanitary sewers. The majority of this flow is suspected to be
inflow and infiltration into the pipe lines due to the
deterioration (poor integrity) of the sanitary sewer lines.
Specifically, sections of the sanitary sewer lines are thought to
have separated; permitting the inflow/infiltration of ground
water/soil moisture from adjacent saturated soil. Because the
Site is low-lying, particularly the northwest corner of the Site,
tidal flooding of the Site probably generates a significant inflow
into the sanitary sewer network.
SCorzn Sewer Utilities
The investigations of the subsurface storm sewers and surface
connected trenches were different. The stormwater trenches were
easy to locate and evaluate, whereas subsurface storm sewers could
only be evaluated at the manholes and/or at the points of
discharge. Contaminated sediment washed from the Site's surface
is believed to be the principal source of contaminants in both
storm sewers and trenches. No evidence of illegal dumping into
the storm sewers or trenches was observed, although any
contaminants dumped in the storm sewers/trenches would naturally
wash downstream and into the Delaware River. Figure 13 indicates
17
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the sections of stormwater utilities with known or suspected
contamination.
Due to its elevation, the storm sewer system appears to be
regularly flushed by tidal flows of the Delaware River. This
condition makes it is difficult to estimate the volume of
contaminated liquids in subsurface storm sewers and trenches. The
majority of Site storm drainage apparently discharges through a
single 48-inch storm sewer located between Piers 105 and 106 (LIQ-
.10 sample location). It should be noted that although a review of
historical data indicated other stormwater discharge points [as
related to historic National Pollutant Discharge Elimination
System (NPDES) permitted discharges], no others could be
identified.) Although a sediment sample could not be collected at
this outlet point, a fluid sample was collected of the discharge
(Sample LIQ-10). It is very difficult to identify from which
portion of the Site the contaminants found in LIQ-10 originate;
however,.it is likely that the stormwater discharge is
representative of Site runoff.
Contaminated sediment exists in the storm trenches. The
storm water trenches that are impacted are located near the
Hortonsphere tank farm. Samples from this area contain numerous
inorganics, such as barium, lead, mercury, and zinc, and several
semi-volatile TICs. Of the 4000 feet of on-site storm trenches,
it appears that approximately 1300 feet contain contaminants.
Based on field measurements, approximately 300 cubic feet of
contaminated sediment reside in these trenches. Contaminated
sediment was also found in some drop inlets (e.g., SED-01 and SED-
05) which lead into storm sewers but it is very difficult to
estimate the length of impacted sewers and the volume of
contaminated sediment. Little or no sediment was observed in some
manholes of the storm sewers, while others contained significant
sediment quantities. No estimate has been made of the volume of
contaminated sediment found in storm sewers.
Electrical Utilities
Figure 14 indicates the portions of the electrical utility
system with known or suspected contamination. Areas of
contamination were estimated based on laboratory data and visual
observation.
Contaminants in electrical utilities are believed to be the
result of two sources: 1) illegal or '[midnight dumping" and 2)
infiltration/inflow from runoff or from surrounding saturated
soils by way of cracks and separated pipe sections. In
determining the extent of contamination, it was assumed that
manholes not found during Site reconnaissance or which could not
be opened were not used for illegal dumping. It should be noted
that migration of contaminants between electrical substations is
believed to have occurred.
18
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According to the Plant/utility plans, substations are
connected by ducts, each of which can contain a dozen electrical
conduits/pipes of up to 4 inches in diameter. During Site
reconnaissance, efforts to identify specific conduits which could
facilitate contaminant transport were unsuccessful. In some
substations, the conduits in the ducts were obviously open-ended
(not sealed). Frequently it was not possible to determine if
electrical conduits were located above or below the surface of the
liquid contamination.
Given the information currently available, it was estimated
that approximately 3000 feet of the 5000 feet of electrical duct
is contaminated to some extent. In all, contamination was
observed or is believed to exist in 21 electrical substations.
Based on field measurements, approximately 28,000 gallons of
contaminated liquid are located in substations. In addition, if
the oily liquid frequently observed in substations has entered
into electrical ducts, between 6,000 and 12,000 gallons of
additional contaminated fluids could exist."
In summary, the subsurface lines at some locations at the
Site are extensively contaminated. Subsurface electrical lines,
conduits, and manholes and surface drainage trenches are the most
contaminated features, although contamination, ^likely exists in all
subsurface features. Subsurface features have been contaminated
as a result of surface runoff and illegal dumping of oily liquids
directly into manholes.
ECOLOGICAL INVESTIGATION
A preliminary ecological assessment was performed to
determine the presence and evaluate the quality of the aquatic and
terrestrial communities in the vicinity of the Site. The scope of
the ecological assessment consisted of a general terrestrial
survey, and an aquatic survey using modified Rapid Bioassessment
Protocols. The focus of the ecological investigation was on the
benthic community in the Delaware River.
Ten sample stations, plus one upstream and one downstream
sample station along the banks of the Delaware River (Figure 15)
were investigated.
General Description
The river bank in the vicinity of .the Site has been heavily
modified by piers, slips, bulkheads, rip-rap, and other structures
of the urban environment such that the river bank habitat
physically no longer resembles natural conditions. In addition,
stormwater discharge, treated sewer effluent, and various other
discharges from both Pennsylvania and New Jersey are introduced
into the river in the area. These discharges, along with the
history of pollution in this river zone, have altered the water
and sediment chemistry. Therefore, the study area has been
19
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heavily modified, both physically and chemically from the natural
conditions.
Terrestrial Vegetation - The terrestrial environment of the Site
is essentially urban. Most of the ground surface consists of
either concrete, asphalt pavement, or is covered by some
structure. However, early successional plant species have formed
thickets on many of the unpaved locations on the Site, and are
also growing in pavement cracks and similar locations. The
vegetation on-site is principally.upland herbaceous species,
typical of the "roadside weed" variety. Common plant species
observed include ragweed, crabgrass, spurge, and other urban
pioneer species. Over time and if left undisturbed, the
vegetation would encroach and perhaps predominate the Site,
although Site buildings and pavement will prevent complete
vegetation from occurring.
Terrestrial Wildlife - The observed terrestrial wildlife community
on the Site is fairly typical of urban environments. The avian
wildlife observed consisted mostly of common urban bird species
(starlings, rock doves, house finches, and house sparrows), open
scrub species (mourning doves, song sparrows, ring-necked
pheasants), wintering songbirds (white-throated sparrows, dark-
eyed juncos), and raptors such as red-tailed hawks and kestrels.
Also observed were species associated with the Delaware River
includ'ing gulls (ring-billed, herring, and greater black-backed) ,
ruddy ducks, and mallards. The only mammals observed on-site were
eastern cottontails, rats, and domestic cats.
Aquatic Habitat - There are no streams or other aquatic
environments on the Site. However, Site stormwater run-off flows
directly into the Delaware River via overland runoff and through
the below grade, storm-water system. The Delaware River in the
vicinity of the Site is freshwater and tidal, however saltwater
intrusion occurs locally. Historically, the Delaware River has
been highly polluted in the study area, but recently the river has
shown substantial improvements in water quality. However, River
Zone 3, in which the Site is located, is still part of the most
polluted reach of the Delaware River. The invertebrate samples
collected at the Site for the RI reflect the generally poor water
quality of the river, with sludge worms (Tubificidae) dominant at
all sample locations.
No jurisdictional wetlands were identified to be on the Site.
However, the Site is within 7 stream-miles of the John Heinz
Memorial National Refuge at Tinicum, which includes the largest
freshwater marsh and important aquatic habitat in Pennsylvania.
Aquatic Vegetation - Aquatic vegetation was not present at any of
the sample stations.
Aquatic Wildlife - The vast majority of the organisms collected at
any of the sample stations were sludge worms (family Tubificidae).
The other taxa collected included midge larvae (Chironomidae) and
20
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various mollusks, including clams (mostly Sphaeriidae), snails
(mostly Physidae) and limpits (Ancylidae). However, no living
mollusks were collected at any of the sample stations. Other taxa
were rare. Diversity at all stations was generally poor.
Benthic Community Evaluations
Reference Station Locations - The downstream reference station
(ECOL-11) is located adjacent to a road, formerly a railroad
bridge, south of pier 109 and north'of the Walt Whitman bridge.
It should be noted that station ECOL-11 is located downstream of
the City of Philadelphia POTW outfall. The upstream reference
station (ECOL-12) is located on the south side of pier 96. ECOL-
12 was unusual in that it was located in relatively deep water.
The water was approximately 12 feet deep at low tide at this
sample station at the time of field investigation.
Habitat Evaluation - The study area reference stations are located
in a highly modified aquatic environment. Piers, bulkheads, rip-
rap, and various structures are present in the study area. The
river has also been dredged for navigational purposes, and a fine
silt was the dominant river bottom substrate. The river was
brown, turbid, and generally less than 10 feet deep at all sample
locations, and field investigation activities were conducted
during low tide.
Community Evaluation - Community evaluations for the ecological
sampling stations were made by comparing various quantitative
community parameters between the sampling stations with the
reference stations using metrics. Of eight metrics suggested for
use, only four were deemed appropriate to use.in assessing the
estuarine community of the Delaware River in the vicinity of the
Site. These are: (1) taxa richness, (2) the modified Family
Biotic Index (FBI), (3) percent contribution of dominant family,
and (4) the Community Loss Index (CLI). FBI is indicative of the
sensitivity of the aquatic community, with zero being the most
sensitive and ten being the most tolerant.' CLI is a measure of
dissimilarity that assesses the loss of benthic taxa between the
reference and the station of comparison. The metrics at both of
the reference stations are indicative of a stressed aquatic
environment. The percent contribution of the dominant family, an
indicator of community balance, is high, and the dominant species'
is tolerant to poor water quality. With a relatively high
background pollution level, it may be difficult to detect changes
in the benthic community that may result from the Site, since the
most striking community shifts have already occurred due to
background stress.
Benthic Community Evaluation - There were 14 different taxa of
aquatic organisms collected in all the sample locations combined.
Individual stations ranged from 1 to 9 taxa, averaging 5. The
taxa present, overall, are very pollution tolerant (FBI =9.79 for
fauna of all stations combined). Organisms sensitive to water
pollution were completely absent from the fauna.
21
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In summary, the preliminary ecological assessment indicates
that it cannot be shown conclusively that the Site is having a
significant impact on benthic organisms beyond that apparent in
background reference stations impacted by other multiple sources
of contaminants. Further, the results of this study are
comparable to other studies conducted in the Delaware River,
indicating a generally impaired benthic community.
DELAWARE RIVER SEDIMENT INVESTIGATION
EPA collected 16 river sediment samples from the Delaware
River, east of the Site. The results of the sample analyses for
semi-volatile base-neutral acid extractables, pesticides, PCBs and
TAL metals are contained in Tables 18 (organic compounds) and
Table 19 (inorganics), and sample locations are shown on Figure
16.
The data from the 16 Delaware River sediment sampling
stations were compared to published "background" river sediment
data collected below the Ben Franklin and Walt Whitman bridges, as
reported by the Delaware River Basin Commission.
Volatile Organic Compounds - Volatile organic compounds were not
analyzed in the sediment samples collected from the Delaware
River, as these compounds were not expected to be present.
Semi-Volatile Organic Compounds - Eight semi-volatile compounds,
including 1 carcinogenic PAH, 6 non-carcinogenic PAHs, and 1 non-
carcinogenic non-PAH semi-volatile compound, are randomly present
in 10 of the 16 sediment samples collected from the Delaware River
adjacent to the Site. The concentrations reported are generally
of low levels (less than or equal to 10 mg/kg) and are less than
or equal to the background concentrations referenced. Based on
this evidence, it does not appear that these compounds can be
directly or exclusively attributable to the Site. Runoff from the
Site, however, likely has contributed some PAHs to the river
sediments.
Pesticides - Low concentrations of at least one pesticide compound
were detected in all of the sediment samples from the Delaware
River. However, the concentrations typically are less than those
of the background stations referenced. Based on this evidence, it
does not appear that these compounds can be directly or
exclusively attributable to the Site. Runoff from the Site,
however, likely has contributed some pesticides to the river
sediments.
PolychlorinaCed Biphenyls (PCBs) - Low concentrations of PCBs are
present at approximately half of the Delaware River sediment
sample stations. Based on this evidence, it does not appear that
these compounds can be directly or exclusively attributable to the
Site. Runoff from the Site, however, likely contributed some PCBs
to the river sediments.
22
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Inorganic Elements - The inorganic elements detected in the
Delaware River sediment samples are presented in Table 19. Most
inorganic elements typically analyzed for are present in the
sediment from the Delaware River, however the data for antimony,
barium, copper, and selenium were not presented. For selected
elements sampled at the background stations, the concentrations
of metals in the Delaware River sediments are generally less than
those reported from background stations.
6 . S'lTprn^trv of Sita Riaka
HUMAN HEALTH RISKS
The potential routes of migration of contaminants at the Site
include:
• airborne migration;
• vadose zone migration;
• ground water migration; and
• surface/subsurface line (runoff) migration.
The airborne migration potential of Site contaminants is low.
There is no evidence of vapor generation or migration at the Site,
and although contaminants can migrate via fugitive dust at the
Site, current Site conditions minimize dust generation.
Site contaminants have migrated from surface spill areas into
the vadose zone. Surface soil, surface feature, and subsurface
contaminants likely continue to migrate downward into and through
the vadose zone. There is evidence that a LNAPL is present in the
vadose zone (i.e., residual saturation in the capillary zone),
although the LNAPL is not likely migrating in the subsurface. The
LNAPL, however, is probably releasing dissolved contaminants to
the' shallow ground water.
Any Site related contaminants in the ground water are
restricted to the shallow aquifers at the Site, and based upon
ground water flow determinations, any contaminant migration
potential would be to areas west and northwest, away from the
Delaware River. The shallow aquifers do not directly discharge to
the Delaware River in this area. No Site related ground water
contaminant migration is likely to the deep aquifer at the Site •
because of the presence of a considerable confining layer.
However, the extent, if any, of contaminant migration between the
shallow and deep aquifers via the former production wells at the
Site is unknown.
Contaminant transport potential in the runoff (liquid and
suspended sediment) is high. This runoff is potentially via
surface/subsurface lines and 'also likely via direct overland flow
to the Delaware River. However, sediment samples from the
Delaware River immediately adjacent to the Site did not indicate
the presence of contaminants at concentrations in excess of
background levels (at sampling locations immediately upriver and
23
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downriver from the Site). Some contaminant migration may occur on
a daily basis as a result of tidal cycle flushing of the storm
sewer system, but the potential for contaminant migration is
greater during periods of heavy precipitation, which can promote
suspended and direct sediment transport from the Site.
The inorganic contaminants present at the Site are very
persistent in the soil/sediment, ground water and surface water
media. Organic contaminants are also persistent in the
soil/sediments media, although with, the exception of oily waste
areas, the organic contaminants are generally not persistent in
the ground water/surface water media.
The baseline risk assessment consists of two assessments:
human health evaluation and ecological evaluation. The human
health evaluation for the Site quantifies potential human health
risks associated with the Site. The human health risk assessment
process consists of four basic steps:
1. Selection of Chemicals of Potential Concern (CPCs).
Monitoring data collected as part of the RI are analyzed
and CPCs are selected. Of the chemicals detected at the
Site, CPCs are selected based on an evaluation of risk
factors (which quantify the relative, percent
contribution of each chemical to the overall risk),
frequency of detection, low toxicity to humans (i.e.,
essential human nutrients were not selected as CPCs),
and background concentrations. Selected CPCs are then
evaluated further.
2. Exposure Assessment. Exposure pathways are identified
based on an evaluation of the environmental setting of
the Site and the environmental fate and transport of
CPCs. Exposure pathways are selected for both current
and future land uses of the Site. Exposure point
concentrations and exposures are estimated for each CPC
for the exposure pathways quantitatively evaluated for
this Site.
3. Toxicity Assessment. Toxicity criteria for assessing
carcinogenic risks and non-carcinogenic hazards for the
selected CPCs are presented and evaluated.
4. Risk Characterization. The exposure estimates and the
toxicity criteria are combined to estimate potential
carcinogenic risks and non-carcinogenic hazards for the
exposure pathways quantitatively evaluated in this
report. These risks characterize the potential human
health impact associated with the Site.
The summary of Chemicals of Potential Concern are listed on
Table 20.
24
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Table 20
Surwary of Chemicals of Potential Concern for the PUBLICKEU Site
Chemical
Organic::
Benzene
2-3utanone
trans-1,2-0ichloro«thene
Oieldrin
Endrtn Keton*
bis(2-Ethylhexyt)phtnalate
Heptaehlar Epbxid*
4-Methyl -2-p«ntanon»
4-Hethypnenol
Potycyetie Aromatic Hydrocarbons
Benzo(a)anthracan«
Benzo(a)pyrene)
3enzo(b)fluoranthtrt«
BenzoC k ) f lueranthan*
0 i b«ni( a , h ) anthracen*
lndeno<1,2,3-c,d)pyrer»
2-Hethytnaphtttiltn*
Phenanthren*-
Aroclor-1254
Aroclor-1260
2,3,7,8-TCHO (Egutvitmts)
Toluen*
Trichtorocthano
Vinyl Chlorid*
Inorganics:
*lLminu»
Arsenic
Sariua
aerylliua
Cadoiua
Grotnd Uater -
AFM
X
«
TCAB
*
K
.
LS
*•
«
X
*
*
•
Soil
Surfac*
*
*
•
•
*
»
•
*
*
•
*
+
*
•
*
*
•
S4*-
Surfic*
*
*
*
•
•
•
•
*
*
*
•
X
*
»
*
Storm Water
Orainog*
Surfac*
W>ttr
•
t
•
•
•
•
•
*
•
•
t
x
•
•
•
. •
•
•
•
Sadinenr
•
*
•
X
•
•
•>
•
25
-------
Cheat cat
Copper
Lead
Manganese
Mercury
Nickel
Thallium
vanadium
Zinc
Ground Water -
AFM
•
TG/US
•
IS
+
Soil
Surface
t>
*
•
•
*
*
*
&*-
Surface
»
#
*
*
*
Store Uattr
Drainage
Surfac*
Water
•
•
•
•
•
Sediaent
•
• Considered to be within background levels but exceeding Risk-Baaed Concentration* (RSCi).
* Considered to be above background levels and exceeding RBC*.
• Background comparison not available
- AFN « alluvion and Mil material, T6/US * Trenton gravel/upper-sand, and IS • Lower sand
x Not stapled in this nediuB
26
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The Site is located in a heavy urban industrial area of
southeastern Philadelphia. An estimated population of only 1,100
people live within a 1-mile radius of the Site, although over
500,000 people live within a 4-mile radius of the Site in
Philadelphia and the New Jersey cities of Camden and Gloucester.
The media of concern in this study include ground water, surface
and subsurface soils, surface water, sediment, air, and biota.
The following current land use exposure pathways were
quantitatively evaluated in the RI:
Incidental ingestion and dermal absorption of chemicals in
surface soil by trespassers (i.e., children) at the Site;
Dermal absorption of chemicals in surface water by
trespassers (i.e., children) exposed at on-site trenches,
manholes, or the outfall to an embayment of the Delaware
River;
Incidental ingestion and dermal absorption of chemicals in
sediments by trespassers (i.e., children) exposed at on-site
trenches, manholes, or the outfall to the Delaware River.
Inhalation of dust from surface soil by trespassers (i.e.,
children) at the Site.
The following future land use exposure pathways were
quantitatively evaluated:
Short-Term Construction Scenario;
Incidental ingestion and dermal absorption of chemicals in
blended surface and subsurface soil by construction workers
at the Site; and
Inhalation of dust from blended surface and subsurface soil
by construction workers during grading activities at the
Site.
LonarTerm Scenario I. Industrial Redevelopment:
Ingestion of chemicals in ground water from industrial wells
by workers on the Site (assuming no treatment of ground
water);
Dermal absorption of organic compounds while showering using
ground water from on-site wells by workers (assuming no
treatment of ground water);
Inhalation of VOCs while showering using ground water from
industrial wells by workers at the Site (assuming no
treatment of ground water); and.
27
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Inhalation of VOCs by on-site workers from an openly vented
cooling tower using ground water from on-site wells (assuming
no treatment of ground water).
Long-Term Scenario II. Plavina Field Development:
Incidental ingestion and dermal absorption of chemicals in
blended surface and.subsurface soil by children and adults
playing at the Site; and
Inhalation of dust from blended surface and subsurface soils
by children and adults playing at the Site.
The toxicity assessment is then developed for each CPC.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day)'1,
are multiplied by the estimated intake of a potential carcinogen,
in units of mg/kg-day, to provide an upper-bound estimate of the
excess lifetime cancer risk associated with exposure at that
intake level. The term "upper bound" reflects the conservative
estimate of the risks calculated from the CPF. Use of this
approach makes underestimation of the actual cancer risk highly
unlikely. Cancer potency factors are derived from the results of
human epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.
Reference doses (RfDs) have been developed by EPA for
indicating the potential for adverse health effects from exposure
to chemicals exhibiting non-catcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals, that
are not likely to be without an appreciable risk of adverse health
effects. Estimated intakes of chemicals from environmental media
(e.g., the amount of a chemical ingested from contaminated
drinking water) can be compared to the RfD. RfDs are derived from
human epidemiological studies or animal studies to which
uncertainty factors have been applied (e.g., to account for the
use of animal data to predict effects on humans). These
uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse non-carcinogenic effects
to occur.
Excess lifetime cancer risks are determined by multiplying
the intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., IxlO"6 or 1E-6). An excess lifetime cancer risk of 1x10"
indicates that, as a plausible upper bound, an individual has a
one in one million chance of developing cancer as a result of
site-related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at a site.
28
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Potential concern for non-carcinogenic effects of a single
contaminant in a single medium is expressed as the hazard quotient
(HQ) (or the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the contaminant's
reference dose). By adding the HQs for all contaminants within a
medium or across all media to which a given population may
reasonably be exposed, the Hazard Index (HI) can be generated.
The HI provides a useful reference point for gauging the potential
significance of multiple contaminant exposures within a single
medium or across media.
The final step in the baseline risk assessment process is
risk characterization. In this step, toxicity criteria identified
are combined with exposure estimates to quantify potential
carcinogenic and non-carcinogenic effects associated with CPCs at
the Site. Potential risks associated with exposure pathways
evaluated under current and future land use of the Site are
presented in Table 21.
Potential carcinogenic risks are expressed as an increased
probability of developing cancer over a lifetime (i.e., excess
individual lifetime cancer risk). A 10"6 increased cancer risk is
the point of departure established in the NCP. In addition, the
NCP states that "for known or suspected carcinogens, acceptable
exposure levels are generally concentration levels that represent
an excess upper bound lifetime cancer risk to an individual of
between 1CT4 and 10'6."
Non-carcinogenic effects associated with exposure to a
chemical are quantified by dividing its Chronic Daily Intake (GDI)
by its reference dose (RfD). This ratio is called the hazard
quotient. If the hazard quotient exceeds unity (i.e., 1), then an
adverse health effect may occur. If the estimated hazard quotient
is less than unity, then adverse non-carcinogenic effects are
unlikely to occur.
The results of the risk assessment are summarized below.
29
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Table 21
Conclusions of the Publicker
Baseline Risk Assessment
Exposure Pathway
Potential
Carcinogenic
Bisk
Potential Non-
care inoaeni'c Bisk
(Hazard IndexMHl)
CoBBents
Current land Use Conditions
Direct contact Mith surface soil by children
playing at the Site
Direct contact Mith surface water by children
playing in the Delaware liver belai outfalls
fro* the Site.
Direct contact with sediments by children
playina in the Delaware River belon outfalls
froa the Site.
Inhalation of airborne dust by children
playing at the Site.
future Land use Conditions
Hypothetical construction workers directly
contacting blended surface and subsurface
soil while working at the Site.
Hypothetical construction workers inhaling
airborne dust fro* blended surface and
subsurface soil at the Site.
4E-5
2E-4
1E-4
2E-6
0.9
0.01
O.M
1E-6
2E-5
0.2
0.9
Potential carcinogenic risk within acceptable risk range
(i.e.. <10" ). Risks priaarily due to arsenic which was
found to be within background levels. Hazard index
below unity (1); therefore, non-carcinogenic effects
'unlikely to occur.
Potential carcinogenic risk exceeds HCP acceptable risk
range (i.e.. >1O~*)- Risk priaarily due to PAHs which
were found to be within background levels. Hazard index
below unity (1); therefore, non-carcinogenic effects
unlikely to occur.
Potential carcinogenic risk reaches HCP acceptable risk
range (i.e.. >10 >. Risk primarily due to arsenic
which was found to be within background levels. Hazard
index exceeds unity (1); therefore, non-carcinogenic
effects My occur fro* exposure to arsenic.
Potential carcinogenic risk within acceptable risk range
(i.e.. <10~*>. Risks priMrily due to ctiroauua which
was found to be within background levels. Hazard index
below unity (1); therefore, non-carcinogenic effects
unlikely to
Potential carcinogenic risk within acceptable risk range
(i.e.. <10~*>. Risk priaarily due to benzo(a)pyrene and
arsenic, which Mere found to be within background
levels, and 2.3.7.B-ICDD. Hazard index below unity (1);
therefore, non-carcinogenic effects unlikely to occur.
Potential carcinogenic risk within acceptable risk rar«e
(i.e.. <10~*>. Risks primarily due to chroaiust. which
was found to be Mi thin background levels. Hazard index
below unity (1); therefore, non-carcinogenic effects
unlikely to occur.
30
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Exposure Pathway
Potential
Carcinogenic
Bisk
Potential Non-
carcinogenic Risk
(Hazard IndexMHI)
Coaaents
future land Use Conditions fcont'dl
Hypothetical industrial park Markers using
ground water for. drinking and showering:
AlluviuB 2E-4
Irenton Crawl/Upper Sand K-5
Lower Sand 3E-5
Hypothetical industrial park workers inhaling
volatile organic ccapounds (VOCs) fro* ground
water being used in • cooling tower at the
Site:
AlluviuB
Trenton Gravel/upper Sand
Lower Sand 3E-5
Hypothetical children and adults directly 4E-5
contacting blended surface and subsurface
soil while playing at the Site.
Hypothetical children and adults inhaling 4E-7
airborne dust fro» blended surface and
subsurface soil while playing at the Site.
1
0.6
0.2
0.2
0.3
0.005
Potential carcinogenic risks all within acceptable risk
range, with the exception of the alluvia* ground water.
Hazard indices below unity (1); with the exception of
the alluvtua ground water. Arsenic was the primary CPC
in the altuviua but was found at siailar levels in
background. VOCs in lower sand mast I ikely due to
regional background. Similar background risks estimated
for use of ground water.
VOCs found only in lower sand. Potential carcinogenic
risk within the NCP acceptable risk range (i.e.. <10~*>
and hazard index below unity CD. VOCs anst likely due
to regional background.
Potential carcinogenic risk within acceptable risk range
(i.e.. <10 ) and hazard index below unity (1). Risk
primarily due to arsenic which was within background
levels.
Potential carcinogenic risk below the NCP point of
departure (i.e.. <10 ). and hazard index below unity
(1).
31
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Overall, the primary conclusions of Che baseline risk
assessment are as follows:
The majority of the total exposure was from multiple routes,-
the majority of the exposure pathways were below the upper
bound of the NCP acceptable risk range (i.e., <10"4) ,• and the
hazard indices were less than unity. The most significant
exposure routes were associated with exposure to surface
water and sediments.
The risks potentially associated with the Site (assuming all
CPCs are Site-related) are very similar to background risks
for soil-, air-, and ground water-related pathways for both
current and future land use exposure scenarios. With the
exception of the surface water, sediment, and total exposure
of construction workers to soil, this analysis indicates that
the Site does not significantly contribute to the overall
risk associated with land use in the area based on the
existing database for the Site. The primary CPCs detected at
the Site (i.e.., arsenic and carcinogenic PAHs) were found to
be within background levels in moat areas, and the VOCs
detected in the lower sand aquifer were not detected at the
Site.
• In the preceding RI summary, several "hot spot" locations
were identified in the surface and subsurface soils. When
the reasonable maximum exposure scenarios were developed, the
risk to human health from these sample locations was
determined to be within EPA's acceptable range.
ENVIRONMENTAL RISKS
The ecological risk assessment consists of the evaluation of
the potential terrestrial and aquatic ecological impacts due to
contaminant releases from the Site. The focus of the ecological
assessment.was on the terrestrial ecology at the Site and the
aquatic ecology of the Delaware River immediately adjacent to the
Site.
Terrestrial Risk Summary
Based on the comparison of calculated exposure rates
(combining food and water intake) and toxicity information, it
appears that iron, lead, mercury, total PAHs, and dibenzofuran may
present Site-wide ecological threats to terrestrial vertebrates.
Localized ecological threats to terrestrial vertebrates are
presented by chromium, copper, manganese, nickel, and vanadium in
the worst case scenario at "hot spot" locations (e.g., SS-28 with
1,220 mg/kg nickel; 58,600 mg/kg copper; and 3,790 mg/kg lead).
Potentially carcinogenic compounds were not evaluated since
carcinogenic effects are not ordinarily an ecological concern.
This is because most organisms are usually not long-lived enough
to develop cancer, although exposure to some highly carcinoaenic
compounds can result in tumors in 4 to 6 weeks.
32
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Insufficient daca are available to assess the potential
toxicity of certain organic compounds, pesticides, and several
metals on terrestrial plants. For other metals, the detected
levels of copper, lead, and zinc were frequently above levels
reported toxic to terrestrial plants. Also potentially toxic to
plants at one or a few locations are arsenic, beryllium, cadmium,
manganese, nickel, and vanadium. Hot spots were located at
sampling locations SS-7, SS-12, and SS-28, but potentially toxic
levels of copper and lead were found in numerous locations.
Aquatic Assessment of Risk
Contaminants in the water column offer two routes of
exposure; the first being direct intake through mouthparts and
gills, and the second through dermal absorption. Exposure to
river sediments may occur by two routes of exposure; the first
being direct and incidental ingestion during feeding, and the
second from dermal absorption. Sample station LIQ-10 was used to
assess aquatic exposure since it is known to be an active
stormwater discharge point from the Site. It was assumed that- the
concentrations of compounds detected at LIQ-10 are representative
of the runoff from the Site, and that aquatic organisms near the
outfall are exposed to the detected concentrations continuously.
These assumptions, however, are not entirely reasonable since the
effluent would immediately mix with the Delaware River, or at
least with that volume of water within the slip area.
Aquatic exposure was evaluated by. comparing the sediment
concentrations of contaminants in the LIQ-10 sample to those
detected in the background surface water and sediment samples.
The aquatic exposure drew upon the results of the benthic
macroinvertebrate investigation.
Considering the above summary of Site risks, actual or
threatened releases of hazardous substances from this Site, if not
addressed by implementing the response action selected in this
ROD, may present an imminent and substantial endangerment to
public health and welfare, or the environment.
7. Description of Alternatives
The table below summarizes the alternatives for the various
media at the Site. A more detailed description of each
alternative follows the table.
33
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Media
Surface Soil
Subsurface Soi I
Ground Water
Contaminated Electric •
Utilities
Contaminated
Stormwater Utilities
Miscellaneous
Alternative
No action
Containment
Treatment/Disposal
No action
Containment
Treatment
No action
Containment
No action
Removal/Treatment/0 i sposal
No action
Retnoval/Treatment/0 < sposal
No action
Removal/Treatment/Oisposal
Paving area identified as
being contaminated
Ex-situ soil wash ing/Off -site disposal
Paving area identified as
being contaminated
In-situ bioremediation
Well abandonment
Removal/Treatment/Off-site
disposal
Removal/Treatment/Of f -si te
disposal
Removal /Treatment/Off -site
disposal
Alternatives for the Site are presented below for each
individual medium. Alternatives are presented on a medium-by-
medium basis because it is feasible that a remedial response
selected for one medium (e.g., surface soil) will be independent
from that selected for another (e.g., ground water). To be
considered for more detailed evaluation, each medium-specific
alternative must be technically feasible and must not interfere
with alternatives applicable to other media. The medium-specific
alternatives described below will be combined to create a Site-
wide ROD.
Alternatives for Surface Soil
The surface soil is contaminated with PAHs and metals, which
pose a potential environmental risk to the Delaware River if the
soil were to. erode.
• The extent of contamination surrounding each sample location-
was estimated based on knowledge of Site history, Site
layout; and professional judgment.
• The remedial alternatives must be capable of addressing all
Site-related contaminants (i.e.,. the technology must treat
metals and organics) .
The alternatives are as follows:
Alternative Surface Soil - 1: No action
34
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Alternative Surface Soil - 2: Surface soil capping - Performing
additional sampling during the remedial design to confirm the
extent of contamination. Clearing and disposal of Site debris
from areas with exposed soil and elevated contaminant levels.
Installing an impermeable cap designed to meet Pennsylvania's
Solid Waste Landfill regulations. Annual monitoring of the
alluvial wells located along the northern Site border for organic
constituents.
Alternative Surface Soil - 3: Ex situ soil washing/off-site
disposal - Performing treatability study during the remedial
design to verify remedial technology and detailed delineation of
extent of contamination. Clearing and disposal of Site debris
from areas with exposed soil and elevated contaminant levels.
Removal of the top 1 foot of soil and physical separation of fine
material (expected to contain contamination). Chemically wash
fine material based on target contaminant identified for the area
excavated; metals, pH-based treatment; organics, surfactant-based
treatment. Replace excavated soil with clean fill. Provide off-
site disposal at a RCRA Treatment, Storage and Disposal (TSD)
facility for fine-grained soil material that fails the Toxicity
Characteristic Leaching Procedure (TCLP).
Alternatives for Subsurface Soil
The risk associated with subsurface soil is actually associated
with the potential for contamination of the alluvial aquifer
(surficial aquifer). The contaminants of concern are VOCs and
PAHs. The contaminants in the subsurface soils are residual and
are therefore not expected to migrate without flushing.
• The subsurface soil located between sample locations
identified to be contaminated is also contaminated.
The alternatives are as follows:
Alternative Subsurface Soil - 1: No action
Alternative Subsurface Soil - 2: Capping over contaminated
subsurface soils - Performing limited borehole sampling during
remedial design to define limits of impacted subsurface soils.
Clearing and disposal of Site debris from areas where cap will be
•installed. Installing an impermeable cap designed to meet
Pennsylvania's Solid Waste Landfill regulations. Monitoring 3
alluvial wells annually for 5 years (organic constituents only).
Alternative Subsurface Soil - 3: In situ bioremediation -
Performing treatability study during remedial design to verify
remedial technology and performing limited borehole sampling to
define limits of impacted subsurface soil. Clearing and disposal
of Site debris and asphalt to gain access needed to distribute
nutrients/biological culture. Introduce nutrients/culture through
a combination of surface application (deep plowing), boreholes,
35
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and shallow wells. Install a combination of subsurface gullies and
shallow boreholes to introduce and extract alluvial ground water.
Alternatives for Ground Water
The ground water has a potential to be contaminated via the
existing on-site wells. The wells can act as a conduit for Site
contaminants to impact the ground water. Ground water remediation
alternatives were not developed because the RI results did not
indicate that the Site was contributing to the ground water
contamination in the area.
• The wells that are considered for abandonment are the
fourteen wells that are located within the footprint of the
boundary, and any others which are located during the
remedial design.
The ground water alternatives are as follows:
Alternative Ground Water - 1: No action
Alternative Ground Water - 2: Abandonment of on-site wells - An
inventory of Site wells will be conducted during the remedial
design. Abandonment of all located wells by perforating the well
casings and grouting to the surface in accordance with state
regulations.
Alternatives for the Electric Utilities
The substations and conduits are contaminated with an oily waste
(predominantly organic in nature) believed to have originated from
"midnight dumping."
Electric Substations
• 23 substations are contaminated with a characteristic
hazardous liquid.
•• A total of approximately 28,000 gallons of contaminated
liquid exists in the substations.
• The heavy sludge in the substations can be vacuumed.
• Approximately 3,000 gallons of liquid waste/cleaning fluids
will be generated during decontamination procedures.
Electric Conduits Connecting Substations
• All conduits between substations that were identified to be
contaminated are themselves contaminated.
• The conduits contain approximately 6,000 gallons of
contaminated liquid.
36
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• Once steam-cleaned, the conduits that exist within a concrete
block can be left on Site.
• Approximately 3,000 gallons of liquid waste will be generated
during decontamination procedures.
The alternatives are as follows:
Electric Utilities - 1: No Action
Electric Utilities - 2: Perform during the remedial design
limited visual inspection of substations to confirm suspected
contamination and extent of migration. Remove all liquids from
substations using vacuum truck technology. Remove all
contaminated conduits by excavation where needed to facilitate
removal of liquids in conduits. Steam-clean substations and
conduits. Vacuum substations'a second time to remove cleaning
fluids and residual wastes removed during the cleaning process.
Incinerate all wastes removed from electrical substations and
conduits (contaminated and cleaning fluids) and dispose of ash at
an approved RCRA TSD facility. All decontaminated conduits would
be left on-Site.
Alternatives for the Stormwater Utilities
The trenches and subsurface storm drains are contaminated with
sediment that eroded from the Site's surface.
• Based on sediment and surface sampling results, as well as
visual observation, all trenches are contaminated with
hazardous substances.
• Assumed all subsurface storm drains extending from trenches
. with contaminated sediment are contaminated.
• Approximately 300 cubic feet of contaminated sediment exist
in approximately 1800 feet of trenches.
• Approximately 800 gallons of liquid waste will be generated
during the decontamination procedures.
• Approximately 1500 feet of subsurface storm sewers are
contaminated with approximately 150 cubic feet of sediment.
The alternatives are as follows:
Alternative Stormwater Utilities - 1: No action
Alternative Stormwater Utilities - 2: Removal/RCRA disposal of
fluids - Perform visual inspection during the remedial design to
identify sediment deposits in subsurface drains and drop inlets.
Remove all sediments from trenches using vacuum truck technology.
Steam-clean trenches and subsurface storm drains. Vacuum trenches
37
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and storm drain outfalls to remove cleaning fluids and residual
wastes removed during the cleaning process. Stabilize and dispose
of all removed sediment and decontamination fluids at an approved
RCRA facility. Sediment monitoring of the major outfall would be
performed annually for 5 years to confirm contaminated sediment
does not originate from the Site.
Alternatives for the Miscellaneous Wastes
The miscellaneous wastes consist of liquid stored in a
Hortonsphere, unknown liquid stored in three 55-gallon drums, 20
drums of wastes that were generated during the remedial
investigation, and residue remaining in tanks.
Hortonsphere
• Approximately 10,000 gallons of-characteristically hazardous
waste is located in 1 of the 20 Hortonspheres.
• Once the liquids are removed from the Hortonsphere and the
Hortonsphere is cleaned, no further action to the
Hortonsphere is required (i.e., removal or disposal).
• The remaining Hortonspheres are considered to be empty.
Drums of "Unknown" content
• Three 55 gallon drums of unknown content are currently stored
on the Site.
• The contents are characteristically hazardous.
Drums Containing Investigation-Generated Wastes
• 10 of the drums are assumed to contain characteristically
hazardous material.
• 10 of the drums are assumed to contain non-hazardous material
that can be landfilled at a solid waste facility.
Residue Remaining in Tanks
• Residual material that may be characteristically hazardous
remains in a small number of above ground tanks after the
tanks were pumped out during the removal action and OU #1.
The alternatives are as follows:
Alternative Miscellaneous Wastes - 1: No action
Alternative Miscellaneous Wastes - 2: Removal/RCRA disposal of
miscellaneous wastes -. Remove all liquid from Hortonsphere by
vacuum extraction technology and clean the Hortonsphere. Remove
all drums containing hazardous waste stored on Site. Incinerate
38
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and landfill all liquid from Che Hortonsphere and the drums of
hazardous waste and dispose of remaining ash at an approved RCRA
facility. Remove all remaining drums containing nonhazardous
investigation-generated wastes and dispose of them at a solid
waste landfill. Residual material remaining in tanks will be
characterized during pre-design activities. Residual material
containing hazardous substances will be removed, treated, and
disposed of off-site at a hazardous or residual waste facility as
appropriate.
8. Summary of Comparative Analysis of Alternatives
Each of the detailed alternatives described above are compared
by using the nine criteria which are described as follows:
Overall Protection of Human Health_and the Environment - This
criterion is used to assess how the alternative achieves and
maintains protection of human health and the environment.
Compliance With Applicable of Relevant and Appropriate
Requirements (ARARs) - This criterion is used to assess how the
alternative complies with chemical-specific, location-specific,
and action-specific federal and state ARARs. If a waiver of
ARARs is required, a justification of such is provided.
Long-term Effectiveness and Permanence - This criterion is used
to assess the long-term effectiveness of the alternative in
maintaining protection of human health and the environment once
response objectives have been met.
Reduction of Toxicitv. Mobility, or Volume through treatment -
This criterion is used to assess the anticipated performance of
each of the treatment technologies to be evaluated.
Short-term Effectiveness - This criterion is used to assess the
effectiveness of the alternative in protecting human health and
the environment during implementation of the alternative.
Implementability - This criterion is used to assess the
technical,, operational, and administrative feasibility of the
alternative and the availability of services and materials.
Cost - This criterion is used to assess the capital and
operational and maintenance (O&M) costs of each alternative. In
this case, the capital cost includes contingencies and present
worth cost is for 5 years of operation. •
State Acceptance - This criterion is used to assess the state's
technical and administrative preferences or concerns about the
alternative.
Community Acceptance - This criterion is used to assess the
community's preference or concerns about the alternative.
39
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The NCP requires chat EPA consider a "no action"'alternative fo3
each site to establish a baseline for comparison to alternatives
that do require action.
40
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CONTAMINATED SURFACE SOIL
CRITERIA
ALTERNATIVE Surface Soil-1
No Action
ALTERNATIVE Surface Soil-2
Surface Soil Capping
ALTERNATIVE Surface Soil-3
Ex-situ soil washing uith off-site
disposal of metals-enriched soils
OVERALL PROTECT IVENESS
Hunan Health
Environment
Hunan health cancer risk of 4X10~5
would remain for children coning into
direct contact uith the surface soil
at the Site.
Contaminant* in surface soils impose
terrestrial and aquatic risk.
Prevents human health cancer risk of
4X10 for children coming into
direct contact with the surface soil
at the Site.
Contaminants in surface soils impose
terrestrial and aquatic-risk.
Prevents human health cancer risk of
4X10 for children coming into direct
contact with the surface soil at the
Site.
Contaminants in surface soils impose
terrestrial and aquatic risk.
COMPLIANCE WITH ARARs
Not applicable.
There are no chemical- or location-
specific ARARs for contaminants.
ARARs restricting the generation of
dust/volatile emissions are
applicable. PA residual waste
regulations would be relevant and
appropriate.
There are no chenical- or location-
specific ARARs for contaminants
remediation for the Site. ARARs
restricting the generation of dust/
volatile emissions are applicable.
Appendix 6.2 of the PA Land Recycling
Program Technical Guidance Manual
(7/95), on contaminated soils is a
TBC.
LONG TERN EFFECT AND
PERMANENCE
Not applicable..
Reduces surface soil migration and
minimizes residual risk. High
reliability. Five year review
required to inspect the integrity
and effectiveness of cap.
Reduces surface soil migration and
minimizes residual risk. High
reliability. No five year review
required.
REDUCTION OF TOXICITY,
MOBILITY, OR VOLUME
THROUGH TREATMENT
Hot applicable.
Reduction of contaminant mobility
but no change in volume or toxicity.
Process reversibility. Does not
satisfy statutory preference for
treatment as a principle element.
Soil washing and stabilization of
contaminant enriched fine grain soil.
65X to 9SX of the contaminants uill be
removed from the Site surface soil.
Decrease in contaminant mobility and
volume but toxicity will increase in
wash waste stream. Process
irreversibility. Process will
significantly reduce the volume of
contaminant, resulting in less volume
of material which oust be disposed.
Satisfies statutory preference for
treatment as a principle element.
41
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CONTAMINATED SURFACE SOIL
CRITERIA
ALTERNATIVE Surface Soil-1
No Action
ALTERNATIVE Surface Soil-2
Surface Soil Capping
ALTERNATIVE Surface Soil-3
Ex-situ soil washing with off-site
disposal of metals-enriched soils
SHORT TERN EFFECTIVENESS
Not applicable.
Slight potential for nigration of
contaainants to community by way of
dust or volatile emissions. Workers
will be placed at a low risk during
capping process. Protocol to be
used during removal relatively
standardized in profession. Limited
potential for increase in existing
environmental risk from erosion
during installation. Implementation
in relatively short tine frame (less
than 6 months).
Slight increase in risk during
remediation. Potential for migration
of contaminants to community by way of
dust or volatile emissions. Workers
will be placed at a low risk during
washing process. Protocol to be used
during removal relatively standardized
in profession. Limited potential for
increase in existing environmental
risk from erosion during the process.
Implementation in relatively short
tine frame (less than 6 months).
IHPLENENTABILITY
Not applicable
High level of technical feasibility,
uses proven technology. Uncertainty
exists as to the physical dimensions
of cap and its nature; State
acceptance of design required.
Materials and services are readily
available.
High level of technical feasibility,
uses proven technology. Uncertainty
exists as to volume reduction realized
from process and disposal costs.
Materials and services are readily
available.
COST
Capital Cost
First Year Annual OIN Cost
Present Worth Cost (PWC)
None
None
Hone
$1.113,000
$11,000
(1,166,000
$2.047.000
$0
$2,047,000
42
-------
HED1A GROUP - CONTAMINATED SUBSURFACE SOIL
CRITERIA
ALTERNATIVE Subsurface Soil-1
Mo Action
ALTERNATIVE Subsurface Soil-2
Capping over Contaminated Subsurface
Soils
ALTERNATIVE Subsurface Soil-3
In-situ Bioremediation
OVERALL PROTECT IVENESS
Hunan Health
Environment
Human health cancer risk of «X10~5
would remain for children and
adults directly contacting blended
surface and subsurface soil while
playing at the Site.
Environmental risk associated with
subsurface soils not quantified.
Prevents human health cancer risk of.
4X10 for children and adults directly
contacting blended surface and
subsurface soil while playing at the
Site.
Environmental risk associated with
subsurface soils not quantified.
Removes human health cancer risk of
4X10 for children and adults directly
contacting blended surface and
subsurface soil while playing at the
Site.
Environmental risk associated with
subsurface soils not quantified.
COMPLIANCE WITH ARARs
Not applicable.
There are no chemical-, location-
specific ARARs for soils. PA residual
waste regulations would be relevant and
appropriate.
There are no chemical-, location- or
action-specific ARARs for soil
remediation for the Site. Appendix B.2
of the PA Land Recycl ing Program
Technical Guidance Manual (7/9S) on
contaminated soils is a TBC.
LONG TERM EfFECT AND
PERMANENCE
Not applicable.
Reduces potential for subsurface soil
exposure during future Site activities.
Moderate reliability. Review required
to inspect the integrity and
effectiveness of the cap.
Long term risk reduced to acceptable
levels. High reliability. No five year
review required.
REDUCTION OF TOX1CITT,
MOBILITY, OR VOLUME
THROUGH TREATMENT
Not applicable.
Reduction of contaminant nobility but
no change in volume or toxicity.
Process reversibility. Does not
satisfy statutory preference for
treatment as • principle element.
Bioremediation. Organics wilt be
destroyed through natural processes.
Decrease in contaminant volume.
mobility, and toxicity.
Process irreversibility. Potential for
creating more residuals with higher
toxicity than original materials is
small. Assumes no external treatment of
cycled ground water is required.
Satisfies statutory preference for
treatment as a principle element.
SHORT TERM
EFFECTIVENESS
Not applicable.
Slight potential for nigration of
contaminants to community by way of
dust or volatile emissions, workers
will be placed at a low risk during
capping process. Protocol to be used
during removal relatively standardized
in profession.
Slight increase in risk to conmunity
during remediation. Potential for
migration of contaminants during
remediation. Workers will be placed at
a low risk during installation and
implementation of bioremediation
process. Protocol to be used during
removal relatively standardized in
profession. ^^
43
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MEDIA GROUP - CONTAMINATED SUBSURFACE SOIL
CRITERIA
ALTERNATIVE Subsurface Soil-1
No Action
ALTERNATIVE Subsurface Soil-3
Capping over Contaminated Subsurface
Soils
ALTERNATIVE Subsurface Soil-J
In-situ Bioremediation
SHORT TERM
EFFECTIVENESS
(CONTINUED)
Not applicable.
Limited potential for increase in
existing environmental risk from
erosion during paving activities.
Implementation in relatively short time
frane (less than 12 nonths).
Limited potential for increase in
existing environmental risk injecting
and extracting ground water from the
alluvial aquifer. Implementation period
unknown; fulfilling remedial objective
may require years.
IMPLEMENTABILITV
Not applicable.
High level of feasibility, uses proven
technology, uncertainty exists as to
the physical dimensions of cap and its
nature; State acceptance of design
required. Services are readily
available.
Moderate level of feasibility. Uses
proven technology but Site-specific
performance not quantified until
tTestability test. Services are readily
available.
COST
Capital Cost
First Year Annual O&M
Cost
Present Worth Cost
(PUC)
None.
None.
None.
(6,032.000
$11,000
$6,082,000
$7.155,000
»0
$7.155.000
-------
MEDIA GROUP - GROUND WATER
CRITERIA
OVERALL PROTECT IVENESS
Hunan Health and
Environment
COMPLIANCE WITH ARARs
LONG TERN EFFECT AND PERMANENCE
REDUCTION OF TOXICITY. NOBILITY,
OR VOLUME THROUGH TREATMENT
SHORT TERN EFFECTIVENESS
IMPLEMENTABILITY
COST
Capital Cost
First Year Annual DIM Cost
Present Worth Cost
ALTERNATIVE Ground
No Action
Water- 1
Site-related human and environmental health risk
Here not quantified for the potential pathway
provided by on-site wells.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not appl i cable
None
None
None
ALTERNATIVE Ground Water-2
Abandonment of On-site Wells
Site-related human and environmental health risk were not
quantified for the potential pathway provided by on-site wells.
No chemical- or location-specific ARARs because the Site is not
the source of contaminant. Well abandonment must be performed
according to existing state ARARs.
Decreases the potential for contamination of the Lower Sand
aquifer. Controls have high reliability.
Reduction of nobility anticipated but not quantified. Volume or
toxicity of contaminants not quantified.
Process irreversibility. Less than 500 gallons of slightly
contaminated ground water removed from well casings.
Precedence exists for discharging of purge water into Delaware
River. Satisfies statutory preference for treatment as a
principal element.
No significant increase in risk to community. Workers will be
placed at a low risk during well abandonment process. Protocol
to be used during removal relatively standardized in
profession. Limited potential for increase during discharge of
ground water purged from on-site wells. Implementation in
relatively short time frame (less than 1 month).
High level of feasibility; uses proven technology. Operation
is a standard and predictable process. Services are readily
available.
(84.000
»0
$84.000
45
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MEDIA GROUP - CONTAMINATED ELECTRIC UTILITIES
CRITERIA
OVERALL PROTECT IVENESS
Hunan Health
Environment
COMPLIANCE WITH ARARs
LONG TERM EFFECT AND PERMANENCE
REDUCTION IN TOX1CITY, MOBILITY. OR
VOLUME
SHORT TERM EFFECTIVENESS
IMPLEMENTABILITY
COST
Capital Cost
First Year Annual O&N Cost
Present Worth Cost (PUC)
ALTERNATIVE Electric Utilities-1
No Action
Hunan health risk not calculated for contaminants.
Permits eventual contamination of alluvial aquifer.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
None'
None
None
ALTERNATIVE Electric Utilities-2
Removal and RCRA Disposal of Contaminants in Electric
Utilities
Human health risk not calculated for contaminants.
Prevents eventual contamination of alluvial aquifer.
There are no chemical- or location-specific ARARs for
contaminants at the Site. Appendix B.2 of the PA land
Recycling Program Technical Guidance Manual (7/95) on
contaminated soils is a TBC.
Removes exposure potential through ground water pathway.
High reliability. No review required since substations
Mill be sealed or removed to prevent additional illegal
dumping.
Almost complete reduction of wastes. Irreversible
destruction. Residual after incineration less than 99.9
percent by weight. Satisfies statutory preference for
treatment as a principle element.
No significant increase in risk to community. Workers
will be placed at a low risk during entry of confined
space. Protocol to be used during removal relatively
standardized in profession. No significant increase in '
risk to environment. Implementation in relatively short
time frame (less than 2 months).
High level of feasibility, uses proven technology.
Permitting waste transportation is a regular and
predictable process. Services are readily available.
(370,000
$0
$370,000
46
-------
HED1A GROUP - STORM WATER UTILITIES
CRITERIA
OVERALL PROTECT IVENESS
Hunan Health
Environment
COMPLIANCE WITH ARAKS
LONG TERN EFFECT AND PERMANENCE
REDUCTION OF TOXICITY, MOBILITY.
OR VOLUME THROUGH TREATMENT
SHORT TERN EFFECTIVENESS
IMPLEMENTABILITY
COST
Capital Cost
First Year Annual O&M Cost
Present Worth Cost (PUC)
ALTERNATIVE Stona Water Utilities-!
No Action
Hunan health cancer risk of 1X10 for direct contact
with on- site surface water and a hazard index of 8
for direct contact with sediments by children playing
in the trenches and manholes on the Site would
remain.
Permits continued degradation of Delaware River
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
None
None
None
ALTERNATIVE Storm Water Utilities 2
Removal and RCRA Disposal of Sediments in Stormuater Utilities
Eliminates the human health cancer risk of 1X10 for direct
contact with on- site surface water and a hazard index of 8 tor
direct contact with sediments by children playing in the trencher
and manholes on the Site.
Prevents degradation of the Delaware River.
There are no chemical-, location- or action-specific ARARs for
sediment remediation in utilities. Appendix B.2 of the PA Land
Recycling Program Technical Guidance Manual (7/95) on
contaminated soils is a TBC.
Reduces sediment contaminant levels and minimizes residual risk.
High reliability. Five year review required to confirm that neu
contaminated sediment does not replace that removed from
stormwater utilities.
Reduction of mobility and toxic ity of contaminants. Process
irreversibility. Volume of treated sediment appro*. 20% more
than original sediment due to solidification agents used to fix
sediment metals. Satisfies statutory preference for treatment as
a principle element.
Ho significant increase in risk to community. Workers will be
placed at a low risk during removal process. Protocol to be used
during removal relatively standardized in profession. Limited
potential for increase in existing .environmental risk during
flushing of sewers. Short time frame (less than 2 months).
High level of feasibility, uses proven technology. Permitting
waste transportation is a regular and predictable process.
Services are readily available.
*71,000
$5,600
S9/.000
47
-------
MEDIA GROUP - MISCELLANEOUS WASTES
CRITERIA
OVERALL PROTECT IVENESS
Hunan Health
Environment
COMPLIANCE WITH ARARs
LONG TERM EFFECT AND PERMANENCE
REDUCTION OF TOXICITY, MOBILITY.
OR VOLUME THROUGH TREATMENT
SHORT TERM EFFECTIVENESS
1MPLEMENTABILITV
COST
Capital Cost
First Year Annual OSM Cost
Present Worth Cost (PUC)
ALTERNATIVE Miscellaneous Wastes- 1
No Action
Human health cancer risk not calculated.
Permits eventual degradation of environment when
miscellaneous wastes begin leaking.
Not applicable.
Not applicable.
Not applicable.
i
Not applicable.
Not applicable.
None
None
None
ALTERNATIVE Miscellaneous Wastes-2
Removal and Destruction of Miscellaneous Wastes
Human health cancer risk not calculated.
Protective of environment.
There are no chemical- or location- specific ARARs for
miscellaneous wastes identified based on TAL/TCL list of
contaminants.
Significantly reduces long term risk imposed by wastes. High
reliability. No five year review required.
Approximately 10,700 (10.000 gallons, 3 55-gallon drums of
unknown and 10 55-gallon drums of fluids) gallons of fluid
wastes destroyed and ten 55 gallon drums of solids treated.
Almost complete reduction in mobility, toxicity and volume for
fluids. Reduction of mobility and toxicity of solids with
approximately SOX decrease in volume. Process irreversibil ity.
Approximately 300 gallons of ash estimated to remain. Satisfies
statutory preference for treatment as a principle element.
No significant increase in risk to community. Workers will be
placed at a low risk during removal process. Protocol to be
used during removal relatively standardized in profession.
Limited potential for increase in existing environmental risk
during removal process. Implementation in relatively short time
frame (less than 2 months).
High level of feasibility, uses proven technology. Permitting
waste transportation is a regular and predictable process.
Services are readily available.
tai.ooo
to
$81,000
-------
9. Selected Remedy and Performance Standards
General Description of the Selected Remedy-
Based upon consideration of the requirements of CERCLA, the
detailed analysis of the alternatives using the nine criteria, EPA
has determined that the following combination of alternatives is
the most appropriate remedy for Operable Unit #3 of the Publicker
Industries Site:
a. Abandonment of on-Site wells;
b. Removal, treatment, and off-Site disposal of liquids and
sediments in contaminated electric utilities;
c. Removal, treatment, and off-Site disposal of liquids and
sediments in contaminated stormwater trenches and
utilities;
d. Removal and off-Site disposal of miscellaneous wastes.
Additionally, should excavation be conducted by current or
future owners or occupants where such activities are not
specifically a part of the above selected remedy, those excavation
activities shall be monitored.
Each component of the Selected Remedy and the associated
Performance Standards are described below.
EPA has selected the no action alternative for surface and
subsurface soils, since the reasonable maximum exposure scenarios
developed for these media indicate the risks to be within EPA's
acceptable range.
Because this remedy will result in hazardous substances
remaining on Site above health-based levels, a review will be
conducted within five years after commencement of remedial action
to ensure that the remedy continues to provide adequate protection
of human health and the environment.
Description and Performance Standards of Each. Component of the
Selected Remedy
a. Abandonment of On-Site Wells.
During pre-design, an inventory shall be performed to locate
all remaining wells. On-Site wells which shall be abandoned shall
include the fourteen wells used for sampling as well as any other
wells that are located during pre-design. Wells shall be
abandoned in accordance with the Pennsylvania Water Well Drillers
Act, PA Act 610, and its implementing regulations, 25 PA Code .
Chapter 107, which regulate the abandonment of ground water wells.
Actual well abandonment procedures shall be in accordance with EPA
Handbook of Suggested Practices for the Design and Installation of
Ground-Water Monitoring Wells, to minimize any potential migration
of contaminants to the ground water.
49
-------
b. Removal, Treatment, and Off-Site Disposal of Materials in
Contaminated Electric Utilities
Materials containing contaminants at unacceptable levels
(levels posing cancer risks greater than 1 x 10"4 for carcinogens
and hazard indices greater than one for non-carcinogens), shall be
removed from subsurface electric substations, and the substations
shall be decontaminated. The substations shall be either sealed or
removed to prevent recontamination. Contaminated electric
conduits between substations shall be identified, excavated and
cleaned until there is no visible contamination. Contaminated
materials' shall be transported off-Site to a permitted incinerator
and incinerated, and the remaining ash disposed of at an approved
RCRA Treatment, Storage and Disposal (TSD) facility.
c. Removal, Treatment, and Off-Site. Disposal of Materials in
Contaminated Stormwater Trenches and Utilities
Standing water shall be drained from contaminated surface
trenches. This water shall be analyzed, treated and discharged
off-site in accordance with the Clean Water Act and implementing
regulations, the Pennsylvania Clean Streams Law and implementing
regulations, and City of Philadelphia regulations. The materials
containing contaminants at unacceptable levels (levels posing
cancer- risks greater than 1 x 10"4 for carcinogens and hazard
indices greater than one for non-carcinogens), shall be removed
from the trenches. Subsurface stormwater utilities with
contaminants at unacceptable levels shall be cleaned and flushed
until there is no visible contamination, with the contaminated
materials contained and collected. The sewers shall be either
sealed or removed to prevent recontamination. The contaminated
materials shall be transported to a RCRA TSD facility for
stabilization and disposal. Contaminated sediment shall not
discharge from the Site to the river. Major outfalls will be
monitored annually for five years as appropriate to ensure this.
d. Removal and Off-Site Disposal of Miscellaneous Wastes
The miscellaneous wastes consist of liquid stored in a
Hortonsphere, liquid stored in 55-gallon drums, wastes that were
generated, during the investigations, and residue remaining in
tanks. The miscellaneous wastes shall be analyzed and segregated
into hazardous and non-hazardous wastes as defined under RCRA. If
the waste is hazardous, it shall be transported off-site,
incinerated at a permitted facility and the ashes stabilized and'
landfilled. Non-hazardous drummed wastes as defined under RCRA
shall be landfilled.
Appropriate Monitoring and Deed Notice
Although EPA has adequately and reasonably characterized
hazards at the Site and assessed the potential risk to workers and
others, the possibility exists due to the complex nature of the
Site,'that contamination above acceptable risk levels may remain.
50
-------
Contamination above acceptable risk levels was not identified
during the RI. However, it is possible that contamination not
previously identified by EPA may exist at the Site. As a
precautionary measure, monitoring shall be conducted during any
future excavation activities which may be undertaken independently
by Site owners or occupants to minimize unexpected worker exposure
and to provide opportunities to minimize release of contaminants.
Monitoring shall be conducted in accordance with appropriate
sections of the Occupational Safety and Health Act (OSHA)
regulations at 29 CFR 1910.120. Deed notices of the above
requirement shall be placed on each deed to provide notice to
future owners prior to any excavation that may occur at the Site.
The above requirement serves specifically to provide notice of
unknowns at the Site since known hazardous conditions are
addressed through the active controls addressed previously in this
section. EPA has not conducted an evaluation of this
institutional controls requirement pursuant to the nine criteria
specified in 40 CFR Part 300, because this requirement is not
being considered or selected in lieu of another alternative;
instead it addresses possible future actions independent of EPA's
required remedy to detect currently unidentified contamination, if
any.
10. Statutory Determinations
Protection of Human Health and the Environment
The selected remedy provides adequate protection of human
health and the environment through removal, treatment and off-site
disposal of contaminants, and engineering controls. ' By removal,
treatment and disposal of the contaminated sediment,
investigation-derived wastes and miscellaneous wastes, the human
health and environmental risks are reduced to acceptable levels.
EPA considers acceptable exposure levels for human health to be
within the 10"4 to 10'6 range for carcinogens and acceptable levels
for non-carcinogens to have hazard indices of less than one.
Abandonment of wells is a precautionary measure to eliminate any
pathway from the Site, to the underlying aquifers. Additionally,
implementation of the selected remedy will not pose unacceptable
short-term risks or cross-media impacts.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
There are few chemical-, location- or action-specific ARARs
for the selected remedy. Standards for removal and treatment of
sediments in electric utilities and stormwater trenches and
utilities have not been promulgated. Well abandonment must
conform with existing Pennsylvania regulations.
51
-------
Chemical-Specific ARARs
• There are no chemical-specific ARARs for soil remediation or
for the remediation of sediment in trenches or utilities for
the chemicals detected at the Site.
Location-Specific ARARs
• There are no location-specific ARARs for soil remediation or
for the remediation of sediment in trenches or utilities.
Action-Specific ARARs
• Any earth moving activities associated with the selected
remedy will comply with the Pennsylvania Erosion Control
Regulations, 25 Pennsylvania Code §§ 102.1 through 102.5,
102.11 through 102.13, and 102.21 through 102.24, which
regulate erosion and sedimentation control. These
regulations are applicable to earth moving activities
associated with the selected remedy which create accelerated
erosion or the danger of accelerated erosion and which
require planning and implementation of effective soil
conservation measures.
• 40 C.F.R. Part 264, Subpart I, and Pennsylvania Code §§
264.10 through 264.56 and 264.171 through 264.177 (in the
event that hazardous waste generated as part of the remedy is
managed in containers) regulate the use and management of
containers of hazardous wastes during the cleanup.
• 25 Pennsylvania Code Chapter 107 and Pennsylvania Act 610
(Water Well Drillers Act) regulate the abandonment of ground
water wells.
Criteria, Advisories, or Guidance To Be Considered (TBCs)
• Contained-in Policy (EPA OSWER Directive 9347.3-05FS) states
that environmental media mixed with a RCRA listed hazardous
waste must, upon collection, be managed as if it were a
hazardous waste until it no longer contains the listed
hazardous waste.
• Methods for Evaluating the Attainment of Cleanup Standards -
Volume 1 (Soils and Solid Media). EPA 230/02-89-042, provides
statistical methods to confirm compliance with soil/solid
media clean-up levels.
• EPA Handbook of Suggested Practices for the Design and
Installation of Ground-Water Monitoring Wells, EPA/600/4-
89/043, February 1990.
Appendix B.2 of the PADEP Land Recycling Program Technical
Guidance Manual, July 1995, "Cleanup Standards for
Contaminated Soils".
52
-------
Cost -Effectiveness
The selected remedy affords a remedy where the overall
effectiveness is proportionate to the costs.
Utilization of Permanent Solutions and Alternative_Treatment (or
Resource Recovery) Technologies to the Maximum Extent Practicable
The selected remedy for Operable Unit #3 utilizes permanent
solutions to the maximum extent practicable while providing the
best balance among the other evaluation criteria. It achieves the
best balance of tradeoffs with respect to the primary balancing
criteria of long-term effectiveness and permanence; reduction of
toxicity, mobility, and volume through treatment; short-term
effectiveness; implementability; and cost; while also considering
State and community acceptance.
The selected remedy provides a high degree of long- terra
effectiveness and permanence as the removal, treatment and off-
site disposal of the contaminated sediments and miscellaneous
wastes would be permanent and irreversible. The variety of
contaminants present on-Site, and the relatively small quantity of
the contaminants cause on-site treatment technologies to be
impracticable and not cost-effective. The selected remedy is
easily implementable, with a relatively short time frame needed
for design development. There is minimal risk to the community
during the implementation of the selected remedy, and the slight
risks to the environment can be reduced by implementing standard
procedures, such as erosion and runoff controls.
Preference for Treatment as a Principal Element
This remedy satisfies the, statutory preference for treatment.
11 • ^'?<'M"fl?Tl*n tion of Sicmif ic*T>t Cl
The Proposed Plan was released for public comment on June 2,
1995. The components of the preferred alternative were:
abandonment of on-site wells; disposal of liquids and sediments in
contaminated electric and stormwater trenches and utilities;
removal and disposal of miscellaneous wastes; and deed notices.
EPA reviewed all written and verbal comments submitted during the
public comment period. After consideration of these comments, it
was decided that several minor clarifications and additions should
be made to the original preferred alternative.
Comments received recommended that all ground water wells be
appropriately abandoned, including the ones that had been
destroyed or were not able to be located during the RI . EPA
agrees that wells that can be located during a pre-design
inventory should be included in the well abandonment portion of
the remedy.
53
-------
EPA also agrees that tanks chat contain residues will be
characterized further during a pre-design study. This
characterization shall include determining quantities remaining as
well as presence of hazardous substances. These hazardous
miscellaneous wastes will be removed, treated and disposed of off-
Site at a RCRA TSP.
54
-------
INDUSTRIAL
AREA
PHILADELPHIA
. NAVAL
YARD
EL*****
LEGENDt
i
1
RIVS*
1 RESIDENTIAL AREA
1 ----- 1
.5 MILES
=K=
SCALE
1 MILE
TETRA TECH, INC.
FIGURE 1
GENERAL LOCATION MAP
PUBLICKER SITE
PHILADELPHIA. PENNSYLVANIA
-------
I
_1
ASHLAND CHEMICAL SITE
o
7
j~
1
r
zz:z3
X3CXXX)lQ8°[
a
TCN 4209
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REV.
JAN/95
>
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<
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o
TE TRA TECH, INC.
FIGURE 2
SITE MAP
PUBLICKER SITE
PHILADELPHIA, PENNSYLVANIA
-------
KN 4209
Rl .REPORI
REV. t
JAN/95
ASHLAND CHEMCAL WTi
Q.QQ.Qk
••t MNL VAPMI SAMPLE LOCATION
NOT WOT AREA*
TOTAL IW VOLATtES > W uo/L
FIGURE 3
SOIL GAS SURVEY RESULTS
PUBLICKER SITE
PHILADELPHIA. PENNSYLVANIA
-------
I
r\>
O
AM&AMD CNEMKAL SITE
IJDDDGQ
QQQQQJra
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TCN 4209
Rl REPORT
REV. 10
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2
>
MM I Moita •«rf*c* San
LoMthM
•OTE. AM ••!••• •>• TK
AM writ* M« «t/k«
r£7/?>l 7FC//. MfC.
FIGURE 4
SURFACE SOIL RESULTS
DIOKIN/FURAN COMPOUNDS
PUBLICKER SITE
PHILADELPHIA. PENNSYLVANIA
-------
ARIA Q|l INVIS710ATION
= K-i—iy- \ i\
2 , f( , \: ^ ^~!'-.
< ' U-.—-=^ cconri!
GENERAL LOCATION MAP
OO!
OQ!
r o 0?
TCH 4209
"I REPORT
REV. ,Q
40-401 CHRYSOTILE
10-301 AMOSITE
LEGEND*
"NDT-0 ASBESTOS SAMPLE LOCATION/RESULTS
r~~! BUILDINGS DESTROYED BY FIRE
70'
._=&.
SCALE
140'
TETRA TECH. INC.
FIGURE 5
ASH RESULTS - ASBESTOS
PUBL2CXER SITE
PHILADELPHIA. PENNSYLVANIA
-------
ASHLAND CHEMICAL SITE
v 0
.... I 00| I
111 "5 r- ; ^
'I L-r I : .
NOTE. WELL
NOT TO
noun
LOCATION
i
— i i
I I noo QO r^=£
|Q^-b .ngfi
I r-J I
u I.I
8HAU.OV WELLS
DEEP WELLS
OFF-SITE WELLS
JCN 4209
I REPORT
«£». IQ
JUN/93
<
7E77M TEC//, MfC.
FIGURE 6
GROUND-WATER SAMPLE LOCATION NAP
PUBLICKER SITE
PHILADELPHIA, PENNSYLVANIA
-------
TCN 4209
Rl REPORT
REV. 10
JUN/93
ASHLAND CHEMICAL MTI
ooq
QQpQQj (
—- aAWTAHV &EWEH
• CANT AMY MANHOLE
TETRATECH, INC
FIGURE 7
SANITARY SEWER LINES
PUBLICKER SITE
PHILADELPHIA, PENNSYLVANIA
-------
ASHLAND CHEMCAL SIT!
TCH 4209
Rl REPORT
REV. 10
JUN/93
<
i
LEOENO.
—— BELOW OftADE STORM SEWER
— OPEN TRENCH STORM SEWER
• STORM SEWEM MANHOLE
226'
••tti
SCALE
450'
TETRA TECH. INC.
FIGURE 8
STORM-MATER SEUER LINES
PUBLICKER SITE
PHILADELPHIA, PENNSYLVANIA
-------
ASW.AND CHEMICAL SITI
noa p
D'ODDl a
QQQQQJ ro
a
TCN 4209
Rl REPORT
REV. 10
JUN/93
1
...... UNDINMOUNO KUCTHIC LINC8
• ELICTMCAL MAMMOUE
TETRA TECH. INC.
FIGURE 9
UNDERGROUND ELECTRIC LINES
PUBLICKER SITE
PHILADELPHIA, PENNSYLVANIA
-------
r
\
I
1
.__
MM
FTTf.-
i
. ioc
1. I T- |- I
ti '•}!' ic i
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i
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i
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r
•
\— -
i | ' TCN 4209
1 ) RI REPORT
, 1 || ' ' 1 \ RE«- '0
tlii'i ASHLAND CHEMICAL SITE 1 "H. 1 ) JUN/93
_.. '- - . I- U ' Jl
- •-- ..,-...;-, , |M- -,i 1 X — ,
n il f K i .) i ( .<• jfl ilt ''f-: -. !i
jfl1 "( „ -::j |j^ "iu |";";'1- ^ !
^i^P-u- n i- " "4*. - -
^^ ^/ ^Ks^_^X I || II ) /"' \ S' "~ "°-^J$*\
'> x-v ^-v-^^j ^" •.S.ori — , \ M 1( ) ! r , .
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• •' QO oi 1 1 ' i \ \{ *\/ \t \ i ' f •' ^
1 1 ° ° 1 \««r>
bACKM ' AVEHUE ""* \1 I"U" ""* IMfta»r«'oun«11
_ _r*1'1*^ n»ei«» j |._ 8t»«m 1 In* fundcigfoundl
1,-- - -^_ "^x J "~"— ~~_ Mol««»»« lundcrgroundl
" r- !- " - - \— .. — ..— Mall.d u«th lunknownl
WALT WHITMAN •-<•— — •— Spent Main lunknownl
,,; j^ TETRA TECH, INC.
I '
', FIGURE 10
i SUSPECTED SUBSURFACE PROCESS,
. 1 ! WATER. AND STEAM LINES
o 99«i' *w PUBLICKER SITE
— ' ** . PHILADELPHIA, PENNSYLVANIA
GALE
-------
ASHLAND CHEMICAL SITE
.
• LIO-11
TCN 4209
Rl REPORT
REV. 10
JUN/93
It
U-i
X
M-„>;,: i I-M
II -:
I ( )l
i
I I
A8EO-OB
"l III |""«J
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E
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1/8.E
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M'..'!
i .
r'
!! ASED-12
id
PACKBH
iWEMoe "" N<| L
ULiWOT
"O
i
WALT WHITMAN
BRIOOC
450'
. ..1:1!
5
i
~ ? I)
./ .. n
(I
A SEDIMENT SAMPLE LOCATION
\ • LK1UIO SAMPLE LOCATION
x\(Al LIQtND/SEOIMENT SAMPLE LOCATION
TETRA TECH, INC.
FIGURE 11
LIQUID AND SEDIMENT SAMPLE
LOCATION MAP
PUBLICKER SITE
PHILADELPHIA, PENNSYLVANIA
-------
IB*.. ,a
»•• -4
It4j>*tf
ASHLAND CHEMICAL SITE
H H
: ,11
n
] ..J
It
II
L
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" nf.y, ti
01 ; i
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i : i
ll
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M • MHC-tO
HC-0« |
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--'•
• II \
III
WALT WHITMAN
4SO'
if; I
s"-1 I
I
I.
TCN 4Z09
RI REPORT
\ REV. 10
' JUN/93
\ £
1 i
tc
LEMNQi
• WASTE SAMPLE STATION LOCATION
TETRATECH^INC.
FIGURE 12
HIGH CONCENTRATION SAMPLE
LOCATION MAP
PUBLICKER SITE
PHILADELPHIA. PENNSYLVANIA
-------
< j
< D
•JI oTO o
i I ool
I ool., I
a:
ItCfHD:
-— COMIMKUICD KU)W CIAM SIOItH StWCD
CONUUM*KO OKU IKHCH SIMM MWCH
COHIUMUKD SIMM Km* MMMOU
on or pwuDCLfM* uwn
nurmaot TO MLAWAM ma.»
® uouo HMO siuuan sumi
m MKH coMcrxnurxw suvus
our stunt
we.
r/cu/?f 13
CONTAHIHAKD STORUWATCR
UTILITIES LOCATION UAP
PUBUCKCR SITE
PHILADELPHIA, PENNSYLVANIA
; m m z
;-< o 5
-------
ASHUNO CHEMICAL SITE
UUUU
OOOOO
COHTAMINAICO UNOCRCftOUND
cucimc COMMNIS
• CONIAMMAKO OCCIMCM.
UAMHOUI
© UOtMO MID SOMHfMt SAHPif (OC4ROMS
coucCMitunoH
• UOUttHI OHtr fAUflf IOCAHOMS
VnmiAM BWOCt
TETRA TECH, INC.
FIGURE 14
COHTAUIHATED fLKTK/C
UTILITIES LOCATION HAP
n/BUCKCR SITE
PHILADELPHIA. PENNSYLVANIA
-------
•eCOL-12
rCN 12Q9
RI REPORT
S£V. *0
JUN/93
LgQEMO.
• ECOLOGICAL 3AUTLC LOCATION
0 170*
•=
SCALE
340'
7E7/M 7ECM WC.
FIGURE 15
ECOLOGICAL SAMPLE STATIONS
PUBLICKER SITE
PHILADELPHIA. PENNSYLVANIA
-------
lOOi ~ r"~"
»^—' v—xi y—. ^-» ,-v ^ VA.I
bDD 8°
ICN
Rl KtPORI
RtV. Ill
JAN/95
RIVER SAMPLE LOCATIONS
TETRA TECH, INC.
FIGURE 16
DELAWARE RIVER SEDIMENT SAMPLE
STATIONS (TAT)
PUBLICKER SITE
PHILADELPHIA. PENNSYLVANIA
-------
TABLE 1
CHRONOLOGY CF SITE EVENTS
1912 Pubticker Industries begins operations at the Site.
1940's Publicker Industries peak production period.
1970's-1980's Site used as a petroleum storage facility.
JUNE 1981 Pennsylvania Department of Environmental Resources (PAD6R) conducts hazardous waste
inspection, issues notice of violation, and requests Publicker Industries to develop
Preparedness, Prevention, and Contingency (PPC) Plan.
JANUARY 1983 PACER conducts another hazardous waste inspection and issues a notice of violation for lack
of records for quantity, description, and disposition of solid wastes, and improper
disposal of laboratory wastes. PADER classifies facility as a small quantity generator.
OCTOBER 1985 PADER conducts another hazardous waste inspection and issues a notice of violation for
storage of more than 100 30- and 55-gallon drums with unknown contents, and leaking 20,000-
gallon tank, contents also unknown. PAOER stops off-specification alcohol incineration at
the Site and requires notification of waste transport and disposal. PAOER also conducts a
water quality management inspection and issues notice of violation for various spills,
including heavy oil and antifreeze or dye.
OCTOBER 1985 Publicker Industries ships over 1,000,000 gallons of hazardous waste via Allied Towing
corporation barge to Allied Petroleum in Norfolk, Virginia.
FEBRUARY 1986 Publicker Industries ceases operations at the Site.
MARCH 1986 Publicker Industries sells the property to Overland Corporation.
APRIL 1986 Dames & Moore, an environmental consulting firm, begins a preliminary environmental
evaluation of the Site for Cuyahoga Wrecking Corporation, the parent of Overland
Corporation. Localized soil and ground-water contamination was identified as a result of
the investigation.
JUNE 1986 USEPA files a complaint and compliance order against Publicker Industries for operating a
hazardous waste facility at the Site without a permit; storing ignitable wastes on Site
from June 9, 1983 to October 31, 1985; and shipping hazardous waste to Allied Petroleum in
Norfolk, Virginia in October 198S.
JULY 1986 PAOER conducts hazardous waste inspection and issues a notice of violation for on-site
storage of drums, many of which were corroded and leaking, and PCS oils in building
transformers. Publicker Industries contends that they contracted Cuyahoga to remove drums
in question.
OCTOBER 1986 PAOER requires Overland Corporation and Cuyahoga Wrecking Corporation to submit proposal
for removal and disposal of wastes. Overland Corporation states that drums have been
removed and transported to a salvage yard in Oakland, Maryland.
NOVEMBER 1986 Two Cuyahoga Wrecking Corporation demolition workers arc killed during an explosion while
cutting a pipeline containing residual ignitable material. Shortly thereafter, Overland
Corporation and Cuyahoga Wrecking Corporation declared bankruptcy and abandoned the Site.
JUNE 1987 PAOER conducts a preliminary assessment (PA) of the Site and discovers large amounts of
asbestos from pip* insulation, and large amounts of solids, sludges, and liquids of unknown
types in rail tank cars, tank trucks, and storage vessels throughout the Site.
JUNE 1987 Fire destroys carbon dioxide utilization portion of Site and one of the piers. The mulri-
al arm fir* burned out of control for almost two hours. During the fire, muffled explosions
and fir* flare* were observed.
JULY 1987 USEPA conducted Sit* inspections after the fire and found numerous spill areas, improper
drum storage, a leaking process line, an oily sheen emanating from the Site into the
Delaware River, and shock-sensitive and explosive materials throughout the Site.
JULY 1987 Bankruptcy court authorizes the Overland/Cuyahoga bankruptcy trustee to sell all inventory,
equipment and fixtures at the Site by private sal*.
SEPTEMBER 1987 USEPA files consent agreement and order under Section 106 of CERCLA against Publicker
Industries, Inc. Under the order, Publicker Industries hired O.H. Materials to perform a
Site assessment.
-------
OCTOBER - O.H. Materials conducts Site assessment activities at the Site.
'^NOVEMBER 1987
.DECEMBER 1987 USEPA conducts Site inspection and determines that Site conditions continue to present
threats to human health and environment. The USEPA initiates a removal action using CERCLA
emergency funds.
DECEMBER 1987- USEPA emergency removal action includes the stabilization of Site facilities, drum and tank
DECEMBER 1988 contents characterization, bulking and securing of over 850,000 gallons of numerous waste
streams, off-site disposal of laboratory containers, and above-grade process line liquids
removal.
SUMMER 1988 PADER conducts a detailed Site Inspection (SI), which includes soils and ground-water
sampling. Results indicate soils and ground-water contamination.
DECEMBER 1988 USEPA emergency removal action is suspended because of the lack of additional funding from
removal program budget. However, a 24-hour Site security and fire watch are maintained.
MAY 1989 Site scores 59.99 on Hazard Ranking System. USEPA proposes that the Site be added to the
National Priorities List (NPD.
JUNE 1989 Remedial Alternative Record of Decision (ROD) for the Site is issued. The ROD addresses
the Site stabilization operable unit (Ou-1) only. The remedial action detailed in this ROD
consists only of transportation and off-site disposal of known waste streams, demolition of
above-grade process lines, and transportation and off-site disposal of wastes discovered in
above-grade process lines.
OCTOBER 1989 Remedial activities, as detailed in the OU-1 ROD, begin at the Site.
NOVEMBER 1989 Remedial Investigation/Feasibility Study (RI/FS) planning activities begin at the Site.
JUNE 1991 The ROD for Operable Unit *2 (OU-2) was issued, addressing limited removal of asbestos
containing materials fro* the Site.
SEPTEMBER 1991 Start of OU-2 remedial design.
APRIL 1992 Fire destroys building containing bagged asbestos staged at that location during 1988
emergency removal activities. The fire was limited to buildings in the central portion of
the Site. No explosions or fire flares were reported.
APRIL 1994 Sediment samples were collected from the Delaware River east of the Site by EPA. In
general, the levels of se«i-volatile organic compounds detected in the samples were
concluded to be within background levels.
DECEMBER 1994 Prospective purchaser agreement finalized.
JANUARY 199S Final RI/FS reports submitted. Delaware Avenue Enterprises, Inc. purchases Site property.
FEBRUARY 1995 Start of OU-2 remedial action.
MAY 1995 Completion of OU-2 remedial action.
-------
TCN -r;?
•«: <£Pcsr
SEV. ,1
JAN/9:
TABLE 2
SURFACE SOIL SAMPLE RESULTS SUMMARY
ORGANIC COMPOUNDS
PU8LICKER SITE
Sample Total
ID Volatiles
SS-1« <12
SS-2 16
-------
RI REPORT
REV. rfl
JAN/95
TABLE 3
SURFACE SOIL SAMPLE RESULTS SUMMARY
FREQUENCY AND CONCENTRATION RANGE DETECTED
INORGANICS
PUBLICKER SITE
Range Detected
(mg/kg)
Aluminum
Antimony
Arsenic
Barium
Beryl Hun
Cadmium
Calcium;
Chroalum
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nlckle
Potassium
Selenium
Silver
Sodium
Thalllumv
Vanadium
Zinc,
Cyanide
2870 -
<14
3.5 -
58.8 •
2.3 -
3.0 -
466 •
13 -
4.3 -
14.3 -
14700 -
52.6 -
1210 •
64.7 -
.14 -
8.9 -
269 -
1.0 -
1.3 -
85.7 -
<1.00
21.4 -
91.3 -
<10,
21700
.0
113
3550
• 15
18.6
12900 '
786
105
58600
139000
16500
62500
1930
69.4
1220
5380
11.6
12.2
1720
- 1.&
3410
13500
.00
Frequency
30/30
0/30
28/30
30/30
3/30
2/30
30/30
30/30
30/30
30/30
30/30
30/30
30/30
30/30
28/30
30/30
30/30
3/30
3/30
21/30
1/30
30/30
30/30
0/30
-------
TABLE 4
SURFACE SOIL SAMPLE RESULTS SUMMARY
OiOXIN
ICN 4209
III REPOKT
REV. II
JAN/95
I50HCK. HONOL06
(IE FACTOR)
Tap Lilt: Concentration at hoaolog in iug/kg
lotlM UMI Co»ctatr«tio» to toifcity equivalent or 2.1.7.0-1000
MUH-
IO >
SS-02
SS 01
SS-IJ
SS H
SS-lu
SS-I/
SS-18
SS Ib
«•
SS-21
SS-25
SS-2»
RC<
SWo
j SS-28
-SS-2II
C (»W)
C.
f ss oo
IAU
ID 1
PC0001
PC 0002
PCOOOJ
• PC0004
K0005
PC0006
PC0007
PCU007RE
pcoooa
P10009
KOOOiIRt
PI 0010
PC0011
PCOOI5
PCOD13
TOTAL
1C
0.004
0.002
0.001
0.002
0.001
0.000
0.190
0.000
0.004
0.214
O.OOOO
0.000
O.OOi
0.001
0.001
M.COO
0.000
o.oooo
0.0000
o.oooo
0.0000
0.0000
0.0000
2.088 J
0.000
0.0000
0.0000
2.451 J
0.000
0.0000
0.000
o.oooo
0.0000
0.0000
2178-
HuCOO
0.100
0.0009
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
1.021 J
0.102
Q.OOOO
0.000
0.0000
0.0000
0.0000
KpCDO
0.000
9,0000
0.0000
9,0000
0.0000
0.0000
0.0000
2. 1(7 J
0.000
0.0000
O.oooo
6.526 J
0.0000
0.0000
0.0000
1.78} J
0,000
0.0000
0.0000
2178-
HpCDO
0.010
0.242 1
9.00?
0.0000
o.oooo
0.0000
0.0000
0.0000
2.418 J
0.024
0.0000
0.0000
7.1S8 J
0.072
.0.0000
0.0000
0.0000
0.0000
0.0000
OCOD
0.001
2.00 J
0.0020
1.67 J
0.0017
1.44 J
0.0014
2.041 J
0.0020
0.918 J
0.0009
0.0000
10.109
0.0101
o.oooo
4.105 J
0.0041
14.842
0.0368
O.OOOO
0.0000
5.261
0.0063
2.551 J
0.0026
1.100 J
0.0011
TCOF
0.000
0.0000
0.0000
0.0000
0.0000
0.0000 '
0.0000
16.484 J
0.0000
0.0000
9.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
PeCOF
0.000
0.0000
0.0000
0.0000
o.oooo
0.0000
0.0000
14.066 J
0.0000
0.0000
0.0000
0.0000
0.0000
o.oooo
0.0000
0.0000
0.0000
12178-
PeCDF
0.050
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
2.418 J
0.1209
9.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
II.CUF
0.000
0.0000
0.0000
0.0000
o.oooo
o.oooo
o.oooo
1.429 J
0.0000
0.0000
0.0000
0.694 J
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
2378-
lucor
0.0000
o.oooo
0.0000
0.0000
0.0000
0.0000
0.107 J
0.0000
o.oooo
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
HpCOF
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.692 J
0.0000
0.0000
0.0000
2.158 J
0.0000
0.0000
0.0000
0.0000
0.0000
2378-
llpCUl
o.oooo
0.0000
0.0000
0 . 0000
0.0000
0.0000
0.163 J
0.0016
0.0000
0.0000
0.116 J
0.0012
0.0000
0.0000
o.oooo
0.0000
l-.ui.ui I COO. ?J/8 ICOO.
> c*l i ai 1 ion rekul 11>
PeCUO. 2178-PeCUO. 2378-KOF. 12378-PeCUf. or OCUF not delected.
-------
SUBSURFACE SOIL SAMPLE RESULTS SUMMARY
ORGANIC COMPOUNDS
PUBLiCKER SITE
Sample
10
BOR 1A*
1-3.5'
BOR IB
3.5-5'
BOR 2A
1-3'
BOR 28
5-8'
BOR 1A
1-4'
BOR 3B
5-8'
80* 4ft
1-3.5'
BOR 48
5-7.5'
BOR 5A
1-J'
BOR SB
3-S'
BOR 6A
1-3*
BOR 6B
3-5'
BOR 7A
1-3'
SOR 7B
3-5'
BOR 8A
2-3'
BOR BA(OUP)
2r3'
BOR 8B
3-5'
BOR 8B(OUP>
3-5'
BOX 9*
1-2'
BOR 9B
7-9'
BOR IDA
3-5'
BOR 108
5.5-8*
BOR 11A
1-3*
Total
Volatile*
1.400
1.300.900
Z46
<16
<1*
78
71SV
<74
16,511
<12
-------
TABLES (continued)
SJBSUKFiCE SOIL SAMPLE xiSULTS SUMMARY
ORGANIC COMPCL'NCS
RI%E?CRT
PUBLICKER SITE
Sampl e
ID
30R 11B
7-91
BOR 12A
1-5'
BOR 12B
5-7'
BOR 13A
2.5-4'
BOR 138
7-9'
BOR 14A
1-5'
BOR 14B
5-7'
BOR ISA
5.5-8'
BOR 15B
11-13'
BOR 16A
1-3'
BOR 16B
3-5'
BOR 17A
5-9'
BOR 17B
9-13'
BOR ISA
2-4'
BOR 188
4-5.5'
BOR 19A
1-3'
BOR 198
5-7'
BOR 20A
1-3'
BOR 20B
3-4'
QA/QC SAMPUS**
Rinseate Blink
Field Blank
Trip Blank 1
Trip Blank 2
Total
Total Semi -
Volatile* Volatile*
34.800 135
7 5.788
<16 3.840
<12 5.496
<14 133.370
<12 37.490
<14 45.163
<13 4.09ft
•
<1.500 <400
<12 3,824
<12 175
<13 5.845.
<12 1.127
<12 115.760
<13 25.444
4 4,179
21 126
<11 9,318
<12 7.760
<10 <2S
<10 <25
<10 NA
<10 NA
Total
PAH's
26
5,722
3,688
5,364
128,700
36,720
41.210
4,043
<410
3.764
152
5.145
1.103
110.960
24,124
4,173
126
9,034
7.630
<25
<25
NA
NA
Total
Non-
Carein
PAH's
26
2.192
1.518
1.856
58.600
14.220
23.730
1.077
<410
1.252
83
3.470
512
48.960
10.904
1,768
83
3.620
230
<25
<25
NA
NA
Total
Carcin
PAH's
<410
. 3,530
2.170
3.508
70.100
22.500
17.480
2.966
<410
2.512
69
1.875
591
62.000
13.220
2.405
43
5.414
2.850
<25
«25
NA
NA
Total
BAP
Equiv
<410
831
4S9
622
12.210
5.180
3.242
712
•<410
491
4
382
109
15.515
2.732
465
1
1.266
764
<25
<2S
NA
NA
Total
Pesticides
<5.0
4.4
<5.2
<3.9
<4.5
9.3
12
<4.2
<4.1
<3.9
<3.9
14
<4.0
<4.0
11
3.8
<4.S
12
<4.l '
<.l
<.l
<.l
«•!
Total
PCB's
<100
<82
-------
JAN/55
TABLE 6
SUBSURFACE SOIL SAMPLE'RESULTS
FREQUENCY AND CONCENTRATION RANGE DETECTED
INORGANICS
PU8LICKER SITE
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromi urn
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickle
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide
Range Detected
(ma/kg)
322 • 18400
3.3 - 11.3
2.3 - 28.7
18.7 - 288
-------
TABLE 7
*CN 4209
Rl REPORT
REV #1
JAN/95
WELL STATISTICS
PUBLICKER SITE
Well
Number
MW-2
HW-4
NW-9
MW-10
MW-11
PACKER-S
PACK£R-0
PH-408*
PH-411
PH-41S
PH-416
PH-417
PH-419
PH-420
PH-750
PH-751
PH-752
(" In feet below top
"' Not all measured
111 Oames and Moor*.
well
Diameter
(inches)
4
4
4
4
4
4
4
10
18
16
16
10
10
10
8
8
8
of casing.
on same date -
10.BS: USfiS. 19t
Total
Depth '"
(feet)
14.6
14.3
14.6
15
14.6
6
52
130
82
92
89
165
143
164
167
77
75
feet below
14
Typical
Water
Level1"
8
6
4
6
8
6
10
26
11
12
12
25
25
26
17
15
16
•easurlng point.
Aquifer
Screened'31
Alluvium/Fill
Alluvium/Fill
Alluvium/Fill
Alluvium/Fill
Alluvium/Fill
Alluvium/Fill
Trenton Gravel
Lower Sand
Trenton Gravel
Upper Sand
Trenton Grave)
Lower Sand
Lower Sand
Lower Sand
Lower Sand
Upper Sand
Upper Sand
Screened"1
Internal
(feet)
3-13
3-13
3-13
3-13
3-13
3-6
42-52
154-194
62-82
72-92
69-89
145-165
135-155
149-164
122-167
62-77
60-75
Thl, well „, orally 194 ft deftp but
1$
-------
TABLE 8
GROUND-MATER SAMPLE RESULTS SUMMARY
ORGANIC COMPOUNDS
PUBLICKER SITE
TCN 4209
Rl RE ('OKI
REV. II
JAN/95
location
Round
VOUIIIES
Tetrichloroithene
Xylenis
Ethylbeniene
Nttfcylene Chloride
VUyl Chloride
Chloroethine
l.l-Olcbloroethini
Cirbon Oliulflde
Acetone
Tra»- 1 ,2-Dlchloroetheni
I.l-D|chloroe thine
CU-l.2-Oichlproethene
2-lutanone
Trlchloroethene
Toluene
Chlorobmiini
l.l.2.2-T«tr«chloroeth*ni
SEMI-VOUULES
Phinolt
4-Helhy (phenol
NiphthtUna
Acmiph thine
FtuoreM
fntbrcne
eceie
inlheoi
1
(b)fluonn thine
Gino(k)fluor«nthene
•emojg.h.Operylene
(•^to(e)anthric«ne
bls(2-elhylhe>yl)phthalato
Chrylene
HU-2
1
2J
.9J
,8J
2
HH-4
1
2
5.0
fM
HW-9
1
•W
2J
ZJ
2J
IJ
U
U
2
MW-10
1
U
2J
U
.8J
.9J
2J
2J
.9J
.9J
.3J
2
2.0
HW-11
1
.ZJ
.9J
2
PACK-S
1
2
.2L
.31
.U
PACK-D
1
.2J
.03J
4J
2
PH-408
1
.4J
.2J
1.5
2
33
II
6.4J
PII-411
1
.U
.03J
.04J
1.4
?
(
piMir
t
.OU
.03J
6.1
I
1.7J
I.4J
i.U
J.1J ,
I • Antlyle Prtxnl. riporltd >*lu* p«l«nmnr
J • HeporUd «*lut U «tiiMl*d
NS • Nat i«»pl«d • lurbln* oil pr«nnl
-------
TABLE 8 (continued)
GROUND-WATER SAMPLE RESULTS SUMMARY
ORGANIC COMPOUNDS
PUBLICKER SITE
P9/1
ICN 1JU9
Rl RlPOUl
REV.. »0.
- JUN/91
Location
Round
VOLATILE*
Tetracbloroethane
Xylenes
Ethylbentene
Hethylene Chloride
Vtnyl Chloride
Chloroethine
l.l-Otchloroelhape
Cerbon OlsuMlde
Acetone
.Trans- l.2-0lchloroethane
I.l-Oichloroetkene
CU-I.Z-DUhloroethene
2-Butanont
Trlchloroethene
Toluene
Chlorobeniene
1.1.2,2-Tetrachloroethan»
StNI-VOUTUES
Phenols
4-Hatbylphenol
Haphthalene
Acenaphtkene
Fluorene
Phentnthrene
Anthracene
fluoraolhane
Pyrene
Benio(fa)fluoranthene
B«nto(k)fluoranthene
Benzo(g.h.l)perylene
Oiethyphthalate
Benia(t)«nlhr«cene
bli(2-eUylhe«yl)phthaUte
Chrysene
PH-416
1
•04J
.OU
.2J
2.4
•w
2
PH-417
1
r?!>
.JJ
.OBJ
.2J
100
2
4S.04
0.3L
PH-419
1
.02J
.02J
.OJJ
}
2
16
PH-420
1
NS
2
4.0
21
1.1J
PH-7SO
1
n.&
.OU
.09J
.07J
3.1
0.7J
«•
.1
M.6
18.1
11.2
2
13.01
JA1
• OL
I8.0L
PH-7SOO
1
"M
.OU
2.1
.09J
6JC
• 0
72-3
ia.t
".»
2
12.0
5 A
.u
21
PII-7S1
1
.U
M
2
PH-752
1
0.8J
.05J
.08J
•6J
.06%)
2
EQR
1
2
rn
i
0.02J
0.14.1
.OJJ
.6J
?
I • Analyle Present, reported value potentially Ion
J • Reported value it estimated
NS • Mot stapled - turbine oil present
-------
TABLE 9
GROUND-WATER SAMPLE RESULTS SUMMARY
FREQUENCY AND RANGE DETECTED - INORGANICS
PUBLICKER SITE
ROUND
Ground Hater
Compound
Aluminum :
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nlckle
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide
(Filtered)
Frequency
0/16
1/16
9/16
15/16
9/16
0/16
16/16
1/16
9/1'
1/16
16/16
0/16
16/J6
16/16
2/16
3/16
16/16
0/16
0/16
16/16
0/16
1/16
14/16
(Hfl/l)
Range
Detected
-------
TABLE 1 0
SUBSURFACE LINE INVENTORY
PUBLICKER SITE
Zone
ELECTRICAL*
SANITARY
36"
24'
18 «
15"
12*
10'
8V
6'
5"
4"
zr--.
STORM
6'X10'
6'X8'
30'x25-
30'x20"
54'
48"
36"
30"
•24'
18"
16"
15"
12"
10"
a-
6"
5"
4'
trench
I
160
600
0
0.
0
530
0
0
90
0
20
0
1240
0
430
50
290
0
0
260
0
0
60
Ov
0
200
0
0
0
0
0
810
2100
2
910
70
0
0
0
120
0
0
550
0
110
0
850
0
440
0
0
0
140
70
260
0
70
0
0
100
0
210
90
0
0
880
2260
3
480
0
0
0
0
480.
0
0
460
0
410
0
1350
0
480
0
0
0
460
0
0
80
0
60
0
610
60
0
0
0
0
490
2240
4
0
0
0
0
0
180
0
170
320
0
240
.0
910
0
200
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
200
5
1450
530
160
670
90
190:
20
280
0
70
80
0
2090
0
0
0
0
0
0
0
0
0
100
0
0
110
180
0
0
0
0
600
990
6
1630
0
0
570
420
300
50
620
160
0
410
30;
2560
480
0
0
0
340
0
160
50
360
470
0
0
380
60
540
320
130
0
340
3630
7
110
0
0
0
0
0
0
0
450
0
0
0
450 .
130
0
0
0
0
0
0
0
210
0
0
60
50
0
70
0
0
70
650
1240
"C.N 42C9
SI REPORT
REV. #1
JAN/95
8 Subtotals Totals
0
0
0
990
150
0
0
0
40
370:
0
0
1550
500
0
0
0
620
0
0
0
0
210
0
0
0
120
290
220
90
0
0
2050
4840 4840
1200
160
2230
660
1800
70
1070
2070
440
1270
30
11000 11000
1110
1550
50
290
960
600 .
490
310
650
910
60
60
1450
420
1110
630
220
70
3770
14710 14710
The electrical lines that tie into the electrical manholes are located In ducts carrying conduits ranging in size
from 1 Inch'to 4 inches.
-------
TABLE 10- (continued)
TCN 4209
RI REPORT
REV. #1
JAN/95
SUBSURFACE LINE INVENTORY
PUBLICKER SITE
Zone
CITY WATER
:«*-^.. '.--"T
6'
"'4*. '"•:'' "
3'
':2"::-:'" ""• • '-••I:
WELL WATER
|.12«::i£v- • ,•"
8'
5"
2'
1
60:
0
1' *
0
•E •:,'"'" ''<*"•
60
;' ": :'•"" :0x. -;:.
70
0
0
70
2
610 *
0
..SO'::
20
•r o«J
680
•'«&;'•
470
0
0
510
3
£ ::-:'fr :'
0
?•• Xias'V
0
§:• :;:VS 0:-;-;"::.
0
;;|^.2ba;:4;:;,:
660
20
0
900
4
:0
0
o-:;-:
0
:... . fe'-':.
0 0
0 0
130 0
730 0
3
0.
0
0
0
,":.'. o •..:'
0
-;•' 0^
0
a
0.
0
Subtotals
2490
840
390
250
• :. w*
4150
.;-v> ;, 84O;
1220
20
130
2210
Totals
4150
2210
-------
"N -^9
1 REPOR
REV. -i
JAN, 95
TABLE 1 1
LIQUID/SEDIMENT SAMPLE STATION DESCRIPTION
PUBLICKER SITE
LIQ-01/SED-01 Minor storm sewer location (less than 3-foot diameter)
UQ-02/SED-02 Shallow open drainage trench location
LIQ-03/SED-03 Shallow open drainage trench location
LIQ-04/SEO-04 Shallow open drainage trench location
LIQ-05/S£D-05 Minor storm sewer location
LIQ-06/SED-06 Minor stem sewer location
LIQ-07/A Major *tor» sewer location (greater than 3-foot diaaeter)
B/SED-08 Shallow open drainage trench location
LIQ-09/SEO-09 Snail *tor«/s«nitaryr seww location (1-foot diameter)
LIQ-10/A Storm sewer autfall - Delaware River
LIQ-I1/A Main city store sewer location (4-foot diameter):
B/SED-12 Shallow open drainage trench location
A - No sediment present; no sediment sample collected.
8 - No liquid present; no liquid sample collected.
-------
I
-g
cr>
TABLE 12
LIQUID SAMPLE RESULTS SUMMARY • ORGAN I CS
PUBLICKER SITE
(X9/D
Location
LIQ-01
UQ-02
LIQ-Oi
liq-04
uq-os
Liq-06
liq-07
Liq-09
LIQ-10
LlQ-10-DUP
L1Q-11
Liq-ER
Designation
SU-drop inlet
SU-drop inlet
SU- trench
SU- trench
SU-drop inlet
E-substation
E-substation
SU- sewer
SU-tewer
SU-sewer
SU-6ewer
Equip- rinsate
Total Total '
Total Non- Total Benzo(A)
Total Semi- Total Carcinogenic Carcinogenic pyrene Total
Volatile* Volatile* PAHs PAHs PAHs Equivalent Pesticides
1220 165 22
5990 260 197
<10 <10 <10
<19 1 <10
<10 9.5 1.5
<10 6 2.5
<10 2.6 1
<10 <10 <10
19 1 «1P
<10 30.2 5
<10 9.6 1.8
<10 2.7 0.7
1 21 <25
^P <10 <25
<10 <10 <25
0.6 0.9 <25
0.5 2 <25
0 1 <25
<10 <10 <25
-------
Compound
Aluminum
Antimony
Arsenic
Barium
Bery Ilium .
Cadmium
Calcium
Chromi urn
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickle
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium-
Zinc
Cyanide
TABLE 1 3
LIQUID SAMPLE RESULTS SUGARY
FREQUENCY AND RANGE DETECTED - INORGANICS
PUBLICKER SITE
Range Detected
fog/1)
384 - 10100
<47.0
5.9 - 39.9
45.7 - 307
<1.0 .
-------
TABLE 1 4
SEV. »i
JAN/95
SEDIMENT SAMPLE RESULTS SUMMARY - ORGAHICS
PU8LICKER SITE
teg/kg)
Sample Total
ID Volatile*
SED-01 <12
SEO-02 25.000
SED-03 36.698
SED-04 <2.300
SED-05 <12
SED-06 <3,100
SEO-Oft <14
SEO-09 <43
SED-1Z <11
QA-O.C SAMPLES*
SED-ER <10
Total .
Seal-
Volatiles
10,979
477.900
668,200
28.110
23.039
49.343
39,800
3.853
1,963
<10
Total
PAH's
6.279
460,900
655.500
23.710
19.699
48,690
39.800
3,853
1.446
<10
Total
Non-Card n
PAH's
2.025
353.700
537,700
4.410
14,880
6.300
8.100
1,693
759
«10^.:
Total
Carcin
PAH's
4,254
107.200
117.800
19.300
4.819
42.390
31.700
2.160
876
««
Total
BAP
Equiv
941
30.491
24.190
4.119
941
9.264
5.968
413
<10
Total
Pesticides
60
105
<6
6.8
13
<8.5
363
177
<4
<.io
Total
PCB's
ISO
430
180
250
330
160
2.600
400
<38
<1.0
•R1ns«it« sampl* - units
-------
Compound
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron:
Lead
Magnesium:
Manganese
Mercury
Nlckle
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Z1nc
Cyanide
TABLE 15
SEDIMENT SAMPLE RESULTS SUMMARY
FREQUENCY AND RANGE DETECTED - INORGANICS
PUBLICKER SITE
Range Detected
(mg/kg)
1070 - 7770
<14
3.8 • 1210
22 - 914
<1.0
<1.9 - 1.5L
6620 - 154000
11.1 - 1530
7.6 - 38.6
285 - 2660
32700 - 322000
72.5 - 2750
1660 - 30000
250 - 3350
.37 - 2.6
19.7 - 299
336 - 1900
<4.0
<4.0
204 - 591
<1.0
8.7 - 61.6
33S - 6380
<10.0
«I REPORT
SEV. fi
JAN/95
Frequency
8/8
0/8
8/8
8/8
0/8
1/8
8/8
8/8
8/8 :
8/8
8/8
8/8
8/8:
8/8
8/8
8/8
8/8
0/8
0/8
5/8
0/ff
8/8
8/8
0/8
L • Analyte present, reported value potentially low.
-------
HC-01-11
HC-02-11
HC-03-11 .
HC-04-11
HC-05-U
HC-05-12
HC-06-JI
HC-07-11
Hc-pa-u
HC-09-11
HC-09-12
HC-10-11
HC-10-U-OUP
HC-12-11
MC-13-H
TABLE 16
WASTE SAMPLE SUMMARY - ORGANICS
PUBLICKER SITE
OruB
Drum
Hortcn sphere
E-substation
E-»ubstation
E-substation
SH-trench
SW-trench
E-substation
E-substation
E-5ubstat1on
E-substation
E-substation
Trip blank
Trip blank
15
6
<5
14
4
2
6
6
7
6
1
7
7
<5
<5
650
140
<200
740
110
6
20
<200
<2QO
123
<200
<200
793
TB
T6
40
30
67
40
<200
<200
<20
E • electrical line
SW • stem water Line
337
TB
TB
10
7
TB
TB
30
57
330
TB
TB
16
<20
TB
TB
<100
<20
<200
<200
<2Q
<50
<20
<20
<50
<20
<50
<50
TB
TB
TCN 4?09
RI REPORT
RI.V. II
JAN/95
Location Designation
-200
<200
?.?
-------
TABLE 1 7
• C.'i 4209
:: REPORT
REV. *1
JAN/95
WASTE SAMPLE RESULTS SUMMARY
Compound
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium.-
Chromium
Cobalt
Copper
Iron-
Lead
Magnesium
Manganese
Mercury
Nickle
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide
FREQUENCY
Frequency
0/9
0/9
1/9
4/19
0/9
1/9
8/9
0/9
0/9
5/9
9/9
8/9
8/9
9/9
1/9
0/9
6/9
0/9
0/9
8/9
0/9
0/9
9/9
0/9
AND RANGE DETECTED -
PUBLICKER SITE
Liquid
(mg/1)
Range
Detected
<384
<38.4
<9 - 101
<21.2 - 653
<2.4
<9.2 - 51.8
11008-177000
<17.2
<38.0
80.2 - 1490
2225 • 426000
<4.6 • 1710
1360 - 25500
131 - 4970
<0.4 - 45.1
<51
11000 - 56000
<8.6
<1.6: .'"•''
2070 • 65100
<9.Z
<38.4
77.8 - 5610
<25
INORGANICS
Frequency
8/9
1/9
3/9
6/9
6/9
3/9
9/9
7/9
3/9
6/9
S/9
7/9
9/9
8/9
5/9
6/9
4/9'
2/9
3/?
2/9
0/9
8/9
9/9
1/9
Solid
(mg/kg)
Range
Detected
<38.4 - 11700
<3.8 - 106
<0.9 - 13.4
<2.12 - 123
<0.24 - 1.4
<0.92 - 15.1
49,3 - 94200
<1.72 - 183
<3.8 - 7.9
<4.4 - 524
27.5 - 20000
<0.46 - 1150
16.3 - 54500
<1.02 - 745
<0.1 - 155
<5.1 - 78
<60 - 1500
<0.86 - 6.6
<0.16 - 0.39
<37.2 - 116
<0.92
<3.84 - 173
3.6 - 1940
<2.0 - 2.7-
-------
TABLE 1 8
UESTON TAT SEDIMENT SAMPLE DATA*
ORGANIC COMPOUNDS
JCN 4^00
Rl REPORI
REV. fl
JAN/9b
SAMPLE NO.
Methyl Phenol
Anthracene
Crysene
Fluoranthene
Fluortne
Ntpthlene
Phentnthene
Pyrene
4.V-DDE
4.4>-DDD
•-Chlordcne
Aroclor 1248
Aroclor 1260
•Dtt« «s reported
ND - Not detected
NS - Not stapled
~J(J
o:
cz.
c.
rv
Ul
rv.
i
7750
ND
NO
ND
HO
NO
NO
NO
14.9
6.2
NO
NO
ND
2
2150
HO
ND
461
HP
208
ND
295
12.7
4.4
5.1
57.8
43.3
3
4530
ND
HO
255
NO
359
NO
NO
12.1
4.2
ND
NO
HO
in Publicfcer Industries
4
ND
ND
NO
ND
NO
HO
HO
NO
9.4
4.5
ND
45.1
34.7
Settling
5
3260
NO
NO
NO
NO
HO
NO
NO
5.8
2.3
NO
33.1
ND
Event
6
1110
NO
ND
462
NO
ND
HD
361
7.9
15.1
NO
38.7
ND
Report.
7
9860
ND
ND
HO
NO
ND
NO
ND
2.9
ND
NO
NO
ND
Weston
8 9
NO NO
ND HO
NO ND
HO ND
ND NO
NO HD
HD HO
NO 310
196 145
3.7 ND
ND NO
172 49.1
127 65.2
TAT. M«y 1994
10
ND
2850
507
NO
585
NO
1590
HD
11
NO
ND
ND
NO
11
ND
NO
ND
ND
NO
HO
ND
HO
7.4
ND
ND
NO
NO
12
NO
NO
NO
ND
NO
NO
ND
HD
10.1
HD
HD
ND
ND
13
NO
NO
NO
HO
ND
NO
NO
ND
123
HD
NO
ND
ND
14
ND
ND
NO
NO
ND
ND
HD
262
8.7
1.4
NO
ND
NO
is 16 uu er
NO NO NS NS
ND NO 170 160
ND NO 480 290
ND ND 1100 1300
NO NO 200 190
ND 264 820 510
NO NO 630 1100
ND 447 1200 1100
4.1 6.4 192 10)4
ND 2.9 94.1 73.2
ND ND 4.7 6.3
ND 29.3 ND NO
NO 29.4 NO ND
(see Appendix 4-M).
-------
TABU 19
HESTON TAT SEDIMENT SAMPLE DATA*
INORGANIC COMPOUNDS
(•9/kfl)
ICN «<>')
ftl KIPUKI
REV. II
JAN/95
SAMPLE NO.
AluBtnua
Arsenic
C«d>1u*
aid i«
Chroviui
Cob* It
Iron
Lead
Mtgnesiioi
Mangtnese
Mercury
Nickel
PoUssliu
Stiver
Sodlui
T.
Vt
Zinc
1
4430
2.6
1.)
1280
12.4
4.7
6260
24. 5
1290
187
0.2
7.9
S21
0.5
99.2
0.2
10. S
143
2
4100
2.8
1.1
1200
16.2
8460
29.5
1320
412
0.20
9.2
538
0.46
101
0.19
11.7
137
1
4260
3.9
1.1
1130
22.5
8670
37.1
1300
346
0.24
8.7
S24
0.47
85.6
0.19
11.1
155
4
3580
3.3
1.1
1420
11.7
7810
36.1
1430
274
0.21
7.1
412
0.49
84.6
0.19
9.9
141
5
4030
9.5
1.1
1350
17.2
7870
50.5
1270
421
0.18
8.4
458
0.47
85.9
0.19
10.9
164
6
3240
2.8
0.75
958
•i»;«
7200
29.9
1190
216
0.30
7.8
435
0.67
108
0.19
0.1
95.2
7
4710
2.2
0.95
1410
12.1
8650
22.2
1410
450
0.18
8.3
50)
0.46
8S.6
0.19
10.7
162
8
5230
5.0
4.1
1330
78.3
11400
52.4
1300
214
0.40
610
0.47
121
0.19
41.7
228
9
3540
4.1
2.4
1390
46.1
7530
124
1180
123
0.46
370
0.47
126
0.19
10.4
235
10
2790
1.8
0.52
399
7.9
6220
13.9
946
151
0.10
479
0.47
91.1
0.19
5.9
63.4
11
2260
1.2
0.37
351
6.8
5500
17.1
820
123
0.10
306
0.47
79.9
0.19
«'*
55.8
12
2320
1.3
0.64
356
6.6
5540
13.6
821
122
0.10
362
0.47
70,4
0.19
4. B
62.1
13
2470
1.5
0.38
506
7-1
5900
20.2
844
182
0.10
295
0.48
80.4
0.19
5. 5
84.7
14
1420
I.S
0.69
1080
10.8
7080
35.9
917
177
0.13
396
0.49
151
0.19
8.9
146
15
3130
1.6
0.68
720
12.3
7150
31.5
934
239
0.28
411
0.47
97.1
0.19
8.3
113
16 WW
3860 11600
2.8 4;46
0.90 3.10
915
15.1 60.3
7630
13.6 117.0
1150
362
0.17 0.200
7.6 30.0
493
0.47 2. ZO
87.0
0.19
10.5
111 833
61
16700
S.79
9.70
-- •
116,0
314.0
--
--
0.500
4.1. 1
3.70
36f\
•Dt(« «s reported in Fublicker Industries Stapling Event Report. Weston TAT. M*y 1994 (see Appendix 4-M).
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Responsiveness Summary for the Record of Decision
Publicker Industries, Operable Unit #3
1 . Overview
A public meeting to announce the issuance of the Proposed
Plan and solicit comments and concerns was held on June 20, 1995.
EPA also met with the Whitman Council (a local neighborhood
group) on June 14, 1995, and the City of Philadelphia on June 28,
1995, to brief them about the Site status and the Proposed Plan,
and to listen to their questions and concerns. In addition to
questions and comments expressed at these meetings, EPA received
4 comment letters during the public comment period. One of these
letters was from a concerned citizen, one from counsel for
Publicker Industries ("Publicker", a PRP) , one from counsel for
Delaware Avenue Enterprises ("DAE", current Site owner and one of
the signatories of the Prospective Purchaser Agreement) and one
letter from counsel for the City of Philadelphia.
No one expressed disagreement with EPA's proposed
alternative. The majority of questions and comments dealt with
how to decide when there is sufficient information- to support a
remedy decision.
These sections follow:
• Background on Community Involvement
• Summary of Public Comments and Lead Agency Response
• Part I: Summary and Response to Local Community
Concerns
• Part II: Comprehensive Response to Specific Legal
and Technical Questions
• Remaining Concerns
2 . Background on <7r""1'>"n^^y Involvement
Most of the neighborhoods in the South Philadelphia area
have community or civic organizations that address local concerns
and problems. The two organizations in the neighborhoods nearest
the Site are the Whitman Council and the Pennsport Civic
Association. There is a high level of interest in the
environmental problems in the South Philadelphia area.
Community concern about the Site began primarily after the
fire in June 1987. However, active community involvement has
been -limited. The extent of known community involvement includes
attendance at public meetings and informal presentations, and
participation during public comment periods.
. 1
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3. Summary of Public Comments and Lead Agency Response
The public comment period on Che Remedial Investigation and
Feasibility Study (RI/FS) and Proposed Plan for the Publicker
Industries Site, Operable Unit #3 was from June 2 to August 2,
1995. Comments received during this time are summarized below.
Part I of this section addresses those community concerns and
comments that are non-technical in nature. ' Responses to specific
legal and technical questions are provided in Part II. Comments
in each Part are categorized by relevant topics.
Part I: Summary and Response to Local Community Concerns
Past Practices at the Site
1. A citizen expressed concern regarding the extent of the
proposed alternative. Her ex-husband worked in the laboratories
at Publicker during the 1970's. The citizen stated that her ex-
husband witnessed and objected to the dumping of chemicals.
Additionally, she stated that she had called EPA in 1970's and-
was fold by EPA that an investigation would be done and any
actions necessary would be taken. Because of this, the citizen
questioned why a ground water clean up is not warranted.
EPA Response: EPA's own investigation supports some of the
information provided in this citizen's comments. However, data
collected during the RI does not currently show site-related
contamination in the ground water beneath the Site. Without this
site-related contamination it would be inappropriate to propose
ground water remediation.
Residents' Health Issues
2. A citizen also expressed concern about the number of people
with cancer in her neighborhpod and asked that EPA investigate
and "do what's right".
EPA Response: Current information about the Site indicates that
there is currently not a major risk of cancer from the Site, and
the off-site risk of cancer from the Site is insignificant. The
citizen's concerns are noted and her request for an investigation
will be passed on to the Agency for Toxic Substances and Disease '
Registry (ATSDR) and the South/Southwest Philadelphia Study
Group. .
Part II: Comprehensive Response to Specific Legal and Technical
Questions
Surface and Subsurface Soil
1.. DAE believes that some areas of soil contamination have not
been adequately characterized, and may contribute to an
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unacceptable risk to on-site workers. DAE noted several areas of
stained soil which they believed should have been sampled. The
City of Philadelphia also believes it may be appropriate to
perform additional sampling.
EPA Response: EPA disagrees. EPA has taken a conservative and
methodical approach to characterizing the hazards at the Site.
Initially, 119 soil vapor points were analyzed during the soil
vapor survey. Next, samples were collected and analyzed from
thirty surface soil locations. These thirty locations were
selected on the basis of soil vapor data, observed field
conditions such as stained soil, and several random locations.
Additionally, subsurface soil samples were collected and analyzed
from twenty boring locations, and from two different depths at
each of the twenty locations. Samples were also collected from
trenches and underground utilities, ground water, miscellaneous
wastes, water and sediments -in the slip area and Delaware River,
and soils after the fire in 1992. While some uncertainties may
exist at the Site due to its lengthy use as an industrial
facility, EPA has adequately and reasonably characterized hazards
at the Site, and assessed the potential risk to workers from
known hazards to be within acceptable ranges. As a further
precautionary measure, EPA is requiring monitoring during any
excavation activities and deed notices to minimize unexpected
worker exposure and from possible contamination that may be
released and that was not identified during EPA's investigation
of the Site.
2. DAE is also concerned that since storm water runoff is noted
in the Proposed Plan to present an unacceptable risk, the
assumption should be made that elevated concentrations of
contaminants in the soil are present which have either not been
investigated or which have had their hazards misinterpreted.
EPA Response: ' EPA disagrees. EPA believes that the main concern
regarding storm water runoff is contact with the sediments,
particularly where these sediments have accumulated over time,
and the erosion of these sediments due to runoff. Erosion of
soil into waterways is not an ideal situation, but the soil does
not contain hazardous substances at unacceptable levels.
Well Abandonment
3. Publicker recommended expanding the well abandonment
alternative to include deep "foundation pilings" if they pose a
risk. Foundation pilings for a proposed freestanding sign were
specifically referenced.
EPA Response: EPA believes that the potential risk of vertical
migration of contaminants by way of the deep pilings is
insignificant and therefore need not be addressed. The
freestanding sign referred to in the comments was never
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constructed. As a further precautionary measure, EPA is
requiring monitoring during any excavation activities to minimize
unexpected worker exposure and from possible contamination that
may be released and that was not identified during EPA's
investigation of the Site.
4. DAE and the City of Philadelphia recommended that the well
abandonment alternative be expanded to include the nine on-site
wells identified in the RI as "destroyed".
EPA Response: EPA agrees. This has been added to the selected
remedy.
5. Publicker requested that EPA note the infeasibility of
ground water remediation and treatment in the ROD.
EPA Response: Information gathered during the RI did not
indicate that Site-related contaminants had migrated to the
ground water beneath the Site. Based on the data collected, the
Site did not appear to be contaminating the ground water.
Therefore, the feasibility of ground water remediation and
treatment was not determined.
Electrical and Storm Water Utilities
6. DAE recommended inclusion in the remedy of all buried and
underground utilities and process lines, rather than limiting it
to the electrical and storm water utilities as in the Proposed
Plan. The City of Philadelphia also expressed concern that a
more detailed characterization was not conducted on all of the
underground utilities, and recommended this characterization take
place. Both commentors expressed concern that some utility lines
have never been located. DAE .also stated that failure to address
material in all utilities may constitute "disposal" of hazardous
waste under RCRA, or residual waste under the Pennsylvania Solid
Waste Management Act.
EPA. Response: EPA disagrees with the statement that failure to
address material in all the utilities constitutes "disposal" of
hazardous waste under RCRA, or residual waste under the
Pennsylvania Solid Waste Management Act. EPA also disagrees with
the suggestion of the need for additional extensive
characterization of the underground utilities and process lines.
EPA believes that sufficient characterization was conducted to
evaluate the nature and extent of contamination in the
underground utilities. Since the Site was operated for many
years as an industrial facility which had changing uses over the
years, it is not surprising that the locating of some underground
lines has been difficult. Because of this, some lines may be
discovered only during excavation activities. Confirmatory
sampling while the remedy is being conducted will provide any
needed information regarding the completion of the remedy.
4-
-------
Monitoring during remediation and any excavation activities will
minimize unexpected worker exposure and from possible
contamination that may be released and that was not identified
during EPA's investigation of the Site.
Underground Structures
7. DAE expressed concern regarding underground or below grade
structures associated with some buildings and underground
utilities. DAE believes there may be a possibility of
contamination and potential hazards in these other subsurface
structures, due to run-off from the Site soils. DAE specifically
mentioned what they term to be a basement area of one building
near the 1992 burn area. DAE also stated that failure to address
material in all utilities may constitute "disposal" of hazardous
waste under RCRA, or residual waste under the Pennsylvania Solid
Waste Management Act.
EPA Response: EPA agrees that the possibility for contamination
and potential for hazards exists at the Site, but disagrees with
the likelihood and extent of the. unknowns. For example, the
basement area noted in the comments is clearly marked on plant
drawings as the grain unloading area. This area had been a
roofed structure with open sides and a catch basin covered by
grates. Grain that spilled during unloading would fall into the
catch basin. This area became covered by debris from the burned
structures. The majority of Site sampling was done prior to the
fire in 1992. The spilled grain catch basin was not sampled at
that time because it did not appear to warrant further
investigation. Water has apparently collected in the catch basin
since that time. EPA believes that monitoring during the
remediation will provide notice of the existence of any potential
hazards, so that any such hazards will be able to be addressed at
that time. EPA disagrees with the statement that failure to
address material in all the utilities.constitutes "disposal" of
hazardous waste under RCRA, or residual waste under the
Pennsylvania Solid Waste Management Act.
Miscellaneous Wastes
8. DAE recommended characterizing and properly disposing of all
miscellaneous wastes at the Site, including residuals left in
tanks after EPA's earlier removal action. DAE stated "As part of
OU-1, EPA previously removed pumpable liquids contained within
numerous above ground storage tanks at .the Site. Most troubling,
however, is the fact that this action failed to address tanks
with non-pumpable contents (e.g., semi-solids or sludges). EPA
has acknowledged the existence of residues in many of the tanks
previously "pumped out" by EPA under OU-1. Many of these tanks
are believed to contain hazardous substances." DAE again stated
that failure to address the residual materials may constitute
"disposal" of hazardous waste under RCRA, or residual waste under
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the Pennsylvania Solid Waste Management Act. The City of
Philadelphia also stated that the material in the tanks should be
tested and removed if found to be hazardous or otherwise
dangerous. Additionally, the City stated that all drums,
cylinders, and other chemicals located on the Site should be
removed.
EPA Response: EPA disagrees with the contention that failure to
address material in all the utilities constitutes "disposal" of
hazardous waste under RCRA, or residual waste under the
Pennsylvania Solid Waste Management Act. EPA agrees that tank
residuals containing hazardous substances should be disposed of
in accordance with current laws and regulations. EPA disagrees
with the alleged number of tanks containing residuals that fall
into this category, believing most of the tanks to be empty,
containing rainwater, or non-hazardous substances based on
surveys conducted during the' removal and site stabilization
phases of the remediation. EPA has included in the selected
remedy the characterization and off-site disposal of tank
residuals containing hazardous substances. EPA has proposed all
along to remove the drums and any containerized miscellaneous
wastes.
Site-related Impacts on Delaware River
9. Publicker requested that EPA reconcile what they believe to
be conflicting statements about Site-related impacts on the
Delaware River.
EPA Response: EPA disagrees with the assertion that the
statements quoted from the Proposed Plan and the RI as noted in
Publicker's comment letter are conflicting statements. Results
from various studies have shown the "high historic and present
level of background pollution" in the Delaware River. With this
background pollution, it is more difficult to determine .the •
impact of contamination from the Site than it would be if the
Site was the only contaminant source in an otherwise pristine
area. Based on recent sampling results it was "concluded that
the runoff from the Site is having little or no impact on the
current benthic community." However, the potential exists for
impact on the Delaware River and it is likely that the Site has
previously impacted the Delaware River.
Confirmation of OU &3 as FinaL Remedial Action
10. Publicker requested that EPA confirm OU #3 as the final
response action envisioned for the Site.
EPA Response: As stated in the ROD, based on information known
at this time, EPA considers Operable Unit #3 to be, the final
respdnse action for the Site.
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Institutional, Controls
11. Publicker suggested that there is a need for an expanded
deed notice and consideration of further institutional controls
regarding excavation activities and disturbance of sediments near
the piers in the Delaware River.
EPA Response: EPA's selected-remedy includes deed notices, as
does the Prospective Purchaser Agreement for the Site. As a
further precautionary measure, EPA is requiring monitoring during
any excavation activities to minimize 'unexpected worker exposure
and from possible contamination that may be released and that was
not identified during EPA's investigation of the Site. New
activities such as dredging in the shallow water environment
around the piers is required to be permitted, and must conform
with requirements contained in such permits.
4. Remaining Concerns
EPA is unaware of any remaining concerns.
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COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
- Please note our new name -
DEPARTMENT OF ENVIRONMENTAL PROTECTION
DEP
Field Operations - Environmental Cleanup Program
Lee Park, Suite 6010
555 North Lane
Conshohocken, PA 19428
610-832-6000
Fax 610-832-6259
December 28,1995
Mr. Thomas Voltaggio
Hazardous Waste Division Director
US EPA Region HI
841 Chestnut Building
Philadelphia, PA 19107
Re: Record of Decision (ROD)
Publicker Industries NPL Site
Philadelphia, Pennsylvania
Dear Mr. Voltaggio,
The Record of Decision (ROD) for the Publicker Industries NPL Site, received by this office
December 21, 1995, has been reviewed by the Pennsylvania Department of Environmental Protection
(the "Department")
The selected remedy for the site includes the following major components, as set forth in the ROD:
1. Abandonment of on-she wells;
2. Removal, treatment; and off-she disposal of liquids and sediments in contaminated
electric utilities;
3. Removal, treatment, and off-site disposal of liquids and sediments in contaminated
stormwater trenches and utilities;
4. Removal and off-site disposal of miscellaneous wastes;
5. Appropriate monitoring during excavation activities and deed notices to provide controls for future
excavation.
An Equal Opportunity/Affirmative Action Employer
DEC-28-1995 15:is
96*
Recycled Paper .flg
P. 02
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ilfcU-28-95 THU V*:iA PM PENNS Yi_ v «ni « utf-, HSUP 610 332 6167 P. 0y
Puoncxer industries NPL Site December 28, 1995
Record of Decision Concurrence Page #2
The Department hereby concurs with the US Environmental Protection Agency's ("EPA") proposed
remedy with the following conditions:
* The Department concurrence is not to be construed as a Department determination that completion of the
remedy will result in the relief from liability under Pennsylvania's Land Recycling and Environmental
Remediation Standards Act, Act 2 of 1995 ("Act 2").
* The EPA will give the Department the opportunity to fully participate in any negotiations with
responsible parties.
* The Department reserves its 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), 42 U.S.C. Section 9604 (c) (3).
* The Department will be* given the opportunity to review and comment on documents, and concur with
decisions related to the design and implementation of the remedial action, to assure compliance with
Pennsylvania ARARs.
In addition, the EPA foils to recognize on Page SO of the ROD, in the Action Specific ARARs section,
the Pennsylvania's Land Recycling and Environmental Remediation Standards Act, the Act of May 19, 1995,
P.L. 4, No. 1995-2, 35 P.S. §6026. IQletseq. ("Act 2") as an ARAR for the Publicker Industries NPL Site a
this time. The EPA makes similar assertions in its' response to comments prepared by the Department The
Department is taking this opportunity to reassert that Act 2 is an ARAR, along with other Pennsylvania
ARARs identified in the ROD. The Department concurs with the remedy chosen for this site. The Department
does not concur with the EPA decision not to recognize Act 2 as an ARAR for the purposes of §121(d) (2) of
CERCLA. Moreover, as stated in the Department's comments to the draft ROD, the Department does not
agree with the EPA's assertion that no action alternatives need not comply with statutory requirements for
selection of a remedy. Consequently, the Department does not concur with the ROD'S analysis indicating that
the remedy selection criteria are not applicable to a no action alternative.
This letter documents the Department's concurrence with he EPA's chosen remedy for the Publicker
Industries NPL Site. Should you have any questions regarding the matter of this letter, please feel free to
contact me at this office.
Sincerely,
Carol R. Collier
Regional Director
Southeast Regional Office
DEC-28-1995 15:19 9S* p'03
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Publicker Industries NPL Site December 28,1995
Record of Decision Concurrence paoc #3
cc: File
Mr. Donald Becker
Mr. Bruce Beitler
Mr. George Danyliw
Mr. Robert Zang
Mr. Matthew Miller
Mr. Craig Olewiler
Mr. Patrick Zaepfel
Mr. Anderson Hartzell
Ms. Alice Tremont
DEC-26-1995 15:20
96X P.04
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