United States Environmental Protection Agency
Region III
Corrective Action Program
Environmental Indicator Inspection Report
For
Philadelphia Coke Co., Inc.
4501 Richmond Street
Philadelphia, PA 19137
USEPA ID No. PAD000427906
Prepared By
aker
January 2012
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TABLE OF CONTENTS
Page
Purpose 1
Documentation Review 1
Attendees at Site Inspections 1
Meeting Summary 1
A. Location and Operational History of the Facility, Including all Wastes Generated
at the Facility and their Management 2
B. Description of all Solid Waste Management Units (SWMUs) and Areas of Concern
(AOCs) 14
C. Description of Exposure Pathways for all Releases or Potential Releases 31
D. Exposure Pathway Controls and/or Release Controls Instituted at the Facility 33
E. Follow-Up Action Items 40
LIST OF APPENDICES
Appendix A
Appendix B
Appendix C
Photographs
Figures
Inventory of Documentation and Reference Documents
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RCRA SITE INSPECTION REPORT
Purpose: To gather relevant information for the Philadelphia Coke Co., Inc. (PCC, facility, or site) in
order to determine whether human exposures and groundwater releases are controlled, as per
Environmental Indicator (EI) Determination forms.
Documentation Review: Prior to the site visit, Michael Baker Jr., Inc. (Baker) personnel conducted a
records review of the Pennsylvania Department of Environmental Protection (PADEP) South East
Regional Office and the United States Environmental Protection Agency (USEPA) Region III
Philadelphia Office files.
Attendees at Site Inspection:
Name Organization
Jamey Stynchula
Andrew Gilbert
Jennifer Wilson
Rick Schmitz
Meredith Reiner
GEI Consultants
PADEP
PADEP
National Grid
Baker
Phone
Number
856-608-6860
848-250-5771
484-250-5744
516-545-2569
609-807-9590
E-Mail Address
i stvnchula@geiconsultants .com
agilbert@pa.gov
iewilson@pa.gov
Richard.schmitz@us.ngrid.com
mreiner@mbakercorp.com
Meeting Summary: A meeting at the former facility property (facility or site) was held with the
attendees noted above on August 11, 2011. Ms. Reiner presented the property owner representatives
with information regarding USEPA Region Ill's Corrective Action process, the EI Assessment Program
and the legislation driving this program. Under this investigation, USEPA Region III is focusing on two
interim Els to evaluate whether any unacceptable risk to human health and/or the environment is ongoing
at each priority facility. The two indicators are determining if human exposures and groundwater
releases are controlled. Prior to and during the site inspection, outstanding issues and discrepancies
encountered in the file review summary were discussed.
The site visit continued with an overview of areas to be observed and a tour of the former facility.
Photographs of the property are presented in Appendix A: Photographs.
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A. Location and Operational History of the Facility, Including all Wastes Generated at the
Facility and their Management
Site Layout and Background Information
Site Layout
The facility was located at 4501 Richmond Street, Philadelphia, Pennsylvania, on a flat, 63-acre
industrial site in the "Bridesburg Section" of Philadelphia (Appendix B: Figure 1 - Facility Location
Map). The property is bordered by Richmond, Orthodox, and Buckius Streets, as well as the
Delaware River. The main portion of the property, north of the former railroad tracks, is entirely
enclosed by a chain linked fence. The property is ten feet above sea level.
The facility had various operations including coke storage, coal storage, coke oven batteries, a rail
line, a smoke stack, decanter tar bottoms, gas holders, a boiler house, a machine shop, and other
structures (Appendix B: Figure 2 - Former Facility Operations and Appendix B: Figure 3 Facility
Layout, Main Area) and fuel blending operations (Appendix B: Figure 4 - Facility Layout, South
Area).
The site visit confirmed that all operations of the facility have been decommissioned, dismantled, and
removed, with only cracked portions of concrete pads and asphalt paved areas remaining. The entire
property is now overgrown with trees, brush and high grasses. Several piles of debris were identified
among the brush and portions of the fence have been cut and evidence of vandalism was noted.
Background Information
PCC operated a gas manufacturing and coke production facility in Philadelphia County, Philadelphia,
Pennsylvania. The facility was active from January 1929 until its permanent closing on May 12,
1982.
The facility was decommissioned, the structures were dismantled, and various cleanup and closure
activities took place from 1982 through 1988, ultimately removing 30,000 tons of contaminated soil
and operational related wastes. The site also underwent various environmental investigations
including groundwater monitoring and soil sampling activities. Certified closure of the facility was
provided to PADEP in December 1994. As a result of stabilized groundwater monitoring trends of
contamination, PADEP terminated the groundwater monitoring requirement in 1999. Available
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documentation does not indicate that any formal release of liability was applied for or extended to the
facility.
During its active years, the facility produced upwards of 220,000 tons of coke annually. The facility
operated as a large quantity generator (LQG) of hazardous waste under the USEPA facility
identification No. PAD000427906. Historical air permits are on file with the City of Philadelphia but
are not presented in this report due their irrelevance in lieu of the closure of the facility. The facility
also operated under a National Pollutant Discharge Elimination System (NPDES) permit No.
PA0011401 for effluent discharge to the Delaware River. Historically, industrial waste discharged to
the Delaware River via a pipe that ran underground throughout the property. Various operations'
discharges and stormwater discharged to the river (Appendix B: Figure 3 - Facility Layout, Main
Area). There were historical effluent concentration exceedances of cyanide and minor oil leaks from
Outfall 001.
The facility was operated by PCC from 1929 to 1982. According to a 1942 land use map, the
property was owned by the Koppers Company (Koppers), which held the controlling interest in a
joint venture with Eastern Enterprises. In 1950, Eastern Enterprises split from Koppers. PCC was a
division of Eastern Associated Coal Corporation, a subsidiary of Eastern Enterprises. A 1962 land
use map identified the facility was owned by PCC, which maintained ownership during the facility's
decommissioning.
In November 2000, Key Span Corporation acquired Eastern Enterprises. Subsequently, in February
2007, National Grid USA purchased KeySpan Corporation. The City of Philadelphia Property
Assessors website (accessed March 31, 2011) and stormwater website (accessed April 5, 2011)
identified the property as being owned by Eastern Enterprises.
Land Use
The use of the property currently remains idle, with no development since the facility's closure. The
surrounding properties are mixed commercial, industrial, and residential uses.
According to the March 21, 2007 development review, PADEP designated the site as a Brownfield
Action Team (BAT) Site (BAT0020) to encourage redevelopment. Thus, current plans for the vacant
property include the development of 2,115 housing units (apartments and townhomes) and retail units
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that will extend along the waterfront. The property is zoned as a Waterfront Redevelopment District
(WRD). The City of Philadelphia Property Assessors website identifies the property as zoned Heavy
Industrial. The property is served by public water and sewer.
Waste Types and Quantities
During its operation, the facility primarily used bituminous coal with some anthracite coal to produce
foundry coke. The principal source of the waste materials from the coking operations was the coke
gas cleaning system. The process generated hazardous wastes including: waste liquor, decanter tank
tar sludge (K087) and spent iron oxide (containing cyanide and phenol). The wastes were stored on
site prior to off-site disposal. Historical wastes contained in solid waste management units (SWMUs)
were removed during 1982 closure and 1988 cleanup activities (summarized in the Investigations and
Remedial Action to Date section).
Releases
There were three release incidents identified at the facility from review of documents: 1) an
inspection in April 6, 1971 that identified illegal discharges to the Delaware River; 2) on September
16, 1976, an oil discharge (estimated at 1 gallon) originated from a small coal tar impoundment and
seeped through a crack in a cooling water discharge trench; and 3) in March 23, 1981 observation of
an unpermitted discharge of water resulting from a work crew attempting to clear a blockage in a line
by pumping water from the No. 7 manhole onto the ground. All of these releases were reported to
PADEP and corrected. Additional details are provided in the NPDES section.
Appendix C contains an inventory of documents and references used in this report.
Permit and Regulatory Action History
Waste
A Notification of Hazardous Waste Activity was made to the USEPA on August 13, 1980. The
USEPA issued facility identification No. PAD000427906 on October 9, 1980. The facility submitted
the Part A Hazardous Waste Permit Application on November 18, 1980. On December 23, 1980, the
USEPA acknowledged receipt of the Part A Hazardous Waste Permit Application. The USEPA
confirmed on July 24, 1981 that the facility could generate hazardous waste as an interim status
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facility.
On October 22, 1982, PCC notified PADEP that the facility had terminated manufacturing operations
at 9 a.m. on May 12, 1982 and that they were working with a consultant to remove hazardous wastes
from the site.
PADEP requested the Part B Hazardous Waste Permit Application on October 27, 1982.
The facility notified PADEP on December 28, 1982 that the removal of hazardous wastes was
complete. The facility indicated that they anticipated installing 10 to 12 monitoring wells at the site
after completing negotiations with their consultant. In June 1983, Roy F. Weston (RFW) submitted a
Closure Plan for the facility (summarized in the Investigations and Remedial Action to Date section).
On July 5, 1983, PADEP sent the Philadelphia Health Department a copy of the Closure Plan for
review. On August 1, 1983, they responded with comments and questions dealing with contractor
procedures.
On October 27, 1983, PADEP issued a Notice of Violation (NOV) for not complying with the
groundwater monitoring requirements, because the monitoring wells had not been installed. On
November 9, 1983, PCC responded to the NOV by citing that 4,400 tons of hazardous waste had been
removed and "that if there was a violation of the regulations, the cause of the violation will have been
eliminated by the removal of the waste materials from the site. I do not believe the installation of
wells is necessary".
On December 13, 1983, PADEP accepted the Closure Plan with the provision of assessing possible
groundwater contamination via monitoring wells and a sampling plan. On March 30, 1984, PADEP
requested documentation of the disposition of hazardous materials and again requested information
about PCC's groundwater monitoring program. On April 13, 1984, the facility responded and
enclosed a December 6, 1983 letter that was sent to PADEP documenting the final disposal and
indicated that information concerning groundwater would be provided at a later date after leaks in the
water mains associated with the fire system were repaired.
On August 17, 1984, Kipin Industries Inc. (Kipin) on behalf of the facility provided PADEP with a
site map that illustrated the locations of the proposed monitoring wells and a sketch of a typical well
(i.e., a "Sampling Plan"). The letter indicated that PCC was in the process of retaining Woodward-
Clyde Consultants (WCC) under contract to manage the investigation
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On August 31, 1984, the USEPA requested submittal of the Part B Hazardous Waste Permit
Application. PCC responded on September 18, 1984 that no Part B Hazardous Waste Permit
Application would be filed as the facility was no longer operational and was closed.
On February 21, 1985, the USEPA provided PADEP comments and requested changes to the Draft
Sampling and Analysis Plan. On March 4, 1985, WCC provided a revised Sampling and Analysis
Plan to PADEP.
On July 16, 1985, WCC sent PADEP a Hydrogeological Assessment which was conducted at the
facility. Analytical results for the second, third and fourth quarter groundwater sampling events were
provided to PADEP on September 26, 1985, January 17, 1986, and April 8, 1986 respectively
(summarized in the Investigations and Remedial Action to Date section).
On September 12, 1985, PADEP approved the June 1983 Closure Plan.
On April 15, 1986, WCC submitted a soil sampling program work plan to PADEP for review. The
USEPA commented on the work plan on May 8, 1986, recommending changes to sample collection.
On July 11, 1986, PADEP issued an NOV for bonding requirements for post-closure care.
On July 15, 1986, PADEP issued an NOV for quarterly monitoring deficiencies. PADEP indicated
that monitoring well W-2 may not have been representative of background groundwater quality,
parameters had not been monitored in quarterly during the background year, replicate measurements
from the upgradient monitoring well was not obtained, and an annual evaluation of groundwater
surface elevations was not performed.
On August 27, 1986, WCC submitted the revised work plan for the soil sampling program including
five sample locations including: 1) the waste liquor pit, 2) underground storage tank area, 3) decanter
tar bottoms area, 4) tar plains, and 5) lime pit. PADEP approved the plan on September 18, 1986 as
noted in the 1992 Engineer's and Owner's Certification of Closure for WMUs. Following the
sampling, PADEP requested a map identifying areas of waste management units (WMUs) on October
31, 1986.
On January 29, 1987, WCC submitted a Hydrogeologic and Soils Investigation report (summarized in
the Investigations and Remedial Action to Date section).
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On July 22, 1987, the facility noted that the Federal regulatory arena favored using technologies
which ultimately destroy or detoxify wastes rather than transferring them to a disposal area. Thus, the
facility advanced options such as bioremediation or other remedial technologies.
On January 28, 1988, the facility sent a follow-up letter following the December 21, 1987 meeting to
discuss anticipated closure approaches. It detailed cleanup levels for the polycyclic aromatic
hydrocarbons (PAHs).
On February 15, 1988, WCC submitted a Soil Contamination Assessment report in response to
PADEP's request to develop volume estimates of contaminated soil that must be handled at closure
(summarized in the Investigations and Remedial Action to Date section).
Later in February 1988, the facility submitted a Detailed Work Plan for Field Pilot Land Treatment
Tests; it was subsequently revised in July 1988. The test' objective was to evaluate the
biodegradability of coal tar-related contaminants in soil. The proposed treatment units would consist
of 16 feet by 24 feet plots and inoculated with naturally occurring microbes to digest coal tar
contamination.
On March 28, 1988, PADEP requested additional information to evaluate cleanup levels.
On April 6, 1988, WCC submitted information to PADEP following a meeting on the same day. It
further described the remediation program and gave a proposed schedule. On April 21, 1988, PADEP
approved the bioremediation pilot study, but indicated that total PAHs could not be used for soil
cleanup characterizations and cleanup levels would be set for specific compounds. Additionally,
WCC performed additional work to control infiltration/leachate from the stockpiles and proposed a
different procedure for determination of background groundwater quality. On May 20, 1988, WCC
proposed cleanup criteria and gave details of how materials would be excavated and stored. The sum
of concentrations of PAH compounds identified by USEPA as suspected carcinogens would be
limited to 50 parts per million (ppm) and no individual compound of the six carcinogenic polycyclic
aromatic hydrocarbons (CPAHs) would exceed 15 ppm. These were based on two other Records of
Decision (RODs) issued by the USEPA at the time for sites with similar contaminants. While it was
never officially approved by PADEP, WCC noted that it represented a reasonable and conservative
criterion.
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Closure activities proceeded in accordance with verbal authorization from PADEP on June 3, 1988
and documented in a June 16, 1988 WCC letter. The activities were initiated on July 12, 1988 and
completed on December 30, 1988. PADEP visited the site at least three times to review the cleanup
effort (Certification of Closure, 1992).
On February 6, 1989, PADEP sent an NOV following a January 18, 1989 inspection and requested
that the W-2 and W-4 be returned to proper operation (1982 to 1989 inspections). On February 22
1989, the facility responded noting that repairs would be made. On March 8, 1989, groundwater
samples were collected from the two newly replaced monitoring wells, along with the other four site
monitoring wells (Certification of Closure, 1992).
On February 24, 1989, WCC sent PADEP confirmatory analytical data for the backfilling operations,
that indicated the materials were non-hazardous, and requested authorization to backfill. PADEP
authorized the backfilling on June 20, 1989.
In September 1989, the facility submitted certification of closure documents and a site restoration
work plan. PADEP verbally indicated that they would not review the document until the coal tar-
contaminated soils were treated on site or removed. Thus, PADEP returned the documents to the
facility. A total of 29,400 tons of the soils were subsequently removed from the site and disposed as
residual waste (Certification of Closure, 1992).
On October 12, 1989, PADEP conducted an inspection and noted that the site was undergoing
closure. PADEP noted a hazardous waste determination should be performed on the two areas of
ground where blue stained rocks were observed (potentially cyanide). (Note: There was no further
documentation in the file concerning this specific area.) Also, PADEP requested that the facility
determine the exact extent of the waste oil contamination near the railroad right-of-way and dispose
of contaminated soils off-site. A plan to remediate the area was to be submitted to PADEP by
November 30, 1989. In May 1990, WCC submitted a Tank Farm Area Restoration Conceptual
Design report (summarized in the Investigations and Remedial Action to Date section).
On September 7, 1990, PADEP issued an NOV for failing to submit the required quarterly
groundwater monitoring reports. On September 7, 1990, WCC sent the quarterly groundwater report.
On November 6, 1990, PADEP sent a civil penalty payment request for failing to submit quarterly
groundwater monitoring reports.
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On January 8, 1991, PADEP collected a sample from MW-2R for volatile organic analysis following
identification of a compound tentatively identified as naphthalene, as well as a second sample
identified as C3-substituted benzene. All results exceeded 2.0 micrograms per liter (ug/L) and
benzene was 80 ug/L.
On June 11, 1991, PADEP enclosed an application for the soil remediation unit and noted that the
Philadelphia Department of Health should be contacted regarding air permits. On June 21, 1991,
PADEP informed the in-situ remediation contractor that they would need to prepare a groundwater
remediation and treatment plan to treat contaminated groundwater. PADEP remained concerned
regarding the appearance of dibenzofurans related to dioxin.
On December 1, 1992, WCC submitted a second Engineer's and Owner's Certification of Closure for
WMUs report, for SWMUs and hazardous waste management units (HWMUs) (Appendix B: Figure
5 - Waste Management Unit Location Map) (summarized in the Investigations and Remedial Action
to Date section).
On May 6, 1993, WCC submitted a Groundwater Monitoring Plan noting four monitoring wells
installed in March 1985 and two wells in 1987 (summarized in the Investigations and Remedial
Action to Date section).
On June 7, 1993, WCC sent PADEP notification that the seal pot, located in the former byproducts
building piping trench, was discovered during excavation activities and was cleaned in September
1992. Coal tar and debris were removed. WCC proposed closure procedures that would pump
surface water through a granular activated carbon filter with discharge on-site. Additionally, WCC
proposed to fill the seal pot with concrete immediately upon pumping out all surface water, and fill
the access excavation above the seal pot to grade with adjacent on-site fill.
On September 16, 1993, PADEP responded to the facility's September 2, 1993 letter and requested an
amendment to the Groundwater Monitoring Plan. PADEP noted that naphthalene, benzene, toluene,
ethylbenzene, and ammonia nitrogen were potentially mobile and quarterly analysis would continue
for benzene, toluene, ethylbenzene, and xylenes (BTEX), trichloroethene (TCE), and
tetrachloroethylene (PCE), and the PAHs. The remaining parameter analysis plan was satisfactory.
In addition, PADEP approved leaving the seal pot in-place for closure.
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On September 16, 1993, WCC submitted a grading plan for the site. The remaining six buildings
were removed in August 1993.
On December 3, 1993, WCC sent PADEP a Certification of Closure for the seal pot in response to
PADEP's November 22, 1993 inspection. It noted that closure activities were completed on October
19, 1993 and that solid materials classified as characteristically hazardous for benzene (DO 18) were
removed in September 1992.
On September 28, 1994, Eastern Enterprises notified PADEP of the proposed plan to complete the
grading program. It noted that clean soil would be imported and spread approximately 6 inches thick.
On December 23, 1994, a Certification of Closure was signed for the facility formerly known as the
Philadelphia Coke Company and located at 4501 Richmond Street, Philadelphia, Pennsylvania in
accordance with the closure plan approved by PADEP on December 13, 1983.
On March 13, 1996, an inspection noted that the facility was abandoned and that groundwater
sampling was conducted on September 8, 1994 and on March 13, 1996.
Comprehensive Groundwater Monitoring Evaluations (CMEs) were conducted by PADEP in 1996
and 1997 (summarized in Investigations and Remedial Action to Date section).
On March 23, 1998, WCC requested approval of the revised groundwater monitoring program. It
noted that monitoring of the six wells sufficiently defined future trends in groundwater constituents.
WCC requested PADEP's concurrence with this report and requested that monitoring be changed
from quarterly to annually. On September 14, 1998, PADEP approved the request to reduce the
monitoring frequency from quarterly to annually.
On July 26, 1999, PADEP reviewed relevant groundwater monitoring data for quarterly sampling
events from 1985 through 1998 noting concentrations of contaminants of concern (COCs) had
significantly decreased. Iron, manganese, specific conductance, potassium, sodium, calcium,
magnesium, sulfate, and chloride remained elevated even after the removal of wastes in 1988. It
noted that benzene and naphthalene in groundwater collected at MW-2R were above the Safe
Drinking Water Act (SDWA) maximum contaminant levels (MCLs), but had not migrated to
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downgradient sampling points and no other wells exhibited elevated results and deemed the
exceedances localized for the past five years. As elevated levels for the remaining constituencies
persisted throughout the groundwater monitoring program both before and after the Resource
Conservation and Recovery Act (RCRA) clean-up activities, PADEP deemed them a natural
phenomenon and indicated groundwater quality was stable. PADEP thus terminated the monitoring
requirement.
On October 27, 1999, a CME inspection was conducted by PADEP (summarized in the Investigations
and Remedial Action to Date section).
On March 3, 2000, PADEP responded to Eastern Enterprise's request for the release of the bond held
for closure and post-closure liabilities. The release was not possible until the post-closure care period
of liability expired on July 26, 2000.
Air
The City of Philadelphia has facility files related to air permitting for the facility. Note: As PCC is no
longer operating and air emissions are irrelevant, these files were not reviewed for this report.
NPDES
On March 1951, the Commonwealth of Pennsylvania, Department of Health issued an Industrial
Wastes Permit (No. 1379) to PCC for the proposed works for treatment of wastes from the facility's
coke, gas and coal chemicals production for discharge to the Delaware River. The permit included
the intermediate treatment of sewage requirement of: 75% removal of suspended solids; 65% removal
of organic pollution load; removal of oils, grease, acids, alkalis, toxic, putrescible, taste and odor
producing substances; provide effective disinfection; and disposal of sludge.
Process wastewaters generated at the facility were discharged to municipal sewers (included ammonia
still liquors to the sanitary sewer). Chlorination was used as a pretreatment to remove cyanide and
sulfide compounds. All other wastewater (predominantly non-contacting cooling water generated
from the liquor plate cooler, barometric condenser, and the gas cooler) as well as some stormwater,
was discharged to the Delaware River via Outfall 001. An oil-skimming device was installed at the
outfall and was put in use prior to commencing effluent discharge (Appendix B: Figure 4 - Facility
Layout, South Area).
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On May 20, 1971, PADEP issued an NOV to the facility following an inspection on April 6, 1971
that identified illegal discharges to the Delaware River. On July 1, 1971, the facility submitted a
discharge application to the U.S. Army Corps of Engineers (USACE).
On January 3, 1972, a court stipulation was enacted against the facility to conduct testing for cyanide
discharges. On August 25, 1972, PADEP issued an NOV for having discharges without a permit. On
February 1, 1973, PADEP made notification that meetings were held regarding the illegal discharge
in late 1971. These meetings were held to resolve differences in cyanide test results between PADEP
and PCC analytical methods.
On December 1, 1973, the facility submitted an Engineering Study of Industrial Wastewater
Management. The facility submitted the study to the Delaware River Basin Commission (DRBC) on
December 10, 1975.
An NPDES permit was issued to PCC on August 9, 1974 by Water Quality Management, Norristown,
with the condition that an application for a Pennsylvania permit would result within 90 days.
On December 19, 1975, the facility notified the DRBC that it submitted its discharge permit
application and fee. PCC noted that on March 3, 1951, the Pennsylvania Sanitary Water Board issued
the facility Permit No. 1379 and that PCC applied to the USACE (and subsequently processed by
USEPA) on May 1, 1972 to discharge wastewater to the Delaware River under NPDES permit No.
0011401.
On January 7, 1976, PADEP notified the facility that the Pollution Incident Prevention Plan (PIPP)
(the precursor to the Preparedness, Prevention, and Contingency Plan) was unsatisfactory. PADEP
received a revised PIPP from the facility on February 18, 1976.
On February 9, 1976, PADEP notified the facility that the permit application had been reviewed and
that some issues needed resolved, including an unsatisfactory PIPP. These modifications were
necessary to the quench station to prevent periodic overflow. On February 18, 1976, the facility
responded by noting that operational changes had been made. On July 28, 1976, PADEP approved
the permit. On September 30, 1976, the DRBC approved Water Quality Management Permit No.
5175203.
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On September 16, 1976, the facility notified PADEP that an oil discharge (estimated at 1 gallon)
originated from a small coal tar impoundment had seeped through a crack in a cooling water
discharge trench and entered the sewer line. On March 3, 1977, PADEP requested a PIPP following
an inspection. PADEP issued an NOV on January 10, 1978 following a discharge of oil from the
skimmer basin.
On May 23, 1978, PADEP issued the facility an NOV for exceedances in cyanide and ammonia
concentrations. On June 1, 1978, the facility indicated that cyanide and ammonia concentrations from
their samples were less than those sampled and reported by PADEP. PCC believed the source of the
leak may have been the quench station, which comes from the final gas cooler.
On July 2, 1979, PADEP notified the facility that they were in violation of Permit No. 5175203 for an
observed oil discharged to the skimmer basin and an elevated concentration of cyanide from the
sample collected during the May 8, 1979 inspection. On July 20, 1979, the facility notified PADEP
that oil leakage from the oil skimmer had been stopped, and that PCC's duplicate sample exhibited a
considerably lower concentration of cyanide.
On March 27, 1981, the facility responded to the March 23, 1981 observation of an unpermitted
discharge of water resulting from a work crew attempting to clear a blockage in a line by pumping
water from the No. 7 manhole onto the ground.
On July 6, 1981, PADEP notified the facility of several violations relating to the unpermitted water
discharge and several housekeeping items at the facility. The facility responded on July 28, 1981,
noting that the extraneous plank was removed from the oil skimmer along with oil-soaked pads and
booms.
On February 22, 1982 and May 21, 1982, PADEP sent the facility a notice that PADEP samples for
cyanide from Outfall 001 had high concentrations, resulting in an NOV being issued. PADEP issued
an NOV on August 12, 1982 for failing to submit the discharge monitoring report (DMR). On June
28, 1982, PCC indicated that all production ceased on May 12, 1982 and the facility effluent was
plugged near the outfall and rendered out-of-service and the facility would be demolished in the
future.
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B. Description of all Solid Waste Management Units (SWMUs) and/or Areas of Concern
(AOCs)
SWMUs
The 1992 Engineer's and Owner's Certification of Closure for WMUs report for SWMUs and
HWMUs provides details of closure and monitoring for the following areas (Appendix B: Figure 5 -
Waste Management Unit Location Map):
AiVii
S\\ MI
IIWMl
Tar Storage Tanks (K087)
X
Waste Liquor Pit (K087)
X
Trash Pile
X
Tar Plains (K087)
X
Clean Oxide
X
Wood Trays
X
Tar Decanters and Lagoon (K087)
X
Iron Oxide Boxes and Pile (D003)
X
Process Piping
X
The SWMUs and HWMUs were certified as closed following various closure and cleanup activities
(summarized in Investigations and Remedial Action to Date section).
Storage Tanks
There are no available records documenting the facility maintained PADEP-registered aboveground
storage tanks (ASTs) and/or underground storage tanks (USTs).
Tar Storage Tanks
The facility had two aboveground steel tanks that were used to store product coal tar from coal gas
cleaning operations with estimated capacities of 1,000,000 and 500,000 gallons (Appendix B: Figures
2 and 3). These tanks are summarized in the Engineer's and Owner's Certification of Closure for
WMUs (1992) report in the Investigations and Remedial Action to Date section.
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Fuel Blending Tanks
Aboveground fuel blending tanks were located south of the main area of the facility located between
the railroad tracks (Appendix B: Figure 4 - Facility Layout South Area). One tank farm had concrete
secondary containment for four fuel tank foundations, as described in the Tank Farm Area
Restoration Conceptual Design (1990). Fuel types and tank specifications remain unknown. The two
fuel oil tanks, located west of the tank farm, were surrounded by earthen dikes. The tank farm was
identified as "not RCRA" by PADEP (August 29, 1990).
Fresh and Spent Oil Tanks
During closure activities, the one fresh oil tank remained on site was filled with clean sand; the one
spent oil tank was removed and scrapped, as documented in the Engineer's and Owner's Certification
of Closure for WMUs report (1992). The USTs were located adjacent the fuel gas holder foundation
in the former decanter area.
USTs
Seven USTs were reported to have been removed at PCC, completed between July 11 and 15, 1991
per the July 1991 Monthly Status Report dated July 17, 1991. Some visual indication of
contamination was observed during the removal of the gasoline UST. PADEP's Storage Tank
Department was contacted, and the excavation was backfilled for safety reasons. No other visual
contamination was observed. Soil samples were collected for the closures and WCC stated they
would be preparing reports summarizing the UST removal activities. Note: No closure reports were
found during the file search.
AOCs
There were no other AOCs identified at the site which were not already designated as a HWMU or
SWMU.
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Investigations and Remedial Action to Date
Initial Removal of Hazardous Waste, 1982
On October 22, 1982, PCC notified PADEP that the facility had terminated manufacturing operations
at 9 a.m. on May 12, 1982 and that a consultant, Clean Venture, Inc. (Clean Venture), was retained to
remove hazardous wastes from the site.
The facility notified PADEP on December 28, 1982 that the removal of hazardous wastes was
complete. The facility indicated that the tar decanters and other production equipment had been
removed and scrapped and the open pits cleaned and filled. The total amount of tar waste material
shipped to an offsite landfill was 4,481.40 tons.
In addition to confirming the waste removal, PCC indicated that two meetings had been held with
representatives from the RFW. These meetings discussed preparing a closure plan for the facility as
well as anticipating the installation of 10 and 12 test wells at the site.
Closure Plan, 1983
In June 1983, RFW submitted a Closure Plan for the facility. During closure, the site was surrounded
by a six-foot fence and a security firm provided guard services. The plan noted the closure of the
facility and the removal and disposing of remaining decanter tar waste and spent iron oxide. The
storage area for the decanter tar waste consisted of three open pits, two of which were concrete-lined
and one having an earthen bottom. This area was identified in Part A Hazardous Waste Permit
Application as surface impoundment storage (S04) with a capacity of 40,000 gallons. The spent iron
oxide was stored on an asphalt pad and in oxide boxes. This area was identified as waste storage area
(S03) with a capacity of 2,000 cubic yards (CY). In addition approximately 1,800 cy of tar decanter
waste (K087) and 2,800 cy of spent iron oxide which were generated during operations prior to
closure were stored on-site prior to off-site disposal. Also, an inspection identified tar remaining in
the two storage tanks and an area (tar plains) surrounding the trash pile (Appendix B: Figure 3 -
Facility Layout, Main Area). Specific areas to be addressed by the closure plan and estimated
quantities included:
• Tar storage tanks (decanter sludge - 650 cy)
• Waste liquor pit (ammonia sludges and tar sludge - 275 cy),
• Trash pile (cleanup tar waste, coal fines, other debris - 2,000 cy)
16
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• Tar plains (decanter tar waste - 2,200 cy),
• Clean iron oxide (unused iron oxide - 2,000 cy)
• Wood trays/wood debris (300 cy)
• Tar decanters (tar decanter waste - 1,800 cy)
• Iron oxide boxes and pile (spent iron oxide - 2,700 cy)
• Process pipe (asbestos-containing insulation -100 to 150 cy)
Prior to demolition, the process and residual piping were steam cleaned with residues collected and
disposed. The remaining chemicals such as sulfuric acid were sold to other firms.
The Closure Plan indicated that during closure, all hazardous wastes were to be removed from onsite
storage. Since the site does not have any hazardous waste disposal facilities, groundwater monitoring
was determined to not be required at closure in accordance with the Pennsylvania hazardous Waste
Management Regulations (see Sections 75.265 (s) (8) and 75.265 (n)). The Closure Plan also stated a
Post-Closure Plan was not required because the site is not a disposal facility, and all wastes were
being removed at closure.
Hydrogeological Assessment, 1985
On July 16, 1985, WCC sent PADEP a Hydrogeological Assessment report which was conducted at
the facility. Four monitoring wells (W-l through W-4) were installed in March 1985 to assess
groundwater quality. The results from the first of four groundwater sampling events indicated the
groundwater flow direction was observed to be radially outward from a central high point at W-2
(Appendix B: Figure 6 - Groundwater Contour Map).
The sediments at the site consist of recent alluvial floodplain and channel deposits, which are overlain
by man-made fill material (sand, brick fragments, coal and cinder). The uppermost natural deposit
encountered in the monitoring wells was a brown to gray, fine to coarse sand containing clay, silt and
gravel. Below the sand is a sequence of very soft, silty clays deposited by the Delaware River. The
wells were advanced 2 to 7 feet into the clay unit and terminated. The clay layer acts as a lower
confining unit to groundwater in the overlying recent deposits and was, therefore, not penetrated. An
historical boring indicates the silty clay layer is approximately 20 feet thick. Underlying the silty clay
layer is a sequence of sand and gravel of varying thickness which lies directly on crystalline (mica
schist) bedrock (WCC, 1987).
17
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Groundwater samples were analyzed for volatile organic compounds (VOCs), base/neutral
compounds, acid-extractable compounds, groundwater quality parameters and contamination,
Appendix II parameters, and additional inorganic parameters. No priority pollutant compounds were
detected in groundwater collected from W-l. The sample collected at W-2, located near old lagoons
in the center of the site, contained a relatively high concentration of acid-extractable compounds,
particularly phenol at 2,710 parts per billion (ppb) and 2,4-dimethylphenol at 27,600 ppb. Other than
methylene chloride, volatile organic compounds detected in W-2 include benzene (143 ppb), toluene
(60 ppb), and ethylbenzene (3.0 ppb). Base/neutral compounds detected in W-2 include nitrobenzene
(90 ppb) and bis (2-chloroethoxy) methane (15 ppb).
It was concluded from the groundwater levels and quality that the PCC site is not presenting a threat
to groundwater contamination in the surrounding environment. Three additional quarterly rounds of
groundwater sampling were scheduled.
On September 26, 1985, WCC supplied PADEP the analytical results of the second quarter
groundwater sampling event. W-l, located near the former tar plains at the property perimeter, and
W-2, located near the former tar decanter bottoms and center of the site, contained VOCs, notably
benzene and toluene, and several base/neutral compounds, most notably acenaphthene. W-2 also
contained ethylbenzene, phenol, and 2,4-dimethylphenol. Other inorganic compounds were also
observed at elevated concentration, such as: cyanide, chloride, sulfate, arsenic, sodium and iron, with
the highest concentrations observed in samples from W-2. These results were consistent with the
results from the first quarter. Groundwater was again determined to flow radially outward from a
central high located near W-2.
On January 17, 1986, and April 8, 1986, WCC sent the analytical results for the third and fourth
quarters of groundwater sampling, respectively. Noted concentration trends identified in the
previous two rounds continued, with W-2 exhibiting the highest concentrations.
Hydrogeologic and Soils Investigation, 1987
On January 29, 1987, WCC submitted a Hydrogeologic and Soils Investigation report to assess the
site's subsurface geologic, groundwater flow, and soil and groundwater quality conditions, as well as
evaluate the effectiveness of the previous site clean-up activities. The purpose was to evaluate the
degree of contamination and document the presence or absence of residual hazardous materials in the
subsurface and to assess the groundwater quality in the water-table aquifer based on the groundwater
18
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sampling conducted in 1985 and 1986. In October 1986, two additional monitoring wells (W-5 and
W-6) were installed to better define the groundwater flow between W-2 and W-4 as illustrated on
Appendix B: Figure 6 - Groundwater Contour Map. All six monitoring wells at the site were installed
in the upper water table aquifer which is comprised of miscellaneous fill, gravel, sand, and silt
extending from the ground surface to a confining and relatively impermeable organic silty clay layer
at a depth ranging from 1 to 14 feet below ground surface (bgs).
Detected VOCs (benzene, methylene chloride, toluene, and ethylbenzene) were limited to
groundwater collected from W-l and W-2. The VOCs did not appear to follow any trend over the
four rounds of sampling. Acid extractables (phenol and 2,4-dimethylphenol) were restricted to W-2.
Fifteen priority pollutant base/neutral extractables were detected in the groundwater including:
acenapthene, acenaphthylene, benzo(a)anthracene, benzo(a)pyrene, bis(2-chloroethyl)ether, bis(2-
chloroethoxy)methane, bis(2-ethylhexyl)phthalate, 2,6 dinitrotoluene, fluorene, fluoranthene,
naphthalene, phenanthrene, pyrene, hexachloroethane and nitrobenzene. Seven quarters of
groundwater samples were collected and analyzed from April 1985 through October 1986.
Soil Sampling Results
As there was no confirmatory sampling during the closure/removal activities, PADEP and the
USEPA requested additional investigations of the following areas to determine the effectiveness of
the previous clean-up activities. The sampling was to determine the presence of contamination, not
delineate the extent of contamination. A total of 18 soil samples (including one background sample)
varying from a depth of 6-inches to 10 feet were collected for priority pollutant organic analyses
(VOC, base/neutral extractables, and acid extractables).
Decanter Tar Bottom Area: Seven shallow borings were advanced (six to nine feet bgs) in the
decanter tar bottoms area (near the center of facility) to assess the effectiveness of the waste removal
program. The area consists of two concrete lined pits, 10 feet wide, 12 feet long, and 8 feet deep and
an earthen lined lagoon, 15 feet wide, 75 feet long, and 8 to 10 feet deep. All borings within the pit
displayed evidence of contamination including elevated organic vapor readings (screened with an
HNU photoionization detector [PID]), strong odors, visible staining of fill materials suggesting that
tar materials were present, and detection of 15 coal tar related base/neutral extractables. The fill
materials inside the lagoon contain the highest concentrations (62,100 to 568,100 ppb) of total
base/neutrals extractables. Outside the lagoon within the fill materials, the total base/neutral
19
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extractables concentrations decline substantially (2,420 to 16,530 ppb). Methylene chloride (29 ppb
total), benzene (80 ppb total), toluene (50 ppb total), and ethylbenzene (84 ppb total) were detected in
the samples.
Tar Plains: Three soil samples (collected randomly from nine possible sample locations) were
collected in the tar plains area (in the southwestern corner of the plant). Samples were composited
over the 6 to 18 inch depth interval at each location. Observations included staining, odors, and an
oily sheen. Analytical results indicated the presence of coal tar related base/neutral extractables, acid
extractables were not detected, and VOCs were limited to low levels (methylene chloride [27 ppb
total], benzene [6 ppb total], and toluene [22 ppb total] were detected in the samples..
Lime Pit: Along the western boundary of the facility, one boring advanced to 10 feet bgs, was use to
evaluate the Lime Pit. From 0 to 5 feet, a mixture of dry sand and fill materials were encountered. At
a depth of 5 feet, a resistant layer 16 inches thick, of white to gray cemented sand sized material was
encountered. Below a depth of 5.5 feet bgs, the water table was encountered and the subsurface
materials appeared stained and had a strong odor. Soil samples for chemical analysis B-9A and B-9B
were collected at depths of 4 to 6 and 8 to 10 feet, respectively. Results of priority pollutant volatiles,
acid, and base/neutral extractable analyses indicate the presence of base/neutral extractable
contamination. All sixteen coal tar related base/neutral compounds were detected in the two lime pit
soil samples. Total base/neutral concentrations of 102,940 ppb (B-9A) and 51,520 ppb (B-9B) were
reported. Additional priority pollutant compounds detected were reported at significantly lower
concentrations; phenol (570 ppb), benzene (10 ppb), and toluene (5 ppb) in sample B-9B.
Waste Liquor Pit: This area was a concrete lined rectangular pit to store tar sludges, acids, and spent
solvents. Soils from a single boring (advanced to 12 feet bgs) were stained and had a very strong
odor at the water table (6.5 feet). A silty clay unit was encountered at a depth of approximately 9 feet
bgs. Analytical results for soil sample B-8A (collected at the 8 to 10 foot-depth interval) revealed
contamination restricted to base/neutral extractable compounds. Fifteen of the sixteen coal tar related
base/neutral compounds were detected. A total base/neutral extractable concentration of 57,190 ppb
was reported. No VOCs were detected.
Site Background: A single "background" surface soil sample (at the northwest corner of the site; 6 to
12 inch interval) had no visible signs of contamination, but 11 of 16 detectable coal tar related
base/neutral extractable compounds were detected in the sample. No background subsurface soil
20
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samples were collected.
Groundwater: Water Quality Standards. Conclusions. Recommendations
Water Quality Standards: During seven rounds of water quality samples, the proposed guidelines for
primary and secondary drinking water parameters were exceeded for nine parameters at the facility.
• Primary: W-2 had benzene, fluoride, chromium, and cyanide exceedances of prescribed limits
for various quarters.
• Secondary: Iron, manganese, nitrate, total dissolved solids (TDS), and sulfate exceeded the
standards at least one round of monitoring in all four monitoring wells.
In addition, the following parameters exceeded other guidelines such as the Recommended MCL
(RMCL) for parameters that did not have MCLs at the time of the study including: 2,5-
demethylphenol, acenaphthene, benzo(a)anthracene, benzo(a)pyrene, bis(2-chloroethyl)ether,
fluoranthene, fluorene, hexachloroethane, phenanthrene and pyrene.
Conclusions: The report concluded that groundwater was monitored in a shallow, unconfined aquifer
beneath the facility and its quality has been impacted by previous waste management practices.
Underground utilities have a hydraulic effect on groundwater flow (Appendix B: Figure 6 -
Groundwater Contour Map). W-2 exhibited the highest level of contamination, resulting from the tar
decanter area storage. Contaminated soils were present in the subsurface. Additional site
remediation was warranted and contaminated soils would continue to be a source of contaminants to
the groundwater. Waste materials were still present in the subsurface at the tar decanter area. A
closure plan to address the closure of WMUs and continued groundwater monitoring was
recommended.
Recommendations: The report recommended continuing quarterly groundwater monitoring of the
original four wells with reduced analytical parameters, semi-annually sample W-5 and W-6 and
additional new wells, install additional shallow wells to further delineate the contaminant plum near
W-2, install deeper wells to investigate the deeper aquifer, and further investigation the tar decanter
area soils. Note: No information was found during the file search indicating deeper wells were
installed at the site.
21
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Soil Contamination Assessment, 1988
On February 15, 1988, WCC submitted a Soil Contamination Assessment report in response to
PADEP's request to develop volume estimates of contaminated soil that must be handled at closure.
Thus, the facility conducted an exploratory soil boring program in December 1987 via 67 borings on
a grid pattern to delineate the extent of soil contamination. Analysis was completed via fluorometric
analyses of 343 samples on site and via laboratory analyses for quantification of individual
compounds. The assessment enabled a detailed delineation of the three-dimensional extent of soil
contamination in the former coking operations area. Using a site-specific background level of 100
ppm of total PAHs, the total quantities of soil above this level was approximately 22,000 cy of
materials, of which 3,000 cy consisted of residual tar materials for off-site disposal and 19,000 cy of
soils were amenable to on-site biological degradation treatment. Soils would be excavated to a
maximum depth of 10 feet.
Composite confirmatory soil sampling was conducted in the area of the former coking operations and
results provided to PADEP on February 24, 1989 (Appendix B: Figure 7 - Confirmatory Soil Sample
Areas). The cleanup criterion of 50 ppm (set forth in their May 20, 1988 letter) of the suspected
carcinogenic PAH compounds were achieved. Backfilling will be completed with imported fill. On
June 20, 1989, PADEP approved backfilling in the areas.
Tank Farm Area Restoration Conceptual Design, 1990
In May 1990, WCC submitted a Tank Farm Area Restoration Conceptual Design report which
included an evaluation of the former tank farm area used to blend fuel oils for off-site customers and
conceptual design for the biorestoration of the area. It aimed to mitigate fuel oil contamination of fill
soils and shallow perched groundwater in the area. The area was 2.5 acres and located at the edge
(south area) of the property nearest the Delaware River (Appendix B: Figure 4 - Facility Layout,
South Area). The area contained two diked tank farms, a pump house, and a boiler house. It was
served by a railroad siding and truck loading station. The tanks were demolished and removed, and
secondary structures demolished to ground level. One tank farm had concrete secondary containment
for four fuel tank foundations; the second tank farm held two fuel oil tanks surrounded by earthen
dikes. No aboveground facilities exist, and several underground structures remain, but are believed to
be inactive and sealed (except at the second tank farm area).
Test pits revealed that the fill consisted of predominately sand and gravel, with some silt and rubble.
The depth to water in the fill was approximately 3.5 feet bgs. A thin layer of floating oil (separate
22
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phase liquid [SPL]) was present at the top of the saturated zone. TPH ranged from 80 ppm to greater
than 20,000 ppm. Total PAHs were detected in a composite surface soil sample (3.7 ppm) and
polychlorinated biphenyls (PCBs) were undetected in two surface soil composite samples.
Two monitoring wells (MW-13 and MW-14) were installed in December 1989 in the thin saturated
zone of the fill down gradient of the tank farm. Samples collected in January 1990 were analyzed for
total petroleum hydrocarbons (TPH) and PAHs; both down gradient wells indicated levels of TPH
contamination. Detected PAHs in MW-13 were said to be attributable to the suspended silt in the
groundwater sample.
In March 1990, a pumping well (PW-1) and two piezometers (P-l and P-2) were installed to perform
a pump test to evaluate saturated zone hydraulic characteristics. The two piezometers were located
20 and 50 feet away from PW-1, respectively. In April 1990, a pump test was conducted for 12 hours
at a continuous pumping rate of 4 gallons per minute. Also, tidal monitoring was conducted at the
piers where the maximum measured difference in the river stage over one tidal cycle was six feet.
Soil sampling was performed during monitoring well installations and analyzed for TPH. The highest
TPH concentrations were observed in the unsaturated zone of the fill layer.
WCC concluded that shallow groundwater within the former tank area was contaminated with TPH,
both dissolved and as a SPL. Decreasing TPH concentrations in groundwater samples across the area
indicated the TPH contamination had not migrated far horizontally. Moreover, the continuous clay
aquiclude on the property implied that vertical migration of contamination was limited. TPH
contamination in the groundwater was derived from floating oil observed in the test pits) and from
unsaturated zone soil through which percolating precipitation passes.
In one location, at the edge of the boiler house, approximately 20 CY of weathered bunker C fuel oil-
contaminated soils were evident at the ground surface. It was disposed off site.
Based on these results, WCC proposed an in situ biorestoration process where groundwater would be
withdrawn from the shallow contaminated zone, treated to remove free product and re-dispersed into
the shallow zone with nutrient and oxygen supplementation. Groundwater collection would be
achieved through the use of sumps screened through the saturated fill layer. Confirmatory samples
will be collected from soil borings advanced down to the silty clay aquiclude. Biorestoration will be
complete when TPH concentrations are less than 300 ppm.
23
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Engineer's and Owner's Certification of Closure for WMUs, 1992
On December 1, 1992, WCC submitted a second Engineer's and Owner's Certification of Closure for
WMUs prepared for the SWMUs and HWMUs in accordance of PADEP hazardous waste
management regulations. It noted the status of the some of the monitoring wells:
• W-l: monitors groundwater downgradient from the former tar plains area; no
contamination associated with former coal gas or tar processing operations
• W-2: monitors groundwater in the vicinity of former tar decanters; highest levels of
groundwater contamination in the shallow zone
• W-3: exhibits essentially no contamination with the former coal gas or tar processing
operations
• W-4: monitors background groundwater conditions upgradient of the former plant
processing areas
The Engineer's and Owner's Certification of Closure for WMUs report also gave
background/summary information for the soil and groundwater sampling endeavors throughout the
1980s:
Associated Chemical and Environmental Services (ACES) completed closure activities in 1988
and removed the following materials:
• Decanter tank tar sludge (K087) and visually contaminated soil: 9,370 tons
• Water contaminated from excavation activities: 439,800 gallons
• Various waste materials: 12 drums
• Fuel oil from unknown source floating in excavations: 250 gallons
• Rubble of railroad ties and wooden timbers: 65 CY
• Scrap metal: 60 tons
The documented closure of identified SWMUs and HWMUs included the following:
Tar Storage Tanks (HWMU): These two above-ground steel tanks were used to store product coal tar
24
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from coal gas cleaning operations with estimated capacities of 1,000,000 and 500,000 gallons,
respectively. As of June 1983, they had 650 CY of coal tar and/or decanter tank tar sludge. Kipin
excavated and removed 3,755 tons of the waste. The tanks were dismantled and reclaimed for scrap.
Waste Liquor Pit (HWMU): This two-chamber solid concrete pit (25 feet wide by 25 feet long by 10
feet deep) was cleaned out during the 1988 closure activities. Odorous fill and rubble were removed
and the interior concrete walls and floor were scraped clean. The pit was filled with demolition
rubble including some concrete from the tar decanter foundations that had a thin coating of tar pitch
(approved by PADEP).
Trash Pile (SWMU): This 50 foot by 250 foot unit held 2,000 CY of tar waste, coal fines, wood,
rubble, steel, and other debris. Kipin removed 1,500 tons of rubble and debris and disposed of it on
site, though the exact disposal location is unknown. An estimated 550 tons were also disposed at an
off-site landfill.
Tar Plains (HWMU): This 150 foot by 450 foot area in the southwest corner held waste including
coke breeze, tar from spills, decanter tar sludge, and miscellaneous rubble during operations. In 1983
materials were screened and then disposed on-site (240 tons at an unknown location) and at two
separate landfills (472 and 1,888 tons). K087 waste materials were removed to a landfill in 1988. Six
backhoe test pits were excavated to assess subsurface conditions during the 1988 closure activities.
No further indication of any K087 materials remained. In 1992 approximately, 2,006 tons of non-
hazardous coke breeze and coal fines were removed from the site for disposal at a landfill.
Clean Oxide (SWMU): This SWMU had 2,200 tons of waste that were disposed on-site at an
unknown location by Kipin in 1983.
Wood Travs (SWMU): Kipin processed 300 CY of wood trays by grinding and processing into solid
fuel in 1983. No other records exist.
Tar Decanters (HWMU): A total of 4,481 tons of waste consisting of a mixture of tar decanter sludge
and spent iron oxide was sent to a landfill. In September 1982, Clean Venture initiated closure of this
unit. ACES completed additional closure in 1988. Most of the decanter tank tar sludge (K087) was
removed in 1982 from the decanters and adjacent decanter sludge lagoon; the areas were reportedly
backfilled. Soil investigations by WCC in 1987 identified additional areas of K087 materials in the
25
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nearby vicinity. Thus, in 1988, additional soil and the concrete foundations were removed by ACES.
Small pockets of identified sludge were subsequently excavated and removed.
Iron Oxide Boxes and Pile (HWMU): These two rectangular above-ground steel containers erected on
concrete foundations contained a mixture of iron oxide and wood chips through which coal gas was
passed through during gas cleaning operations. Clean Venture removed wastes in 1982 to a landfill.
The above-grade portion was demolished and salvaged. WCC's soil investigation in 1987 revealed
additional areas of K087 in the vicinity and revealed additional small pockets of sludge that were
subsequently excavated and removed.
Process Piping (SWMU): Asbestos-containing insulation from process piping totaled 30 CY; it was
sent to a landfill during closure in 1982. No other documentation is available.
To achieve closure criteria, 16 composite soil samples from a 50 feet by 50 feet grid were collected
and analyzed, one from each of the 16 sampling areas identified in Appendix B: Figure 7 -
Confirmatory Soil Sample Areas. Sample Area 16 was the only area that exceeded the 50 ppm
CP AH, believed to be the former coal tar-derived macadam paving, since no tar decanter sludge
(K087) was observed in the area. After excavating each area, samples were collected and analyzed.
Analytical data indicated that the remaining soils in all 16 areas were nonhazardous.
Groundwater: As previously described, a groundwater monitoring program was implemented at the
facility beginning in 1985. Details included:
• W-l: no contamination associated with the former coal gas or tar processing operations; no
uncontrolled migration
• W-2/2R: appeared to be impacted by contaminants associated with the former coal gas and
tar processing operations; monitoring would continue
• W-3: (downgradient) no contamination/migration
• W-4: (upgradient) was replaced. bis(2-ethylhexyl)phthalate (20 ppb) is a compound not
associated with former plant processing areas
26
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• W-5: (upgradient) low levels of contaminants potentially related to former plant operations
• W-6: low levels of contaminants potentially related to former processing areas
Conclusions: The report concluded that the five HWMUs and four SWMUs were closed in
accordance with the PADEP-approved Closure Plan. Low levels of contaminants potentially related
to former plant operations are present in groundwater from three of the six monitoring wells, though
there was no indication that they were migrating from the site in an uncontrolled manner according to
wcc.
Groundwater Monitoring Plan, 1993
On May 6, 1993, WCC submitted a Groundwater Monitoring Plan summarizing groundwater
monitoring activities and trends at the site. In accordance with Pennsylvania RCRA Regulations, a
long-term monitoring plan was identified, including semi-annual and annual groundwater sampling.
The Groundwater Monitoring Plan noted that there was no uncontrolled migration of contaminants
and no existing or anticipated plan to utilize the shallow groundwater. WCC expected groundwater
quality to continue to improve due to natural attenuation and biodegradation.
The presence of dibenzofurans detected in W-2R and MW-6 during the first quarter 1991 sampling
event was summarized in the report. Dibenzofuran can be associated with dioxins, but it is typically a
product of high-temperature carbonization process used a former manufactured gas plant sites;
therefore, dibenzofuran at the PCC site is not likely to be related to dioxins.
CME, 1996 and 1997
CMEs were conducted by PADEP (split samples with WCC) in 1996 and 1997. Samples collected
by WWC were analyzed for select PAHs, TCE, PCE, benzene, ethylbenzene, toluene, total organic
carbon (TOC), total organic halides (TOX), pH and specific conductance from groundwater collected
from MW-1R, MW-2R, MW-3, MW-4, MW-5, and MW-6. The samples were collected in March
1996 and February 1997. WWC results are presented in the following table.
27
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PAR.WIKTKRdi"/!. )
i'w./iw7 (Mi: momtokim; wv.i.i. ri:si lis
\1W-IR
\1W-2R
MW-3
\1W-4R
MW-5
\1\W.
l'AHs
-/ND
-/ND
-/ND
-/ND
—/ 43
-/ND
ICE
ND/ND
ND/ ND
ND/ND
ND/ND
33/14
ND/ND
PCE
ND/ND
ND/ND
ND/ND
ND/ND
55/ND
ND/ND
Benzene
ND/ND
83/42
ND/ND
ND/ND
ND/ND
3 no
Ethylbenzene
ND/ND
1/ND
ND/ND
ND/ND
ND/ND
2/3
Toluene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
2/5
TOC (nig/)
29/19
28/24.4
12/11.2
42/45.3
5/4.3
8/ 7.2
TOX
33/17.7
42/29.5
25/20.6
11/9.5
71/95
6/ 7.1
pH
7.05/6.96
8.45/8.17
6.88/6.74
6.93/6.79
6.39/6.6
7.01/6.7
Specific Conductance
(umhos/cm)
3,370/2,740
2,140/
1,780
6,640/
3,630
2,160/
2,590
293/
392
1,080/
828
Naphthalene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ ND
ND/ND
Acenaphthylene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
Acenaphthene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
48/62
Fluorene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
11.9/
17.5
Phenanthrene
ND/ND
9.8/7.6
ND/ND
ND/ND
ND/ND
ND/ND
Anthracene
ND/ND
2.1/1.5
ND/ND
ND/ND
ND/ND
ND/ND
Fluoranthene
ND/ND
3.12/2.61
ND/ND
ND/ND
0.78/ND
1.07/
0.74
Pyrene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
Benzo(a)anthracene
ND/ND
0.17/0.14
ND/ND
ND/ND
0.25/ND
0.49/
0.28
Chrysene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
Benzo(b)fluoranthene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
0.44/ ND
Benzo(k)fluoranthene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
0.24/
0.13
Benzo(a) pyrene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
0.55/ND
Dibenzo(a,h)anthracene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
Benzo(g,h,i)perylene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
Indeno( 1,2,3-cd)pyrene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
0.&5/ND
Notes: * All results in ug/L except where indicated
** Proposed property use included residential units
ND = Not Detected;
— = not applicable
micromhos/centimeter = (umhos/cm)
CME, 1999
PADEP's summary of the last CME inspection (October 27, 1999) stated the historically TCE, PCE,
naphthalene, ethylbenzene, benzene and toluene (all site-related contaminants) were extremely
elevated in concentration in the monitoring well samples. However, since 1996, the identified
contaminants have exhibited decreasing concentrations trends. Some other constituents in
groundwater, sulfate, chloride, specific conductance, TOC, TOX, phenols and ph have remained
stable since 1985; some (specific conductance and sulfate) have maintained concentrations above the
MCLs for drinking water. (Note: However, the concentrations are below the PADEP Land Recycling
Program, Act 2 medium specific concentration [MSCs] for groundwater in non-use aquifers, which is
the case for the aquifer beneath the facility.)
28
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The groundwater program at the facility started with quarterly sampling, but in 1998, PADEP allowed
for a reduction in monitoring to annual, for the reasons stated above. The groundwater is apparently
stable and there does not appear to be a need for further monitoring after 1999.
Note: On July 26, 1999, PADEP reviewed relevant groundwater monitoring data for quarterly
sampling events from 1985 through 1998 noting concentrations of COCs had significantly decreased.
Iron, manganese, specific conductance, potassium, sodium, calcium, magnesium, sulfate, and chloride
have remained elevated even after the removal of wastes in 1988. It noted that benzene and
naphthalene in MW-2R were above the SDWA MCLs, but had not migrated to downgradient
sampling points and no other monitoring wells detected elevated results and deemed the exceedances
localized for the past five years. As elevated levels for the remaining constituencies persisted
throughout the groundwater monitoring program both before and after the RCRA clean-up activities,
PADEP deemed them a natural phenomenon and indicated groundwater quality was stable. PADEP
thus terminated the monitoring requirement.
Inspections
Following the facility's closure, an inspection on June 4, 1982 noted a lack of the following: 24-hour
surveillance, inspection schedule, written operation record, groundwater monitoring program, closure
and post-closure plan, 2-feet freeboard in a surface impoundment, surface impoundment inspections,
waste dispersal wind prevention, and run-off collection prevention. An NOV was issued on June 29,
1982.
On February 6, 1989, PADEP sent an NOV following a January 18, 1989 inspection and requested
that W-2 and W-4 be returned to proper operation. On February 22, 1989, the facility responded
noting that repairs would be made. On March 8, 1989, groundwater samples were collected from two
newly replaced monitoring wells, along with the other four site monitoring wells (Certification of
Closure, 1992).
On October 12, 1989, PADEP conducted an inspection and noted that the site was undergoing
closure. Also, on March 13, 1996, an inspection noted that the facility was abandoned and that
sampling was conducted on September 8, 1994 and on March 13, 1996.
On December 3, 1993, WCC sent PADEP a Certification of Closure documents for the seal pot in
29
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response to PADEP's November 22, 1993 inspection. It noted that closure activities were completed
on October 19, 1993 and that solid materials (DO 18: benzene) were removed in September 1992.
On September 28, 1994, Eastern Enterprises notified PADEP of the proposed plan to complete the
grading program. It noted that clean soil would be imported and spread approximately 6 inches thick.
On December 23, 1994, a Certification of Closure was signed for the facility formerly known as the
Philadelphia Coke Company and located at 4501 Richmond Street, Philadelphia, Pennsylvania in
accordance with the closure plan approved by PADEP on December 13, 1983.
Routine hazardous waste inspections were conducted on March 9, 1983, June 17, 1983, November
16, 1983, December 21, 1983, March 22, 1984, June 6, 1984, July 5, 1984, February 14, 1985,
September 18, 1985, September 24, 1985, January 16, 1986, July 8, 1986, January 9, 1987,
September 29, 1987, October 12, 1989, July 10, 1990, August 28/29, 1990, January 8, 1991, and May
4, 1993.
PADEP conducted inspections at the empty facility noting it was closed, razed, shut down, and no
hazardous waste was present on: August 1, 2000, December 15, 2000, August 28, 2002, June 9, 2004,
April 1, 2005, February 24, 2006, August 1, 2007, February 25, 2008, January 8, 2009, and March 22,
2010 (2000 to 2010 inspections).
On March 13, 2003, an inspection noted that Keyspan Energy was on site and that they had acquired
the property when they bought the previous company that owned the site. Keyspan Energy was
collecting samples as part of a preliminary assessment.
NPDES
NPDES inspections were conducted on February 13, 1975, April 7, 1976, June 10, 1976, November
4, 1976, January 3, 1978, June 22, 1978, May 8, 1979, December 18, 1979, May 6, 1980, June 24,
1980, August 12, 1980, March 23, 1981, December 30, 1981, January 14, 1982, March 29, 1982,
June 15, 1982, January 11, 1983, and February 6, 1985 .
A March 4, 1982 inspection noted that the spilled oil on the ground around the quench tower and
manhole had been cleaned up, though some oily residue remained.
30
-------
A September 2, 1982 inspection noted that the NPDES permit had been cancelled.
C. Description of Exposure Pathways for all Releases or Potential Releases
Air: The facility was located in Philadelphia, Pennsylvania with a 2009 population of 1,547,297,
according the US Census Bureau (www.factfinder.census.gov. accessed August 31, 2011). The City of
Philadelphia has files relating to air permitting for the facility. As PCC is no longer operating;
therefore, there are no emissions.
The groundwater at the facility was observed to be at depths that ranged from approximately 2.2 to
9.4 feet below the ground surface (bgs) during the 1996 CME sampling. Shallow groundwater
resides in a shallow layer (approximately 10 foot thick) of fill and recent sands. Volatile organic
compounds (VOCs) detected in the uppermost aquifer during the 1996 and 1997 CME sampling
events conducted shortly before termination of monitoring at the site had concentrations of volatile
organics in the interior of the property but not at the perimeter of the property boundaries. There are
no buildings on the site or buildings located within 100 feet of historical monitoring well locations
with documented groundwater exhibiting elevated VOCs.
Groundwater: Information obtained from the Pennsylvania Department of Conservation and Natural
Resources (DCNR) Groundwater Information System (PaGWIS) accessed on February 5, 2011
provided the following information regarding 15 groundwater wells located within a 0.5 mile radius
of the facility; all were southwest of the property. Six were owned by American Smelting and
Refining and have been destroyed. Three wells were drilled in 1920 and were 400 feet deep; three
wells were drilled in 1914 and were 200 feet deep. Six wells were owned by Keystone Concrete; all
destroyed. Most of these wells were drilled in 1975 and ranged from 80 to 100 feet in depth. Three
wells were owned by Liberty Corporation; drilled in 1903, are 55 feet deep, and were listed as
unused. According to the Philadelphia Department of Public Health, the Bridesburg Outboard Club,
which is located immediately east of PCC, also maintains a potable water well on their property. This
well is located sidegradient to downgradient of the facility. It was reported by the Philadelphia
Department of Health that the water is used for restroom use. Specifics about the well, typical
pumping rate, well depth, or other construction details were not provided. MW-3 is the closest
downgradient well to the Bridesburg Outboard Club. Groundwater collected from MW-3 exhibited
concentrations of VOCs and PAHs below detection during the 1996 and 1997 CME sampling events,
31
-------
although specific conductance concentrations were elevated (>3000 umhos/cm).
The groundwater at the facility was observed to be at depths that ranged from approximately 2.2 to
9.4 feet bgs during the 1996 CME sampling. Shallow groundwater resides in a shallow layer
(approximately 10 foot thick) of surficial deposits of variable thickness, consisting of natural sands
and gravels deposited by the Delaware River, as well as man-made fill materials. Groundwater flow
in the upper aquifer does not conform to regional trends. It indicates radial groundwater flows away
from a centrally high area near MW-2 with relatively flat gradients (0.002 to 0.006 foot/foot typical)
both toward the Delaware River to the east and to the west (WCC, 1993). The site lies over both an
upper unconfined aquifer and lower confined aquifer.
Surface Water/Sediment: The site is 10 feet above sea level and less than 100 feet from the
Delaware River. Based on information obtained from PADEP eMapPA (accessed February 5, 2011),
the Delaware River is a designated use warm water fishery according to the standards contained in
Title 25, Chapter 93 (Water Quality Standards) of the Pennsylvania Code. The site is within a mile of
the Federal Emergency Management Agency (FEMA) 100 year floodplain and within the
Philadelphia Water Department area.
The facility discharged wastewater to the sanitary sewer. Non contact waste water and stormwater
discharged via Outfall 1. A few minor incidents occurred during the operation of the facility. No
sediment data is available.
Soil: Surface soils at the site are composed of primarily of fill. Areas of the site were backfilled with
demolition rubble, and clean iron oxide during the decommissioning of the facility. However,
hazardous waste was removed from the facility, and it was certified closed in accordance with the
closure plan 1994.
The site lies along the westernmost margin of the Atlantic Coastal Plain Physiographic Province,
characterized by relatively undiversified lowland. It is underlain by a wedge of unconsolidated
sediments which thicken in a southeasterly direction. The subsurface soil is characterized by a
sequence of sand and fill materials underlain by a geologically recent silty clay alluvium layer.
32
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D. Exposure Pathway Controls and/or Release Controls Instituted at the Facility
Air: As the facility is no longer operating, air emissions from facility operations are no longer a
factor of concern. The entire facility has been dismantled and removed and areas where waste
material was stored and may have impacted soils have been remediated, thus reducing the sources for
groundwater contamination which were exhibiting decreasing trends when monitoring was
discontinued.
USEPA has requested that the vapor intrusion pathway be evaluated as part of the EI process. The
USEPA 2002 OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway
from Groundwater and Soils (Subsurface Vapor Intrusion Guidance) provides a methodology for
vapor intrusion evaluation under current land use conditions using available site data. It should be
noted that the USEPA 2002 guidance is not generally recommended for use in evaluating settings that
are primarily occupational; however, a neighborhood is located adjacent and northwest of the facility
and a recreational facility is located adjacent and northeast of the facility.
In 1987, soil samples were collected from borings during the Hydrogeologic and Soils Investigation to
determine the effectiveness of the previous clean-up activities. The sampling was to determine the
presence of contamination, not delineate the extent of contamination. The sampling targeted the main
areas of the facility: decanter tar bottoms, tar plains, lime pit, and waste liquor pit. A total of 17 soil
samples varying from a depth of 6-inches to 10 feet were collected for priority pollutant organic
analyses (VOCs, base/neutral extractables, and acid extractables). The VOC detected were as follows:
33
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Parameter
(ppb)
l>\
l)il';nills
Kis \ III
In 1A
Siivin
(|>|>l»
li-IA
U-IU
U-2A
U-2U
B-3A
U-3U
IMA
13-5A
B-6A
U-7A
U-7U
B-8A
B-9A
U-9U
TP-I
l'P-2
l'P-3
I .ocalion
DTU
DTU
DTB
DTB
dtu
DTB
DTU
DTU
DTU
DTU
DTU
WLP
I.P
I.P
TP
TP
TP
Methylene
Chloride
380
BDL
BDL
18
BDL
11
BDL
BDL
BDL
BDL
BDL
BDL
WLP
BDL
BDL
10
17
BDL
Benzene
370
80
BDL
BDL
BDL
BDL
BDL
BDL
BDL
9
9
15
BDL
BDL
10
BDL
BDL
6
Toluene
76,000
50
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
5
22
BDL
BDL
Ethylbenzene
5,700
84
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL - Below detection level
DTB - Decanter tar Bottoms
TP - Tar Plains
LP - Lime Pit
WLP - Waste Liquor Pit
None of the concentrations exceeded the PADEP Defaults Residential Volatilization to Indoor Air Screen (Defaults using SL-SCREEN.XLS version 2.3 03/01; PADEP Soil parameters; 15 cm
to bottom of enclosed space; 150 cm to top of contamination; RL = 10-5, HQ = 1.) As such, they also do not exceed the USEPA-PA Defaults Nonresidential PELs Volatilization to Indoor Air
Screen.
34
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Volatile organic compounds detected in the uppermost aquifer during the 1996 and 1997 CME sampling
events conducted shortly before termination of monitoring at the site had TCE concentrations greater than
the USEPA Target Groundwater Concentration as listed below:
im/IWCMF. MONITORING Wi l l. RI.Sl I IS
i s/:i> i hu^d
(iromuhuilcr
PARAM IUT.R
( oiiccnlmlioii"
(Uli/I.)
MW-IR
MW-2R
MW-3
MW-4R
MW-5
MW-(»
TCE
ND/ND
ND/ND
ND/ND
ND/ND
33/14
ND/ND
5.0
PCE
ND/ND
ND/ND
ND/ND
ND/ND
55/ ND
ND/ND
5.0
Benzene
ND/ND
83/ 42
ND/ND
ND/ND
ND/ND
3/ 10
5.0
Ethylbenzene
ND/ND
1/ND
ND/ND
ND/ND
ND/ND
2/3
700
Toluene
ND /ND
ND/ND
ND/ND
ND/ND
ND/ND
2/5
1,500
Note: * USEPA OSWER Guidance, 2002, where the soil attenuation factor = 0.001; Risk = 1E-06
Groundwater collected from MW-2R, that is located approximately 125 feet off of the facility fence line
near the residential neighborhood, exceeded the USEPA generic target groundwater screening value for
indoor air for TCE. MW-5, that is located near the northwest portion the facility, exceeded the USEPA
generic target groundwater screening value for indoor air for TCE and PCE. Monitoring well MW-6, that
is located near the center of the facility, exceeded the USEPA generic target groundwater screening value
for indoor air for benzene. No volatiles were detected in MW-1R, which is closest to the property
boundary in southwest corner the facility. No volatiles were detected in MW-3, which is closest to the
property boundary in south portion the facility. No volatiles were detected in MW-4R, which is closest to
the property boundary in northwest portion the facility. An historical boring log indicates the silty clay
layer below the shallow water zone is approximately 20 feet thick. Under current conditions, it is
concluded that no controls are relevant for the vapor exposure pathway.
Note: Currently, no deed restrictions are in place.
Groundwater: Upon the facility's closure, the impact to soils and subsequently the groundwater were
investigated. Impacted soils were remediated through removals and in-situ methods. Monitoring of the
groundwater was conducted on a regular basis with oversight from the PADEP and USEPA, eventually
reaching acceptable concentrations to permit the discontinuation of future monitoring after 1999. The
neighboring properties, within a 0.5 mile radius of the site, are reportedly connected to the public water
supply, except for the Bridesburg Outboard Club. According to the Philadelphia Department of Public
Health, the Bridesburg Outboard Club, located immediately east of PCC, maintains a potable water well
on their property which reportedly use the water for restroom use. It is unknown if there are signs
designating any use restrictions at the club. The PCC property has no deed restriction or land use
covenant prohibiting the use of groundwater.
35
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A PADEP Land Recycling Program, Act 2 site, Rohm & Haas Philadelphia Plant East Area 1, which
received a Non-Use Aquifer Determination on April 16, 1999 is located less than 0.4 mile
(approximately) northeast of the site, and 0.6 mile (approximately) north of the Bridesburg Outboard Club
well.
Concentrations of the COCs in the site groundwater were generally below the residential used aquifer
MSCs at the site monitoring wells during the 1996 and 1997 CME investigations except for TCE
collected from MW-5 in 1996 and 1997, PCE in MW-5 in 1996, benzene in MW-2R in 1996 and 1997
and MW-6 in 1997, and benzo(a)anthracene, benzo(b)fluoranthene, benzo(a) pyrene, and indeno(l,2,3-
cd)pyrene in MW-6 in 1996. Only PCE in MW-5 exceeded the residential non-used aquifer MSC during
1996. In general, groundwater concentrations indicated a general decreasing trend over time at the
facility, which was why PADEP allowed the facility to discontinue monitoring after 1999. Some
concentrations, such as benzene (16 ug/L) and naphthalene (36 ug/L) remained elevated above drinking
water standards (5 ug/L and 30 ug/L, respectively) in groundwater collected from MW-2R, but appeared
to be relatively stable and localized (PADEP, July 26, 1999). The concentrations were also below
detection levels in groundwater collected from MW-1, MW-3 and MW-4 during 1996 and 1997, which
were the perimeter downgradient wells for the facility.
36
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rw./iw oil. momtorim; wki.i. ri:si lis
Nim-l si-
I si'j/ It/iii/cr
lies iilcn rial
PARWIKI'Kit
Ri'sidi-nihil
us< **
(u»/l. >
MW-IR
MW-2R
MW-3
MW-4R
MW-5
M\W.
MS(
PAlls
-/ND
-/ND
-/ND
-/ND
—/ 43
-/ND
—
—
ICE
ND/ND
ND/ ND
ND/ND
ND/ND
33/14
ND/ND
50
5
PCE
ND/ND
ND/ND
ND/ND
ND/ND
55/ND
ND/ND
50
5
Benzene
ND/ND
83/42
ND/ND
ND/ND
ND/ND
3110
500
5
Ethylbenzene
ND/ND
1/ND
ND/ND
ND/ND
ND/ND
2/3
70,000
700
Toluene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
2/5
100,000
1,000
TOC (nig/)
29/19
28/24.4
12/11.2
42/45.3
5/4.3
8/ 7.2
—
—
TOX
33/17.7
42/29.5
25/20.6
11/9.5
71/95
6/ 7.1
—
—
PH
7.05/6.96
8.45/8.17
6.88/6.74
6.93/6.79
6.39/6.6
7.01/ 6.7
—
—
Specific Conductance
3,370/
2,140/
6,640/
2,160/
293/
—
—
(umhos/cm)
2,740
1,780
3,630
2,590
392
1,080/828
Naphthalene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ ND
ND/ND
30,000
100
Acenaphthylene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
16,000
2,200
Acenaphthene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
48/ 62
3,800
2,200
Fluorene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
11.9/17.5
1,900
1,500
Phenanthrene
ND/ND
9.8/7.6
ND/ND
ND/ND
ND/ND
ND/ND
1,100
1,100
Anthracene
ND/ND
2.1/1.5
ND/ND
ND/ND
ND/ND
ND/ND
66
66
Fluoranthene
ND/ND
3.12/2.61
ND/ND
ND/ND
0.78/ND
1.07/0.74
260
260
Pyrene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
130
130
Benzo(a)anthracene
ND/ND
0.17/0.14
ND/ND
ND/ND
0.25/ND
0.49/ 0.28
11
0.29
Chrysene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
1.9
1.9
Benzo(b)fluoranthene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
0.44/ ND
1.2
0.29
Benzo(k)fluoranthene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
0.24/0.13
0.55
0.55
Benzo(a) pyrene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
0.55/ND
3.8
0.2
Dibenzo(a,h)anthrace
ne
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
0.6
0.029
Benzo(g,h,i)perylene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
0.26
0.26
Indeno(l,2,3-
cd)pyrene
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
0.&5/ND
62
0.29
Notes: * All results in ug/1 except where indicated; 1996 values from WCC/ 1997 values from PADEP.
** Proposed property use included residential units
ND = Not Detected
— = not applicable
As the vertical delineation of groundwater quality was not conducted at the site, no deed restrictions are in
place to restrict groundwater use at the site for potable use, and with the presence of the Bridesburg
Outboard Club well located east of the site, it is unknown whether controls are needed for the use of
groundwater at this time. Note: The Bridesburg Outboard Club is located adjacent to land that was
identified as the Rohm & Haas Co. residual waste landfill and downgradient of the Rohm & Haas drum
storage and container storage area (PADEP, August 29, 1990).
Surface Water/Sediment: The closest surface water body to the facility is the Delaware River,
approximately 100 feet to the east. During its operation, several NOVs were issued pertaining to oily
discharges (in minor quantities) in violation of NPDES permits at the time. Upon it closure, the facility
posed no further direct discharge impact to the Delaware River. In groundwater, the concentrations of the
COCs were below detection at the far downgradient wells (MW-1R and MW-3) in the main area, and
therefore, should not be a source of contamination to the surface water/sediment.
37
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Two monitoring wells (MW-13 and MW-14) were installed in December 1989 in the thin saturated zone
of the fill down gradient of the tank farm. In-situ biorestoration of groundwater was achieved through
the use of sumps screened through the saturated fill layer. Confirmatory samples were collected from soil
borings advanced down to the silty clay aquiclude. Biorestoration will be complete when TPH
concentrations are less than 300 ppm.
Based on the information presented, it is concluded that no controls are relevant for the surface
water/sediment exposure pathway.
Soil: Since the facility ceased operations in 1982, access to the property has been restricted by a perimeter
fence of the main area. During it operations, the facility produced and stored waste at the facility, which
impacted the site soils. Highly contaminated soils were removed and appropriately disposed, while mildly
contaminated soils were remediated with other remedial methods such as bioremediation. The facility was
certified as closed in accordance with the closure plan in 1994.
The facility was remediated to removed PAHs with a combined CP AH concentrations not to exceed 50 ppm
with no individual of the six CP AH exceed 15 ppm. Soils were remediated in 16 areas as illustrated on
Appendix B: Figure 7 - Confirmatory Soil Sample Areas. The maximum concentrations of base neutrals in
the confirmation samples from the Soil Contamination Assessment (1988) were as follows:
38
-------
Soil Ki
Soil in
Maximum
Direct
Dirccl Cnuiacl
Direcl Cuiiiacl
(¦munriwiikT
(ii'iiuudwaler Nou
( oiiceiiinilioii
("on tact
\niircsidciiiial
Nuiircsidcuiial
Residential I sod
Residential MSC
kcniaiuum
Sample
Residential
MSC Sin lace
MSC subsurface
A(|iiilVr 1 l)S <
I scd \iiuilei I DS
I'aramclcr
Oii-siie mm km
\rca
MSC
Soil
surface soil
2.500
2.500
Acenaphthene
1.27
I
13,000
170,000
190,000
2,700
4,700
Acenaphththylene
1.33
XVI
13,000
170,000
190,000
2,500
6,900
Anthracene
7
XVI
66,000
190,000
190,000
350
350
Benzo(a)anthracene*
17.7
XVI
5.7
110
190,000
25
320
Benzo(a)pyrene*
11
XVI
0.57
11
190,000
46
46
B enzo(b)fluoranthene *
22
XVI
5.7
110
190,000
40
170
Benzo(g,h,i)perylene
8.7
XVI
13,000
170,000
190,000
180
180
Benzo(k) fluoranthene
***
XVI
57
1,100
190,000
610
610
Chrysene*
26.7
XVI
270
11,000
190,000
230
230
Dibenzo(a,h) anthracene*
2.13
XVI
0.57
11
190,000
13
160
Fluoranthene
31.7
XVI
8,800
110,000
190,000
3,200
3,200
Fluorene
2.57
V
8,800
110,000
190,000
3,000
3,800
I ndc no (1.2.3 -c. d) pv rc nc *
7
XVI
5.7
110
190,000
2,200
28,000
Naphthalene
26.7
VIII
4,400
56,000
190,000
25
25
Phenanthrene
23
XVI
66,000
190,000
190,000
10,000
10,000
Pyrene
24.7
XVI
6,600
84,000
190,000
2,200
2,200
Total PAHs
188.4
XVI
—
—
—
—
—
Total Carcinogenic PAHs
85.5
XVI
--
-
-
-
-
Notes: Maximum concentration based on 16 confirmation samples from the Soil Contamination Assessment (1988). One confirmatory sample
per remedial area.
MSC = PADEP Medium Specific Concentration
Note that samples from Area XIV exceeded the standard so additional excavation was conducted and the area was resampled (sample XIVR).
*** = compound could not be distinguished from benzo (b) fluoranthene in analysis; reported values are the combined concentrations
39
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While the concentrations in area XVI exceeded the required cleanup criteria of 50 ppm of the
carcinogenic PAHs, the source was believed to be the former coal tar-derived macadam paving that
covered Area XVI and not the decanter tank tar sludge (K087) waste, because no K087 waste was
observed in the area. Therefore, no further action was taken in Area 16; however, no follow up
testing was performed to verify this hypothesis. The current residential MSCs were exceeded for
several of the carcinogenic PAHs in Area XVI. However, the concentrations are less than or equal to
the non-residential MSCs for all of the tested PAHs. The maximum naphthalene concentration
slightly exceeded the soil to groundwater MSCs in Area VIII. While no monitoring well was
specifically located in Area VIII, naphthalene was not detected in groundwater during 1996 and 1997
at any of the existing site six monitoring wells. An insitu biorestoration process where groundwater
was withdrawn from the shallow contaminated zone, treated to remove free product and re-
dispersed into the shallow zone with nutrient and oxygen supplementation was performed in the
south area. Biorestoration was to be complete when TPH concentrations are less than 300 ppm in
the confirmatory soil samples. In summary, direct contact residential MSCs were exceeded for
several of the carcinogenic PAHs in Area XVI, biorestoration was complete when TPH
concentrations were less than 300 ppm in the soil in the south area, access to the site is
permissible through the un-maintained perimeter fence operations, there are no deed restrictions,
and the site is adjacent a residential neighborhood and recreational facilities. Therefore, it is
concluded that controls are relevant for the soil exposure pathway.
E. Follow-up Action Items
USEPA Region III will decide if additional information or sampling at the facility is required to
determine whether or not the environmental indicators have been met or if corrective action is
required for the facility.
40
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aker
Michael Baker Jr., Inc.
APPENDIX A
Photographs
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MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
Comments: View from Main Gate.
Comments: Intersection of Lefevre and Garden Streets.
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MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
PHOTOGRAPH
3
VIEW
West
PHOTOGRAPHS
BY
Comments: Northern area of property.
Comments: Former garage and storage building location. Northern property boundary.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
Comments: Adjacent property across Orthodox Street.
Comments: Adjacent property across Orthodox Street.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
PHOTOGRAPH
7
VIEW
Northwest
PHOTOGRAPHS
BY
Baker
Comments: Property boundary at Orthodox Street.
PHOTOGRAPH
3
VIEW
West
PHOTOGRAPHS
BY
Baker
Comments: Vandalized fence along Orthodox Street.
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MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
PHOTOGRAPH
9
VIEW
West
PHOTOGRAPHS
BY
Baker
Comments: Vandalized fence along rail line.
PHOTOGRAPH
10
VIEW
Southwest
PHOTOGRAPHS
BY
Baker
Comments: View along southern property boundary.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
PHOTOGRAPH
Comments: Coal pier.
PHOTOGRAPH
Comments: Pier.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
PHOTOGRAPH
13
VIEW
South
PHOTOGRAPHS
BY
Baker
•VV;
Comments: Former ship docking area.
PHOTOGRAPH
14
VIEW
Exterior
PHOTOGRAPHS
BY
Baker
Comments: Outfall 1.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
Comments: Southern view towards rail line and coal pier.
Comments: Southeast corner of property.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
PHOTOGRAPH
17
VIEW
Southeast
PHOTOGRAPHS
BY
Baker
Comments: Eastern property boundary along Buckius Street.
PHOTOGRAPH
18
VIEW
East
PHOTOGRAPHS
BY
Baker
Comments: Adjacent school property across Buckius Street.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
Comments: Northeast comer of property.
Comments: Unused portion of northern property looking at Garden Street.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
PHOTOGRAPH
21
VIEW
Northwest
PHOTOGRAPHS
BY
Baker
Comments: Northwest corner of property.
PHOTOGRAPH
22
VIEW
Exterior
PHOTOGRAPHS
BY
Baker
- W-
W
* &
t-»v *
••. :.¦ lii,. ^ ••¦ v-wet1 .¦': ibw-SH f.-v?i»
';¦£?.pW^'v^M ,ii., • , . &Rj\;
«rtKf®pP^®«CSB^ v ¦ MsHSS
NraHPRra
Comments: Former oil skimmer basin.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
Baker
. _fe>
Comments: Former area of excavation.
PHOTOGRAPH
24
VIEW
Exterior
PHOTOGRAPHS
BY
Baker
Comments: Former change house floor.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
Comments: Former tar decanter area.
Comments: Former tar decanter area.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
PHOTOGRAPH
27
VIEW
Exterior
PHOTOGRAPHS
BY
Baker
Comments: Former office arid lab area.
PHOTOGRAPH
28
VIEW
Exterior
PHOTOGRAPHS
BY
Baker
Comments: Former coke oven battery location.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
PHOTOGRAPH
29
VIEW
Exterior
PHOTOGRAPHS
BY
Baker
Comments: Concrete fragment in excavation area.
PHOTOGRAPH
30
VIEW
Northwest
PHOTOGRAPHS
BY
Baker
Comments: Monitoring well MW-1 along Orthodox Street.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
Comments: Monitoring well MW-2.
PHOTOGRAPH
32
VIEW
Exterior
PHOTOGRAPHS
BY
Baker
Comments: Monitoring well MW-3.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
PHOTOGRAPH
33
VIEW
Exterior
PHOTOGRAPHS
BY
Baker
Comments: Monitoring well MW-4.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
PHOTOGRAPH
35
VIEW
Exterior
PHOTOGRAPHS
BY
Baker
Comments: Former coal storage pile area.
PHOTOGRAPH
36
VIEW
Exterior
PHOTOGRAPHS
BY
Baker
Comments: Former smokestack foundation location.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
PHOTOGRAPH
37
VIEW
Exterior
PHOTOGRAPHS
BY
Baker
Comments: Old tank foundation location.
PHOTOGRAPH
38
VIEW
Exterior
PHOTOGRAPHS
BY
Baker
Comments: Former oxide box location.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
SITE NAME: Philadelphia Coke Co., Inc.
PHOTOGRAPH
39
VIEW
Exterior
PHOTOGRAPHS
BY
Baker
Comments: Former spent iron oxide excavation area.
-------
MICHAEL BAKER JR., INC. - PHOTOGRAPHIC RECORD
Comments: Former tar plains area.
PHOTOGRAPH
42
VIEW
Exterior
PHOTOGRAPHS
BY
Baker
%
- ¦ ^4gswv'
oi > U- 'ifn awBSl
' .. ¦•¦¦¦'
Comments: Monitoring station.
-------
aker
Michael Baker Jr., Inc.
APPENDIX B
Figures
-------
i-PaGWIS Wells
Source: PASDA.2008
1 inch = 800 ft
SCALE: 1" = 800"
S.O. NO.: 120686
DSN/OWN: MM/RRR
DATE: NOVEMBER 2011
FILE: 120686—PCC—08
CHK: SRF
aker
MICHAEL BAKER JR., INC.
MOON TOWNSHIP, PENNSYLVANIA
FIGURE 1
FACILITY LOCATION MAP
PHILADELPHIA COKE COMPANY
4501 RICHMOND STREET
PHILADELPHIA, PENNSYLVANIA 19137
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Temple University Libraries, Urban Archives
FIGURE 2
FORMER FACILITY OPERATIONS
PHILADELPHIA COKE COMPANY
4501 RICHMOND STREET
PHILADELPHIA, PENNSYLVANIA 19137
SCALE: NOT TO SCALE
S.O. NO.: 120686
DSN/DWN: MM/WJH
DATE: NOVEMBER 2011
FILE: 120686—PCC—02
CHK: SRF
aker
MICHAEL BAKER JR., INC.
MOON TOWNSHIP, PENNSYLVANIA
-------
SCALE: AS SHOWN
S.O. NO.: 120686
DSN/OWN: MM/WJH
DATE: FEBRUARY 2011
FILE: 120686—PCC—03
CHK: SRF
aker
MICHAEL BAKER JR., INC.
MOON TOWNSHIP, PENNSYLVANIA
FIGURE 3
FACILITY LAYOUT, MAIN AREA
PHILADELPHIA COKE COMPANY
4501 RICHMOND STREET
PHILADELPHIA, PENNSYLVANIA 19137
-------
! t- ¦>!
><«.& il
Source:
WASTE PERMIT APPLICATION
NOVENBER 18, 1980 (BASEMAP)
PADEP INSPECTION, AUGUST 1990
FIGURE 4
FACILITY LAYOUT, SOUTH AREA
PHILADELPHIA COKE COMPANY
4501 RICHMOND STREET
PHILADELPHIA, PENNSYLVANIA 19137
SCALE: NOT TO SCALE
S.O. NO.: 120686
DSN/DWN: MM/RRR
DATE:NOVEMBER 2011
FILE: 120686—PCC—06I
CHK: SRF
aker
Michael Baker Jr., Inc.
MICHAEL BAKER JR., INC.
MOON TOWNSHIP, PENNSYLVANIA
-------
Delaware River
LEGEND;
U3 S0L'D WASTE MANAGEMENT UNIT (SWMU)
g HAZARDOUS WASTE MANAGEMENT UNIT (HWMU)
* FOR PURPOSES OF CLOSURE CERTIFICATION,
THE DECANTER SLUDGE LAGOON IS CONSIDERED
PART OF THE TAR DECANTERS HWMU
NOTE: THE PROCESS PIPING THROUGHOUT THE
SITE SWMU IS NOT SHOWN.
SOURCE; ADAPTED FROM JUNE 1983 CLOSURE
PLAN PREPARED BY R.F.WESTON, INC.
FOR PHILADELPHIA COKE COMPANY.
PHILADELPHIA COKE COMPANY
PHILADELPHIA. PENNSYLVANIA
WOODWARD-CLYDE CONSULTANTS
Consulting Engineers, Geologists and Environmental Scientists
WASTE MANAGEMENT UNIT
LOCATION PLAN
Job No.: 87C2B39A5
Checked by;
Scale:
Brewing No. 78390060
Rev. No.:
Date: 8/15/69
FIGURE 3
SCALE: AS SHOWN
S.O. NO.: 120686
DSN/OWN: MM/WJH
DATE: NOVEMBER 2011
FILE: 120686—PCC—04
CHK: SRF
aker
MICHAEL BAKER JR., INC.
MOON TOWNSHIP, PENNSYLVANIA
FIGURE 5
WASTE MANAGEMENT UNIT LOCATION MAP
PHILADELPHIA COKE COMPANY
4501 RICHMOND STREET
PHILADELPHIA, PENNSYLVANIA 19137
-------
ORTHODOX ST
'O 60, '
r
i ! iiv. y
FENCE LINE
8UCKIUS ST
LEGEND:
+ MONITORING WELL
8 0 GROUNDWATER CONTOUR
GROUNDWATER ELEVATIONS. OCT 27, 1986
PHILADELPHIA COKE COMPANY
PHILADELPHIA, PENNSYLVANIA
WOODWARD-CLYDE CONSULTANTS
CONSULTING ENGINEERS. GKXOGISI5 AND ENVHJONMtNlAL SCIfNtlSIS
DiuwnBy y p
SCALE: AS SHOWN
S.O. NO.: 120686
DSN/OWN: AAF/RRR
DATE: NOVEMBER 2011
FILE: 120686—PCC—07
CHK: SRF
aker
MICHAEL BAKER JR., INC.
MOON TOWNSHIP, PENNSYLVANIA
FIGURE 6
GROUNDWATER CONTOUR MAP
PHILADELPHIA COKE COMPANY
4501 RICHMOND STREET
PHILADELPHIA, PENNSYLVANIA 19137
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aker
Michael Baker Jr., Inc.
APPENDIX C
Inventory of Documentation and Reference Documents
-------
The following is a list of documents in the order referenced in the report:
Document Date
Document
March 21, 2007
Site Development Review
August 13, 1980
Notification of Hazardous Waste Activity
October 9, 1980
EPA ID No. Issued
November 18, 1980
Part A Application
December 23, 1980
Acknowledge Notification
July 24, 1981
Acknowledge Processing Part A
October 22, 1982
Notification of Closure and Disposal
December 28, 1982
Removal Complete
June 1, 1983
Closure Plan
October 27, 1982
Formal Part B Request
July 5, 1983
Closure of Hazardous Waste Facility
August 1, 1983
City Review of Closure Plan
October 27, 1983
NOV
November 9, 1983
Waste Removed
December 13, 1983
PADEP Accept Closure Plan
August 17, 1984
Monitoring Well Site Map
March 30, 1984
Request of Waste
April 13, 1984
Waste Disposal Follow Up
August 31, 1984
Part B Request
September 18, 1984
Site Closed Will not Submit Part B
February 21, 1985
USEPA Draft Sampling and Analysis Plan
March 4, 1985
Revised Sampling Plan
July 16, 1985
Hydrogeologic Assessment
September 26, 1985
Hydrogeologic Investigation
January 17, 1986
Third Quarter 1985 Sampling
April 8, 1986
Fourth Quarter 1985 Sampling
September 12, 1985
Closure Plan Approved
April 15, 1986
Work Plan Soil Sampling
May 8, 1986
Soil Sampling EPA Comments
July 11, 1986
NOV Bonding
July 15, 1986
NOV Wells
August 27, 1986
Revised Soil Sampling Program
December 1, 1992
Engineering and Owner Certificate of Closure
October 31, 1986
PADEP Request of WMUs
January 29,1987
Hydrogeologic & Soils Investigation
July 22, 1987
Remediation Options
January 28,1988
Letter Follow-up PAH
February 1, 1988
WP Field Pilot Land Treatment Tests
1
-------
February 15, 1988
Soil Contamination Report
March 28, 1988
PADEP Response
April 6, 1988
Follow-up Response
April 21, 1988
PADEP Approves Pilot Study
May 20, 1988
Proposed Cleanup Criteria
June 16, 1988
WCC Letter Documenting PADEP Verbal Approval
February 6, 1989
NOV GW Wells
1982-1993
Hazardous Waste Inspections
February 22, 1989
Facility Response
February 24, 1989
Nonhazardous Results
June 20, 1989
PADEP Backfill Approval
September 1, 1989
WCC Certificate of Closure Report
May 1, 1990
Tank Farm Area Restoration Conceptual Design
September?, 1990
NOV Quarterly Groundwater Monitoring
September?, 1990
Quarterly GW Reports
November 6, 1990
Civil Penalty GW Monitoring
January 8, 1991
PADEP Groundwater Results
June 11, 1991
PADEP Application Soil Remediation Unit
June 21, 1991
Groundwater Monitoring
May 6, 1993
Groundwater Monitoring Plan
June 7, 1993
Closure of Seal Pot
September 16, 1993
Grading Plan for Site
September 16, 1993
Groundwater Response
December 3, 1993
Seal Pot Closure
September 28, 1994
Grading Plan for Site
December 23, 1994
Certificate of Closure Seal Pot
March 13, 1996
Inspection
1996
Comprehensive Groundwater Monitoring Evaluation
1997
Comprehensive Groundwater Monitoring Evaluation
March 23, 1998
Groundwater Approval Request
September 14, 1998
Groundwater to Annual Requirement
July 26, 1999
Termination of Groundwater Monitoring
October 27, 1999
CME Inspection
March 3, 2000
Bond Release Response
May 20, 1971
NOV Cyanide
July 1, 1971
Permit Application
January 3, 1972
Court Stipulation Cyanide Testing
August 25, 1972
NOV No Permit for Discharge
February 1, 1973
Meeting for NOV
December 1, 1973
Engineering Study of Wastewater
December 10, 1975
Industrial Waste Application
2
-------
December 19, 1975
Notice of Application
January 7, 1976
PIPP Unsatisfactory
February 18, 1976
Revised PIPP
February 9, 1976
Application Questions
February 18, 1976
Response to Letter
July 28, 1976
PADEP Approval
September 16, 1976
Response to PADEP
September 30, 1976
DRBC Decision
March 3, 1977
DEP Requests PIPP
January 10, 1978
NOV
May 23, 1978
Result of NOV
June 1, 1978
Response to Results
July 2, 1979
Response to Inspection
July 20, 1979
Response to Oil Leak
March 27, 1981
Response to Discharge
July 6, 1981
NOV Housekeeping
July 28, 1981
Response to Inspection
February 22, 1982
NOV Cyanide
May 21, 1982
NOV Cyanide
August 12, 1982
NOV DMR
June 28, 1982
Response to NOV
June 29, 1982
NOV
2000-2010
Hazardous Waste Inspections
1975-1985
Facility NPDES Inspections
3
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