THIRD FIVE-YEAR REVIEW REPORT FOR
METAL BANK SUPERFUND SITE
PHILADELPHIA COUNTY, PENNSYLVANIA
£
<
33
V
£
PRO^°
x>
z
LU
O
T
July 2023
Prepared by
U.S. Environmental Protection Agency
Region 3
Philadelphia, Pennsylvania
Digitally signed by PAUL
LEONARD
Date: 2023.07.25 12:22:00
-04'00'
Paul Leonard, Director Date
Superfund & Environmental Management Division
U.S. EPA, Region 3
PAUL
LEONARD
-------
***THIS PAGE INTENTIONALLY LEFT BLANK***
1
-------
Table of Contents
LIST 01 ABBREVIATIONS AND ACRONYMS 3
I. INTRODUCTION 4
Site Background 4
FIVE-YEAR REVIEW SUMMARY FORM 5
II. RESPONSE ACTION SUMMARY 5
Basis for Taking Action 5
Response Actions 6
Status of Implementation 8
Institutional Control Review 8
Systems Operations/Operation and Maintenance (O&M) 13
III. PROGRESS SINCE THE PREVIOUS REVIEW 14
IV. FIVE-YEAR REVIEW PROCESS 15
Community Notification, Community Involvement and Site Interviews 15
Data Review 15
Site Inspection 17
V. TECHNICAL ASSESSMENT 17
QUESTION A: Is the remedy functioning as intended by the decision documents? 17
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and remedial action objectives
used at the time of the remedy selection still valid? 18
QUESTION C: Has any other information come to light that could call into question the protectiveness of the
remedy? 20
VI. ISSUES/RECOMMENDATIONS 20
Other Findings 21
VII. PROTECTIVENESS STATEMENT 21
VIII. NEXT REVIEW 21
APPENDIX A - SITE MAPS A-l
APPENDIX B - SITE PHOTOS B-l
APPENDIX C - PRESS NOTICE C-Error! Bookmark not defined.
2
-------
LIST OF ABBREVIATIONS AND ACRONYMS
AOC
Administrative Order on Consent
ARAR
Applicable or Relevant and Appropriate Requirement
AUL
Activity and Use Limitaions
BTAG
Biological Technical Assistance Group
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CFR
Code of Federal Regulations
EPA
United States Environmental Protection Agency
ESD
Explanation of Significant Differences
ft
feet
FYR
Five-Year Review
HQ
Hazard Quotient
IC
Institutional Control
LNAPL
Light Non-Aqueous Phase Liquid
LTMP
Long-Term Monitoring Plan
MCL
Maximum Contaminant Level
(ig/m3
Microgram Per Cubic Meter
l-ig/L
Microgram Per Liter
mg/kg
Milligram Per Kilogram
NAPL
Non-Aqueous Phase Liquid
NCP
National Contingency Plan
ND
Non-Detect
NO A A
National Oceanic and Atmospheric Administration
NPL
National Priorities List
O&M
Operation and Maintenance
OU
Operable Unit
PADEP
Pennsylvania Department of Environmental Protection
PCB
Polychlorinated Biphenyl
PRP
Potentially Responsible Party
RCRA
Resource Conservation and Recovery Act
RI/FS
Remedial Investigation/ Feasibility Study
ROD
Record of Decision
RPM
Remedial Project Manager
RSL
Regional Screening Level
SVOC
Semi-Volatile Organic Compound
TCDD
Tetrachlorodibenzo-p-dioxin
TEF
Toxicity Equivalence Factor
TEQ
Toxicity Equivalency
TSCA
Toxic Substances Control Act
UST
Underground Storage Tank
UU/UE
Unlimited Use and Unrestricted Exposure
3
-------
I. INTRODUCTION
The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy to
determine if the remedy is and will continue to be protective of human health and the environment. The methods,
findings and conclusions of reviews are documented in FYR Reports such as this one. In addition, FYR Reports
identify issues found during the review, if any, and document recommendations to address them.
The U.S. Environmental Protection Agency (EPA) is preparing this FYR pursuant to the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the National
Contingency Plan (NCP) (40 Code of Federal Regulations (CFR) Section 300.430(f)(4)(ii)), and considering EPA
policy.
This is the third FYR for the Metal Bank Superfund site (Site). The triggering action for this statutory review is
the completion date of the previous FYR. The FYR has been prepared because hazardous substances, pollutants
or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure (UU/UE).
The Site consists of one operable unit (OU), which addresses soil, sediment and groundwater contamination.
EPA Remedial Project Manager (RPM) Andrew Hass led the FYR. Participants included EPA hydrogeologist
Ayowale Ayodele, EPA biologist Bruce Pluta, EPA toxicologist Jennifer Hubbard and EPA Assistant Regional
Counsel Robert Hasson. The potentially responsible parties (PRPs) were notified of the initiation of the FYR. The
review began on 8/8/2022.
Site Background
The Site is located at 7301 Milnor Street in an industrial area of Philadelphia, Pennsylvania (Figure 1); it includes
a fenced 10-acre upland property along the Delaware River and portions of the Delaware River contaminated by
past site operations. The upland property is bordered by Cottman Avenue and a mudflat on the west; Milnor Street
on the north; Revolution Recovery (a recycling company and salvage yard) on the east; and the Delaware River
on the south. The former St. Vincent's School that was located west across Cottman Avenue has been demolished
and a new, large building is currently under construction on the former St. Vincent's property. Quaker City Yacht
Club is a marina located adjacent to the mudflat farther west. A stormwater outfall owned by the City of
Philadelphia at the southern end of Cottman Avenue empties into the mudflat.
The Site was formerly operated by Metal Bank of America, Inc. and others (together "metal Bank") as a scrap
metal and transformer salvage facility. Site operations contaminated the property and portions of the Delaware
River with polychlorinated biphenyls (PCBs) and other contaminants. The upland portion of the Site includes two
areas: 1) the courtyard area in the north, which consists of one vacant steel building (Building 7) and a former
courtyard that is now a gravel parking/storage area; and 2) the southern area, which includes a vegetated, capped
landfill that was formerly used for scrap metal recovery. Seven Three Zero One LLC purchased the site property
in August 2016 and leases it to Revolution Recovery, who have expanded their operations on the Site by reusing
Building 7 and potentially creating additional container storage areas near the southern area cap. There has been a
proposal for City of Philadelphia to build a recreational waterfront trail through the Site. Appendix A includes a
Site Location map showing the Site property and surrounding areas.
An unconsolidated aquifer and a bedrock aquifer are present at the Site. Shallow groundwater in the
unconsolidated aquifer at the Site flows south and discharges to the Delaware River; groundwater in the bedrock
aquifer flows southeast. The Site's groundwater is designated as Class III, which is not a source of drinking water
and will not likely be in the future.
4
-------
FIVE-YEAR REVIEW SUMMARY FORM
SITE IDENTIFICATION
Site Name: Metal Bank
EPA ID: PAD046557096
Region: 3
State: PA
City/County: Philadelphia / Philadelphia
NPL Status: Final
Multiple OUs?
No
Has the Site achieved construction completion?
Yes
Lead agency: EPA
Author name: Andrew Hass
Author affiliation: EPA Region 3
Review period: 8/8/2022 - 7/3/2023
Date of site inspection: 9/22/2022
Type of review: Statutory
Review number: 3
Triggering action date: 8/23/2018
Due date (five years after triggering action date): 8/23/2023
II. RESPONSE ACTION SUMMARY
Basis for Taking Action
In 1972, the U.S. Coast Guard investigated oil seeps to the Delaware River and concluded that the Site was the
source, ultimately finding PCBs in the oil seeps at concentrations over 800 milligrams per liter (mg/L). Several
federal, state and local agencies then inspected the Site. EPA requested that Metal Bank conduct cleanup work,
but Metal Bank instead chose to perform additional studies. In 1983, EPA placed the Site on the National
Priorities List (NPL). PCBs were identified as the contaminants of primary concern. Other contaminants of
concern included polycyclic aromatic hydrocarbons, phthalates, dichlorodiphenyltrichloroethane and its
metabolites dichlorodiphenyldichloroethylene and dichlorodiphenyldichloroethane, and cadmium.
EPA completed the human health risk assessment in 1994, which identified the following potential populations at
risk from contaminant exposure, primarily to PCBs and dioxins/furans: future on-site construction workers, and
current and future recreational boaters who fish near the Metal Bank property. The risk assessment also evaluated
the risks to current and future off-site residents and future on-site industrial workers but found those risks to be
within EPA's acceptable range. Site contaminants did not pose an unacceptable noncarcinogenic risk.
5
-------
National Oceanic and Atmospheric Administration (NOAA) completed the aquatic ecological risk assessment in
1994, which evaluated potential impacts to several fish species and to benthic invertebrates. One fish, the
shortnose sturgeon, has been designated an endangered species. Exposure of aquatic receptors to sediment and
any non-aqueous phase liquid (NAPL) seeps presented unacceptable risk. The terrestrial ecological risk
assessment determined that terrestrial receptors' potential exposure to sediment and groundwater (directly through
seeps and springs and indirectly through contaminant transport to other media like surface water and sediment)
indicated a potential risk.
Response Actions
On April 23, 1980, EPA filed a civil action against Metal Bank and others under the Resource Conservation and
Recovery Act (RCRA) and the Toxic Substances Control Act (TSCA) for injunctive relief and recovery of EPA's
costs.1 On December 13, 1983, the court approved a stipulation between the United States and Metal Bank that
required Metal Bank to install and operate a groundwater recovery and treatment system until all recoverable oil
was removed from the property. The system consisted of three recovery wells, several oil separation units, and
several 55-gallon drums containing activated carbon to treat groundwater. The system removed most, but not all,
of the subsurface oil at the Site. Metal Bank operated this system until 1989, when Metal Bank dismantled it and
placed approximately one to two feet of clean-fill material over the surface of the southern area of the Site. EPA
monitoring in 1989 showed that despite several years of groundwater pump-and-treat operations at the Site, a
layer of PCB-contaminated oil at least three inches thick was still floating on the groundwater at some portions of
the Site. PCB concentrations measured in the oil layer were 1,539 ppm in 1977, prior to the oil recovery
operation, and were almost the same, 1,540 ppm, in 1989 when the oil recovery operation was terminated.
Meantime, EPA listed the Site on the Superfund National Priorities List (NPL) in 1983, and in 1987, identified
several other Potentially Responsible Parties (PRPs), many of which were utility companies that sent used and
discarded transformers to the Site. The PRPs formed a committee and the site owners and operators, including
Metal Bank, declined to join this group. In 1991, EPA entered into an administrative order on consent (AOC)
under CERCLA with a group of ten of the utility companies ("the Utility Group" or "PRP Group" ). Under the
AOC, the Utility Group agreed to perform an RI/FS at the Site.2
EPA issued a Record of Decision (ROD) to document the Selected Remedy on December 31, 1997. EPA
modified the remedy in three Explanations of Significant Differences (ESDs) issued on September 27, and
December 15, 2000, and April 2, 2014, respectively.
In 1998, EPA issued an administrative order to the PRP Group and the Site owners to design and construct
the cleanup. Metal Bank did not comply with the order and subsequently declared bankruptcy in 2003 after
the federal district court found Metal Bank liable under CERCLA for all costs of remedial action at the Site.
In September 2002, the PRP Group submitted a remedial design, but that remedy was not implemented due to an
order of Federal District Court Judge James Giles.3 After several months of negotiations, EPA and the PRP Group
agreed to certain modifications of the remedial action. These modifications are reflected in the 2006 Revised
Remedial Plan that was part of a 2006 Consent Decree under which the PRP Group agreed to implement the
remedial action, as revised. The 2006 Revised Remedial Plan (RRP) modified the remedial action most
significantly by calling for limited excavation of some contaminated sediments and the placement of marine
1 The Complaint was later amended to include claims under CERCLA, which was signed into law by President Carter in
December 1980.
2 Metal Bank also sued the members of the Utility Group, which became third-party defendants to the original lawsuit the
United States brought against Metal Bank.
3 Under Section 113(h) of CERCLA, a federal court may review a challenge to an EPA-selected remedial action under certain
circumstances, including when the government initiates a civil action under CERCLA § 107 to recover response costs. In this
case, because the government had filed a Complaint under Section 107, the court was permitted to review and modify EPA's
selected remedial action, which had been challenged by the PRPs.
6
-------
mattresses (a/k/a subaqueous caps) over other contaminated sediments in the Delaware River, rather than the
ROD's requirement that all contaminated river sediments be excavated. No remedial action objectives were
selected in these documents. However, the intent of the remedy was to prevent exposure to contaminated soil,
groundwater and sediment and to prevent the migration of contaminants to the Delaware River. Generally, the
RRP, which comprises the final Court-approved remedial action for the Site, consists of the following
components:
• Excavation of courtyard area soils CY-1 and CY-2 (to a depth of two feet for hot spots and to a depth
of one foot for the remainder of the courtyard), and placement of a soil cap over the courtyard area
and the former locations of buildings 2, 3, 4, 5 and 6.
• Power washing and surface coating of the floor in courtyard Building 7.
• Installation of a sheet-pile wall at the southwestern corner of the Site to prevent erosion of fill
materials into the river.
• Removal of the underground storage tank (UST) near the southwestern corner of the Site.
• Excavation of southern area "hot spots" SA-2, SA-3 and SA-4/5, and off-site soil disposal.
• Excavation of near-shore sediments with total PCBs greater than 1 mg/kg.
• Capping with marine mattresses of other sediment areas with total PCBs greater than 1 mg/kg.4
• Pre- and post-construction monitoring.
• Implementation of institutional controls (ICs).5
Soil excavation areas CY-1, CY-2, SA-2, SA-3 and SA-4/5 are depicted on the site map in Appendix C. Soil and
sediment cleanup levels are included below in Table 1. In addition, the RRP stated, "the performing parties must
take into account that the interface between the 6 to 24-inch cap and the old surface contains dioxin
concentrations of concern to EPA. Therefore, EPA will consider allowing the cap material to remain onsite if the
parties can demonstrate that concentrations of dioxins/furans are less than 5 ppb dioxin TEQ or the old cap
material is placed under four feet of material and does not threaten groundwater."
Table 1: Soil/Sediment Contaminant Cleanup Levels
Mcriiii
( oiiiiiiiiiiiiiiii
( lOillllip (idill
Sediment
Total PCBs
1 mg/kg
Southern area soil (SA-1, SA-4, and SA-
4/5)
Total PCBs
25 mg/kg
Courtyard area soil (two feet from surface)
(CY-1 and CY-2)
Total PCBs
10 mg/kg
Note: Cleanup Goals are site-specific risk-based standards.
Sources: 1997 Record of Decision, 2006 Revised Remedial Plan and 2008 Revised Design
Report. In addition, the cleanup goal for groundwater is to achieve a downward trend in
groundwater, as such, there are no cleanup levels specified in ROD
The 1997 ROD notes that due to the Class III groundwater status and the expected benefits of excavation and off-
site disposal of contaminant "hot spot" soil and sediment areas, no additional groundwater remediation was
required.
EPA issued an ESD on April 2, 2014, to add a requirement for additional institutional controls on upland
components of the remedial action and for the subaqueous caps in the Delaware River.
4 The marine mattresses are rock-filled containers constructed of high strength geogrid material.
5 The Revised Remedial Plan notes that other institutional and engineering controls to be implemented at the Site include
marking of the geotextile liner under the soil cap in the southern area, a new fence around portions of the Site, warning signs,
and a public education program.
7
-------
Status of Implementation
The remedial action was conducted by the PRP contractor from July 2008 to March 2010 and consisted of the
following activities:
• Excavated and backfilled areas CY-1, CY-2, SA-2, SA-3 and SA-4/5.
o Overburden or cover soils with PCB concentrations below 25 mg/kg were used as backfill in
the southern excavation areas;
o Soils with PCB concentrations above 25 mg/kg were disposed of it off-site.
• Removed the southern area UST and properly disposed offsite.
• Removed two additional USTs found during construction and disposed of them off-site.
• Power washed and surface coated Building 7 floor with epoxy.
• Installed the sheet pile wall.
• Excavated near-shore sediments and backfilled with geotextile and R-3 stone in the Delaware River.
o Approved sediments from the mudflat and deep-water excavation areas were placed in the
southern cap area.
• Installed marine mattresses and buttress stone to cap sediments in the Delaware River.
• Installed a Light Non-Aqueous Phase Liquid (LNAPL) trench for monitoring presence of LNAPL.
• Installed six monitoring wells in the southern area.
• Covered the southern area with geotextile and 24 inches of cover soil (with a total of 48 inches in the
southern part of the southern area).
• Covered the courtyard with geotextile and 12 inches of cover soil.
• Posted PCB warning signs along the Delaware River.
Some remedial components, such as the geotextile liner in the courtyard area, were not specifically required by
the 2006 RRP but added additional protectiveness.
Institutional Control Review
Under the 1997 ROD, the 2006 Consent Decree, 2006RRP and the 2014 ESD institutional controls (ICs) are
required for implementation of certain activity- and use-limitations (AULs) at the Site.
Institutional Control Review
Under the 1997 ROD, the 2006 Consent Decree and RRP, and the 2014 ESD, institutional controls (ICs) are
required for implementation of certain activity- and use-limitations (AULs) at the Site.
1997 ROD
The 1997 ROD required ICs to implement three AULs on the upland portion of the Site ("the Site property")6,
prohibiting (i) the use of the land for residential and agriculture purposes; (ii) the use of on-site groundwater for
domestic purposes, including drinking water; and (iii) excavation at depths (a) that encounter the water table or
contaminated soils or sediments beneath the soil cover, or (b) that compromise the stability of soil-covered areas
along the Delaware River.
The 1997 ROD also required informational ICs in the form of signs -
Signs shall be posted along the property boundary, including the river shoreline, warning individuals not
to eat fish caught in the vicinity of the Site. The warning signs shall read:
6 The Site property is located on adjacent parcels at 7301 and 7333R Milnor Street, Philadelphia, PA.
8
-------
WARNING.. .DO NOT EAT FISH
Fish caught in this area contain high levels of PCBs
PCBs may cause cancer
In addition, the 1997 ROD also required restriction of access to the Site by installation and maintenance of a fence
around the perimeter of the Site property. The signs and fence are currently maintained by the PRP Group as part
of their operation and maintenance (O&M) obligations under the Consent Decree.
Revised Remedial Plan and 2006 Consent Decree
Although it modified other parts of the remedial action selected in the 1997 ROD, the RRP generally requires the
same AULs selected in the ROD and adds one informational IC: namely, a public education program to inform
the local community about the Site and the potential safety hazards it poses.7 Like the ROD, the RRP requires
construction (and maintenance) of a fence around the Site property to restrict access.
As mentioned above, the RRP was part of the overall settlement under the 2006 Consent Decree between the
United States, on behalf of EPA, and the Utility Group. The 2006 Consent Decree affirmatively mentions land
and water AULs that are required at the Site and expressly reserves EPA's authorities to require additional AULs
that the Agency determines are needed (i) to implement the remedial action, (ii) to ensure the remedial action's
integrity and protectiveness, or (iii) to prohibit interference with the remedial action. As described immediately
below, EPA exercised these authorities in the 2014 ESD in which the Agency selected additional AULs for the
Site.
2014 ESD
The additional AULs selected in the 2014 ESD focused on non-interference with the components of the remedial
action that were in place on the Site property, as well as in the Delaware River and on the riverbank. As such, the
2014 ESD required ICs to implement the following two AULs:
• A prohibition on all activities that would, in any manner, disturb or interfere with the remedial systems
that have been implemented on the upland portion of the Site, without prior written permission from EPA.
The remedial systems include the soil cover, monitoring wells, epoxy coating on the floor of Building 7,
LNAPL trench, sheet-pile wall, and security measures to prevent access to the upland portion of the Site.
• A prohibition on all activities at the Site that would, in any manner, disturb or interfere with the remedial
systems placed in the Delaware River, including subaqueous caps, "danger" buoys, bank armoring and
the sheet-pile wall, without prior written permission from EPA.
River-Related Institutional Controls
Besides the upland areas of the Site property, the Site includes the riverbank, sediments in the Delaware River,
and other places, including a mud-flat adjacent to the Site, where hazardous substances from the former Metal
Bank facility have come to be located.
As discussed above, three subaqueous caps were placed over contaminated sediments in the Delaware River
during the remedial action. These three caps, as depicted on Figure 2, below, are referred to as (i) the Western
Subaqueous Cap, which lies on the River bed just south and west of the Southern Cap Area of the Site Property;
(ii) the Central Subaqueous Cap, which lies on the River bed north and east of the Site property; and (iii) the
Eastern Subaqueous Cap, which lies on the River bed just north of the Central Subaqueous Cap.
7 The 2014 ESD states "The Utility Group will also conduct annual educational meetings with the Quaker City Yacht Club to
provide information regarding the potential hazards posed to boaters and other recreational users of the Delaware River by
the subaqueous caps."
9
-------
Generally, under Pennsylvania law, the owner of property abutting the Delaware River in Philadelphia ("the
riparian owner") owns the submerged land within the River's bed adjacent to the riparian owner's property, out to
a "Bulkhead" line established by the United States Army in 1940. The Commonwealth of Pennsylvania
(Commonwealth) owns the submerged land within the River's bed from the Bulkhead line to the "Pierhead" line,
which is just east of the Bulkhead line.8 Riparian owners along the Delaware River have legal rights to build
structures on the submerged lands that they own - i.e., on submerged land out to the Bulkhead line. With the
consent of the Commonwealth, a riparian owner may also build out to the Pierhead line, provided the construction
is adjacent to the property they own.
In this case, ICs need to be put into place for all three subaqueous caps because they were placed on submerged
lands to which riparian owners have property interests under Pennsylvania law. For instance, portions of the
Western and Central Subaqueous Caps, as depicted in Figure 2, are on submerged lands owned by Revolution
Recovery. Larger portions of both of these caps are also on submerged lands owned by the Commonwealth. As
reflected in Figure 2 and in publicly available property records, other riparian owners on whose submerged lands
the subaqueous caps have been placed include:
(i) The City of Philadelphia - The Western Subaqueous Cap partially lies on submerged land that
includes the City's right of way for Cottman Avenue;9
(ii) B9 Milnor Owner, LLC, a Delaware limited liability company - The Western Subaqueous Cap
partially lies on submerged land of 7101 Milnor Street, a contiguous property formerly owned by
St. Vincent's Orphan's Asylum and currently owned by B9 Milnor Owner, LLC (B9 Milnor), a
Delaware limited liability company.10 Most of the Western Subaqueous Cap appears to be on
submerged land between the Bulkhead and Pierhead lines (i.e., Commonwealth-owned
submerged land) upon which B9 Milnor could build a pier or wharf with the Commonwealth's
consent; and
(iii) RW Holdings, Inc. - The Eastern Subaqueous Cap lies entirely on submerged land owned by
another contiguous property owner, RW Holdings, Inc. (RW Holdings). The address of this
property is 5200 Bleigh Avenue. In addition, a substantial portion of the Central Subaqueous Cap
also lies on submerged land owned by RW Holdings. Most of the Central Subaqueous Cap lies on
submerged land owned by the Commonwealth; and RW Holdings may have the right to construct
a wharf, pier, or other structure on this submerged land with the Commonwealth's consent.
Institutional Controls in Place at the Site
Institutional controls are currently in place for the Site property and the submerged land immediately adjacent to
it. The current owner of the Site property, Seven Three Zero One, LLC, an affiliate of Revolution Recovery,
recorded an Environmental Covenant for the property on August 1, 2019, in accordance with the Pennsylvania
Uniform Environmental Covenants Act.11 The Environmental Covenant implements all the AULs specifically
related to the Site property that were selected in the 1997 ROD, the RRP, the 2006 Consent Decree, and the 2014
ESD. It specifically implements the AULs related to both the upland and submerged areas of the Site property.
Informational Controls. As mentioned above, the Utility Group maintains the signs and fencing required under the
1997 ROD and the RRP. In addition, as required by the RRP, the Utility Group has conducted occasional public
educational sessions at the Quaker City Yacht Club (Yacht Club) to inform the local community about the Site
and the potential safety hazards it poses to the boating public. The 2013 FYR states that the PRP group will
conduct annual educational meetings with the Yacht Club. During the current FYR period, the PRP has not
conducted any meetings with the Yacht Club due to alleged lack of interest of the Club's members. EPA will
8 The Commonwealth also owns the submerged land east of the Pierhead line, out to the middle of the navigational channel
of the Delaware River.
9 A very small portion of the Eastern Subaqueous Cap may also lie on submerged land that is part of the City's right of way
for Bleigh Avenue.
10 B9 Milnor acquired the property on or around November 2, 2021.
11 Act No. 68 of 2007, 27 Pa. C.S. §§ 6501-6517.
10
-------
consider and suggest other public outreach options, including distribution of fact sheets or other public notices,
that the Utility Group might choose to do to meet the public education requirement of the RRP. An event that
occurred at the Site within the past five years arguably illustrates the need for public education about the Site,
especially the remedial components in or near the Delaware River. An unidentified boater moored their boat to the
sheet-pile wall, where it remained moored for several days. The Site owner notified EPA about the matter. EPA
contacted the City and the Pennsylvania Fish & Boat Commission for assistance. Eventually, the boat was moved.
Events such as this one could damage the sheet-pile wall and may be less likely to occur if more public outreach
happened.
Figure 2: Institutional Control Map
136Ni00088
li136N;l;00.065]
P"3'6W
200
400
800
H Feet
Legend
Sources: Esri, DigitalGlobe, GeoEye, Earthstar
Geographies, CNES/Airbus DS, USDA. USGS, AEX,
Getmapping, Aerogrid, IGN, IGP, swisstopo.
Philadelphia Atlas, the Philadelphia Department of
Records and the 2016 Long-Term Monitoring Report.
Approximate Site
Boundary
ix xi Approximate
I—*—' Subaqueous Caps
nro
] Parcels
Parcels under 2002
Notice of Hazardous
Substance Disclosure
and Declaration of
Restrictions
Skeo
Metal Bank Superfund Site
City of Philadelphia, Philadelphia County, Pennsylvania
Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey.
11
-------
Table 2: Summary of Planned and Implemented ICs
Mediii. l.niiiiK'civd
( oil(nils. ;iikI AiViis
1 hill Do \o(
Support I 1 /I 1.
IJiised on ( iirrenl
C ciiitl i I ions
ICs
Needed
ICs ( idled
lor in llie
Decision
Documents
Impiicled
Piireelisr'
IC
OI).jee(i\e
Tide of l(
lusl riniieiil
Implemented
iintl Diile
Groundwater, soil,
sediment, and
components of
remedial action
Yes
Yes
7301 Milnor St.,
Tax Parcel ID
No.884258000;
Map Reg. Nos.
136N100065 and
136N100066);
and 7333R
Milnor St. (Tax
Parcel ID No.
884258010; Map
Reg. Nos.
136N100069 and
136N100064)
• Prohibit residential or
agricultural uses.
• Prohibit excavation,
digging, drilling or other
disturbance of the soils.
• Prohibit groundwater use
at the Site.
• Prohibit activities that
would interfere with the
upland remedial systems.
• Prohibit activities that
would interfere with the
Delaware River remedial
systems, including
subaqueous caps,
"danger" buoys, bank
armoring and the sheet-
pile wall.
Environmental
Covenant,
recorded August
1,2019
Sediments and
subaqueous caps
Yes
Yes
5200 Bleigh
Avenue (Tax
Parcel ID No.
884252000; Map
Reg. No.
136N100088);
and 7101 Milnor
Street (Tax
Parcel ID No.
885000043; Map
Reg. Nos.
116N070009 and
116N070010),
and City of
Philadelphia
R/W Cottman
Ave., Delaware
Ave., and Bleigh
Ave.
(See Figure 2)
• Prohibit activities that
would interfere with the
Delaware River remedial
systems, including
subaqueous caps,
"danger" buoys, bank
armoring and the sheet-
pile wall.
Not yet
implemented
Subaqueous caps,
buoys, and sheet-pile
wall
Yes
Yes
See above.
• Conduct annual
educational meetings
with the Quaker City
Yacht Club to provide
information regarding
the potential hazards
posed to boaters and
other recreational users
of the Delaware.
2006 Revised
Remedial Plan
Notes:
a. Parcels accessed at htft>s://atlas.t>hila.eov/ on 3/13/2018.
12
-------
Systems Operations/Operation and Maintenance (O&M)
The PRP Group performs O&M in accordance with the approved 2020 Long-Term Monitoring Plan (LTMP). The
primary activities include groundwater, LNAPL trench and sediment monitoring; inspections of the caps,
Building 7 floor slab, and the sheet pile wall; and mudflat and marine mattress inspections.
Upland cap inspections during this FYR period indicated that erosion was not evident, and that vegetation
remained intact on the southern cap area. An invasive plant survey was also conducted in 2022. The survey noted
that total percent cover of invasive species increased from 4.0% in 2021 to 7.0% in 2022. Although there was a
3.0% increase in invasive species cover, it continues to be maintained below the ten percent performance measure
of the site.
In 2020, Revolution Recovery placed additional fill material (e.g. crushed concrete and gravel aggregate) atop the
vegetated cap area south of Building 7. Revolution Recovery provided USEPA and Ramboll notice of these
changes on December 4, 2019, and all parties agreed to the change in land use. The fill material covers
approximately 0.9 acres of the northern portion of the remaining vegetated cap area (approximately 7.9 acres)
south of Building 7. The fill material was placed to further increase Revolution Recovery's storage capacity at
the Site and to provide additional staging areas. Revolution Recovery provided EPA and Ramboll (the Utility
Group's contractor) with prior notice of these changes on December 4, 2019, and both parties approved the
change in land use.
During the current FYR period, Revolution Recovery completed the backfilling of Building 7 as well as covering
an 80'x 55' section of epoxy-coated floor slab with an 8-inch concrete slab after receiving EPA approval. The
epoxy coated floor is now completely capped and no longer visible for inspection.
The repaired sheet pile wall is inspected annually. Eight prisms mounted on the sheet pile wall continue to be
surveyed and compared to the post-repair as-built survey for signs of outward movement (towards the Delaware
River) as well. Significant wall movement is defined as a net outward (i.e. towards to Delaware River) departure
of more than 0.5 inches from the as-built survey performed on July 14, 2016, at the completion of the sheet pile
repairs. During the annual inspection, the structural condition of the sheet pile wall is done by looking for signs of
wall failure or movement and commenting on the state of structural wall components from both the land-side and
water-side of the sheet pile wall. The latest sheet pile wall inspection took place on October 6, 2022. No
significant outward movement has been noted during the inspection since the repair. The repairs welds have held
and providing the necessary support to the sheet pile wall.
The mudflat backfill and marine mattress inspections are currently conducted every five years. The marine
mattresses were surveyed in 2022 using diver-assisted observations and GPS technology. Features of the
subaqueous caps that were more easily observable were noted to be in good condition and in the correct location.
The dive team reported during the inspection that the caps appeared to be intact as built and remained surrounded
by their respective/associated rip rap buttress. The dive team also reported that the mattresses appeared in good
condition, only showing minimal signs of wear and tear (i.e., ripped mesh likely from anchor or tree snags).
Additionally, their report indicated there was sediment deposition over the mattresses, especially closer to shore,
and that there was established submerged aquatic vegetation (i.e., eel grass) growing in these areas. Less
sediment was present over the portions of the mattresses that were closer to the navigation channel, which is
likely the result of exposure to the faster moving current. As visually confirmed by the dive team, the mattresses
remain where they were originally installed and continue to function as intended.
Sediment sampling is not currently conducted at scheduled intervals. In 2020, a meeting occurred to discuss PRP
proposed modifications to the LTMP. As a result of the meeting, the following sediment monitoring
modifications to the 2011 LTMP were agreed to:
• Visually inspect mudflat backfill at low tide and perform elevation survey
(every five years).
• Visually evaluate sediment accumulation in backfill areas at low tide and
13
-------
measure subaqueous cap sediment thickness (every five years).
• Visually inspect marine mattresses (divers) and perform bathymetric survey
(every five years, plus after anthropogenic disturbance or 25-year storm event)
With EPA's approval, the Utility Group have not conducted any biological monitoring during the review period
and instead conducted sediment inspections. Results of groundwater, LNAPL trench monitoring, and sediment
inspection are discussed in the Data Review section of this FYR.
III. PROGRESS SINCE THE PREVIOUS REVIEW
This section includes the protectiveness determination and statement from the previous FYR as well as the
recommendations from the previous FYR and the status of those recommendations.
Table 3: Protectiveness Determination/Statement from the 2018 FYR
Sitewide Protectiveness Statement
Protectiveness Determination:
Short-term Protective
Protectiveness Statement: The remedy at the Site currently protects human health and the environment
because contaminated soil and sediment were excavated and/or capped, Building 7 was sealed with
epoxy, institutional controls are in place for the upland property, and long-term monitoring is being
performed. For the remedy to be protective over the long term, the institutional controls required by the
2014 ESD must be implemented.
Table 4: Status of Recommendations from the 2018 FYR
()l #
Issiio
Kccoiiimcnriiilion
( II ITCH 1
Sliilus
( iirivnl Impk'iiK'nliilion
Sliilus Description
( omplclion
Diilc (if
;ippliciil)lc)
Sitewide
Institutional
controls
required by the
2014 ESD are
not in place.
Implement institutional
controls required by the 2014
ESD
Completed
An environmental
covenant was recorded for
the former Metal Bank
Facility.
An
environmental
covenant for
former Metal
Bank facility
was recorded
on August I,
2019.
14
-------
IV. FIVE-YEAR REVIEW PROCESS
Community Notification, Community Involvement and Site Interviews
A public notice about this FYR was published by the EPA in the Northeast Times on 3/22/2023 (Appendix D).
The results of the review and the report will be made available at the Site's information repository, Northeast
Regional Library, located at 2228 Cottman Avenue, Philadelphia, PA 19149, and online at the Sites webpage:
www. epa.gov/superfund/metalbank
Interviews were not conducted as part of this FYR. The Site is fenced with a 6-foot chain-link fence topped with
barbed wire. Access to the Site is restricted by the gate of the adjacent scrapyard operated by current site
operators, Revolution Recovery. There are "no trespassing" signs on the fence that also identify the area as a
Superfund site. The Site is not in close proximity to residential areas.
Data Review
Information reviewed in this FYR period include monitoring results from the LNAPL trench monitoring data and
groundwater monitoring data.
LNAPL Trench
No measurable free product has been observed visually or with a probe in the LNAPL trench during any of the
inspections conducted to date. Measured trench groundwater elevations at the Site have ranged between
approximately 2 and 4 feet (ft) above mean sea-level since monitoring began. Groundwater fluctuations at each of
the LNAPL trench sumps over the years of measurements have ranged from 3.33 ft (at Sump 1) to 2.24
ft (at Sump 5).
Sediment
The 2022 bathymetric survey data show a general increase in surface elevations over the 2012 and 2017 surveys,
indicating modest levels of deposition have taken place over time. The average sediment accumulation over the
sub-aqueous cap areas, as measured by divers, has increased from 0.6 ft in 2017 to 0.7 ft in 2022, and the median
sediment accumulation has slightly decreased from 0.4 ft in 2017 to 0.3 ft in 2022. These sediment accumulation
data are consistent with the bathymetry described above and support the argument that the marine mattresses have
not moved.
Groundwater
The objective of the groundwater monitoring program is to evaluate the effectiveness of the upland source
removal at reducing contaminant concentrations by reviewing concentration trends and to determine the potential
for contaminant migration from groundwater to surface water. Shallow groundwater is monitored by the PRP
Group annually in MW-3 and MW-4 and biannually in MW-1, MW-2, MW-5 and MW-6. Analytical parameters
included in the monitoring program are PCB Aroclors and semi-volatile organic compounds (SVOCs). In the last
five years, PCBs were infrequently detected in groundwater and all instances of PCB detections are shown in
Table 5, below. No PCBs were detected in groundwater in 2018 and 2020. The 1997 ROD and 2006 Revised
Remedial Plan did not identify cleanup levels for PCBs in groundwater; however, for comparison purposes, all
PCB detections during this FYR period were below the federal Maximum Contaminant Level (MCL) of 0.5 (ig/L.
15
-------
Table 5: PCB Detections during FYR period
pen
CoiKTiilmlion
um/i.)
Diilo
Well
Total PCBs/Aroclor 1248
0.009J
May 26, 2021
MW-3
Total PCBs/Aroclor 1268
0.0052 J
May 26, 2021
MW-3
Total PCBs/Aroclor 1248
0.022 J
May 26, 2021
MW-4
Total PCBs/Aroclor 1268
0.049
April 24, 2019
MW-3
Notes:
J = estimated value
SVOC concentrations in groundwater during this FYR period were comparable to previous years. The highest
SVOC concentrations were in MW-5, which is downgradient of the southern cap area (Figure 3). SVOCs detected
during this FYR period are shown in Table 6, below. The PRP Group contractor evaluated SVOC concentration
trends in groundwater since construction of the remedy was completed in 2010 using the Mann-Kendall statistical
test. The test determined that there was not a statistically significant trend in any of the monitoring wells at the
Site over the past seven years.
Table 6: SVOC Concentrations during FYR period
SY()(
( onceii I r;i I ion ui»/l.)
April 30. 20IS
April 24. 20l«>
.Inno 24. 2020
M;i\ 2(.. 2021
AiiuiisI 3. 2022
MW-4
\ccii;iphlhcnc
1 "J
: 4
3.7
. (.
: 4
Miihiviic
i i j
1 5 .1
1 4 .1
0 <>.l
MW-5
Acenaphthene
3.4
17
23
Acenaphthylene
1. J
0.86J
Anthracene
1.4 J
Carbazole
1.3 J
11
Dibenzofuran
1.8 J
8.3J
2,4-Dimethylphenol
2.7 J
Fluoranthene
0.62 J
4.1
2.6
Fluorene
2.4
11
2-Methylnaphthalene
4.3
Naphthalene
16
Phenanthrene
3.3
Pvrene
^ 6
3.6
MW-6
April 23. 2019
M;i\ 25. 2021
Acenaphthene
8.4 J
4-Nitrophenol
1.1 J
Notes:
J = estimated value
Blank cell = compound was not detected
16
-------
Site Inspection
The site inspection was performed on 9/29/2022. Participants included EPA RPM Andrew Hass, EPA BTAG
Biologist Bruce Pluta, EPA CIC Lisa Trakis and Owen Zalme of Ramboll (PRP contractor). The purpose of the
inspection was to assess the protectiveness of the remedy.
The Site is fenced with a 6-foot chain-link fence topped with barbed wire. Access to the Site is restricted by the
gate of the adjacent scrapyard operated by current site operators, Revolution Recovery. There are "no trespassing"
signs on the fence that also identify the area as a Superfund site. Participants began the inspection in a former
vegetated area that Revolution Recovery covered with additional gravel and is used for truck and container
storage. Participants then inspected Building 7. EPA observed where Revolution Recovery raised the floor of the
building by adding crushed stone and laying a concrete slab on top of the epoxy floor coating in Building 7.
The southern cap area was well vegetated with tall grasses. Site monitoring wells are visible and the wells are
properly secured. Participants also inspected the site fence and sheet pile wall on the southern part of the Site
along the Delaware River from the land. The fence has fish advisory signs facing the river. Rip rap is present just
beyond the sheet pile wall. On October 7, 2022, the sheet pile wall repair, which appeared to be in good condition,
was inspected from the river side.
V. TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents?
Yes. The Selected Remedy appears to be functioning as intended. Soil contamination in the southern and
courtyard areas was excavated, disposed of off-site, or consolidated on-site and capped, thereby preventing
exposure to contaminated materials. The southern area cap is well vegetated, and the courtyard area cap is
covered with gravel. O&M of the capped areas is performed by the PRP Group in accordance with the 2020
LTMP.
The sheet pile wall is still in good condition following a 2016 repair and effectively prevents erosion of fill
materials into the river. Monitoring of the LNAPL trench is being performed in accordance with the selected
remedy and no measurable LNAPL was observed during this FYR period. The Building 7 modifications by
Revolution Recovery to back fill the floor and install a concrete slab over an 80' x 55' section of the epoxy
coating floor was completed during this FYR period. The subaqueous caps were inspected in 2022 during this
FYR and appeared to be in good condition and intact. The Site is fenced and has "no trespassing" and fish
consumption warning signage.
Groundwater monitoring data show that source control is effective, as there are not significant impacts from site
groundwater to the river.
Institutional controls selected in the 1997 ROD are in place on the Site property and include restrictions on
residential or agricultural uses, excavation or disturbance of the soils, and groundwater use. The 1997 ROD also
required signage to warn the public about dangers posed by consumption of fish caught in the Delaware River
near the Site. EPA issued a 2014 ESD to also require institutional controls to: 1) specifically protect upland
remedial systems, including the soil cover, monitoring wells, epoxy coating on the floor of Building 7, LNAPL
trench, sheet pile wall, and site security measures, and 2) prohibit activities that would interfere with the Delaware
River's remedial systems, including subaqueous caps, "danger" buoys, bank armoring and the sheet-pile wall.
These additional institutional controls are also in place. A public education program is required by the Revised
Remedial Plan; however, these educational meetings have not occurred for several years.
17
-------
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and remedial action objectives used
at the time of the remedy selection still valid?
The initial risk assessment was performed in 1994. Significant changes to toxicity factors, exposure factor
defaults, and risk assessment methodology have been implemented since then. Therefore, this FYR focuses on
evaluating the ongoing protectiveness of the remedy components and site media in the light of these changes.
Soil and fish are the most significant sources of potential human health risk, but the exposure pathways have been
rendered incomplete. Current soil risk estimates demonstrate that maintaining intact covers and preventing non-
residential site uses are important to ensure continued protectiveness of the soil remedies. The most recent fish
tissue data indicated potential concerns for fish consumers. Signs are posted warning people not to consume
locally caught fish. In addition, since the completion of the 1994 Ecological Risk Assessment for the Site, there
has been continued evolution of the methods available for the completion of the ecological risk assessment
process. This includes the issuance of EPA's 1997 Ecological Risk Assessment Guidance for Superfund: Process
for Designing and Conducting Ecological Risk Assessments and the 1999 OSWER Directive 9285.7-28 P
Issuance of Final Guidance: Ecological Risk Assessment and Management Principles for Superfund
Sites. Despite advances in available ecotoxicological data, the cleanup levels used at the time of remedy selection
are still protective as implemented. Especially considering the primary components of the remedy were removal
and containment, the remedial action objectives continue to be valid.
All of the site media and associated risks are discussed in more detail below:
Soil
Most of the site soils have been excavated or covered. The Site soil goals mentioned in the site documents were
25 mg/kg PCBs, 10 mg/kg PCBs, and 5 ug/kg dioxin TEQs; these were coupled with soil covers.
For default industrial workers, direct contact with 5 ug/kg of 2,3,7,8-TCDD equivalents would be associated with
an HI of 6 and a cancer risk of 2E-4. These risks exceed EPA's acceptable ranges. PCBs would be associated with
a 2E-5 cancer risk at 25 mg/kg. If the PCBs were in the form of Aroclor 1254, which also has an oral Reference
Dose, then this concentration of PCBs would slightly exceed the acceptable HI (estimated HI 1.5, rounded to 2).
The 10 mg/kg PCB concentration would be within the acceptable risk range for workers.
However, the remedy remains protective because covers are in place and maintained that prevent exposure to soil
at these concentrations. In addition, institutional controls are in place that prevent residential and agricultural use
of the site.
Groundwater
The Proposed Plan stated that the groundwater has been designated as Class III; this was also stated in the
responsiveness summary to the ROD. In that case, any risks from groundwater would be associated not with
future potable use, but with two migration pathways: into indoor air via vapor intrusion, or into the river. Drinking
water intakes were reported on the river two miles upstream but within the zone of tidal reversal effects. It should
be noted that in the latter scenario, dilution would be expected due to the distance and the size of the river.
Groundwater has been monitored regularly. High metals concentrations were reported in the samples from the
early 1990s, which is not unexpected given the site history of scrap metal handling. By October 2011, the metals
concentrations appeared to be much lower. EPA determined at that time that there was no more need to monitor
for groundwater metals.
The groundwater was apparently last sampled for VOCs around 1992, at the time of the RI, when concentrations
of hundreds of parts per billion were detected beneath the southern portion of the site. Although the RI referred to
the highest concentrations as being at the "upgradient edge," they were highest in the southeastern area, and
18
-------
groundwater reportedly flows to the south and east. In 1992, the wells nearest the buildings were non-detect for
VOCs, except for one detection of PCE of 8 ug/L, and the wells nearest the river were non-detect or had total
VOCs at 11 ug/L. The RI also described the VOCs as attenuating rapidly, and there were dramatic decreases from
1991 to 1992. While it would be reasonable to suppose that VOCs have continued to decrease over the years,
VOCs have not been part of the sampling suite for monitoring, increasing the uncertainty. Because VOCs have
not been sampled in over 30 years, EPA will be recommending that they be included in a future groundwater
sampling event at the Site.
SVOCs and PCBs in groundwater have been monitored regularly and appear sporadically. The 2021 groundwater
data were below levels of concern, but more detections of SVOCs were found in 2022, demonstrating that the
concentrations continue to fluctuate. The 2022 monitoring report found no significant trends in groundwater. As
in the previous report, notable contamination was only found in MW5, where many SVOCs are detected.
Surface Water
Recreational use of the river was not associated with unacceptable risk in the RI. The potential for migration to
drinking water intakes was discussed above, in the groundwater section.
Sediment
The PCB goal of 1 mg/kg would still be protective for recreational and industrial users. The excavation and
covers provide additional protection. The PRP assumed that the PCB-based actions would address the risks from
PAHs and dioxins as well.
The 2015 and 2016 data were evaluated in the 2018 FYR. That assessment found that only one non-reference
sample exceeded 1 mg/kg PCBs, a concentration of 1.1 mg/kg that was higher than both its duplicate and split
results. One reference location had PCBs at 1.3 mg/kg. These concentrations do not pose an unacceptable risk for
human exposure. The 2018 FYR stated that EPA would evaluate the need for additional sediment sampling during
the 2023 FYR period. However, in a 2020 meeting, EPA agreed to suspend this requirement, with the
understanding that further sediment sampling may be necessary if other monitoring activities indicate
disturbance or failure of any of the components of the remedy. Further sampling may be required if there
are indications of changed conditions.
Fish and Other Biota
PCBs can bioconcentrate in the food chain, and therefore this a potential concern. The most recent available fish
data were from 2011-2012. These mostly consisted of killifish, minnows, and eels. PCBs, including dioxin-like
congeners, were detected. The maximum concentrations from the site samples were in eel (2.36 mg/kg total PCB
congeners, 0.001 mg/kg 2,3,7,8-TCDD equivalent congeners). Consuming even one half-pound meal per year of
such concentrations would exceed EPA's acceptable risk levels.
The 2013 FYR recommended further sampling to examine trends, but EPA later determined during the 2018 FYR
period that the sediment data was sufficient. EPA acknowledged that fish tissue concentrations have
decreased significantly from pre-remedial concentrations. In addition, concentrations at the site have
continued to decline since the remedy was implemented and were currently comparable to reference
concentrations at Pennypack Creek
Signs are posted warning people not to consume locally caught fish. There is currently no evidence to support
discontinuing this recommendation.
19
-------
Onsite Building
High PCB concentrations (e.g., 372 mg/kg) were once detected in Building 7, which led to the power-washing
and epoxy floor-coating of this building. The integrity of the coating was monitored regularly, and the floor was
repaired on at least one occasion. Recently, the coated floor was covered by another 8 inches of concrete. Overall,
the exposure pathway to any floor contamination has been interrupted.
The greatest concerns for potential vapor intrusion would be to the onsite building, Building 7. VOCs were not
noted in the nearest wells, although the data are thirty years old, as noted above. Some SVOCs, such as
naphthalene, are also volatile enough that this pathway still be considered. Naphthalene has been detected
intermittently in groundwater; in 2022 it was detected at a maximum of 55 ug/L. This concentration exceeds the
Vapor Intrusion Screening Levels, but would be within the acceptable risk range for either residential or
commercial buildings (cancer risk between 1E-6 and 1E-4; HI less than 1). The installation of a new 8-inch
concrete floor in Building 7, on top of the existing epoxied floor, may incidentally provide additional protection
against vapor intrusion.
QUESTION C : Has any other information come to light that could call into question the protectiveness of the
remedy?
No other information has come to light that could call into question the protectiveness of the remedy.
VI. ISSUES/RECOMMENDATIONS
Issues it ml Recommendations Identified in (ho l-'Yk:
OU(s): Sitewide
Issue Category: Institutional Controls
Issue: Institutional controls required by the 2014 ESD are in place for the real
property that comprised the former Metal Bank facility. However, ICs are still
required for the subaqueous caps placed on submerged lands owned by
contiguous property owners and the Commonwealth
Recommendation: Implement institutional controls required by the 2014 ESD.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
9/30/2026
OU(s): Sitewide
Issue Category: Institutional Controls
Issue: Need for Sitewide Institutional Control Implementation Plan
Recommendation: Develop an acceptable Institutional Controls Implementation
Plan for the Site
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
9/30/2024
20
-------
OTHER FINDINGS
Several additional recommendations were identified during the FYR. These recommendations do not affect
current and/or future protectiveness.
• The PRP conducted one meeting with the yacht club to inform them of potential hazards posed to boaters
and other recreational users of the Delaware River by the marine mattresses; however, no further
meetings have been held due to lack of interest from the yacht club. Consider resuming yacht club
educational meetings if needed in the future. Should lack of interest from yacht club continue, EPA will
consider and suggest other public outreach options, including distribution of fact sheets or other public
notices, that the Utility Group might choose to do to meet the public education requirement of the RRP.
• Any change to the vegetative cap at the Site must receive EPA/PADEP approval per the environmental
covenants.
• The RI described VOCs as "attenuating rapidly" as there were dramatic decreases from 1991 to 1992.
However, VOCs have not been part of the sampling suite for monitoring in over 30 years increasing the
uncertainty. EPA recommends that groundwater sampling include analysis for VOC in the next Annual
Monitoring Report to ensure concentrations have continued to decrease over the years.
VII. PROTECTIVENESS STATEMENT
Sitewide Protectiveness Statement
Protectiveness Determination:
Short-term Protective
Protectiveness Statement: The remedy at the Site currently protects human health and the environment
because contaminated soil and sediment were excavated and/or capped, Building 7 was sealed with
epoxy, institutional controls are in place for the upland and submerged areas of the Site property, posted
signs at the Site warn against fish consumption, and long-term monitoring is being performed. For the
remedy to be protective over the long term, institutional controls for the subaqueous caps required by
the 2014 ESD must be implemented on submerged lands of contiguous property owners and the
Commonwealth and an acceptable Institutional Controls Plan needs to be implemented.
VIII. NEXT REVIEW
The next FYR Report for the Site is required five years from the completion date of this review.
21
-------
APPENDIX A - Site Map
Figure A-l - Site Location
Metal Bank
Superfund Site
Burli i i
Courtyard
Areal\
Revolu1
. Recovi
BHormerM
[StrfSent^s]
*School3|
250 500
1,000
I Feet
Sources: Esri, DeLorme, AND, Tele Atlas, First American, UNEP-
WCMC, USGS, DigitalGlobe, GeoEye, Earthstar Geographies,
CNES/Airbus DS, USDA, AEX, Getmapping, Aerogrid, IGN, IGP,
swisstopo and the 2016 Long-Term Monitoring Report.
Legend
Approximate Site Boundary
Approximate Subaqueous Caps
^ Skeo
Metal Bank Superfund Site
City of Philadelphia, Philadelphia County, Pennsylvania
A-l
-------
Figure A-2 - Detailed Site Map
f / / '
JrRir V ¦*,
. ^ |T
|W *2®^
Courtyard \ Revo|ution
% v\ Recovery
\
Y
W'
0 100 200
400
I Feet
k tra
L\J
*
fcMW£
Southern
Area
«
\
»MWr4tl
Sources: Esri, USGS, DigitalGlobe, GeoEye,
Earthstar Geographies, CNES/Airbus DS, USDA,
AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo
and the 2016 Long-Term Monitoring Report.
Legend
L__| Approximate Site Boundary LNAPL Trench
|
-------
APPENDIX B - SITE PHOTOS
Upland View Looking East
B-l
-------
Upland View Looking North
B-2
-------
Upland View Looking West
Sheetpile Wall Looking Southwest
B-3
-------
Sheetpile Wall Repaired Section and Rip-Rap
Monitoring Well
B-4
-------
APPENDIX C - PRESS NOTICE
EPA PUBLIC NOTICE
EPA REVIEWS CLEANUP
METAL BANK SUPERFUND SITE
The U.S. Envrcminental Protection A^pncy I'EFfl) is reviewing tte deanup that was conducted at the
Metal Bank Supflrfund Site located in Philadelphia, Fem^'kania. EFA conducts Fwe-Vear Reviews
to ensue that cleamps continue to protect public health and the environment EFA conducted the
previous Ri'e-^fear Review in 3IHS and conduded that tfie site current*' protects hurnan health and
tfie environment EFA plans to make the findings from this Five-Year Rev few available by August 2023.
To acceas aite information, including the Five-Year Review, via'rti
www.epa.g^sqDerfund,,metalbank
For queations or to provide site-related information for the review, contacts
Lisa Irakis, EFA Gommunity Invohjemsnt Coordinalor
2i £-814-S4-99 or trakisJisaftepajgw
C-l
------- |