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;
                                -1-

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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
                                -2-

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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,

                                10

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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.
                                11

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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.

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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

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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.


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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.
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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

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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.

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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.
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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

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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

-------
               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

-------
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

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                                                     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

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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

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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

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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

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 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

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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

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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

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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

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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

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     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

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                                              INDUSTRIAL

                                                AREA
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                                                     1 MILE
                                          TETRA  TECH, INC.
FIGURE 1
GENERAL LOCATION MAP
PUBLICKER SITE
PHILADELPHIA. PENNSYLVANIA

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                                             PUBLICKER SITE
                                             PHILADELPHIA. PENNSYLVANIA

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                                          PUBLICKER SITE
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                                                         PHILADELPHIA, PENNSYLVANIA

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                                                        LOCATION MAP
                                                        PUBLICKER SITE
                                                        PHILADELPHIA. PENNSYLVANIA

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                 FIGURE 15
                 ECOLOGICAL SAMPLE STATIONS
                 PUBLICKER SITE
                 PHILADELPHIA. PENNSYLVANIA

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                                                               FIGURE 16
                                                               DELAWARE  RIVER SEDIMENT SAMPLE
                                                               STATIONS  (TAT)
                                                               PUBLICKER SITE
                                                               PHILADELPHIA. PENNSYLVANIA

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                                                    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.

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 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.

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                                                                   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 
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                                                             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).

-------
        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

-------
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

-------
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

-------
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-

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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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