FINAL CLOSE OUT REPORT
U.S. Environmental Protection Agency
Table of Contents
- Introduction .
- Summary of Site Conditions
- Location of Site
- Summary of Site Ownership
- Contamination at the Site
- Listing of Site
- Removal Action
- Remedial Investigation/Feasibility Study
- Records of Decision
- Record of Decision Operable Unit #1
- Record of Decision Operable Unit #2
- Record of Decision Operable Unit #3
- Prospective Purchaser Agreement and Operable Unit #3
- Summary of Remediation Costs
- Demonstration of Cleanup Activity Quality Assurance and Quality Control
- Summary of Operation and Maintenance
- Five Year Review
- Attachments to Final Close Out Report
- Supplemental List of Documents
FINAL CLOSE OUT REPORT for
PUBLICKER INDUSTRIES SUPERFUND SITE
by U.S. EPA REGION III
This Final Close Out Report (FCOR) documents that the U.S. Environmental Protection Agency (EPA) completed all construction activities for the Publicker Industries Superfund Site in accordance with Procedures for Completion and Deletion of National Priorities List Sites and Update (OSWER Directive 9320.2-3C). EPA and the Pennsylvania Department of Environmental Protection (PADEP) conducted a final site visit on September 8, 1999, and determined that the all the remedial action have been successfully executed.
II. SUMMARY OF SITE CONDITIONS
A. Location of Site
The Publicker Industries Superfund Site (the Site) is located in southeastern Philadelphia. The Site is bordered to the east by the Delaware River, to the north by the Ashland Chemical Company, to the south by the Packer Marine Terminal and New Orleans Cold Storage, and to the west by Christopher Columbus Boulevard (formerly Delaware Avenue). The Site is adjacent to, and partially under the Walt Whitman Bridge, which spans the Delaware River from Pennsylvania to New Jersey. The Site covers approximately 42 acres. (s attached.)
B. Summary of Site Ownership
Publicker Industries owned and operated a liquor and industrial alcohol manufacturing plant at the Site from 1912 to late 1985. Publicker Industries discontinued operations in February 1986 and, later that year, Publicker Industries sold the property to the Overland Corporation. Overland Corporation declared bankruptcy in November 1986. In 1994 Delaware Avenue Enterprises, Incorporated (DAE); Cresmont Limited Partnership (Cresmont); and Holt Cargo Systems, Incorporated (Holt) entered into a Prospective Purchaser Agreement (PPA) with EPA and PADEP (See Section II. H. for more information on PPA). On January 9, 1995 DAE purchased the Site from the bankrupt estate of Overland Corporation. Currently, the Site supports the activities of the adjacent marine terminal.
C. Contamination at the Site
The Site contained the remains of nearly 440 structures including large tanks, chemical laboratories, reaction vessels, production buildings, warehouses, and power plants. Beside the manufacturing of liquor and industrial alcohols, the Site was also used as a petroleum product and chemical storage facility during the late 1970's and early 1980's. Based on the review of Site records, numerous chemicals were manufactured or stored at the Site during plant operation. (Attached is a chronology of events to 1995.)
D. Listing of Site
In May 1989, the Site scored 59.99 on the Hazard Ranking System, and was added to the National Priorities List in October 1989.
E. Removal Action
From December 1987 to December 1988, EPA conducted an emergency removal action which included the stabilization of structures, characterization of the contents of drums and tanks, bulking and securing of over 850,000 gallons of numerous waste streams, off-site disposal of laboratory containers, and removal of liquids from abovegrade process lines.
F. Remedial Investigation/Feasibility Study
EPA began the Remedial Investigation/Feasibility Study (RI/FS) activities in November 1988. In January 1995, EPA finalized the RI/FS.
The Remedial Investigation (RI) was performed in accordance with project plans (Work Plan, Quality Assurance Project Plan, Health and Safety Plan, and Field Sampling Plan) developed by Tetra Tech and submitted to EPA initially in June 1990, and subsequently amended in January 1991, October 1991, and July 1992.
Project planning and scoping activities for this project were completed initially during spring/summer 1990, with subsequent field activities conducted during fall 1990, winter 1990-1991, fall 1991 and summer 1992. Data review, analysis and evaluation were completed during the fall 1990 through fall 1992.
A detailed site-characterization was performed through extensive sampling, including two rounds of groundwater sampling of on-site and off-site wells; a soil vapor survey; surface and subsurface soil sampling; liquid and sediment sampling from sewers, trenches, and other subsurface lines; and an ecological sampling of the Delaware River in the vicinity of the Site.
Evaluation of the nature and extent of contaminant transport pathways and potential risk to human health and environment is based collectively on these field efforts as well as previous field efforts. The risks to human health were evaluated in the context of the current land use, as an industrial site, and future land uses, such as shortterm construction, industrial redevelopment, and a playing field. No unacceptable risks were projected in the base line risk assessment for construction workers, long-term commercial/industrial workers, and recreational users (both children and adults). Even though no unacceptable risks were projected, cleanup levels were used in the removal of soils at Operable Unit #3.
The Feasibility Study (FS) was submitted to EPA in January 1995. The purpose of the FS was to identify, develop, and evaluate remedial alternatives for the Site to address human health and the environment. The FS was organized by medium: soils, ground water, contaminated utilities, and a miscellaneous category which included waste such as drums. Alternatives were developed for each medium and then evaluated.
G. Records of Decisions
The Site was divided into three operable units. Below is a summary of each operable unit and the selected remedial actions.
- Operable Unit #1 - Site Stabilization
- Operable Unit #2 - Asbestos Removal
- Operable Unit #3 - Soil and Ground Water
1. Record of Decision Operable Unit #1 - Site Stabilization
In June 1989, the first Record of Decision (ROD) for the Site was issued. The ROD addressed Site Stabilization. The remedial actions detailed in the ROD consisted of transportation and off-site disposal of known waste streams, draining and demolition of above-grade process lines, and transportation and off-site disposal of wastes discovered in above-grade process lines. During this remediation, asbestos-containing materials were encountered on the process lines. This asbestos-containing material was bagged and stored on-site. Remedial activities began in October 1989 and were completed in December 1990.
2. Record of Decision Operable Unit #2 - Asbestos Removal
Many of the above-grade process lines were wrapped with asbestos insulation. As a result of Operable Unit #1 remediation, asbestos-containing materials remained on-site in bags as well as on pipes. The asbestos was investigated in the early spring of 1991. A Focused Feasibility Study (FFS) was completed in the spring of 1991 and EPA subsequently issued a ROD for Operable Unit #2 on June 28, 1991.
The remedy included:
- The removal of remaining asbestos from piping staged throughout the Site; placement in secure packaging (plastic bags); and staging and preparation for transport and disposal;
- The collection of asbestos previously packaged and staged at the Site; repackaging it, if necessary; and preparation for transport and disposal; and
- Transportation of asbestos to a permitted off-site disposal facility.
An initial remedial design was developed in September 1991; however, a site fire in April 1992 delayed remedial action until February 21, 1995. The Site was divided into five work areas. The asbestos-containing material was removed using three methodologies: gross removal, glove bag, and remote containment. The material was then packaged and transported to off-site disposal facilities. The remedial action was completed on May 19, 1995. A total of 199.87 tons of asbestos-containing materials were disposed during the remedial action.
3. Record of Decision Operable Unit #3 - Soil and Ground Water
The third and final ROD for the Site was signed on December 28, 1995. Before beginning the remedial work, the Remedial Action Work Plan (RAWP) was approved by EPA on July 17, 1997. The contractor proceeded on August 6, 1997; mobilization took place on August 7, 1997; and construction activities started on August 11, 1997. The selected remedy involved:
- Abandonment of on-site ground water wells - Eleven wells were located on-site and abandoned by sealing with a cement mixture.
- Removal, treatment, and off-site disposal of liquids and sediments in contaminated electric utilities - A total of thirty-two electric utilities were located, excavated, and cleaned. The excavation consisted of removing and demolishing the concrete casings. The electrical units were decontaminated by pressure washing with a soap and water mixture to remove any contamination, this solution was captured, and then disposed offsite. The electric utilities were then backfilled.
- Removal, treatment, and off-site disposal of liquids and sediments in contaminated storm water trenches and utilities - Twenty-one stormsewer manways and eleven stormwater trenches were located on-site. Six of the manways were remediated and the all the manways were sealed. Only one trench required excavation. Besides the known stormwater trenches and manways, several other stormwater structures were located. Five stormwater outfalls were located: one 48-inch diameter pipe and four 12-inch diameter pipes. The 48-inch pipe was videotaped, eleven inlets were identified, and then the inlets and 48-inch pipe were sealed. Likewise, the four 12-inch pipes were sealed at the outfalls. Also, a 6 foot diameter City of Philadelphia stormsewer main was located and 47 inlets were identified. The 47 inlets were sealed with concrete at the inlet location.
- Removal, treatment and off-site disposal of miscellaneous wastes - Off-site disposal of miscellaneous waste included approximately 560 tons of solid waste (non-hazardous) and over 63,000 gallons of liquid waste (non-hazardous). There were also eighteen drums (non-hazardous) that were sampled and then transported and disposed off-site on September 29, 1997. Two 10,000 gallon underground storage tanks (USTs) were found on-site. They had previously been filled with sand. The two USTs, sand, and soil were removed.
The ROD did not require remediation of the surface soil or the subsurface soil. During remediation of the electric and stormwater utilities, however, some soils were removed around the utilities. The amount of soils removed around the utilities was determined by the clean-up levels for lead, benzo(a)pyrene, and PCBs in the soils. Soils that exceeded one or more of these clean-up levels were removed for off-site disposal at an approved facility. These clean-up levels were based on protecting workers on-site.
The ROD required that if excavation should occur on-site in the future, that monitoring will be conducted to ensure worker safety. A deed notice has been filed which notifies future owners of the listing of the Site on the National Priorities List, the releases of hazardous substances, and the existence of RODs for the Site. Furthermore, the deed notice alerts future owners that they, shall not put the Site to any use which could disturb or be inconsistent with the remedial response action implemented at the Site. (Deed Notice attached.)
EPA and PADEP conducted several inspections during the remediation. These inspections included: an inspection of the abandoned wells on September 5, 1997; an inspection of the stormsewers on October 10, 1997; an inspection of the electric utilities on December 2 and 9, 1997; an inspection of the stormwater trenches on December 2, 1997; and finally an inspection of the additional storm water lines on January 13 and 16, 1998. The remedial activities were performed according to design specifications set forth in the Remedial Action Work Plan.
EPA issued a Preliminary Close Out Report on December 2, 1997 which documented the completion of construction activities. Remedial actions were completed on May 11, 1998. A final report which described the remedial activities was submitted to EPA by Delaware Avenue Enterprises. A follow-up site-visit and interview was held on September 8, 1999 as part of the review of the final report and as part of the five year review. An addendum was later submitted to EPA, and EPA accepted the final report on September 29, 1999.
H. Prospective Purchaser Agreement and Operable Unit #3
In December 1994, EPA and the PADEP, finalized a prospective purchaser agreement (PPA) for the Site. The primary purpose of the PPA was to settle and resolve the potential liability of the prospective purchaser DAE, Cresmont, and Holt (collectively referred to as the Parties).
In exchange for the covenants not to sue, the Parties agreed to pay EPA and PADEP a total of $2.3 million. Additionally, the PPA stated that the Parties may petition EPA to be allowed to perform all or a discrete portion of the CERCLA response selected in the ROD Operable Unit #3. The agreed upon value of such work may offset any balance of payments still outstanding to EPA and/or PADEP under this PPA. In January 1996, DAE petitioned to do the remedial work. An amendment to the PPA was signed on December 19, 1996 allowing DAE to implement the remedy.
III. SUMMARY OF REMEDIATION COSTS
To date EPA expended 18.1 million dollars for remediation, removal, investigation, and enforcement for the Publicker Superfund Site. The ROD for Operable Unit #1 estimated the cost of remediation would be 13.9 million dollars. The remediation for Operable Unit #1 was conducted by EPA and EPAs contractors. The ROD for Operable Unit #2 estimated the costs for remediation would be $293,420. Again, EPA and EPAs contractor, Tetra Tech Incorporated, remediated Operable Unit #2. The final report submitted by Tetra Tech Inc., listed the costs for remediation as $419,058. The ROD for Operable Unit #3 estimated the costs for remediation would be $611,600. The remediation of Operable Unit #3 was not conducted by EPA, but by Delaware Avenue Enterprises contractors, Snow Environmental and Environmental Maintenance Company. According to the final report the total costs for remediating Operable Unit #3 was $725,606.
IV. DEMONSTRATION OF CLEANUP ACTIVITY QUALITY ASSURANCE AND QUALITY CONTROL
Remedial activities at the Site were consistent with the Records of Decisions for all three operable units. Performance standards were met and construction quality was assured through regulatory oversight. EPA and EPAs contractors provided project management, evaluation, and inspections by qualified personnel. This oversight ensured that the work was implemented according to designs.
In the case of Operable Unit #3, the remedial activities were consistent with the Remedial Action Work Plan (RAWP) that included a Quality Assurance Project Plan. EPA analytical methods were used for all validation and monitoring samples during remedial activities. All procedures and protocol followed for soil and air sample analysis during the remedial activities are documented in the Remedial Design Report and were conducted through a participating Contract Laboratory Program (CLP). The QA/QC program used throughout the remedial action was rigorous and in conformance with EPA and PADEP standards; therefore, EPA and PADEP determined that all analytical results are accurate to the degree needed to assure satisfactory execution of the remedial action, and consistent with the ROD and RAWP.
V. SUMMARY OF OPERATION AND MAINTENANCE
None of the Operable Units require operation and maintenance or post-remedial action monitoring. Originally, for Operable Unit #3 the stormwater outfalls were to be monitored to assess if the Delaware River was receiving any contamination. However, the stormwater outfalls and connections to the city sewer were sealed to eliminate the need to monitor the outfalls.
This Site meets all the site completion requirements as specified in OSWER Directive 9320.2-09-AP, Close Out Procedures for National Priorities List Sites. The remedial actions were implemented in accordance with the respective Records of Decision as evaluated by the five year reviews. EPA conducted two five year reviews: one in October 1996 and another in February 2000. A five year review ensures that the remedial actions are protective of human health and the environment. During the first five year review, the remedy for Operable Unit #3 had not yet been completed and, therefore, the five year review concluded that the remedy for the entire Site was not protective. The second five year review (February 15, 2000) concluded that the remedies are protective of the environment and human health for non-residential uses.
VII. FIVE YEAR REVIEW
Statutory reviews need to continue for this Site. The next five year review will be conducted by February 2005. A statutory review is necessary for this Site because the risk assessment only addressed non-residential uses for the Site and does not allow for unlimited use and unrestricted exposure. Reviews are also required by statute when institutional controls, like deed notices, are placed on a site. In the case of the Publicker Industries Superfund Site, a deed notice was filed for the Site in accordance with the Record of Decision for Operable Unit #3.
This Final Close Out Report records the completion of remedial activities for the Publicker Industries Superfund Site.
Bradley M. Campbell
A bibliography of all reports relevant to the completion of the Site under the Superfund program is attached.
A. Attachments to Final Close Out Report
- General Location Map
- Chronology of Site Events until 1995
- Deed Notice
- Index of Documents
B. Supplemental List of Documents
Below is a list of documents pertaining to the Site. These documents are
not attachments to the Final Close Out
- Remedial Action Report, Publicker Industries Site, Operable Unit #2, Asbestos Removal, Philadelphia, Pennsylvania, revised September, 1995 by Tetra Tech Inc.
- Publicker Industries Superfund Site, Preliminary Close Out Report, dated December 2, 1997 by EPA Region III.
- Final Report, Operable Unit No. 3, the Publicker Industries Superfund Site, Philadelphia, Pennsylvania, June 1998 prepared by Snow Environmental Services, Inc.
- Five Year Review Report, Publicker Industries Superfund Site, Philadelphia, Pennsylvania, dated February 15, 2000 by EPA Region III.