FEDERAL ON-SCENE COORDINATOR'S REPORT PUBLICKER INDUSTRIES SITE PHILADELPHIA, PHILADELPHIA COUNTY, PENNSYLVANIA CERCLA ACTION DECEMBER 8, 1987 through DECEMBER 14, 1991

SEPA REGION HI EMERGENCY RESPONSE TEAM

United States Environmental Protection Agency Region EQ Philadelphia, Pennsylvania

flR!*GQ2Q7 PUBLICKER INDUSTRIES SITE TABLE OF CONTENTS

^CONTENTS ...... i HEETS ...... ~ ...... I...... ,.;... vi

I. INTRODUCTION . . . A. Initial Situation B. Location of the Site C, Efforts to Obtain Cleanup by Potentially Responsible Party (PRP) ...... 3

H. ROSTER OF AGENCIES, ORGANIZATIONS AND INDIVIDUALS ...... 3 . A. Names and Addresses ...... 3 B. Organization of the Response ...... 9 C. Glossary of Abbreviations and Definitions ...... 10

TTT NARRATIVE OF EVENTS ...... 11

TV RESOURCES COMMUTED ...... 17 A. Initial Funding Request ...... 17 B. Estimated Total Cost Summary ...... 17

V EFFECTIVENESS OF THE REMOVAL ...... 18 A. Activities of the Various Agencies ...... 18 1. Potentially Responsible Party ...... 18 2. Federal Agencies ...... 18 3. State and Local Agencies ...... 19 4. Contractors ...... 19 B. Analytical Synopsis ...... 19 C. Disposal Methods and Quantities Removed . . :...... 20

VT. CHRONOLOGY OF EVENTS ...... 21

VII. PROBLEMS ENCOUNTERED AND RECOMMENDATIONS ...... 79

APPElft>ICES A. Sit&Map and Sketch A85 B. Pfioto Documentation ...... i ...... A87 C. Newspaper Articles ...... A120 D. Funding Documents and Declaration For The Record Of Decision .... A135 REGION HI PROJECT #192 CERCLA/SARA REMOVAL FACTS SHEETS (page 1 of 4)

SITE: T^lttfr" Publicfcer Industries, Inc. SIZE; J^BBE Approximately 37 acres LOCATIONr ... 2903 S. Delaware Ave., Philadelphia, Philadelphia County, Pennsylvania

INITIAL RESPONSE DATE: June 26, 1987 PROJECT DATES: December 8, 1987, through December 14, 1990

DESCRIPTION: The Publicker Industries Site consisted of an abandoned chemical processing and fuel oil storage facility that contained over 400 bulk large storage tanks, drum storage, product - storage, five QA/QC and R&D laboratories' three waterfront piers, and hundreds of miles of overhead process piping on a 37-acre parcel of land beneath the Walt Whitman Bridge in South Philadelphia. A multi-alarm fire in June 1987, caused by arson at the facility, resulted in the closure of the Walt [Whitman Bridge and evacuation of local residents. During the fire numerous explosions and fire flares were observed, leading fire officials and EPA personnel to believe that chemical product was still present on site. The Philadelphia Fire Marshal's Office certified the site as an imminent fire and explosion threat due to improper and unstable storage of laboratory chemicals and to leaking tank and process lines. Following the fire, the EPA secured a CERCLA 106 Consent Order with the responsible party (RP), Publicker Industries, to stabilize the site. Publicker contracted with O.H. Materials (OHM) to perform the stabilization work. As RP stabilization continued, EPA re-inspected the site. The following site conditions were observed:

• Large-volume storage tanks had not been certified as empty. * A leaking tanker was observed onsite. • "The drum staging area was not properly maintained. • Unknown laboratory chemicals were jstill in unstable buildings. • Workers were observed smoking onsite. • No fire fighting equipment was available onsite.

Based on these observations, EPA determined that the RP had not taken appropriate action fo'mffi^afe'the threat, and on December 8, 1987, OSC Wright exercised his " authority under Delegation of Authority. 14-1-A (5/1/85) to begin mitigating the threat to the public and the environment. The Publicker Site was officially declared a CERCLA Emergency Removal, and EPA's Removal Branch assumed control of site stabilization . , activities.

HAZARDOUS SUBSTANCES: The Publicker Site contained various hazardous substances including flammables, corrosives, air and water reactive metals, poisons, gas cylinders of unknowns, small amounts of radioactive materials, and large amounts of asbestos insulation.

flRU00209 REGION m PROJECT #192 CERCLA/SARA REMOVAL______FACTS SHEETS (page 2 of 4)

QUANTITIE

Quantities Removed # Drums CU Yd. Material # Gallons Wastestreams Phase I 14 .30 Crushed laboratory Material 34 Corrosives 150 Used protective clothing 15 PCB oil & 2 transformers 359 Lab bottles (lab packs) 9,299 Treated Acetaldehyde 123 4,000 Flammable liquid 6 Mercury containing waste 1 Radioactive material 42 Flammable solids, oxidizers, peroxides, organic peroxides, poisons Phase IT 8 5,000 Flammable/contaminated oils SITE SPECIFIC 146,316 Organic liquids (Tank 190) 44,200 Oxidizing liquids (Tank 189) 327,917 Base-neutral liquids (Tanks 185-186) 211,885 Contaminated fuel oil (Tanks 306, 238, 106) 487 Organic liquid, base neutral liquid and solid, oxidizing solids and liquids, PCB 471 Empty poly drums 585 Crushed metal drums 346 Spent PPE REGION m PROJECT #192 CERCLA/SARA REMOVAL :..._. FACTS SHEETS (page 3 of 4)

OSCs: 1-J^ David Wright, Lisa Price and Edward M. Powell, " L. U.S. EPA, Region HI, Philadelphia, PA

CLEANUP CONTRACTOKSJ OH. Materials, Findly, Ohio B.E.S. Environmental Services, Kingston, Pennsylvania E.H.R.T. Louisville, Kentucky Laidlaw/ GSX, Chattanooga, Tennessee

DISPOSAL LOCATIONS: PHASE I DISPOSAL:

Bulked alcohol; Frontier Chemical Waste Prowess, Inc., Niagara Falls, NY. Uranyl nitrate; USEcology Nuclear, Hanford Reservation, Richland, WA.

Spent personal protective equipment; Envirosafe Services of Ohio, Inc., Oregon, OH.

Acetaldehyde, second roll-off box of crushed unknowns; Chemical Waste Management, Emelle, AL.

First roll-off box of crushed unknowns; Chen-Met Services, Wyandotte, ML

PCB transformer carcasses, capacitors, oils and debris; > 500 ppm, APTUS Environmental Services, Coffeyville, KS.

Materials > SOOppmPCB; USEcology Nucluar, Beatty NV.

Flammable liquids and solids, water reactivp metals, poisons, and peroxides; Trade Waste Incineration, Inc., Sauget, IL.

Oxidizing liquids; SCA Chemical Services, Chicago, IL.

Mercuric wastes; Mercury Refining, Albany,NY.

Flammable solids, halogenated mercury compounds and lab packs; Thermal KEM, Rock Hill, SC. .

PHASE H DISPOSAL:

Flammable liquids and contaminated fuel oil; Waste Conversion, Hatfield, PA.

SITE-SPECIFIC CONTRACT DISPOSAL:

Bulked flammable liquids; Delaware Container Co., Inc. Coatesville, PA.

Bulked oxidizing liquids; OSCO Environmental Management, Inc., Columbia, TN. REGION m PROJECT #192 CERCLA/SARA REMOVAL______FACTS SHEETS (page 4 of 4)

Bulked base/neutral liquids; OSCO Environmental Management, Inc., Columbia, TN and Tricil Environmental Services, Inc., Hillard, OH.

Contaminated fuel oil; Casie Ecology Oil Salvage, Vineland, NJ.

Baled PPE, crushed metal and plastic drums; GSX Services of South Carolina, Pinewood, SC.

Consolidated drummed waste; GSX Services of South Carolina, Pinewood-, SC, and GSX Services of Maryland, Laurel, MD. PROJECT CEILING; $ 22,733,000 ESTIMATED COSTS: S 14,866,639 COMMENTS: Numerous Federal, State and City agencies responded in a well coordinated effort to assist in mitigating the threat to the public health and the environment posed by this site. Due to the volume and types of substances present, the threats posed by the site could have resulted in a catastrophic event.

lEdward M. Powell On-Scene Coordinator U.S. EPA Region HI Philadelphia, PA

flRU00212 PUBLICKER INDUSTRIES SITE

FOREWORD

This report is submitted in accordance with procedures outlined in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). The primary objective of the Plan is to provide a coordinated Federal response capability at the scene of an unplanned or sudden discharge of oil or hazardous substance that poses an imminent and substantial threat to the public health and/or environment. In addition, the provisions of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), as amended by the Superfurid Amendments" and Reauthorization Act of 1986 (SARA), promote a coordinated federal, state and local response to mitigate situations at hazardous waste sites that pose a potential threat to the public health. The presence of hazardous substance at the Publicker Industries Site posed a threat to both the public health and the environment, thereby providing a legal .basis for federal response activities. The provisions of the NCP Section 300.415 were implemented by the U.S. Environmental Protection Agency, Region III, Philadelphia, Pennsylvania.' The OSC would like to express his gratitude to all participants in the activation and removal operations.

Edward M. Pbwell On-Scene Coordinator U.S. EPA Region IH Philadelphia, PA

ARU002I3 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 1

Publicker Industries Inc. of Greenwich, Connecticut, owned and operated a distillation and carbon dioxide (dry ice) manufacturing facility at 2903 S. Delaware Avenue in Philadelphia, Pennsylvania. The company had maintained operation at the South Philadelphia facility from 1913 to March 1986, when the facility, idle since 1982, was sold to Overland Development . Corporation, a subsidiary of Cuyahoga Wrecking Company, of Great Neck, New York. During the time Publicker operated the facility, it was the third largest producer of industrial ethyl alcohol in the world. In addition to industrial alcohol, the facility produced industrial solvents and ethers, fermented alcohols for whiskey and other liquors, blended ethylene glycol (anti- freeze), and produced bulked carbon dioxide and dry ice. In 1979, Publicker entered the bulk liquid storage business, utilizing previously idle storage facilities to store chemicals and fuel oil for other manufacturers, for which they operated a marine terminal for ocean going vessels. In March 1986, Publicker sold the Philadelphia facility for £crap to the Overland Corporation. Overland began dismantling the plant but halted the operation after two workers were killed when the torch they were using ignited materials remaining in a pipeline. Overland eventually declared bankruptcy due to legal problems unattributable to Publicker, but associated with their involvement in other hazardous waste sites. Overland ceased operations at the plant and left the facility abandoned, with the structures compromised by weather, vandalism and neglect. On June 26, 1987, EPA's Regional Response Center received notification from the Philadelphia Fire Department of a multi-alarm fire at the Publicker facility. EPA Emergency Response Section personnel, accompanied by the Roy F. Weston, Inc. Technical Assistance Team (TAT), responded to the scene of the fire, which had destroyed the carbon dioxide utilization portion of the plant. During the fire, numerous explosions and fire flares were observed, as well as pools of oily.material and widespread stained and discoloreDelaware River. The fire and the existing condition of the plant prompted EPA officials to recommend that an immediate emergency assessment be performed to the determine the extent of contamination and the threat this site posed to the public. On July 9, 1987, a site entry was performed by EPA TAT and City of Philadelphia representatives. Numerous spill areas, improper drum storage and leaking process lines were observed in portions of the site that were unaffected by the fire. Additionally, approximately 140 bags of friable asbestos waste, remnants of the demolition of site buildings, were discovered. The threat of future fire/explosions was deemed as extreme by the Philadelphia Fire Marshal's Office. On-Scene Coordinator (OSC) Robert Caron determined that, based on the assessment, the site required immediate control and stabilization measures. The following day, July 10, 1987, OSC Lisa Price met with TAT and began a preliminary round of sampling. Also on this date Mr. James Weis, Vice President of Publicker Industries, and flRI*002|tt Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 2 PADER perajjujel were on site to perform an inspection. The boiler plant was investigated and numerous umfuOtad drums and possible PCB transformers were discovered. On July 20, 1987, the EPA Enforcement Section secured a Consent Agreement/106 Order with RP Publicker Industries, and a site assessment by Publicker's contractors commenced, followed by site stabilization efforts. Publicker contracted with O.H. Material (OHM) of Findley, Ohio, to provide security, placement of booms on former slips, a fire watch, and site stabilization efforts. Upon completion of RP Publicker stabilization efforts, a site assessment was performed on December 8, 1987, by Thomas Massey of the Superfund Branch; Dr. Walter Lee, CRES; and TAT. The following conditions were observed to be present at the site: 1) Large-volume storage tanks had not been certified as empty, 2) A tanker was leaking, 3) The drum staging area had not been properly maintained nor secured, 4) Unknown laboratory chemicals were staged inside an unstable building, 5) Workers were observed smoking onsite, 6) There was no firefighting equipment available on the site. Due to the fact that the imminent fire and explosion threat had not been effectively mitigated, OSC David Wright determined that the site required immediate action. The RP's were notified of the site conditions observed and the Agency's intent to proceed with a Removal Action. OSC Wright met with the EPA Office of Regional Counsel, Enforcement, RP representatives and the EPA ERT. At the meeting it was determined that the Federal Government would retain the lead and continue with the clean-up using its ERCS contractors. On December 8, 1987, OSC Wright initiated an emergency response and activated $50,000 in emergency funding under Delegation of Authority 14-1-A (5/1/85) to begin immediate mitigative measures at the Publicker Industries Site. On December 9, 1987, Dr. J. Winston Porter, Assistant Administrator for Solid Waste And Emergency Response, approved an additional funding request in the amount of $1,702,000 to bring the project ceiling to $1,752,000. The OSC was directed by EPA HQ Contract Office not to activate O.H. Materials (OHM) because of possible conflict of interest issues since OHM had been utilized by Pufalicker to perform initial site stabilization work. Instead, the OSC utilized Baranowski Environmental Services (BES) of Kingston, Pennsylvania, to serve as clean- up contractors* B. Location of the Site The Publicker Industries Site is located in Southeast Philadelphia on the waterfront of the Delaware River. The site lies directly under the Walt Whitman Bridge and is split in half by Packer Avenue. The site is bordered to the east by the Delaware River, to the north by the Ashland Chemicals Inc. Synthetic Polymers plant, to the south by the Packer Avenue Marine Terminals, and to the west by Delaware Avenue. The area is primarily industrial, however, there are major population centers within one mile of the facility. Estimated population within one mile of the site is approximately 400,000. In addition, there are several hundred businesses (primarily food processing plants), the Philadelphia Naval Ship Yard, two large sports arenas ftRi*002l5 Publicker Industries NPL Site Fedenil On-Scene Coordinator's Report Page 3 and InterstagSgjji close proximity. Center City Philadelphia is approximately two miles from the site. W^^pltgreje-quarterS: of a mile are the cities of Gloucester and Camden, New Jersey. Three schooSand, two hospitals are located within a one and a half mile radius of the site. C. Efforts to Obtain Cleanup by Potentially Responsible Party (PRP) The U.S. EPA Region HI Enforcement Section identified Publicker Industries of Greenwich, Connecticut, the bankrupt Cuyahoga Wrecking Company and its subsidiary the Overland Corp., and Freedom Savings and Loan, mortgage holder for the Overland Corp., as potential responsible parties for the Publicker Site. Qn July 20, ^987, the EPA CERCLA Removal Enforcement Section secured a Consent Agreement/106 6rder with Publicker Industries to stabilize, secure and cleanup the site; Publicker thereby accepted status as Responsible Party (RP). Publicker contracted with O.H. Materials of Findley, Ohio, to serve as cleanup contractor. EPA's Superfund Removal Branch provided oversight of the RP's cleanup contractor's efforts. On December 8, 1987, Tom Massey and Dr. Walter Lee performed a site inspection of the facility to .check progress of the RP's stabilization efforts. Based on that inspection, it was determined that the RP efforts were inadequate and that site conditions continued to present a threat to human health and the environment. OSC Wright activated $50,000 under Delegation of Authority 14-1-A to mitigate these threats, and EPA assumed all authority for further site stabilization efforts.

H. ROSTER OF AGENCIES, ORGANIZATIONS AND INDIVIDUALS A. Names and Addresses

AGENCY CONTACT ; SR^F;r3EscRipnoN ; '. FEDERAL U.S. Environmental Protection Agency David P. Wright Fi-deral On-Scene Coordinators; Emergency Response Section Lisa Marie Price responsible for the overall coordination 841 Chestnut Bldg. (3HW31) Edward Powell ar d success of the project. Philadelphia, PA 19107 (215) 597-980a- U.S. Environmental Protection Agency Walter Lee Cx>rdinated PRP search; responsible Enforcement Section Chris Thomas for consent orders with Publicker and Cilyahoga/Overland Corp. U.S. Environmental Protection Agency FAS - Linda Marzulli Provided the OSC with project cost Emergency Response Section FAO - Rich Messimer tri eking and administrative support. FAO - Joan Henry U.S. Environmental Protection Agency Marie Murphy Assisted the OSC with ERCS Contract Office Russ T. Bowen COntractual matters; assisted the OSC Wlth formulation/solicitation of site special T&D contract.

fiRliOQ2l6 PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page 4

CONTACT ; , BRIEF DESCRIPTION U.S. Environment*! Protection Agency Jeff Winegar Assisted the OSC in coordinating Hazardous Waste Management Nick Dinardo remedial concerns at the site. Division Remedial Section U.S. Environmental Protection Agency Fred MacMillian Investigator for cost recovery case. Cost Recovery U.S. Environmental Protection Agency Brian Nishitani Assisted the OSC with legal aspect of Office of Regional Counsel site activation and funding documents. U.S. Environmental Protection Agency Harold Yates Assisted the OSC with inquiry from Office of External Affairs media. Environmental Response Team Dr. Joe LaFornara Assisted the OSC with development of. (ERT)/Roy F. Weston, Inc. REAC site safety plan. U.S. Environmental Protection Agency Bob Boody Investigated pier fire. Office of Criminal Investigation U.S. Coast Guard P.O. Charles Wyatt Provided health and safety monitoring. LANTERA Strike Team U.S. Environmental Protection Agency Ben Mykijewycz, Section responsible for investigative Site Investigation Section work for possible NPL ranking. Dept. of Interior/Bureau of James Felix Provided the OSC with technical Reclamation assistance concerning structural Engineering and Research Center integrity and dismantlement of Division of Construction structures onsite. P.O. D-3500 Denver, CO 80225 CodeD-1310 (303) 236-8330 CITY PADER Rob Alien Coordinated State's concerns with the 1875 New Hope St. Mark Bonenberger OSC. Norristown, PA 19401 (215) 631-2430^ LOCAL • ; Philadelphia Managing Director's John Hadalski Coordinated City's concerns with the Office OSC. City Hall City of Philadelphia Roger Ulshafer Inspected site post fire. Fire Department Fire Marshal's Office 3rd & Spring Garden Sts. Philadelphia, PA 19123 (215) 592-5962 flRl*OQ2!7 Publicker Industries NPL Site Federal On-Scene Coordinator's Report PageS

•v^^SBHP^;:-"""'.^:.'1":';;>.. j:''CONTA'c^^Jv;-:;j ;S- ^V^BR^€D^<^^oii;l..;.?:," •: ' City of Philadelphia Robert Hoyt post tire investigation. License & Inspection T. W. Patterson 1101 Market St. Philadelphia, PA (215)592-6073 City of Philadelphia Capt, Robert post lire investigation. Police Department Campbell llth & WhartonSts. Philadelphia, PA 19147 (215) 686-3040 City of Philadelphia Chief Gerald Janda i,xpressed concerns over future Hazardous Material Admin Unit i [AZMAT incidents at the site. 3rd & Spring Garden Sts. Philadelphia, PA 19123 (215)574-1140 City of Philadelphia Wynn Hill EExpressed concern over amount of Dept. of Health William Reilly asbestos remaining onsite. Advised 5005 Broad St. C>SC during remote open operations. Philadelphia, PA 19146 (215) 875-567 City of Philadelphia Jen Nicolo. IExpressed concern over how site Water Department Jerry Kuziw 0perations would interfere with 25 Patterson Ave. Enonitoring sewage outfall. Philadelphia, PA 19148 (215)686-1706

City of Philadelphia Don Vache /Authorized closure of Delaware Ave.; Dept. of Streets/Traffic Engineering Provided signs for closure. Division 880 Municipal BIdg. Philadelphia, PA (215) MU6-5524 City of Philadelphia Lt. Merkert Aiisisted in removal of shock Ordinance Disposal Unit sensitive/explosives material for controlled detonation. i-.-.,:.\^-^f^i^--i^/^'\^. •••>•/. ^•'••'oTHEitf, ;>:•.: /^:^iM:^ Roy F. Weston, Inc. Dennis Matlock Technical Assistance Team who 5 Underwood Court Thomas Paciga provided administrative assistance, Delran, NJ 08075 photo- and video documentation, (609)461-4003 contractor monitoring and overall technical service to the U.S. EPA on- Scene Coordinator. Baranowski Environmental Services Rich Baranowski ERCS contractor responsible for site P.O.Box 1801 stabilization and manpower; Kingston, PA 18704 coordinated subcontractors. (717) 774-5316 I Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 6

CONTACT BRIEF DESCRIPTION . !. .. .:. Guardian Company Dave Anderson Provided fire fighting capabilities for 1280 Porter Rd. fire watch. Bear, DE I970I (302) 834-1000 ThennalKem David Jones Subcontractor for lab packing 454 S. Anderson Road, ETC 532 operations; mercury and flammable Rock Hill, SC 29730 solids. (803) 329-9690 Reactives Management George Walton Subcontracted explosive specialist for Chesapeake, VA 23320 shock sensitive material. (804) 523-9256 M. G. Industries Charlie Weintz Supplier of cylinders found on site; agreed to remove them. ECRECON Inc. Clem Simone Removal equipment previously 1312 Philadelphia Pike purchased from RP Cuyahoga. Wilmington, DE 19809 (302) 792-7800 Matheson Gas Products Jack Faught Supplier of gas cylinders found on site; 932 Paterson Plank Rd. agreed to remove them. E, Rutherford, NJ 07073 (201) 933-2400 Gas Technics Company Supplier of gas cylinders found on site; agreed to remove them. Mainserv James Hammond Inspected, hydrostatically tested bulk 5 Mecco Circle storage tanks for EPA waste bulking Wilmington, De 19804 operations. (302) 944-0139 Wastex Industries Craig Achenback Provided drum sampling analysis. 28 S, Hanover St. Pottstown, PA 19464 (215) 327-088O . Eastern Environmental Service Asbestos subcontractor. Drums, PA HART Environmental Management Gary Brown Consultant for PRP Publicker 6981 North Park Drive Industries. Suite 401 East Pennsauken, NJ 08109 NUS Corp, (EPA FIT) Contract Garth Glenn Conducted site investigation for EPA 999 West Valley Rd. Remedial Branch. Wayne, PA (215) 687-9510 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 7

^^^•H^tM^'V*:\^: ^'fqp^t^^:-:^(|K ^;;];t J3R$fcoE|^^ "mf^-^~~ ~~ ~ Pendrill "^^3^ '" James Adams &fonitorin g well driller for EPA site 1205 Chartiers Ave. iiivestigation sub-contractor. Pittsburgh, PA 15220 (412)921-5816 Lippincott Engineering Daniel Jones Performed structural engineering 501 Burlington Ave. ssessment on several buildings on site. Delanco, NJ 08075 (609) 461-1239 - - - - SCA Chemical Services )xidizing liquid disposal. Chicago, IL : APTUS Environmental PCB oils disposal. Coffyville, KS AAA Warehousing Eugene Osterrich Owner several stainless steel tanks and Linfield, PA ethylene glycol. Mercury Refining Iecycled mercury containing waste. Albany, NY Carmelo Vasi Carraelo Vasi 5 pecialty gas consultant; identified 4 Hampton Place unknown cylinders. Nutley, NJ (201)661-0669 " '" Airco Gas Company Identified six cylinders as their property. ChemWast e Management Treated Acetaldehyde waste. Newark, NJ U. S. Ecology Nuclear Radioactive material. Richland, Wv' i Frontier Chemical Waste Process Bulked alcohols, flammable waste. Niagara Falls, NY Envirosafe Services of Ohio Tim Kerchinski PPE disposal. P. O Box 833 r*;' Valley Forge, *tA 19482-0833 (215) 962-0800? Chem Waste Solids disposal from lab container Emelle, AL ------. crushing. Triple C . Removed railcars under enforcement agreement. Envirogenics Glenn Uhler C)E site asbestos air monitoring and air 136 W. Franklin Ave. s.aiipling. Pennington, NJ (609)737-3233 - -

'flRU00220 Publicker Industries NFL Site Federal On-Scene Coordinator's Report PageS

"llfoii CONTACT; BRIEF; DESCRIPTION All State Power Vac Video taped the interior of process lines on south side of plant. General Security Mark Smylie Site security during Phase I. 1125 Clinton Ave. Irington, NJ (201) 374-5303 Mahoney Security Phil Mahoney Site security during Phase EL PECO John Shovelin Provided electrical to command post. 830 Schuylkill Ave. Philadelphia, PA 841-6258 Industrial Lift Rob Jablonski Supplier of aerial lifts and manlift. Route 206 Vincentown, NJ 080SS (800) 346-0075 Godwin Pumps Bob B. Pjmmer Provided pumps for fire watch and tank I Floodgate Rd. pumping operations. Bridgeport, NJ 08014 (609) 467-3636 Motorola Michael Bille Two-way radios. 301 Masons Mill 'Road Huntington Valley, PA 19006 (215) 657-7880 Ashland Chemical John Cushman, Plant Chemical facility adjacent to Publicker. 2801 S. Delaware Ave. Manager Philadelphia, PA (215) 336-6500 Schnader , Harrison, Segal & Lewis Richard Pemme Counsel for Publicker Industries. Attorney at Law Barry Newman Suite 1000, 1IU 19th St. Washington, DC 20036 Shea & Goold" Theodore Firetoy Counsel for Freedom Savings & Loan 330 Madison Ave, Mortgage. New York, NY 10017 (212) 370-8460 Waste Conversion Richard Jackus Flammable liquids, contaminated fuel Hatfield, PA oil disposal. (Phase II) OSCO Environmental Management Bulked oxidizing and base/neutral liquid Columbia, TN disposal. (Site Specific T&D) Tricil Environmental Base neutral liquid disposal. (Site Hillard, OH Specific T&D) Publicker Industries NPL Site Federa On-Scene Coordinator's Report Page 9

S&ilS^BHK^ir.'I l^^i'^^OTAqj^v;1;1; '••^•'f;^$ljB^ ^ • '.-. ' ' Casie Ecologjn^" Contaminated fuel oil disposal. (Site Vineland, NJ Specific T&D) i GSX Service PPE disposal; consolidated drum waste. Pinewood South Carolina (bite Specific T&D) Laurel, MD

B. Organization of the Response

OPA LANTEREA U.S. ARMY i MSO CORPS OF PHILADELPHIA ENGINEER

PRPs PUBLICKER INDUSTRIES, CUYAHOGA WRECKING, FREEDOM B & I

KDB INTERNATIONAL (BARRY SHAPIRO)

CLEVELAND WRECKING

ftRU00222 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 10 C. GIossarorAbbreviatioiis and Definitions AAC Asbestos Abatement Corporation ACU Asbestos Control Unit BES BBS Environmental Specialists CERCLA Comprehensive Environmental Response, Compensation and Liability Act CLP Contract Laboratory Program COB Close of Business CRES CERCLA Removal Enforcement Section CWA Clean Water Act DOT U.S. Department of Transportation DPO Deputy Project Officer EESI Eastern Environmental Services, Inc. EHRT Environmental Health and Research Testing EPA U.S. Environmental Protection Agency ERCS Emergency Response Cleanup Services ERPS EPA Emergency Response Preparedness Section ERT Emergency Response Team FAS Field Administrative Specialist FIT Field Investigation Team HAZMAT Hazardous Materials HNU-PID Photo-ionization Detector LEL Lower Explosive Limit MSO Marine Safety Office NCP National Oil and Hazardous Substances Pollution Contingency Plan NPL National Priority List NUS Nuclear Utility Services (FIT Contract) OHM O. H. Materials OPA . Office of Public Affairs ORC Office of Regional Counsel OSC EPA On-Scene Coordinator OSWER Office of Solid Waste and Emergency Response OVA Organic vapor Analyzer PADER Pennsylvania Department of Environmental Resources PCB Polychlorinated biphenols PFD Philadelphia Fire Department PHD Philadelphia Health Department PMDO Philadelphia Managing Directors Office POLREPS Pollution Reports PPE Personal Protective Equipment PRP ~ Potentially Responsible Party PWD Philadelphia Water Department QA/QC Quality Control/Quality Assurance RCMS Removal Cost Management System REAC Response Engineering and Analytical Contract ROD Record of Decision flRi*00223 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 11 RP .jpSgsponsible Party RRC Response Center SARA ^Superfund Amendments and Reauthorization Acto of 1986 SIO Site Investigation Officers SSO Site Safety Officer T&D Transport and Disposal TAT Roy F. Weston, Inc., Technical Assistance Team USCG/LAST U.S. Coast Guard/Lantera Strike Team

NARRATIVE OF EVENTS The EPA Emergency Response and Preparedness Section (ERPS) first became involved with the Publicker Industries Site when at 1430 hours on Friday, June 26, 1987, the EPA Region ffl Regional Response Center was notified of a multiple alarm fire in progress at Publicker Pier #105 involving what the Philadelphia Fire Department and U.S. Coast Guard officials suspected to be hazardous materials. The fire completely destroyed tU'O large buildings on the Publicker property along the Delaware River, Pier #105, and several piles of debris. The origin of the fire was not known but was suspected to be arson. The OSC's Bob Caron and Lisa Price and TAT arrived on scene at 1530 hours and were advised by first responders of what they believed sounded like tanks and drums rupturing in the fire affected buildings. At that time, the Philadelphia Fire Department had the fire under control. EPA and TAT surveyed the fire perimeter and performed airmonitoring on a HNU-PID, which revealed no levels of organic vapor levels above background. It was noted that runoff from the fire was entering the storm sewers and the Delaware River; however no sheen was detected. The OSC's and TAT remained at the site until the Philadelphia Fire Department determined that the fire was "out". Fire and police personnel maintained thai: water and power had been turned off at the site, thereby increasing future fire potential. The following day, the OSC's Caron and Price and TAT returned to the site to assess the situation in the daylight. An inspection of the fire-impacted area revealed: 1) Evidence of widespread chemical contaminatian on the surface of the site with pools of oily material, small lagoons, and areas of stained/discolored soils being common throughout the site. 2) Evidence of bulk storage of chemicals as well as gas cylinders containing acetylene, oxygen and unknowns. 3) Although no sheen was visible entering the Delaware River, the large volumes of water used to fight the fire posed serious potential for off-site migration of contamination via runoff.

On July 1, 1987, Tom Massey contacted John Aduddell of EPA Criminal Investigation to inform him that emergency response activities may soon be initiated at the site due to the hazards Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 12 jL^t--4Bj present. Mggey also contacted John Hadalski of the City of Philadelphia Emergency Services in an efforflBnltiate coordination between the City of Philadelphia and EPA regarding the Publicker SitST'^ Publicker Industries accepted responsibility for site security, but would not accept responsibility for the cleanup until further testing and information could be provided. Publicker hired the services of O.H. Materials Inc. of Findley, Ohio, to perform initial site stabilization as required by the EPA. This consisted of harbor boom placement to contain site discharge, and to implement a bonded security service and fire watch. Publicker was also to retain a qualified contractor to perform an assessment and sampling of the entire site. Also on July 9, 1987 an assessment was made of the fire impacted area by personnel from the Philadelphia Fire Department, USCG/MSO Philadelphia, City of Philadelphia, PADER, EPA/OSC and TAT. EPA/OPA was also present as several news crews were onsite due to high media interest. A "level B" entry was performed by EPA and TAT to survey the fire impacted area. A sheen was observed being generated onsite and migrating into the Delaware River. In addition, many unlabeled and bulging drums, leaking process lines, asbestos and on-site spills were observed,

A small laboratory was also assessed, revealing extremely poor housekeeping and spilled laboratory chemicals. A large variety of strong acids, bases, metal-bearing compounds, organic compounds, inorganic compounds, and specialty compressed gases (including hydrogen) were observed. An inspection of portions of the site that were not affected by the fire was also performed by City of Philadelphia personnel. Numerous spill areas, improper drum storage and leaking process lines were discovered in addition to those in the fire impacted areas. Following the completion of the assessment, OSC Clark met with TAT to discuss locations and procedures for sampling to be conducted the next day On July 10, 1987, samples were collected at five locations. Mr. Weis of Publicker Industries and PADER personnel were on site to perform an inspection. The boiler plant was investigated, revealing numerous unmarked drums and possible PCB transformers.

On July 20, 1987, a consent agreement was signed with Publicker Industries and a site assessment by the Publicker environmental contractor commenced, followed by site stabilization measures. Upon completion of Publicker's stabilization efforts, on December 8, 1987, a site inspection was performed by Thomas Massey and Dr. Walter Lee, and TAT. The following conditions were observed still to be present at the site: 1) Large volume storage tanks had not been certified as empty. 2) A leaking tanker was observed. 3) The drum staging area had not been properly maintained nor secured. A-RU00225 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 13 ^ own laboratory chemicals were staged inside an unstable building. brkers on site were observed smoking. There was no fire fighting equipment available on site. Due to the imminent threats posed by the conditions on site, the OSC obligated $50,000 in emergency funding under Delegation of Authority 14-1-A to begin mitigative measures at the Publicker Industries Site. Through the ERGS mechan'ism, OSC Wright directed BES Environmental Services, Kingston, Pennsylvania, to mobilize personnel and equipment to the site to initiate stabilization efforts. The OSC was directed by EPA/HQ Contracts R. Mueller not to activate O.H. Materials (OHM) due to possible conflict of interest issues as OHM was the RP's cleanup contractor. The primary threats posed by the facility were elaborated! in the additional funding request. These threats were identified to be the five onsite laboratories, 440 tanks and reactor vessels with their associated piping, hundreds of inadequately staged drummed material, hundreds of known and unknown gas cylinders, pools of unidentified material and potentially contaminated ground, and significant amounts of suspected asbestos material. All of these threats culminated in a fire and explosion threat deemed extreme by the Philadelphia Fire Marshal's Office. The additional funding request was approved and signed on December 9, 1987 in the amount of $1,702,000 which brought the total project ceiling to $1,752,000. Identification, segregation and stabilization of the onsite laboratories began immediately. A labpack task force consisting of ERT, ERCS, TAT, TherrnalKem (ERCS subcontractor) was forme*! expressly for this purpose. On December 17, 1987, the labpack task force expressed extreme concern regarding potentially shock-sensitive materials (primarily ethers) found in four of the onsite labs. The OSC notified the City Ordnance disposal Unit to assess the threat. Additionally, the OSC directed ERCS to provide an explosive expert, and to prepare to take immediate actions to abate these threats. These concerns were elaborated in Special Bulletin

During December 19, 1987 through December 22, 1987, the Ordnance Disposal Unit removed a total of 14 containers of potentially shock-sensitive/explosive items from the site and transported them to the Philadelphia Police Academy for a controlled detonation. The OSC submitted Special Bulletin "E" concerning the detonation £>f these shock-sensitive/explosive materials. On January 4, 1988, budgetary constraints nearly forcecthe demobilization of the site. Additional monies necessary for the continuing stabilization of the onsite laboratories and the subsequent disposal of the labpack containers were received the following day, allowing the stabilization efforts to continue as planned. Upon the receipt of these additional funds, disposal of the labpacked containers began on January 7, 1988. On January 14, 1988, an emergency situation developed involving a tank (tank #152) containing extremely flammable n-butyl chloride. All appropriate emergency officials were notified and all other site operations were terminated in order to mitigate the spill. Mitigation operations Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 14 included U'eiSijSlBg the area around tank #152 and collecting the material. These operations were successful aKVfork was completed over the next several By February 4, 1988, Removal funding constraints again temporarily halted disposal shipment of labpacks containing known material. Preparations were underway to remotely crush the remaining labpacks (110) containing unknown materials. Identification and segregation of cylinders onsite began; the cylinder manufactures were identified as PRP's and have agreed to handle disposal/removal of their cylinders. Using a specially modified steel rolloff, equipped with a see-through lexan blast shield, ERCS began the remote crushing of unknown laboratory containers on pier #105, The lab containers were placed in absorbent material and then crushed using the flat end of an excavator bucket, The operator of the excavator was protected by the addition of a steel and plexiglass blast shield mounted to the front of the excavator. From February 18 through February 26 ERCS crushed 4,483 lab containers, resulting in 212 drums of waste. On February 29, 1988, Regional budgetary constraints slowed stabilization effort at the Site. In response, the OSC began a gradual demobilization of equipment in an effort to conserve monies but maintain necessary stabilization activities. The OSC drafted Special Bulletin "P" stressing the importance of additional funding and the need to exceed the $2-million dollar limit. On March 2, 1988, OSC Wright received $200,000 in interim funding. This allowed for the disposal of the 80 remaining known labpack drums. With the primary goal of stabilization of the five onsite laboratories completed, site operations were concentrated on assessing the remainder of the plant. ERCS began an assessment of the process lines and storage tanks. Because of the expected large quantity of material, drumming of the material was not feasible due to site space limitations and the cost of the eventual disposal of so much drummed waste. To avoid this, bulking strategies were discussed and four onsite tanks were selected, refurbished and hydrostatically tested to be used as bulk storage for this material. A subsidiary problem associated with the assessment of the pipelines was the large amount of asbestos insulation. Since asbestos posed a potential exposure problem to site workers, an asbestos subcontractor was hired to perform perimeter and personnel air monitoring for asbestos. Drum staging areas were established for material that was not compatible with the large bulking schemes. This material was systematically identified, overpacked and staged. As more and more acid material was identified, it was bulked in preparation for the neutralization operations. The same consideration was given to the several thousand gallons of acetaldehyde, a flammable derivative from the production of acetic acid. This material was neutralized in its original storage tanks and disposed of in a safer form.

As the site assessment progressed, numerous pressurized cylinders were discovered and staged. These cylinders, many poorly marked, posed a significant threat to site workers and the local area. A cylinder disposal subcontractor was hired to identify the contents and possibly the supplier of the cylinders. As supplier/owners were identified, they were notified and allowed 5RUOQ227 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 15 to pick apjagiprspose of their property. Eventually, all of the pressurized cylinders were disposed o£|tp|^ manner. ^v*1- "~' •"*& "•*- The completion of Phase I activities at the Publicker site included the treatment of four large tanks full of spent grain material. It was feared that the continued fermentation of this material would result in the production of flammable liquids or vapors. The contents of these tanks were mixed with a combination of boiler fly ash and portland cement, rendering the material solid and essentially inert. The final task under Phase I was the attempt to stabilize tank #238. The #6 oil inside the tank was contaminated with low levels of pesticides; worse, the dilapidated wooden roof atop the tank allowed rain water to accumulated, thereby increasing the volume of the tank. An oil/water separator was constructed in hopes the rainwater could be decanted and the oil disposed of. However, due to the heavy viscosity of the material and the onset of cooler weather, the oil could not be sufficiently heated and effectively pumped. This operation proved unsuccessful, and was abandoned until an alternative method could be found. Last, one more round of remote opening/crushing of unknown materials occurred. These small containers were discovered during ground sweeps through the site for just this purpose. This second round of opening yielded 3,092 containers, which were handled in the same manner as the previous containers.

During the summer of 1988 through the end of Phase I, legal and claims of ownership issues arose centering on the remaining ethylene glycol on site and previously purchased tanks and distillation equipment by a private party. With the assistance of EPA's Removal Enforcement Section, ECRECON (purchaser) under an order from .EPA was allowed to dismantle the distillation columns under an approved work plan. EPA's enforcement section was also able to secure an agreement with AAA/Linfeld the owner of the ethylene glycol to remove the seven railroad tank cars containing the material. However, due to legal issues independent of the Publicker Site, the five stainless steel tanks remained on site. From May through November of 1988, routine disposal operations were prevalent. This resulted in the disposal of all of the laboratory chemical, PPE, tie neutralized acids and acetaldehyde, PCB oils and transformers and nearly all the drummed material. .However, due to budgetary constraints, ERCS contractor contract capacity .and the anticipated cost for the disposal of the bulked waste, the disposal of the bulked wastes and decommissioning of the process lines were to be addressed during Phase n of the project. On May 5, 1989, EPA proposed that the Publicker Industries Site be added to to the National Priorities List (NPL). Later, on June 30, 1989, EPA's Remedial Section selected long-term remedial plans for the Site as stated in the Declaration for the Record of Decision (ROD). On September 5, 1989, with the approval of an additional funding request in the amount of $13,906,000 by the Acting Assistant Administrator Jonathan Cannon, Phase II of the removal began at the site. The proposed actions as stated within the additional funding request are to complete the response actions at the Publicker Industries Site. These actions were specified in the first operable unit ROD for the Site, therefore the ROD will be implemented utilizing site- specific contracting for the disposal of bulked waste and the Emergency Response Contractor Service (ERCS) for the decommissioning of the Site. Environmental Health Research and &RUGQ228 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 16 Testing ser^pliQ&e ERCS contractor for the remainder of the project. The Phase n objective was the comgfSte decommissioning of the overhead pipe network, estimated to be around 300 miles. ERClfwere responsible for tapping, draining and drumming any contents of the pipes and then shearing and lowering the cut section to the ground. During mis phase of the work, an overhead grain trestle was demolished because of its safety risk and its construction around an overhead network of pipes. Additionly, the "OLD HICKORY" sign was demolished because of the safety risk to site workers. These activities continued through June of 1990. In an attempt to expedite the work, the interior of piping on the south side of the plant was video taped to ensure the process lines were empty of liquids. Because no liquid material was discovered during the video taping these pipe were left in place. October 12, 1989 the Publicker Industries Site is listed #44 on the National Priorities List. June 29, 1990, ERCS arranged for the final disposal of material recovered from the decommissioning operations. This included 5,300 gallons of contaminated #6 oil, 5,200 gallons of a mixture of #6 oil, alcohol, acetone and ethylene glycol and 80 drums of solvents and corrosives. With the conclusion of this phase, preparations were made to award a site specific transportation and disposal contract for the removal all remaining drummed, bulked and tanked waste at the site. August 3, 1990, an emergency situation developed concerning tank #238, which contained contaminated #6 oil. The tank had developed a leak; in an effort to prevent a catastrophic release, the contents of the tank were transferred to tank #306. Both tanks contained similar material and both were slated for disposal under the site specific contract. With the issuance of Special Bulletin "RR" the OSC remobed ERCS (EHRT) to perform this operation. ERCS was successful in transferring a majority of the oil,however due to the extreme viscosity (peanut butter-like) pumping operations were discontinued. September 14, 1990, GSX/Laidlaw Government Services was awarded the site specific transportation and disposal contract for the removal of bulked waste from Phase I operations. This included waste in tanks #185, #186, #189, #190, #238, #306, and #106. The remaining drummed waste, spent PPE, and crushed steel and poly drums. From September 14 through December 14, 1990, GSX disposed of 645,416 gallons of organic, flammable, and oxidizing liquid and contaminated #6 oil, 346 cubic yards of baled spent PPE and 585 cubic yards of crushed drums. The aforementioned tanks were cleaned so that a hot work permit could be acquired to dismantle them. On December 14, 1990, OSC Powell made all necessary arrangement to transfer remaining site operations to the EPA Superfund Remedial program. ERCS made final arrangements to demobilize site trailers.

ftRl*00229 Publicker Industries NP1, Site Federal On-Scene Coordinator's Report Page 17 IV. RESOURCES COMMITTED

A. Initial- Fundin_^^5B^™^JjSt1-n£g— Request The Publicker Industries Site Emergency Action was initiated by OSC Wright on December 8, 1987, when he obligated $50,000 under Delegation of Authority 14-1-A. OnDecember9, 1987, the Acting Regional Administrator approved an Interim Funding Request for $1,702,000, raising the Removal Ceiling to $1,752,000. In March 1988, the Regional Administrator approved an Interim Funding Request for $200,000, bringing the removal ceiling to $1,952,000. On March Hi 1988, the Assistant Administrator of the Office of Solid Waste and Emergency Response (OS\\JER) gave verbal approval to exceed the $2,000,000 statutory limit and authorized an additional $1,375,000 to bring the total project ceiling to $3,327,000. - _: -' On April 8, 1988, an additional $4,912,500 was approved1 by the Assistant Administrator of OSWER to confinue'the stabilization of the site, which brought the total ceiling to $8,239,500. These monies were used to continue the ongoing Removal action to a point short of transportation and disposal of the major waste streams onsite. An exemption to the limitation of response actions beyond twelve months {Section 104 (c) of SARA [section 104(c) (1) of CERCLA 1980, as amended]} was granted by the Regional Administrator on November 17, 1988. Additional funding in the amount of $587,500 was approved on November 28, 1988, and increased the total ceiling to $8,827,000. These additional funds were utilized to continue 24- hour site security and fire watch. These activities allowed EPA to retain control over the site and comply with ARARs until Remedial actions could be initiated. On September 13, 1989, the Assistant Administrator of OSWER approved a request for $13,906,000 in Remedial funds to continue response actions at the Publicker Industries Site. The total project ceiling was raised from $8,827,000 to $22|733,000. B. Estimated Total Cost Summary 1. Extramural

ERCS $ 6,88] ,000.00 Remedial Action 6,95^,075.40 Coast Guard 6,700.12 NCLP 7,715,01 TAT 34^,585.15 Misc. Costs 9,252.23 Extramural Subtotal $14,204,327.91 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page IS

Regional Direct $ 183,547.95 Regional Indirect 471,555.00 HQ Salary - 6,468.56 HQ Travel 739.88 Intramural Subtotal $ 662,311.39

TOTAL PROJECT COST $14,866,639.30 Total Project Ceiling: $22,733,000 Percent of Ceiling Expended: 65%

V. EFFECTIVENESS OF THE REMOVAL A. Activities of the Various Agencies 1. Potentially Responsible Party EPA and Publicker Industries entered into a CERCLA Section 106 Consent Order on July 20,1987. During 1987, Publicker Industries conducted a site assessment and limited site stabilization efforts under a this Consent Order. An inspection was performed by the EPA on December 1, 1987. As a result of this inspection, EPA determined that the RP's actions were inadequate and the site conditions continued to pose a threat to the public health, welfare or the environment. It was at this time that the U.S. EPA assumed site control and lead on site stabilization actions. 2. Federal Agencies David Wright, Lisa Price and Edward M. Powell, EPA Region HI, Philadelphia, Pennsylvania, served as principal Federal On-Scene Coordinators for this project, and were responsible for coordination with other federal, state and local authorities, and the direction of the removal contractors, as well as the formulation of a site specific transportation and disposal contract, to ultimately eliminate the threat posed by this site.

Jeff Winegar and Nick DiNardo, EPA Region HI, Philadelphia, Pennsylania, were responsible for the development and Declaration of the Record of Decision (ROD). The quick development of the ROD enabled the utilization of Remedial funds to complete removal actions at the Site in a timely manner and promulgate the Site onto the NPL. Due to the large and complex nature of the Site, the OSC's were able to utilize many additional goverment agencies for assistance in completing removal actions at the Site. These include EPA's Emergency Response Team; for assistance in developing site safety protocols, a site safety plan and advise on the segregation of the thousands of small laboratory containers. The United States Coast Guard (U.S.C.G.), Marine Safety Office/Philadelphia for advise and HRU0023I Publicker Industries NPL Site FederU On-Scene Coordinator's Report Page 19 recommendj igM on the bulk oil tanks on Site and U.S.C.G, Alantic Area Strike Team (Lantera) for technicl sJ8|( Site safety monitoring. The U.S. Department of Interior, Bureau of Reclamation for advise and recommendation on the demolition of unsafe structures on the Site. 3. State and Local Agencies PADER, throughout the removal, coordinated with the oSCs and served EPA in an overall support role, especially in providing support for the Remedial Branch to expedite placement of the Publicker Site on the National Priorities List. The Philadelphia Fire Department initially responded to the Publicker Pier fire and because of their concerns notified the RRC, suspecting that chemicals were involved in the fire. The Fire Department and its Hazardous Materials Administrative Unit served an important role in assuring that proper fire fighting equipment was onsite for EPA's fire watch teams and that in an event of an incident this equipment was compatible with the City of Philadelphia's equipment. The City Managing Director's Office was supportive of the removal activities at the site and assisted the OSCs with arranging the closure of Delaware Avenue while removal activities.were being conducted as well as assisting the OSCs in dealing with the large onsite asbestos problem.

4. Contractors The Roy F. Weston, Inc., Technical Assistance Team (TAT) participated in the initial emergency response and subsequent follow-up assessment at the site. During the EPA removal operations, TAT was responsible for providing the OSC with technical and administrative support that included, sampling, air monitoring, photographic and site activities documentation and site safety. BES Environmental Service was the clean-up contractor under the Emergency Response Cleanup Services (ERCS) mechanism for the duration of the Phase I stabilization efforts. Environmental Health Research and Testing was the ERCS contractor for the duration of the Phase n stabilization efforts. ERCS personnel were responsible for performing the actual removal activities and providing the necessary manpower, equipment and materials to safely remove the drums and stabilize the site. GSX/Laidlaw" Government Services provided manpower arid equipment to dispose of bulked wastes from Phase I activities under the site specific transpoitation and disposal contract. B. Analytical Synopsis Sample analysis was performed on several matrixes at the Publicker Industries Site. Matrixes sampled and analyzed included drummed, tanked and pipelined material.

All drums onsite were sampled, and the samples were sent for compatibility analysis. Results showed that the material fell into several categories: organic liquids, metals, flammable liquids and solids, radioactive, peroxides, poisons, water reactive metals, and PCBs. These waste streams were sampled and analyzed to facilitate disposal arrangements. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 20 C. Dispo^iftfr-fhods and Quantities Removed The following table provides information on wastestreams and their methods of disposal for materials that were found at the Publicker Industries NPL Site. Actual manifests are stored in the site file in the U.S. EPA Region HI Central File Room, Philadelphia, Pennsylvania.

DISPOSAL METHODS 1 u

* CUYD DATES DRUMS MATERIAL # GAL WASTESTREAM DISPOSAL LOCAtiON , . ' METHOD., 04/20/33 14 30 Crushed Lab Chem-Met Services, Wyadotte Ml Stabilization 11/07/88 Material Enivrosafe, Oregon, OH and Landfill Chemwaste Management, Emelle, AL 10/28/33 34 Corrosive Solids Chemwaste Management, Neutralize Emelle, AL and Landfill 10/38 150 Spent PPE Envirosafe Services, Oregon, OH Landfill

OS/14/SS 15 PCB Oil and 3 APTUS, Loffyville, KS Oil- 10/83 Transformers Incinerated landfilled 03/10/33 359 Lab Bottles (Lab Thermal Kern, Inc., Rock Hill, SC Incineration 01/07/88 Pack) 10/11/88 01/24/SS 09/12/83 9,299 Treated Chemwaste Management, Wastewater 09/13/88 Acetaldehyde Newark, NJ Treatment

08/31/33 € Mercury Mercury Refining, Albany, NY Recycled Containing Waste

09/21/88 '1 Radioactive U.S. Ecology Nuclear, Landfilled Material Ricnland. WA

1 2/23/87 42 Flammable Solids, Trade Waste Incineration, Incineration Oxidizers, Sauget, IL Parcxides, Organic Peroxides, Poisons

09/16/88 123 4,000 ' Rammable Liquids SCA Chemical Services, Incineration 09/27/88 Chicago, IL Frontier Chemical Waste Process, Inc., Niagara Falls, NY 05/90 S 5,000 Flammable Liquid Waste Conversion Inc., Incineration Contaminated Oil Hatfield, PA 09/90- 146,316 Organic Liquids DuPont, Chambers Works, Biological 12/90' (Tank 190) Dsepwater, NJ Treatment 09/90 - 44,200 Oxidizing Liquids OSCO Inc., Columbia, TN Wastewater 12/90 (Tank 189) Treatment 09/90- 327,917 Base Neutral OSCO, Inc., Columbia, TN Wastewater 12/90 Liquids (Tanks Clean Harbors, Baltimore, MD Treatment 185- 186) Tricil Environmental, Hillard, OH ftRi*OQ233 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 21

;>;:;';i'.::::>'V:'y-'.',•;'" IVi f1'; i: Vi'-'i1!'; :^^^pjpjlfc^1.^^--^^: •:''''• •••>::^^^^^^^'^S1:.^.:.':.':I11.!"VI!,.'. :;: K1 .'•';• ^^^J^kAl^il^liklHlli^- ' :'.TPii^rC'wli>\i?i''* TTx:-:.»!|ji tiif iVlilWTrWffi'"^ ! '•'' V. • '•" '',, ! • .' ,. . •',. '...•,: .;;....'.^•••' .•' ,.^^.,;:;;' ''.,-•.• .>.,«•>..•_.,.>.....' ••' •'•^1'1 .:•.;'>;•& •— ,' ;;•,•• ' . I pei# YD&l ; i-'OATE^I ••;yiifi$$liJ I J&^ERW&J|::;;$:eA£*;;l ^Ir^ST^TREA^!^ §• J^^'l'iptiHS^OS^ti^A^ipN ^ '.'• ! 'I.' ;';:J'.'tAEtti$Q^., 09/90- 21 1 ,885 Contaminated Fust Caste Oil Salvage, Vineland, NJ Fuel Blended 12/90 Oil (Tanks 306, GSX: Services, Pinewood, SC Landfill 238, 106) 09/90 - 487 Organic Liquid, GSX, ENSCO, Cyanochem Incineration 12/92 Base Liquid Solids, Landfill Oxidizing Solids and Liquids, PCB

471 Empty Poly Drums GSX, Pinewood, SC Landfill 585 Crushed Metal GSX, ^inewood, SC Landfill Drums 346 Spent PPE GSX, 3inewood, SC Landfill

Totals 1,518 1,111 748,659

VI. CHRONOLOGY OF EVENTS This section provides a synopsis of events as they occurred ai the Publicker Industries NPL Site, CERCLA Removal Action. The chronology is derived from POLREPS and site logs. Copies of POLREPS may be obtained from the U.S. EPA Region III through the Freedom of Information Act,

.Tune 26. 1987 - At 1430 hours the RRC was notified of an active fire involving Publicker Pier #105 on Delaware Avenue, Philadelphia, PA. EPA and TAT responded and arrived on scene at 1530 hours. The Philadelphia Fire Department had the fire under control, but advised the OSC of their belief that hazardous chemicals may have been involved in the fire. Power and water had been shut down at the facility, thereby increasing the potential for future fires. There was no site security and parts of the site were undergoing demolition.

OSC and TAT examined the perimeter of the site and took HNU-Photo-ionization detection readings which showed no organic vapor levels over background.

.Tune 27. 1987 - OSC and TAT returned to site to assess the situation. Improper chemical storage was observed in the fire-impacted area, as were scattered cylinders. Also present j was evidence of widespread chemical contamination, pools of oily material, small lagoons and areas of stained/discolored soil.

.Tune 29. 1987 - Jr. OSC Lisa_Clark briefed Bob Boody, EPA Criminal Invtigator, of the Publicker fire.

Jujy I, 19jt7 - ERPS Chief Massey contacted EPA Criminal Investigator^ John Aduddell, concerning Publicker investigations and advised him that emergency response activities may soon be initiated. Chief Massey also contacted PMDO John Hadalski to initiate coordination between the City ani 1 EPA regarding Publicfcer.

July 2. 1987 - OSCs Caron and Clark met with EPA Criminal Investigatorsregarding future assessment plans.

July 7.1987 - Meeting held to discuss Publicker situation and future assessment plans. In attendance were L&I, PHD, Air Management, PFD, and Emergency Services; PA DER; CRES, ERPS; iind USCG.

July 9. 1987 - Verbal notice, issued to the following PRPs: Attorney for Trustee (including Cuyahoga and Overland); Freedom Savings and Loan; Publicker Industries, Inc. Publicker accepted responsibility for site security, PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page 22 but requested fas^KBgSf *°d information prior to accepting responsibility for cleanup. Publicker hired OHM, who placed boom md. jjjgttiod for site security and tire watch.

A site assessment was conducted of fire-impacted area. Level B entries revealed bulging drums, leaking process systems, asbestos, spills of laboratory chemicals, strong acids and bases in a laboratory, and cylinders containing specialty compressed gases, including several marked "hydrogen sulfide.'

.Tulv 10. 1987 - Mr. Weis of Publicker participated in a site inspection accompanied by EPA, PFD, PA DER, OHM, Hart Environmental, Publicfcer, and TAT. EPA and TAT investigated the boiler plant and discovered numerous unmarked drums and possible PCB transformers. TAT collected samples at five locations.

JolT 14. 1987 - OSC met with PubUcker and contractors to determine scope of work for site stabilization.

.Tulv 17. 1987 - OSC briefed PMDO Hadalski of Publicfcer situation and status of Consent Agreement. CRES Walter Lee worked with Publicker on Consent Agreement for site assessment.

July.20*. 1987 - Consent Agreement was signed with Publicker. Publicker thereby accepted RP status. RP continued site stabilization measures. OHM continued as RP cleanup contractor.

December S. 1987 - Tom Massey, now SSC, conducted a site inspection of RP stabilization efforts, accompanied by CRES Lee, and TAT. During this visual inspection, it was determined that RP efforts were inadequate and site conditions continued to present threats to human health and the environment. OSC Wright obligated $50,000 under Delegation of Authority 14-1-A (05/01/85) to mitigate these threats.

Through the ERCS mechanism, OSC Wright directed BBS to be on site as soon as possible as prime cleanup contractor. The OSC was directed by EPA HQ Contracts R. Mueller not to activate OHM due to possible conflict of interest issues as OHM was RP cleanup contractor.

Fire watch and 24-hour site security were instituted. Since this site was officially declared a CERCLA Removal Action, ORC and CRES would be required to have, any PRP disclose all intentions and methodologies for proposed tasks on site, which would be performed only as approved by the OSC.

December 9. 1987 - QSC Wrigfat met on site with ERT. CRES and SSC to assess and define emergency removal logistics and operational tactics. OSC Wright also met with PFM Harry Cusick and PMDO John Hadalski to brief them on site developments and future actions. PA DER Rob Alien was on site to be briefed by the OSC as to current site status and EPA plans for future activities. _. _ ; __ -.-

At the request of ORC Martin Harrell, OSC Wright directed BES to compile a list of items that needed to be immediately addre«cd to mitigate the extreme threat to the public and the environment, and to estimate the associated cost of these items,

ERT Zownir reviewed (he preliminary draft site safety plan prepared by TAT at the request of the OSC. It was understood that the plan would be updated and refined as the scope of removal activities warranted.

OSC Wright directed BES to provide an operations and logistics center at a nearby hotel (Quality Inn) until a permanent command post could be established.

TAT conducted safety survey to identify site physical hazards and inspected structural integrity of fencing around the perimeter of the facility.

Decemher 10. 1987 - Additional funding request for $1,702,000 was approved and signed by the Regional Administrator, bringing the total project ceiling to $1,752,000. FAS Joan Henry on scene to assist in implementing flRi+00235 PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page 23

RCMS. BES continued site stabilization efforts and assessed imminent threats to human health and the environment.

- On-site command post was placed into operation, an i OSC initiated strict site security and control through site logs and radio communications.

OSC Wright, ERT Zownir, and ORC Harrell met with RPs to discuss their intent for site control/stabilization. Meeting consensus was that EPA would remain lead and would take any action necessary to protect public health and the environment. OSC Wright would be notified of any RP issues through ORC Harrell.

OSC Wright requested advice/guidance concerning asbestos found at the site and directed TAT to establish an air monitoring program to determine the levels of protection necessary in the various work areas within this 37-acre site. Site map was drafted and posted in the command post for all site personnel to reference. As requested by the OSC, a memo to PMDO concerning the closure of Delaware Avenue between Packer Avenue and Ashland Chemical was drafted.

A Level B entry was performed by BES to examine process lines near the cooling racks that were to be removed by KDB International, represented by Barry Shapiro. The drum storage^ area was also inspected on die south side of the site.

December 12. 1987 - As prearranged via contract with=the RP, KP_B International removed purchased materials. Section Chief Massey monitored their operation and required that all workers follow the site safety plan. Communications/ personnel-tracking base station was established and became operational at 1100 hours this date.

Further delineation of work/level of protection zones continued. Placement of barriers and signs to designate clean routes of travel and exclusion areas was initiated.

TAT continued air monitoring utilizing Forced Air Collection Evaluation" FACE). BES fire watch patrol replaced TAT as air monitoring team at COB. BES chemist continued to compile data in preparation for future labpacking operation. .OSC requested ERT Campagna to coordinate an asbestos aii surveillance/sampling program for implementation as soon as possible.

PFM Cusick reviewed the proper fire fighting equipment with Guardian Fire Protection personnel on site under federal contract, per Section Chief Massey's request; all systems were r

- Preliminary Operations Plan to control and stabilize the Publicker Industries NPL Site was submitted to OSC Vfoght. CRES, ERT, Section Chief Massey, BES, and TAT provided input to the plan.

- Walt Whitman Bridge Port Authority Safety Manager [George Ballendorf on site to delineate to the OSC their property boundaries on the Publicker Site. This area becajoe part of the site air monitoring route.

December 15* 1987 - A meeting was held at the adjacent Ashland Chemical Company to create a good neighbor policy with all parties involved, either directly or indirectly, with the Publicker Removal Action.

Final safety plan was approved by OSC Wright, and SSO duties were transferred to USCG personnel. Decontamination trailer was mobilized to the site. Labpacking operations commenced. Segregation of lab chemicals began in dilapidated lab area by subcontractor (ThermalKEM). PMDO Hadalski informed the OSC that EPA needed to contact John Borrse (Chief Traffic Engineer for the City of Philadelphia) concerning the closure of Delaware Avenue.

Pecembg:_.!& ljj% • Assessment of site zones continued. Labpacking operations continued (13 30-galkm fiber drums labpacked withffi&f of 129 bottles).

TV Channel 10 BJMt interviewed OSC Wright on site and received a site status update.

City Traffic Coordinator Don Vasche approved me closure of Delaware Avenue adjacent to the Publicfcer Site. BES was directed to provide DOT signs for this closure.

Ecrecon, Inc., representatives were on site to discuss with OSC Wright the removal of three previously purchased tacks. OSC referred Ecrecon to CRES concerning this issue.

OSC directed BES to obtain video equipment to document chemical labs and work areas.

December 17.1987 - The lab chemical task force, consisting of ERT, TAT, AMO and ThennalKEM, expressed extreme concern to OSC Wright regarding shock-sensitive materials identified in the four on-site labs. City Ordnance Disposal Unit Lt. Merkert was contacted by the OSC. Lt. Merkert went to the site and assessed the potentially explosive materials. The OSC prepared to take immediate action to abate these threats and directed BES to subcontract an explosives expert. George Walton of Reactives Management was selected.

December 18.. 1987 - Labpacking operations, site zone assessments, and air monitoring along the Level D route continued. BES was directed to clear gate #6 area for future fire watch access and also future lab area cleanup access.

PWD James Nioolo and City Air Management John D'Ambrosio visited the site and were briefed by OSC Wright on current site status.

December 19. 1987 - ERT/REAC was on site to review site safety plan and to assess the Publicker Site for possible future air monitoring program. TAT continued to photodocument lab areas and provide technical support to the lab chemical task force.

City Ordnance Disposal Unit began removal of shock-sensitive/explosive materials. These materials were transported to the Philadelphia Police Academy for controlled detonation. December 22. 1987 - City Ordnance Disposal Unit removed six containers of shock-sensitive/explosive items from the labs for a final total of 14 items removed. OPA was briefed on all City Ordnance Disposal Unit operations. PFM Cusick, City Ordnance Unit Lt. Merkert, and L&I Robert Hoyt made, the decision that KDB International would not be allowed to reoccupy their premises (building #173) until scattered unknown lab chemicals were addressed and the building was determined safe.

Decetphpr 23. 1987 - Labnacking in building #118 was conducted and completed; total of 55 drums labpacked. An assessment was performed in building #173 to determine working conditions and level of protection mat would be necessary (Level B) during labpacking operations.

December 28. 1987^- Labpacfcing operations began in building #173.

December 29. 1987 - Draft contingency plan and emergency call down procedures were developed by TAT. Fire control specialists, along with fire control equipment, were set up on site by BES.

December 30.1987 - OSC Wright met with PFM. City Transit Authority, PPD, PMDO, and the Walt Whitman Bridge Authority concerning protocol for incident and release notification procedures.

Pecanber 31. 1987 - BES continued to provide on-site air monitoring. BES ceiling was increased by $72,000; however, even with increase, estimates indicated that current funds would be exhausted COB 1/4/88.

January 1. 1988 - Thirty additional drums were packed from building #173 for a total of 227 to date. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 25

January 2. 1983L^19SS completed labpacking in building #173 and installed security doors on it. Total site assessment continagjgd collection/staging of abandoned cylinders began.

January 3. 1988 - Approximately 35 full to partially full drums were found in tank #75 (a semi-trailer), listed as empty in previous site assessments. BES staged 67 cylinders collected in building #162; three contained unknowns.

198JI - Second floor of building #118 was surveyed to ensure all lab materials had been removed; additional materials were uncovered. Buildings #157 and #160 were also surveyed for lab materials.

At 0930 hours, OSC Wright received approval from PFM and L&I ^o allow KDB International access to their building (#173), as all chemical hazards had been removed.

Demobilization of the site was planned for COB 1/5/88 if additional requested funds were not committed. Funds were necessary to ensure timely shipping for disposal of labpacked materials. OSC Wright requested an EPA Contracts representative to visit the site to discuss issues of concern raised by the OSC and BES.

January 5. 1988 - Additional funding was received, raising the BES ceiling by $500,000 to $857,000, which allowed stabilization efforts to continue as planned.

Samples were collected of sludge and leaking fluid from tank #174. Samples were sent to lab for analysis. j PFM Cusick and OSC Wright met to review Publicker Site Emergency Operations Plan.

January

EPA Contracts personnel arrived at the Publicker Site to view conditions first hand. Conrail representative was on site to speak with OSC Wright about the railroad spur running through the site.

January 7, 1988 - A total of 121 drums of labpacked chemicals were loaded and transported to ThermalKEM, Rock Hill, SC, facility. As the site assessment and building sweeps continued! increasing numbers of both known and unknown compounds were located and tagged for removal with the labpacks.

As part of the emergency procedures, a site map was created showing emergency command locations should an incident at the primary command post occur. PFD personnel were on site to ensure equipment compatibility and to familiarize their personnel with the site.

JanuaryA19£3 - A comparison of RP contractor OHM data on tank stability/security and known site conditions was conducted for verification of information.

January 9. 1988 - TAT updated the site map to provide a better base Wp for site documentation and zone assessment. Labpacking in building #118 was completed; 25 additional drums were packed for a total of 80,

January 10. 1988 - Cylinder recovery/staging continued,

January 11. 1988 - Hazardous Waste Management Division Director Stephen Wassersug and now ERS Chief Bob Caron met with OSC Wright and viewed site conditions first hand. Cindy Taylor and_Norm Zeeman of EPA Contracts met with OSC to discuss contract issues. _:EPA and TAT ceilings were increased to $55,000 and $110,000,respectively.

Labpacking in building #153 commenced, with 20 drums packed.

SRM30238 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 26

notified regarding contents of tank #159. PWD acknowledged that material met discharge specifiiiggiB^ but refused to accept any discharge without a release of liability. ^ • Screening of buildings continued for hazardous chemicals. OSC Wright requested additional EPA assistance.

January 13. 1988 - Cylinders in building #164 were staged according to compatible groups. A total of 86 known cylinders had been identified, with 5 listed as unknown.

January 14. 1988 - An emergency situation involving an n-butyl chloride tank occurred. All appropriate City officials were notified, as were EPA Emergency Response Section personnel. All other site operations were terminated due to the threatening situation involving tank #152 (highly flammable n-butyl chloride product).

January 15. 1988 - PWD representatives inspected the proximity of the sewer/storm drain to the n-butyl chloride spill area and monitored these areas. There was no indication that any product was emanating from the outflow pipes into the Delaware River. '

Cylinder manufacturers were contacted. As PRPs, they agreed to handle disposal of their cylinders.

January 16. 198S - Transfer of remaining contents from tank #152 was completed. Soil sampling around area revealed traces of n-butyl chloride,

Jypuary 17. 1988 - Trenching operation began for the recovery of spilled n-butyl chloride. ERCS completed labpacking in building#l53 and began labpacking in building#162. Cylinder removal staging continued from buildings #162, #163, #167, and #169.

January 19. 1988 - PMD representative Hadalski met with OSC concerning current site removal status. January 2Q. 1988 - OSC met with CRES and ORC and personnel from Holt Industry concerning their possible purchase of the Publicker property, ERT A. Humphrey and T. Kady arrived on site per OSC request to provide advice and guidance on the need for further trenching for the recovery of spilled n-butyl chloride.

January 21. 1988 - Analytical results for samples taken from the three on-site tankers were received.

BES investigated burned out pier area for drums, cylinders and other hazardous materials.

L&I Charles Summers was on site and informed OSC Wright that he would be the liaison for his office and would handle future Pubikker issues.

M.G. Industries representative Charles Weintz was on site agreed to recover 21 cylinders. He also identified 11 of the unknown cylinders. John Antonaccio (Freedom Bank trustee for Publicker Industries) was on site to speak with the OSC.

January 22, 19S8 - Spilled n-butyl chloride product recovery continued. Collection trench, refilled with less product after each pumping action.

OSC requested representatives from CRES, EPA, ERT, TAT and BES to attend a group meeting on site to discuss past, present, and future actions for this CERCLA/SARA removal. OSC expressed concern regarding the ability to bulk materials as a means to consolidate materials, thereby facilitating disposal, following completion of priority labpacking. flRi*OQ239 PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page 27

BES secured and cohered transformers and capacitors for later disposal.

of building #162 was completed; no oiher chemicals or hazards were observed during final building screening. Pumping of tank #159 into holding tank #145 began, eliminating the threat of the cracked shut-off valve to release large volumes of water treatment wastes.

Pumping of spilled n-butyl chloride from trench continued. OSC planned to discontinue recovery operations soon as no additional product was apparent. Air monitoring would continue and pumping equipment remain on stand-by in the event future recovery action became necessary.

January 24.1988 - A total of 116 fiber drum labpacks were transported for disposal at ThermalKEM. Tank #306 discovered to be leaking organic liquid product.

January 25. 1988 - Draft $2-mUIion exemption was delivered to EPA Region III for review and comment. BES ceiling raised from $500,000 to $1,357,500.

Clearing began of burned out pier debris in anticipation of cleanup of this area. Site zone assessment and sampling continued. Zones Al, A2, A3, Bl, and B2 were surveyed and 120 tanks were inspected for contents. Work was hampered by snow and ice conditions.

Xanuarv 26TJ1988 - PA DER Alien met on site with OSC Wright concerning current removal status of the site.

January 27. 1988 - Ecrecon, Inc., set up an appointment with the OSC todiscuss removal of equipment they had previously purchased from the RP.

After a thorough search of the burned-cut pier area, three samples were collected: a waste pile of white material, a drum labeled "carbide," and a drum containing a purple-colored compound.

January 28. 1988 - Approximately 65 percent of the Publicker Site surveyed to date. Zones Cl, C2, and the southside of the property, heavily clustered with tanks, remained to be surveyed.

A tank inspector from Tank Maintenance, Inc., assessed the condition of tanks that were considered secure bulking areas for compatible products.

January 29. 1988 - Zone assessment/tank inventory was completed in Zones Cl, C2, C3, and Dl. Fifteen additional tanks not included in the OHM September report were discovered in these areas. Ground search completed in Zones Al, A2, A3, A4, C4, and B4_with removal of lab wa»te, cylinders, fire extinguishers, drums and 5'gallon containers. ._ ^

Ecrecon inspected previously purchased equipment and discussed future removal of equipment with OSC.

January 30. 1988 - Zone assessment/tank inventory completed in Zones A4, B4, and C4 (50 percent completed). Ground search and removal operations completed in Zones Bl, B2, B3, and B4.

January 31. 1988 - Zone and tank assessment completed in Zone C4. All staged carbon dioxide fire extinguishers were rendered safe.

February 1. 1988 - A total of 230 labpacked drums of known materials disposed of to date; 80 known and 110 unknown labpacks remained on site. It was expected that additional materials would be found during site survey. Bags of asbestos found in buildings were moved to lower floors for j future disposal. Tank #188 was found to have a leaking valve. The line was emptied, yielding approximately 30 gallons of unknown product.

OSC requested ERD personnel to visit the site and view site conditions first .band. \ Publicker Industries NPL Site Federal Ou-Scene Coordinator's Report Page 28

February 2. 19|pp3>I.G. Industries removed 23 cylinders. Ecrecon inspected section of property previously purchased from MHfeker Industries.

OSC assessed bumped out pier area as a possible location for the remote opening of labpacked unknowns. Tank/zone assessment 95 percent completed as of COB this date.

T 1988 - Tank Maintenance, Inc., discussed proposal to examine and test six tanks being considered for bulking operations. Lab #160 completely cleared of lab chemicals, glassware, etc. this date. USCG representatives on site to" view site activities. ' " "

FebniaPLjLJ988 - EPA Removal funding restraints temporarily halted labpack shipments. The $2-miIIion exemption/additional funding request was submitted into Regional concurrence chain.

Tank survey completed; comparison with PRP data indicated discrepancies requiring further evaluation. Establishment of a remote opening site at the pier area was initiated.

February 5. 1988 - Final proposal for site for remote opening of unknowns was submitted to OSC Wright. Overpacking of deteriorated drums continued.

February 6^1988 - Pier clearing operations continued in preparation ' for remote opening operations. Phatodocumentation performed by TAT to confirm all laboratory materials had been removed from buildings. Representatives from Geppert Brothers, Inc., and American Demolition Company on site to meet with OSC.

FehniaryJjL19SS - Matheson Cylinder Company removed 45 gas cylinders. Ground sweep completed in Zones A, B, and C. Final material staging still in progress.

February 9. 1988 - Section Chief Massey on site to assess tank inspections and associated safety issues. At 1400 hours, OSC met with Superfund Branch Chief Tom Voltaggio to discuss site status (Special Bulletin "H").

Screening of building #171 confirmed the presence of a small lab on the fourth floor.

February 10. 1988 - Overpacfcing and staging of drums found on site continued.

February:11 . 1988 - The $2-million exemption/funding increase document with changes sent to Region III for approval.

12T 1988 - Preparation for remote opening operation continued. Drum crushing equipment set up in preparation for the crushing of empty drums.

February 13. 1988 - Drum crushing operation began. Crushed drums were staged for later disposal.

OSC Wright conducted an operations meeting with BES to clarify potential contract issues that may arise during the removal project. OSC contacted OSC Jerry Heston concerning these contract issues.

February J4>1 9_SS - Preparation for remote opening operation continued. Welding of remote opening staging pad, as well as customizing of equipment (Cat 215) with explosion-proof shield, completed.

February 15, 1988 - OSC Wright conducted a meeting with Section Chief, TAT, and BES to discuss the remote opening operation and safety practice runs to ensure a smooth operation. Tank inspection was initiated by MainServ.

6. 1988 - Practice remote opening procedure successfully performed. Final operations plan for the remote opening of unknowns was submitted to the OSC by TAT in draft form. PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page 29 SIO Paul Racette ojpjj fc to discuss process necessary to calculate preHminiry ranking of the Publicker Site for the NPL.

Februar-•y• 17—. 198^Ot— ^ fi_ D Victoria Van Roden on site to view site conditions and removal activities. Demonstration of remote opening operation performed at 1500 faou-s. Those in attendance to view the demonstration included PFD, PPD, Ashland Chemical Company, USCG,PMDOi and PA DER. EPA Region m emergency response mobile command post on site to provide operational assistance.

February 1 j. 1988 - Remote opening operation began with seven runs conducted; three drums with 105 containers crushed.Bulk storage tank inspection continued.

February 19^1988 - Empty drum crushing continued; approximately 550 drums rendered safe for disposal to date. Special Bulletin "I" was submitted. Due to unacceptable wind direction, OSC Wright discontinued remote opening operations this date,

February 20. 1988 - Remote opening/crushing resumed; 17 drums containing 333 containers crushed. PFD Ettore observed remote opening/crushing operation. Video and photpdocumentation performed by TAT and BES of remote opening/crushing operation.

February 21^1988^. Steel Irbeam located above access road to the remote opening pier area collapsed onto the BES 710 dozer. Damage was inflicted on the cab of the machine. No personnel were injured.

Remote opening/crushing continued; 19 drumscontaining 369 containers crushed for a total to date of 39 drums containing 80S separate containers.

Interim additional funding request completed this date as Special Bulletin ' J".

February 22. 1988 - At 1000 hours, the OSC met with CRES, ORC, and representatives and counsel for Freedom Savings (trustee), concerning Publicker Site status. City Air Management representatives observed site conditions.

Remote opening/crushing operation continued; 6 drums containing 223 ix>ntainers crushed, for a total to date of 45 drums containing 1,028 separate containers.

Interim funding request submitted to Region 111 concurrence chain for review and comment.

February 23, 1988 - Last remaining cylinder was removed by Gas Technics Company. At this time, all known cylinders had .been transported off site.

Remote opening/crusfiing continued; 22 drums containing 223 containers crushed for a total to date of 67 drums containing 1,251 separate containers.

FebruaryL24f 1988 - FAS Joan Henry on site to update EPA project cjosts. TAT performed air sampling in anticipation of an EPA Remedial documentation/investigation.

Remote opening, /crushing operation continued; 47 drums containing 840 containers crushed for a total to date of 114 drums containing 2,091 separate containers. Drum crushing operations completed. Any additional empty drums would be crushed as found.

February 25jj988 - During the remote opening/crushing operation, a reaction from one container created a fire within the crushing box. The fire was contained (Special Bulletin "K"). Seventy-two drums containing 1,218 containers were crushed for a total to date of 187 drums containing 3,309 separate containers. ARU002U2 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 30

BBS began prep»|g5 [fl?* new drum staging area. Publicker site fencing was repaired to allow KDB International Shapiro access toJj§C Jbck of his property, located adjacent to the Publicker property.

February 2£^198S - Remote opening/crushing operation completed with; 31 drums containing 1,174 containers crushed fora final total of 212 drums containing 4,483 separate containers. BBS subcontractor (Reactives Management George Waltoa) departed the site due to the completion of the remote opening/crushing operation. New drum staging area prepared and ready for the relocation of all on-site drums and containers.

PFD representatives (Harry Cusick, Tom Brennan and Joe McAIeer) met with OSC Wright and Section Chief Massey. SIO Acker met with PA DER Alien and TAT regarding the ongoing remedial investigation at Publicker.

February 29. 1988 - Special Bulletin "M", detailing current funding situation, sent to Regional Management. Due to funding restrictions, gradual demobilization of equipment began.

March 1. 1988 - BES continued to relocate drums to new drum staging area.

March 2. 1988 - OSC Wright received notification from the Regional office that the $200,000 interim funding document had been approved; $130,000 of this was for BES. OSC was advised that there was not $130,000 available for BES and that only $123,5000 would be obligated to the BES ceiling.

TAT performed air sampling around the acetic acid tank area of the site.

March 3. 1988 - Equipment continued to be decontaminated in preparation for demobilization. . 19g8 - BES completed relocation of all drums to the new staging area. Special Bulletin "O" submitted this date concerning current funding status.

March 7. 1988 - OSC Powell on scene to direct cleanup efforts in the absence of OSC Wright and OSC Price (nee Jr. OSC Clark) due to other Regional commitments.

March 8, 1983 - Roll-off box containing crushed unknowns was sampled for disposal. Several leaking drums were overpacked and restaged in the new staging area.

IVjarcfa g. 198J8 - Contaminated 'soil from the previous PRP dnim staging area was scraped up and drummed. All operations in both old and new drum staging were areas completed. Several additional lab containers were found, labpacked and stored for later disposal. Several drums were also found and staged. Pumping of contaminated liquids from sump pits began.

March 10. 1988 - Remaining known labpacks transported off site. A schedule prioritizing work was developed to be initiated after additional funds were approved.

March 11. 1988 - BES demobilized for the weekend to conserve remaining funds until approval of the $2-million exemption.

IVferch |4. IpgS - An additional $130.000 was allocated to the project by Regional Management, allowing removal activities to continue for seven to ten days. Additional drums were collected, overpacked and staged.

March 15. 1988 - Transformers were inspected and evaluated for PCB content. iVfarch 16, 1988 - Transformers found to contain PCB-contaminated fluid were drained. Building #130, being used for the storage of unknowns, partially collapsed when a 16-inch diameter steel pipe fell through the roof. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 31

Itional drums found on site were collected, overpacked and staged. Preparation for the e and leaking tank cars into ratlcars began.;

Per OSC request, a schedule of Publicker site removal activities was developed by TAT and BES. With only limited funding available, the OSC wanted to be certain that site priorities were addressed in the event additional monies were delayed. BES initiated painting/marking operation to delineate hazards.

March 18. 1988 - BES sampled capacitors for PCB content.

March 21. 1988 .- OSC received notification at 1020 hours of a bomb threat on site that was reported to the PPD on Saturday, 3/19/88. The OSC requested a follow-up report from the PPD commanding officer, Capt. Robert Campbell.

Sampling continued of unknown drums in preparation for ultimate disposal. Emergency destruction of building #118 due to the questionable integrity of the structure was completed. Process line consultant on site to evaluate problem of asbestos wrapping.

March 22. 1988 - CRES Lee on site for RP railcar inventory.

March 23j_1988. - Funding increase of $570,000 received from Region. SlOs Racette and Acker accompanied by sub-contractor NUS assessed site for air and well monitoring for preliminary NPL ranking. PA DER Alien coordinated with SlOs.

March 24^J^jLjfteliminary priority listing was established for waste disposal. Transfer of contents of leaking tank cars into railcar continued. Unstable tank cars were relocated to a more secure area. Sampling of unknown drums continued. BES initiated process line assessment and marking per OSC request.

March 25T 1988 - Survey/assessment of on-site waste pits continued. Transfer of contents of leaking and unstable tank cars into railcar was completed.

March 28. 1988 -.Process line assessment/marking continued with maximum subcontractor effort due to the lengthy turnaround period for analytical results necessary prior to performing actual bulking operations. Section Chief Massey assessed safety procedures during process line assessment/marking. Compatibility samples of unknown drums were collected.

March 29.1988 - OSC Wright in Washington. DC. to meet with EPA H<3/ERD personnel concerning the original $2-mUlion exemption/additional funding request to continue removal operations at the Publicker site.

Fifty-two drum samples were collected and sent to Wastex Labs for analytic at/compatibility testing. A pipeline in close proximity to the EPA command post was discovered to be leaking an unknown product. Valve was resealed without incident and without major product loss.

March 30. 1988 - OSC Wright escorted Assistant Superfund Branch ChiefDennis Carney on a site tour to observe removal activities in progress.

Partial collapse of building #165 occurred. No one was working in the building at the time of collapse(SpeciaI Bulletin *Q'), March 31. 1988 - Per OSC request, consolidation/bulking removal option cost breakdown was prepared in draft form for OSC review. Sampling of wastes continued in preparation for eventual on-site consolidation and bulking.

April _U988 - Buried drums were discovered while subcontractor was performing grading of a drum handling area. Samples were collected (Special Bulletin "S"). Process line assessment/marking continued. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 32

April 4. 19S8 -^X^T performed a geological assessment of the pier area where the buried drums were discovered 4/1/SS. GPR suJrtjtwas conducted to scan for possible buried metals (i.e., drums, cylinders etc.).

Leaking process lines in two separate locations were discovered within 50 feet of the Delaware River.

April S. I98S - A full drum of unknown product was found on top of building #103. Process line disconnection and removal of overhead hazards began inside of gate #2. Unknown containers were discovered by the OSC under the loading dock where the unknown labpacks were previously stored.

April 6. 1988 - Analytical results received for acid solids, transformer oils and unknown drums. Tank #217, believed to contain caustic product, was discovered to be leaking. The tank was plugged and surrounding tanks were also checked for leaks,

April 7. 1988 - Several leaking drums were found, overpacked and restaged. Severe weather conditions hampered work.

April 8^1988 - Sampling of on-site waste streams continued in preparation for eventual consolidation and bulking. As of this date, 199 samples had been sent to Wastex Labs for compatibility analysis.

April 9. 1988 - Process line assessment./marking continued. Work estimated to be 75 percent complete. Fire control personnel conducted an emergency test on pier #106 utilizing foam induction nozzle to determine pressure and effectiveness of foam spray.

Aori! 10, 1988 - Three partially buried cylinders were found by OSC Wright and TAT during a routine site inspection along pier #106. Cylinders were unearthed and staged.

April..! L_198S - Removal of overhead hazards at the end of road #2 continued. Fire watch personnel were on constant standby to wet down process line piping to minimize the potential asbestos hazard to personnel in the area. Fifty samples were seat to Wastex Labs for compatibility analysis. Leaking process line of unknown product near building #163 was discovered and repaired without incident or major spillage.

April 12 J 988 - A cracked flange on an eight-inch process line was repaired. Only a small amount of unknown material leaked from the cracked pipe.

April 13, 1988 - One PECO and four PWD representatives visited the site to gain permission from the OSC to enter gate #8 to view city discharge system.

Results received for samples sent to lab 4/11/88 identified flammable waste stream; 50 additional samples were sent to Wastex Labs for compatibility analysis.

Two additional transformers were found and drained. Resulting oil product was drummed.

April 14«_!.9S8 • Bid was accepted for bulking/consolidation tank repair. The subcontractor selected was MainServ, Inc., of Wilmington, DE. Bid was accepted for the asbestos survey subcontractor. The subcontractor selected was Eastern Environmental Services, Inc. (EESI), of Drums, PA.

On-site test bulking of compatible wastes began.

April 15. 1988 - Process line assessment/marking was completed. Sampling of waste streams continued. Asbestos sampling also continued. Fifty samples sent to Wastex Labs for analysis. Analysis received of 50 unknown waste streams sent 4/13/88. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 33

Removal of overixjid "hazards continued. Roll-off box of crushed unknowns was sampled for full priority pollutant analysis.

April |8. 1988 - MainServ began refurbishing bulk storage tanks; prep iration for bulking of flammables initiated. Samples of 53 unknown waste streams sent to Wastex Labs for analysis. Results of 50 samples which were sent out 4/15/88 were received. Proposal received from Bruga, Inc., outlining their request to dismantle two portions of the Publicker facility. The OSC contacted ORC to set up a meeting.

April lg. 19g8 - Consolidation of flammable liquids began.

4j3rij^gfl^4988. - EESI representatives were on site to determine complete scope of asbestos survey. Roll-off box containing crushed unknown lab pack materials was sent to Fondessey Landfill in Oregon, OH, for disposal.

April 21«_. 1988 - High winds caused damage to cylinder storage building (#164) slowing progress in several work areas. Crews continued to work in areas not near or directly beneath unsafe structures.

OSC requested Section Chief Massey to supervise and direct safety issues involved in the installation of a powerline by PECO,

OSC Powell, ERS Section Chief Caron, CRES Lee, ORC Nishitani, and Publicker legal counsel met at 1000 hours to discuss issues regarding past, present, and future actions at Publicker.

April 22j 1988 - BES performed demolition of frontal structure supports oi: the cylinder staging building (#164) due to the partial collapse as a result of high winds on 4/21/88. Concrete portions of the roof structure of Old Hickory building (#153) were blown off the roof.

April 23. 1988 - Sampling of waste streams continued. Removal of overhead hazards continued. Roadway stone spread throughout the site to fill in roads traveled by equipment and vehicl es to eliminate tire hazards.

April 24. 1988 - Two leaking pipelines were discovered along pier #106 Both leaks of unknown product were contained without incident. Warming temperatures caused previously leaking molasses tanks (#36, #37, and #38) to again start leaking. An alcohol mixture was suspected within the molasses tanks.

Per OSC request, site"maps were continually revised to indicate the location of mobile fire units mat are moved from day to day to accommodate critical areas of work and ensure personnel safety in the event of a fire.

Aorii 25. 1988 - Additional $1,000,000 added to BES ceiling; current obligated BES monies: $3,181,000

BES equipment (welding torches and gauges), located adjacent to the ]JES command post, stolen from the site late Sunday night or early Monday morning.

Bulking/consolidation of flammable liquids continued. Drum and tank analysis of 50 samples that were sent out 4/22/88 were received; 50 additional samples were sent to Wastex Labs, j

OSC Wright met with ORC and Bruga, Inc. (previous purchaser of two portions of the Publicker facility), at 1000 hours at the EPA Regional office.

April 26. 1988 - Section Chief Massey was requested by OSC Wright toevaluate safety issues in regard to the MainServ tank refurbishing operation. Hawthorne, Inc., equipment rental, on site with a 100-foot crane for the placement of the tank bottoms. Approximately 450 gallons of flammable oxidizing solids were bulked.

Dowtherm chemical product leak found in old ethylene hydration tank area (tank #3C2030). The leak was the result of warming temperatures. Lines previously designated empty may have to be reassessed. Two lines near Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 34 the Dowmernt tefljLlmre- also found to be leaking #6 oil product. These lines were previously assessed to be empty during col April 27. 198S - Consultant for PRP Publicker Industries (Hart Environmental Management) reviewed POLREPS, analytical results, and site safety plan and procedures. Estimates of total wastes were also made available to Hart.

MainServ continued tank repair operation. EESI asbestos assessment continued. Bulking/consolidation of base-neutral liquids; approximately 1,000 gallons bulked. Vapors were noticed emanating from tank #38, containing alcohol/molasses product; OVA readings were up to 9 ppm. The area was sectioned off.

Analysis of 50 samples sent 4/25/88 were received; 52 additional samples sent to Wastex Labs.

April 28. 1988 - MainServ completed refurbishing of tank #190; 36 drums of organic liquids were bulked.

April 29. 1988 - PWC and PECO worked on their utilities within gate #8. BBS vacuum tanker was moved to pier #106 area to prepareTor the pumping of process lines.

Results were received of 50 samples sent 4/27/88; 54 additional samples sent to Wastex Labs for compatibility analysis.

Mav 1. 1988 - PWD representative periodically collected water samples from discharge outlet within gate #8. BES performed inventory of remaining drums to prepare for the proper bulking order of waste streams.

May 2. 1988 - OSC Wright met with CRES Lee, Ecrecon Pat Halligan, and Bruga Clem Simone in regard to previously purchased Publicker Site property.

Bulking/consolidation of waste streams continued. Analysis of 56 samples, two sent 4/27/88 and 54 sent 4/29/88, received; PCB contamination indicated in sample collected from pipeline on pier #106. An additional 50 samples were sent to Wastex Labs.

May 3. 1988 - EPA Remedial Racette and Acker, and NUS consultants met at 0900 hours with OSC Wright concerning future remedial investigative work.

OSC met with the Director of Operations for the Philadelphia Port Corporation and the Philadelphia Industrial Development Corporation concerning future access to Publicker through gate #8 (Packer Avenue extension).

EESI completed asbestos survey/assessment. Transfer of oxidizing liquids into refurbished tank #190 began; approximately 4,000 gallons were transferred this date.

Mav 4. 1988 - Results were received from samples sent 5/2/88. Sampling of waste streams continued; 52 samples sent to Wastex for oompttibility analysis. PA DER sampled three shallow wells and adjacent soil.

Draining/cutting of process lines continued. Shearing of overhead hazards on road #1 completed. PCB transformer was removed from building #163.

5T J[988 - Preparation for the neutralization of acids was performed. Sampling of waste streams continued. Due to heavy rains and lightning, work activities were discontinued at 1530 hours as a safety consideration.

Mar 6. 1988 - Sampling for full EPA priority pollutant analysis of waste streams before bulking was initiated in association with proper QA/QC and documentation. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 35

Mav 7. 1988 - BffiBISt of organic liquids from tank #ST-003 into refurbished tank #190 continued. An estimated total of 21,500ga^^5cpnsolidated to date. PCB oil from transformer TR-015 was drained into drums. Overhead hazards near buildmg"Jl73 at gate #8 were eliminated.

Mav 9. 1988 - OSC expressed concern for worker safety and instructed .that level "C" and level "B" work would be monitored for heat stress due to increased temperatures. _ TAT performed air monitoring to determine the levels of styrene emissions from nearby Ashland Chemical Company.

Results were received for 49 waste stream samples sent 5/4/88; 50 additional samples sent to Wastex.

Cutting of oil line on pier #106 was drained. This line had been previously drained empty which indicates this line was recharging. It was noted that bricks and cinder blocks had fallen off building along the right side of road #2 near .the pier #105 bumped section.

May IQ^lijSj - Preparation for the neutralization of acids on site continued. MainServ completed tank repair operations; a liner was placed in tank #189 for caustic waste, while tanks ^185 and #186 were not lined.

City of Philadelphia structural engineer evaluated building structures. Recommendation was that further evaluation was needed and that the sign on top of the Old Hickory building may have to be removed.

Mav 11. 1988 - SIOs Paul Racette and Ben Mykijewycz observed remedial well operations. Section Chief Massey conducted a pre-safety meeting for Remedial Program personnel who would conduct site investigative activities involving well purging and sampling. NUS continued investigative site work.

During bulking operations, a 2,000-gaUon_bulking tank had a chemical reaction as organic liquids were being consolidated. Draining of cutting" oil tine'on pier #106 completed.

May 12, 1988 - CRES _Lee met on site_with Ecrecon sjnd. Bruga representatives to discuss liability concerns of the EPA/OSC in reference to any private contractor working on site while a CERCLA/SARA removal was in progress.

May 13. 1988 - TAT sampled waste streams for full EP_A, priority pollutant analysis before bulking continued in association with proper QA/QC and documentation. An estimated total of 63,500 gallons of organic liquids consolidated into tank #190 to date.

May 14. 1988 - OSC Wright authorized BES to begin cutting and welding operations in preparation for acid neutralization in area where previous remote opening' operation was performed.

May 15. 1988 - TAT 'discovered three partially buried cylinders in the brush adjacent to pier #106. A further search of the area uncovered a total of 17 cylinders. TAT also noticed a leaking j line previously marked as empty behind building #162.

Mav 16. 1988 - Caustic liquids were drained from tanks #148 and #149 and bulked into 13 poly acid drums.

OSC and TAT discovered two more leaking tanks. Due to warm temperatures and additional walk through assessments, the discovery of additional leaking tanks and lines had been anticipated.

Drums from bulking operations were crushed and staged in bermed area near road #7.

MavJl7L1988 - Bulking operation was suspended due to rain. Hydrostatic testing of tank #189 was conducted to determine tank integrity. EPA Regional personnel toured site to expand knowledge of hazardous waste cleanup operations. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 36 EPA/CLP cooiirnsq i»eir assistance in the QA aspect of high-hazard sample analytical (priority pollutant scan). The OSC was infcrmeiljliiCLP could not handle the high volume of samples for analytical, but would lend assistance in the data review^SSc! technical assistance to a subcontracted lab. All appropriate EPA reference materials stating proper analytical procedures and deliverables will be forwarded to subcontracted lab to ensure quality of the product.

May 18^!9S8 - Bulking operation was suspended due to rain. Crushing continued of drums emptied during bulking operation continued. Video and photodocumentation by TAT and BES continued.

MayJi9L1988 - Due to inclement weather (heavy rains), work was suspended for the day. General maintenance and housekeeping tasks were performed until 1000 hours.

Mar 20. 1988 - Alcohol line along road #4 was drained and 34 drums of oxidizing liquids were bulked. Line draining continued with the removal of 2,000 gallons of cutting oil and three 55-galIon drums of glycol contaminated with PCB'S. Hydrostatic testing of tank #189 was completed and transfer of water into tank #185 began.

May 23.1988 - Leaking glvcol line adjacent to tank #186 was discovered. Leaking line of #6 oil from pipeline on pier #103 was attributed to increasing temperatures and expanding pipes. Subcontracted structural engineer (Lippincott Engineering Associates) performed a preliminary assessment of building structures.

May 24J.983 - CRES Lee met with Ecrecon and Bruga representatives on site concerning purchased site equipment.

Special Bulletin "X" sent expressing temperature/heat related concerns. A BES employee broke foot, which represents the first and only worker accident to date.

Line draining continued.

May 25T1988 - OSC contacted EPA Contracts for advice and guidance concerning the repair of radios broken during working operations on site.

Acid neutralization equipment preparation continued. Line sampling of glycol product for compatibility analysis was performed, Approximately 1,500 gallons of flammable liquids were transferred into bulking chamber. Flammable oxidizing solids from 23 drums were consolidated into 12 drums. TAT sampled flammable oxidizing liquid waste stream for priority pollutant analysis.

M9JL3jLJl?SS - Acid neutralization equipment preparation completed. Hydrostatic testing of acid neutralization chamber and trial run of acid neutralization operation were successful. Hydrostatic testing of tank #185 completed. Transfer of water into tank #186 began. Mercury compounds" were secured in proper containers. Radioactive materials also placed in proper containment for later shipment and disposal.

May 27. 1988 - Consolidation of flammable solids continued.

May 31. 19S8 - Lippincott Engineering Associates continued assessment of buildings and structures. Assessment of glycol lines to determine quantity of product continued. Due to extremely high • temperatures, work was suspended by the OSC at 1500 hours.

June 1. 1988 - Hydrostatic testing of tank #186 completed. All four consolidation tanks were successfully tested. Sampling for compatibility analysis for drums, tanks and lines completed. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 37

PFD personnel tou^pfufalicker facility and observed cleanup operations. OSC received asbestos survey results from EESI. OSC soii^tt^ advice and guidance from Section Chief Massey and ERT concerning findings and

June 2. 1988 - Acid neutralization process began to detect possible acid vapors; wind speed, wind direction, and ambient temperature were monitored every 15 minutes. The USCGi PMDO, and PFM were notified of operations.

Construction of a pavilion for shading work crews during breaks, lunch, and cool down periods began. This structure was designed to aid in reducing the possibility of heat stress.

June 4. 1988 - Removal of overhead hazards and stairs around bulking/consolidation tanks # 185, # 186, # 189 and # 190 continued. Pavilion structure was completed. Medical monitoring continued.

JuneJS?^1988 - PFD conducted a hazardous spill scenario under the Walt Whitman Bridge on Delaware Avenue.

JuneJi. 1988 - Three sump pump pits and two tanks were sampled. Samples were shipped to Wastex Labs for analysis. _

.Tune 7. 1988 - OSC received notification from Regional Management of itn additional $1,000,000 for BES. Section Chief Massey reviewed asbestos report prepared by EESI per OSC request.

Bulking/consolidation of organic liquids continued. Reassessment of drum staging area was performed to ensure all organic liquids were consolidated.

June_S. 1988 - EPA personnel (including Regional Administrator Jamis Seif) visited site to observe operational procedures and protocol at this Superfund removal project.

Acid neutralization pumping transfer lines replaced because of deterioration due to highly concentrated acids. Assessment and evaluation of tank #T-002 (containing acetaldehyde) was performed. Additional analytical will be gathered on this waste stream prior to handling and acid neutralization.

June 9. 1988 - Due to heavy rains and lightning, site activities suspended per OSC concern for worker safety,

June 10. 1988 - CRES efforts in regard to Consent Orders to RP were not successful up to this point in time. EPA elements investigated other enforcement options for the transport and disposal of consolidated Publicker wastes.

Wastex Labs picked up 39 samples for priority pollutant analysis. Bulking of base-neutral liquids began.

June 13. 1988 _ An emergency incident involving possible acetaldehyde exposure to two BES personnel in level "B" protection occurred at 1100 hours during sampling. Personnel were taken to the Hahnemann Hospital emergency room where they were treated for respiratory difficulties and released.

Due to extreme temperatures, heat stress conditions, and related safety concerns, work was suspended at 1600 hours. Early work schedule (0500 hours) start time continued.

June_14«. 1988 - FAS Henry and. two EPA finance personnel checked costtracking and site files.

Leaking line on road #2 was discovered; leak appeared to be No. 6 fuel oil.

OSC consulted with ERT concerning the findings and recommendations of EESI asbestos survey. OSC continued to seek advice and guidance from ERT concerning the asbestos issue. &RI4Q0250 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 38 ta--,- personnel reviewed cost tracking procedures used on this removal project.

June 16. 1988 - B7X personnel observed operational procedures and protocol at this Superfund removal project

June 17. 1988 - CRES and ORC were contacted bv OSC concerning the full glycol lines. OSC-sought advice and guidance on 'whether to address the draining of these lines or to leave them intact for later draining by the private party who claimed to have previously purchased the product.

Drum on top of building #102 was sampled. Acid neutralization operation was completed. Bulking/ consolidation of base-neutral liquids was completed. Cylinders were identified for disposal.

June IS. 19S8 - Asbestos piles and deposits were covered. Flammable oxidizing solids were sampled.

June 20. 1988 - Covering of asbestos deposits continued.

Jiffljg-21j_198S - ERT and ERT/REAC personnel addressed asbestos issue and conducted air monitoring/sampling. Samples were turned over to BES for delivery to lab for analysis. Bulking/consolidation of oxidizing liquids continued. BES continued draining flammable oxidizing liquids into 55-gallon drums for transport and disposal.

June 22. 1988 - CRES Lee spoke with OSC concerning equipment previously purchased by Ecrecon and Bruga and their operations and safety plans for future work action.

OSC spoke with ORC this date concerning "ethylene glycol" products on site. OSC sought advice and guidance from ORC as a private party had made claim to this product in the tanks and process lines.

OSC notified CRES and ORC that the "glycol" was potentially contaminated, given previous analytical results (low PCB levels detected in one line). ORC informed OSC that the private party continues with the claim of ownership. Given this fact, the "glycol" would not be addressed (tank and/or line draining and consolidation) during this phase of operations on site.

Site sweep/search began at approximately 0730 hours and several chemical containers and one drum were discovered during searcb; area south of Packer Avenue 95 percent completed.

Junc.23i_19.88 - EPA HQ personnel met with OSC Price. Removal actions and work efforts were explained during a tour of the Publicker facility.

Draining of alcohol process lines continued. Road barriers were mobilized to the site to close off road adjacent to gate #8.

June 24. 1988 - CRES Lee and ORC Nisfaitani met with OSC and AAA/Linfield (alleged previous "glycol" product owner) to discuss and identify lines and tanks that AAA/Linfield claimed to own. Overhead pipelines were wrapped to abate potential for airborne asbestos. Unknown lab containers found during site sweep were labpacked. Base- neutral solids were completely consolidated.

Jifi|fi_27f,.ljj§8 - Wetting down/covering of suspected asbestos deposits was completed. Overhead pipelines and piles were wrapped and covered to minimize the potential for airborne asbestos. Any further covering would be performed on an "as needed" basis. Acid neutralization equipment was broken down and decontaminated.

PA DER representatives met with OSC Price to discuss past water sampling results from the monitoring wells.

June 28. 1988 - Preparation for the treatment of contaminated spent grain underway.

fl-RU0025l Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 39 June 29.1988 - R^joggultant (Hart Environmental) on site. CRES Lee authorized RP agent to receive copies of any and all POLREP*

June 30. 1988 - Cleanup crew continued to collect containers and drums identified by site sweep crew.

July 1. 1988 - OSC spoke with ERD Van Roden concerning the potential future funding needed for the transport and disposal of consolidated waste streams.

Thirteen samples were collected from pierJ'lOS's bumped-out buildings fcr PCB analysis. Draft scope of work plan for remaining cleanup activities was prepared by BES and submitted to OSC for review.

July 6^198j - Seventy 55-gaIlon drums containing flammable liquids we -e loaded and transported for incineration at the SCA facility, Chicago, IL.

.Tulv 7. 1988 - At approximately midnight (7/6/88), fire watch personnel reported a small fire outside gate #13 caused by a downed electrical cable. The fire was contained and the area was seared by fire watch personnel until PPD and PFD personnel arrived on scene,

Site survey/ground sweep was completed. Work crew continued to collect materials identified during site sweep. Preparation of spent grain treatment area continued. A sand pad lined with visqueen was being constructed in the spent grain area between roads #5 and #6. A berm was constructed around the pad for containment OSC contacted ERT for advice, guidance and recommendations concerning the acetaldehyde and asbestos issues.

Preliminary analytical results on No. 6 oil samples were received. Many of the results identified the presence of pesticides and levels and types of volatile organic compounds typical of No. 6 oil.

.Tjuly 8^198g - Draining of alcohol/flammable liquid lines continued. Acetaldehyde tanks sampled and field tested for flammability, pH, and LEL. A roll-off box was set up on pier #105 for consolidation of unknowns through second remote crushing operation.

July 9. 1988 - Bulking of flammable oxidizing solids and flammable solids underway.

July 10. 1988 - Spent grain treatment continued. Estimating total volume was difficult to determine on a daily basis.

July 11. 1988 - PDM representative was on site and was briefed by OSC on current site operations. OSC met with USCG G. Crot to discuss on-site oil spill problems and the possible use of CWA 311 (k) funds to address oil spills and unsecured oil storage vessels on site. OSC felt this was appropriate due to the nearness and potential impact on the Delaware River, a major navigable waterway of the United States.

Remote opening/crushing of unknowns began. No observable reactions took place during the operation. Work crew completed collecting materials identified during site sweep for handling as unknowns. Sampling of 13 drains and pits located throughout the site completed by BES. Samples would be analyzed for PCBs and flammability.

July 12,1988 - Preparation of acetaldefavde treatment area completed. All lines emanating from tanks #001 and #002 were disconnected and vented.

OSC was contacted by Assistant Superfund Branch Chief Dennis Carney concerning bulk oils. He concurred with the actions proposed by the OSC in Special Bulletin "CC." The contaminated oil would be removed from the structurally unsound storage vessels, bulked into compatible waste types, and secured on site. If any flammable materials were discovered, they would be handled and disposed of during this phase of operations. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 40 ._.»^fc ERT R. Turpu^j^ jjfrtghvi, and T. Pritchett were on site to provide advice and guidance on the acetaldehyde treatment proceag fUr OSC request, ERT/REAC C. Burchette was on site to further assess the asbestos situation. OSC sought advfsT guidance a^ recommendations in keeping with current EPA policy concerning asbestos.

ORC informed OSC that they had received the Publicker structural engineering report and would pursue this matter further with City of Philadelphia Officials.

July 14. 1988 - Remote crushing of unknowns was completed: approximately 1.498 containers crushed for a total of 3,092. Removal activity status submitted to OSC by BES. The report also documented additional or continued work that was necessary to abate future hazards to human health and the environment.

July IS. 1988 - At 1230 hours, OSC Wright and OSC Price met with CRES M. Letzkus and W. Lee, ORC B. Nishitani, PFM H. Cusick and J. McAleer, PMDO J. Hadalski, and Bruga representatives concerning Bruga's pending work on site, through the issuance of a 106 (Consent) Order.

Acetaldehyde treatment process proposed as follows:

1) Acetaldehyde would be diluted by 10 times original volume with solution of ferrous sulfate and water. 2) Treatment process would take place in one tank at a time. 3) Inside of tank would be sprayed down in order to neutralize any potentially explosive residues on the sides of the tank. 4) Diluted material would remain in the tank for approximately seven days in order to neutralize all potentially explosive materials. 5) After treatment, material would be sampled; disposal or further treatment options would be explored.

The OSC concurred with recommendations and directed treatment to begin this date.

OSC contacted ERD Van Roden concerning bulk oil issue per Special Bulletin 'CC." ERD concurred with actions proposed by OSC; however, OSC to check "Petroleum Exclusion Clause" which would enable a clearer distinction to be made between CERCLA and CWA 311 issues. • ERT R. Turpin and P. Campagca and ERT/REAC C, Burchette contacted OSC with recommendations concerning the asbestos issues on site based on current EPA policy from EPA HQ (January 1988). The recommendattoos were is follows:

1) Asbestos droppings and piles - bag materials and store on site. 2) Aa^cctos on floors in buildings - secure buildings and post warning signs. 3) Piping and process lines - do not address as no air releases documented to date.

July 16. 1988 - PGW crew on site to disconnect and render "abandoned" the gas line servicing the Publicker site.

July 18. 1988 - Large utility pole located within gate #2 snapped at its base during thunderstorm at 2000 hours the night of 7/17/88, Acetaldehyde treatment completed; four samples were collected for analysis. After seven-day holding period was completed, further treatment or disposal options would be explored. Asbestos droppings and piles were bagged and staged in building #168. July 19. 1988 - Six drums of PCB-contaminated waste were transported for disposal at the APTUS facility, Coffeyville, KS. Line draining and disconnection of overhead process lines continued. Treatment of spent grain continued. flRU00253 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 41

July 20. 1988 - EP^Ejadiation specialist Bill Belanger informed OSC thaithe NRC did not require a license to ship the quantify1 of low-level radioactives that were on site.

Philadelphia Hazardous Air Pollution Unit Wynne Hill on site to discuss asbestos1 removal in the Bruga work zones. OSC requested that Ms. Hill contact CRES Lee concerning this issue.

JJily_J3L1988 - An oil sheen being discharged from the city sewer outflow was observed by OSC between piers #103 and #104. USCG and City Sewer Department were notified.

JJtdY_24.JI988 - Drainage of process lines continued to yield unknown product.

July 26. 1988 - Delaware River Port Authority representative on site for in update on site activities.

TAT sampled the separate product layers in drains #8 and #9 along road #2. Samples would be tested for flashpoint and compatibility.

Iuly_27, J£8S - Several containment areas on site were_ discovered to be flooded with excess rain and tidal waters. In some of these areas, several sump pits which contained oil were washed out oil was and spread over a larger area outside sump or pit containment.

July. 38. 1988 - USCG on site to meet with OSC concerning current sitstatue s and future plans for addressing on site oil products and ground contamination.

Treatment of spent grain suspended until final pipeline assembly was finalized for the transfer of the waste product to the neutralization area.

- Drainage of process lines continued.

August 1^ 1988 - At approximately 1325 hours, an oil sheen was observed between piers #108 and #109. OSC Price notified the USCG and Industrial Waste of the situation. No action was taken by either party.

Updated fire equipment location map was completed and posted in all offics locations.

August 3. 1988 - Treatment of spent grain resumed.

August 4f_198_8 - Process line disconnection between EPA area and Ecrecon area on road #6 underway.

Au2u$t 5. 1988 - BES and TAT identified major asbestos areas (on basis ofprevious survey) for bagging operation. jScope of work was. .drafted. Recovery of plastic drums from dumptrailer #T-075 was completed. All oil- contaminated drums were wrapped in plastic sheets and staged in poly drum staging area located on road #7. Draft additional funding request was sent to HQ/ERD for review and comment.

August 6. 1988 - Treatment of spent grain continued: approximately 28,OJOO gallons treated to date. Base-neutral solids bulking continued.

August 9. 198S - OSCs Wright and Price met with CRES, Bruga representatives, and City officials at 1000 hours. On-site contingency plans, safety concerns and modifications to existing city contingency plans were discussed.

Bulking operation continued.

August 10, 1988 - PWD Joe Cerrone tested three fire hydrants at the southend of the facility. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 42 Analytical data jfe&ialdefayde treatment analytical and priority pollutant received by BES. Building #148 to be prepared for stofljggjftfeated spent grain. August 13. 19SS - Draining/venting of process lines continued.

August 12, TJgSS - Treatment of spent grain continued; approximately 50 percent completed.

August 15. 1988 - Final draft of additional funding document transmitted to HQ/ERD.

August 16. 1988 - OSC hand delivered Special Bulletin "FF" and CWA 311 oil issue documents to USCG office in Philadelphia,

Spent grain treatment continued. Progress was slow as product became more difficult to pump. Sample collected from roll-off box of consolidated crushed unknowns for analysis for waste disposal options.

AAA Eugene Osterrich on site with five associates to check several stainless steel tanks they had previously purchased from the RP.

August 17. 1988 - OSC submitted revised final draft of funding document to HQ/ERD for comment and review.

August 18. 1988 - Line draining continued. Line disconnection between EPA and Bruga areas continued.

August 19. 1988 - OSC was notified that additional funding was obligated to BES this date ($2,000,000), raising obligated BES monies to $6,181,000. Additional funding document was submitted into chain of concurrence.

T .IgSS - Cylinder opening area preparation began.

August 23, 19S8 - Ecrecon and Bruga personnel on site to remove previously purchased equipment; removed 15,000-gallon fiberglass tank from along road #2. CRES Lee on site to observe work activities.

U.S. Congressman Florio's office (NJ) called the command post. OSC directed Congressman's representative to Regional Management for answers to site activity questions.

August 24f |g8jj - Spent grain treatment process continued. Treated product was transferred into building #148 for permanent staging. Dowtherm product leak discovered and contained.

August 26. 1988 - Asbestos piles and debris previously covered with poly were inspected and recovered as needed.

Additional funding request resubmitted to Regional Management this date. The OSC proposed two options in the funding request: 1) T&D to be performed as soon as possible due to the physical condition of the site and the associated high threat of potential release, and 2) maintain fire watch and site security in order to retain EPA control over the site until such time that funding (either removal or remedial) could be obligated to continue removal activities. Regional Management explained to the OSC that due to current financial constraints they would prefer that T&D be performed through Remedial Program and its monies perform the T&D.

Regional Management expected the site to be finalized on the NPL in December 1988 and activities to begin again three, months hence.

BES presented disposal and handling options for contaminated oil to the OSC. August 31 . 1988 - Five drums containing mercury compounds were transported for recycling to Mercury Refining, Albany, NY. Specially Gas consultant (Carmelo Vasi) on site for compressed cylinder identification, information was relayed to OSC concerning possible ownership contacts for disposal. ftRlt00255 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 43

OSC contacted PJjyjf elphia Health Department concerning syringe found washed up from the Delaware River along pier #106.

September 1. 1988 • AIRCO Cylinder removed six compressed gas cylinders identified as their property.

September 2. 1988 - Spent grain treatment process completed. All treated grain product was transferred to staging area. Air monitoring of product continued.

Septemrjgr'JkJlgSJi - Survey of Ecrecon/Bruga area verified line disconnection was completed. ARC Gas Supply picked up one cylinder identified as their property.

September 7-tili)88 - Remaining drums relocated to drum staging area. M.G. Industries removed three cylinders from the site.

SepJegTjbei:Jla^l988 - Contaminated oils would be staged in the separation tank prior to bulking operations to extract uncontaminated water. BBS conducted demonstration of high-pressure laser draining of contaminated oil.

September JtOf 1988 - Contaminated oil lines were sampled to aid in assessment prior to bulking/consolidation. September 12. 1988 - Draining of contaminated oil from tanks and lines .-ontinued.

September 13. 1988 - OSC met with L&I, PFD, and PMDO representatives, and with Philadelphia Port Corporation representatives C. Trovato and D. Damfaly concerning access issues to the Port-owned refrigeration area. Access was needed through Packer Avenue. Philadelphia Port informed the OSC and City officials that a guard would be posted on Packer Avenue in order to control traffic and access.

Treated acetaldehyde product (approximately 5,000 gallons) was pumped into tanker for transport and disposal to the Chemical Waste Management, Inc. (Chem Waste), disposal facility in Newark, NJ.

&AE.—•————*.Septariber 14.— 198 — 8 - SIO-_s .. Kh.o and Nard. - i received a tour of site operationsf | . FASs Henrjy and Messimer reviewed RCMS program and site files. Remaining treated acetaldehyde product (approximately 5,000 gallons) pumped into tanker for second and final transport for disposal to Chem Waste in _Newar^, NJ. PCB wastes consolidated into one E-size drum in preparation for transport and disposal.

September 15. 1988 - Preparation for small-volume acid neutralization in bulking area began and was completed.

September 16, 1988 - Flammable liquids (39 55-gaIIon drums) transported for disposal by Envirosure, Inc.

September 21t 19ffi - Assistant Branch Chief Carnev contacted OSC concerning availability of additional funds to determine if funding could be obligated within the current BES ceiling.

Radioactive material (uranyl nitrate) transported by Radiac, Inc., for ultimate disposal by U.S. Ecology, State of Washington. No. 6 oil sampling completed to determine extent of contamination in process lines.

September 22. 1988 - OSC contacted ERT Turpin concerning asbestos scope of work abatement safety issues. BRT concurred with OSC recommended safety procedures during asbestos abatement operations.

September 23. 1988 - EPA/HQ Contracting Officers Ron Wiley, Rodney Cartwright and Jim Clark and FAS Rich Messimer reviewed site operations and RCMS program. City Air Management Officers Ed O'Neil and Wes Bickell visited the site.

Acid neutralization began as sufficient volumes had been accumulated and bulked. Bulking/consolidation of site wastes continued. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 44

Line draining and assessment continued. Mercury halogen compounds were labeled and packed for TJJJpJBB-neutral liquids continued to be transferred from tank #238 into tank #185. September 27. 19SS - CRES Lee met with OSC to discuss analytical results on contaminated oil pesticide screens. A total of 4,000 gallons of flammable liquids were loaded into vacuum tanker for T&D to Frontier Chemical Co., Niagara Falls, NY. Final tank assessment was initiated.

BES began to prepare pier #106 for the No. 6 oil holding tank and staging area and began bagging of all iised/contaminated personal protective clothing for T&D.

September 28. 1988 - Two unauthorized people caught loading scrap metal from building #171. Sampling of No. 6 oil lines completed. Priority pollutant sampling conducted for tank #T-016.

September 29. 19S8 - Line draining/venting, /disconnection continued.

September 30. 1988 - Additional $400,000 was obligated to BES ceiling. As stated previously, these funds (inaccurately quoted" as $300,000) became available within the Region's Removal Program and the additional funding was available for obligation from not previously obligated BES contingency funding (funding request approved 4/8/88). New BES ceiling -56,58 1,000.

October 4. 1988 - Preparation of pier #106 for No. 6 oil holding tank and staging area continued. Tank being modified for oil/water separation.

L 1988 - Final tank assessment completed. Line venting/draining/disconnection completed. Recovery of hazardous materials from on-site process lines discontinued, completing this phase of operations.

Asbestos air monitoring performed.

October 7. 1988 - Bulking/consolidation of waste streams completed.

October 10. 1988 - BES replaced damaged fence across pier #101 to restrict site access. Crushing of empty drums from bulking operation completed.

October 11. 1988 - OSC English assisted OSC Price with cleanup efforts. Draft additional funding request for continuation of 24-hour site security and fire watch submitted to Regional Management and HQ/ERD.

Transporter on site to remove three 5-gaIlon fiber drums containing mercury compounds and 13 30-gallon fiber drums containing flammable solids to Thermal-KEM, Inc., Rock Hill, SC, for disposal. Transporter on site to haul away one trailer containing 30 cubic yards of used protective clothing to be transported to Envirosafe Services of Ohio, Inc., Oregoff, OH, for disposal.

Drums being rearranged in drum staging area to make use of extra space created during recent bulking operations.

October 12^1988 - Set up of heating unit (furnace/boiler) for use in heating/separation of contaminated oil underway. Enclosure of ground floor of building #171 was initiated by BES. October ;pLJ9$3j - Second load of spent protective clothing shipped for disposal to Envirosafe.

October 14. J98J? - OSC Wright relinquished OSC responsibilities concerning the Publicker Industries site to OSC Price.

Preparation for contaminated oil operation on pier #106 completed. Installation phase of heating/ separation unit completed- ARU00257 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 45

October 18. 19Jjjpp?,&SrHenrv on site to assist in finalizing contractor awaiting bills.

Tank #238 prepare^ for pumping of contaminated oil. Third load of contaminated used personal protective clothing picked up for disposal at Envirosafe.

October 19. 1988 - The oil/water separator unit was put into service on pier #106 for 24-hour operation with contaminated oil. A small BES crew would monitor the operation 24 hours a day to ensure safety and productivity of steam heater/oil separator unit.

OSC Price received comments~bn draft additional funding document fron; Regional Management.

October 20. 1988 - Fourth trailer loaded with spent protective clothing for disposal at Envirosafe. Trailer #T-075 containing waste oil and various debris was drained into oil/water separation tank. Thirty-four drums of acid solids loaded for T&D at Chem Waste, Emelle, AL.

October 21. 1988 - USCG on site to meet with CRES, Ecrecon, and Bruga representatives

A spill occurred during oil transfer from tank #238. Release valve on skid-mounted transfer tank broke, causing a spill at the east end of road #4.

24.«_1988 - Asbestos abatement operation continued with the enclosure of buildings. October 25« 1988 - Fifth and sixth trailers loaded with spent protective clothing for T&D at Envirosafe.

October 26. 1988 - Contents of tank #T-075 transferred into poly drums and placed in the drum staging area.

October 27. 1988 - Enclosure operation of building #171 completed. •

OSC Price spoke with Assistant Supertund Branch Chief Camey concerning contaminated water associated with 'the contaminated oil operation. The OSC recommended that T&D for | the contaminated water be handled during this phase of operations. Assistant Branch Chief Camey concurred with the OSC's recommendation.

October 28. 1988 - OSC Price contacted ORC Nishitani concerning scheduled railcar removal on 10/29/88 and 10/30/88 by AAA under the direction of CRES. ORC Nishitani advised that removal would not occur those dates. Glycol samples picked up for AAA.

October 31. 1988 - CRES Lee on site to discuss issues with OSC Price and Ecrecon and Bruga representatives concerning previously purchased property. Ecrecon subcontractor also on site to begin asbestos removal operation of ethylene area on pier #108.

Cleaning, marking and staging of drums on road #5 from #TC-008 and trailer #T-075 complete.

November..!* 1988"- Site activities suspended at 1200 hours due to heavy rains. Contaminated oil operation, pier #106, steam heater and water separator operation discontinued (Special Bulletin "MM"). Final three of PCB- • contaminated materials transported for disposal at the APTUS facility.

November 2. 1988 - Regional and HQ finance personnel were on site to be briefed by the OSC on removal activities.

Enclosure operation of Old Hickory building #153 commenced as asbestos abatement continued.

November 3. 1988 - Consolidation of 19 flammable liquid drums into 15 drums accomplished. BES sampled and labeled the drums in preparation for T&D. \

Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 46

November 7. IS^y Freparatioa for asbestos abatement operation began in buildings #172 and #173. Roll-off box containing matociitf jffSin laboratory container remote opening operation transported for disposal to Emelle, AL. Due to extreme wetgdToTme box, 14 drums were filled with excess material from the roll-off box to alleviate the excess weight problem. Drums scheduled to be transported to Emelle on 11/08/88. Due to unauthorized entries being made at the south end of the site, OSC directed BES to repair/restore the fence. BBS personnel utilized existing fencing to make these repairs.

^988 - EPA HQ Joan Woods'perfbnned photodocumentation of site activities. The 14 poly drums from the roll-off box were transported to Emelle as scheduled.

Noyember9. 1988 - PFD personnel on site to be briefed on removal activities.

NQTerober 10. 1988 - One BES storage trailer was demobilized from the site. Enclosure of buildings #172 and #173 completed as part of the asbestos abatement operation.

Noysnbcr 14. 1988 - BES continued mending holes and stringing barbed wire on the fences due to prior unauthorized entries made onto the site. Asbestos Abatement Corporation (AAC) began limited asbestos abatement/cleanup.

November 16. 1988 - Ambient asbestos air monitoring performed by BES; samples sent to EMSL, NJ, for analysis.

November 17. 1988 - High winds blew open several upper floor windows in building #171, enclosed as part of the asbestos abatement operation. BES personnel resecured the windows.

November 21 . 1988 - One-year exemption request signed by the Regional Administrator. Copies of the exemption request were forwarded to EPA HQ.

AAC continued site asbestos abatement operations while building enclosure operation continued.

November 22. 1988 - Fourteen drums of flammable liquids were transported to Frontier Chemical, Niagara Falls, NY, for disposal.

OSC directed BES 'to inventory all field purchases and subcontractor equipment (Special Bulletin "NN").

November 23, 198S - PFD Chief Janda. L&I T.W. Patterson. and Police Lt. Sidaraswere briefed on site activities and access control problems with building #171. TAT performed ' a site sweep to inspect asbestos cleanup by AAC. Several areas remained to be addressed under the current scope of work. Noytmber.28. 19SS • CRES Lee, TAT, and representatives of Triple C and AAA inspected railcar tankers and previously purchased glycol product. Ecrecon continued asbestos removal operation in the ethylene area on pier #108. BES decommissioned 15 compressed gas cylinders. All cylinders were subsequently marked "vented 1 1/28/8S" and were placed into building #152 with the empty fire extinguishers.

Noyenber 29. 1988 - TAT contacted Insta-Foam Products. Inc., concerning return shipment of Part "B" Froth Pak component, and DOT Regulatory office to verify shipment could be made by ground transportation.

November 30, 19S8 - L&I Inspector Daniel Sourer on site. Pier areas #104 and #105 and road #2 asbestos-wrapped pipes were covered with visqueen to aid in abatement work.

PecembeiLJ . 1988 - AAC completed scope of work and cleaned up areas which were previously overlooked.

2. !£88 - Asbestos abatement and building enclosure operations continued. Publicker Industries NPL Site Federal, On-Scene Coordinator's Report ^^ Page 47

Decanter 5r 198&|J?AS Messimer reviewed site file. Five new concrete barriers were added to the site entrance to enhance seeurjSJ|Jlp?asures. General site maintenance continued in preparation for demobilization operations. A detailed map ofttrums in the drum staging area was prepared by BES per OSC request.

December 6. 1988 - All four bulk storage tanks (#185. #186. #189. and #190) were reinspected; no indications of leaks were observed.

Snow fence was installed between the concrete barriers near Packer Avenue to control unauthorized vehicle entry and exit.

December 7. 1988 - CRES Kho and Triple C representatives inspected railcar tankers prior to removal. New locks installed on all site gates to control site access.

Pecem])ier 8, JL9S8 - Return shipment of urethane "B" component, resin, compressed gas N.O.S., non-flammable gas UN 1956 via Federal Express to Insta-Foam Products, Inc., Joliet, IL, for disposal. December 9. 1988 - PFD McAleer met with OSC Price. Ecrecon continued asbestos removal of ethylene area on pier #108.

Through coordination with CRES Lee, Triple C employees removed seven railcars. However, due to legal issues outside of the realm of EPA, the five stainless steel tanks remained on site.

OSC Price instructed BES on the remaining cleanup activities and site stabil zation efforts required before demobilization could be implemented.

De£gnbe!vl2. 1988 - BES began installing snow fence along the closed portion of Delaware Avenue to further deter any future trespassers from entering the site. Demobilization of site files and equipment was initiated. December 13. 1988 - BES began installing site security/warning signs.

December 14. 1988 - BES completed installing site security/warning signs. One 60-foot manlift was demobilized by equipment services. All building doorways were secured with plywood. All issues specified by OSC Price to be addressed were completed with exception of the fuel area scheduled to be cleaned up 12/15/88. All wooden barriers were in place to establish "level D" road on site.

J)ecember_15. 1988 - BES continued remaining cleanup activities and site stabilization efforts. Additional asbestos warning signs were posted.

DecembenJL6f ^988— A detailed site map illustrating locations of remaining wastes was posted in the command post left on site. Firje watch and 24-hour site security would continuej on site. All site personnel demobilized at 1300 hours. PHASE n AcnvmEs

September'22* 1989 - BES work crew overpacked two leaking drums thatwere discovered in the drum staging area.

September 27. 1989 - Six EHRT personnel met on site with the OSC to dscuss future work activities.

September39. 1989 - BES demobilized and EHRT continued to mobilize equipment, personnel, and utilities. OSCs Wright and Powell reviewed EHRT draft scope of work and discussed Phase II removal activities. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 48

QctpfofiT ?i IPJiji^yHR'r began site work by tagging and inspecting process lines in preparation for the shearm£/dismaiii§Rjpiie_ration, Ecrecon/Bruga continued removal operations per their removal enforcement contract order. ~— z- ~-~~ •<-

._ 19J9 - Fire watch/security continued on 24-hour basis. EHRT continued to assess and tag process lines.

Media attention was minimal. A reporter from the Philadelphia, Inquirer was on site to discuss site history and Superfund.

October^ 5. I?g9 - EHRT continued to trace and manually dismantle process lines in area A-l (alcohol area). OSC Powell contacted Dr. John Barry of OSHA to discuss the exemption of EHRT personnel of the Sikh religion from safety regulations such as hardhats and respirators, due to facial hair and turbans.

. 1989 - Ecrecon/Bruga personnel continued removal operations. EHRT continued to trace and manually dismantle process lines in area A-L OSC and TAT continued to monitor site activities.

FAOs Henry and Marzulli initiated RCMS for tracking Phase II project costs.

October 7, 1989 - EHRT drained one 55-gallon drum of alcohol from the lines and staged it in the proper area.

October 10. 1989 - OSCs Powell and Koob directed removal activities. FAO Henry continued site cost tracking. OSC, OPA, RPM, PA DER and PFD met to discuss site activities.

l 1, jgS9 - Ecrecon/Bruga continued removal activities.

OSWER Assistant Administrator Don Clay and his assistant (M. Fehrenbach) were on-site and met with Assistant Superftmd Branch Chief Dennis Caraey, OSC Powell and RPM Winegar. OSWER was briefed on site history and current cleanup activity, and taken on a site tour.

October 12, 1989 - EHRT continued to trace and manually dismantle process lines in area A-l; approximately 50 gallons of suspected alcohol product collected this date.

October 13_«_1983. - Approximately 400 feet of pipe was dismantled and lowered to the ground.

OSC Powell sent a letter to OSHA Regional Administrator, U.S. Department of Labor, concerning site-specific safety requirements of Sikh religious beliefs.

October 14. 1989 - EHRT tapped 10 process lines and collected 30 gallons of suspected alcohol. Approximately 400 feet of pipe was dismantled and lowered to the ground. Suspected asbestos-insulated process lines were wrapped in polyurethane material,

October 16, 19S9 - Eight drums of various unknown products were collected. Approximately 360 feet of pipes were dismantled and lowered to the ground.

October 37, 1989 - EHRT tapped eight process lines and dismantled 200 feet of pipe.

October 18, 1989 - Due to heavy rains and slippery conditions, work progress was slow. EHRT continued to trace and manually dismantle process lines in area A-l; six process lines were also tapped.

October 19. 1989 - EHRT dismantled 280 feet and tapped 200 feet of process lines. TAT assessed the asbestos and recommended that licensed/certified personnel be subcontracted to handle asbestos removal. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 49

October 20. 1989_- An EHRT crew member was slightly injured when a board on an adjacent building was knocked off and struck him in the neck. He was examined at an area hospital and released. EHRT continued to dismantle pipes and tap process lines, TAT continued to monitor site operations and enforce safety protocols.

October 21. 1989 - Process lines continued to be tapped and 700 feet of 'pipe was dismantled and lowered to the ground, recovering 55 gallons of one product and 5 gallons of another from the process lines.

October 23, J989 - Approximately 50 gallons of molasses/water ' was released in area A-I between tanks #9308 and #9309 while cutting process lines; no readings above background were detected on the OVA. This material was residual and was not detected/drained during the line tapping and draining operation.

TAT continued to assist in the development of the site-specific disposal contract.

QcjQfaer 24. 1989 - Approximately 20 gallons of product were recovered from tapping eight process lines. The hydraulic shears were used to facilitate dismantling 1400 feet of pipe. EHRT began winterizing a decontamination unit.

TAT and EHRT investigated a strong n-butyl chloride odor coming from an open ditch on road #4. It was concluded that it was probably caused by extremely high tides flushing underground.

October 25. 1989 - EHRT continued to trace and manually dismantle process lines in area A-l. Winterizing the decontamination unit continued. EHRT cut a 1/2-inch pipeline, releasing two gallons of suspected acetone; no readings above background were detected by TAT. EHRT sampled 120 drums: of oxidizing solids from Phase I. OSC stressed the importance of being conscious of the potential for spills and being prepared to initiate emergency containment procedures if necessary. OSC directed EHRT to complete work in area A before continuing in area B.

October 2$, 1989 - Using hydraulic shears, 4500 feet of process lines were dropped in place along the road. EHRT completed sampling staged Phase I oxidizing solid drums, and began sampling base-neutral solid drums. Five tons of sand and five tons of stone were delivered to site for roadway modifications and spill containment.

October 27. 1989 - EHRT_continued to trace and manually dismantle process lines in area A-l; approximately 3000 feet of process lines were downed using hydraulic shears. Winterization of the decontamination unit continued. Sampling of drums staged from Phase I was completed.

OctoibeiL2g,L198jg - Forty-five gallons of product was collected and staged. Approximately 3000 feet of process lines were downed using hydraulic shears. Winterizing the decontamination unit completed. TAT outlined a model for the decontamination line and submitted it through the OSC to EHRT for modifications.

October 30, 1989 - EHRJcontinued to trace and manually dismantle process lines in area A-l; product was collected and staged as lines were dismantled. Shearing operations continued in areas A-2 and A-3; 700 feet of lines were downed by shearing operations this date. Shears were taken out of service for approximately 2.5 hours for routine weekly maintenance.

Samples collected from Phase I drums were sent for analysis. TAT estimate i that 103,000 gallons of ethylene glycol remained on site.

October 31, 1989 - EHRT manuaUy dismantled 300 feet of process lines in! area A-l. Shearing operations downed 800 feet of process lines. EHRT recovered 80 gallons of suspected No. 6 fuel oil from the downed lines.

November 1^1989 - EHRT_nianually dismantled 300 feet of process lines in areas A-l and A-2. Shearing operations downed 2000 feet of process lines^Whiie removing lines in area A-2, EHRT accidently punctured tank #306 with the hydraulic shears. The puncture occurred above the liquid level in the talk, and only the outer steamjacket was PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page 50

punctured, causing 1000-2000 gallons of water from within the jacket to be discharged into the diked area. A neadspace analysis was performed on a sample of the water and no levels of volatile compounds were measured, and the pH was neutraL^The hole in the tank lining was plugged.

November 2. 1989 - EHRT manually disconnected 400 feet of process lines; 80 gallons of product were collected. Hydraulic shearing operations were not conducted. An EHRT box truck was set up as site-specific spill response truck. Buffer zones within the hot zone established around work areas. The formal drum staging area was completed. The OSC directed all EHRT personnel to adhere to all safety protocols.

November 3. 1989 - EHRT manually disconnected 950 feet of process lines and bulked several staged, partially full drums of molasses and No. 6 oil.

City Asbestos Control Unit (ACU) Joseph Roache was on site due to a complaint regarding working with suspected asbestos. The OSC assured Mr. Roache that all asbestos was being handled safely, including materials resembling asbestos, which were being handled as if they were asbestos. The complaint was suspected to have originated from Ashland Chemical, which is located adjacent to the site.

November 4. 1989 - EHRT collected approximately 200 gallons of product and moved shearing operations to road #4 in area A-l.

November 6. 1989 - A small release of less than 50 gallons occurred during shearing operations, The material discharged was a clear liquid with a. neutral pH; no readings above background were detected on the OVA. The material came from an eight-inch line that had been disconnected the previous year and was suspected to be accumulated rainwater.

November 7. 1989 - At 1600 hours, EHRT experienced difficulty when the 30-ton rental crane being used to secure and lower pipelines was overloaded. It tipped, causing extensive damage to the boom of the crane. Fortunately, there were no injuries or material releases.

November 8. 1989 - OSC contacted ESD Asbestos Inspector David O'Brien regarding asbestos issues on site. Hart Environmental, contractor for PRP, was on site to view site files. RPM Winegar met with Hart. The damaged 30-ton crane was up righted and demobilized.

November 9. 198? - At the OSC's request. ESD O'Brien performed an asbestos demolition inspection (NESHAPS). A copy of ESD O'Brien's report was to be sent to the OSC upon completion. OSC gave formal notification of planned asbestos removal activities to EPA Asbestos Coordinator Carol Febho. ...

No_yem!?er_.l0^.1989 - A 50-ton crane and an additional 40-foot manlift was delivered to the site.

November 11. 1989 - During the week of 11/6 to 11/11/89, a total of 2250 feet of process line was dismantled, 6510 feet of piping was sheared, and 49 locations within area A-l were tapped. Liquid recovered included 40 gallons of liquid, 15 gallons of product, and 305 gallons of product, most of which was acetic acid. All material collected was staged in the drum staging area on road #4. -• -

Analytical results from sampling of Phase I drums and bulk tanks received; EHRT was to prepare a summary of the data for inclusion into the site-specific disposal scope of work.

November 13. 1989 - OSC informed CRES Thomas that the ethylene glycol lines on site may be dismantled sooner than expected. The glycol was the property of Eugene Ostreicher, AAA Warehousing, who was under a Consent Order to remove the material. OSC directed EHRT to track the costs associated with the ethylene glycol for cost recovery purposes, '•

ARl*00263 PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page 51

OSC held a teleconference with Gerald (Bureau of Reclamation) regarding demolition of the "Old Hickory" sign. A previous engineering study determined that this sign, weighing several ions placed on top of the building, was structurally unsafef.l~.EPA Region HI had an interagency agreement with the Bureau of Reclamation for technical assistance.

November 14. 1989 - OSC conducted a site tour and discussion to ERS Section Chief Crystall and the Honorable John Welt, Mayor of Recklinghausen, West Germany.

Tom Sirs (Bureau of Reclamation) contacted the OSC and advised arrangements would be made for a civil/structural engineer to perform an assessment of the "Old Hickory" sign, and make recommendations for its dismantlement.

OSC provided CRES Thomas with estimated quantities of ethylene glycol. OSC was requested to continue tracking all costs associated with collecting the glycol from the line.

November 15. 1989 - Tom Simms informed the OSC that Jim Felix. Sr. Engineer, would perform the assessment of the "Old Hickory" sign under the intragency ageement with (he Bureau of Reclaimation

The report of the asbestos (NESHAPS) inspection conducted by ESD O*Brien was received by the OSC.

November16r 1989 - OSC, TAT and Bureau of Reclamations engineer, inspected the structural integrity of the *OId Hickory" sign. Site operations temporarily suspended due to heavy thunderstorms and strong winds

Njive!Jnber^l71Jt989 - EHRT completed and submitted work plan for handling pipelines wrapped with suspected asbestos. EHRT finalized arrangements for No. 6 oil expert to be on site tj advise OSC on procedures for removal of die oil pipelines. Recommendations to be finalized in a written report.

November 18. 1389 - O_S_C_ and TAT continued to work on site-specific disposal contracts. EHRT workplan for handling pipelines wrapped with suspected asbestos was reviewed by OSC and TAT. EHRT submitted the summary of analytical data from Phase I (drums, bulk storage tanks and oil storage tanks).

November 20. 1989 - An expert on No. 6 oil from Energy Associates, Len.Seglir, was on site to provide the OSC with guidance in addressing the No. 6 oil that remained in pipelines.

OSC and TAT continued to work on site-specific disposal contracts.

OSC and TAT completed reviewing the. EHRT workplan for handling pipelines wrapped with suspected asbestos. Due to the OSC's concerns regarding the applicability of parts of this plan, a copy was sent to ERT for further review.

November 21. 1989 - Sits work was temporarily suspended due to high winds of up to 55 raph.

OSC, TAT and EHRT discussed procedures necessary for removing No. 6 oil from lines. Len Seglir advised the OSC that the only way was to heat the pipelines to approximately 350 degrees F to drain the oil.

November 27. 1989 - EHRT disconnected and dropped 200 feet of process line in the alcohol area between roads #4 and -#S.

OSC, TAT and EHRT continued discussions concerning removal of No. 6 cil from pipelines.

OSC Powell contacted Philadelphia Air Management (Wes Bickle) regarding future asbestos removal operations.

November 28. 1989 - EPA/DPO Van Fossen was on site to discuss site-spscific disposal contract with the OSC and TAT. ' " Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 52

Tapping and manual disconnecting continued: 220 feet of process lines were vented and disconnected in area Bland 26 locations were tipped, yielding 60 gallons of product that was generically waste streamed and staged in the drum staging area on road #4, and 860 feet of pipeline were sheared and lowered to the ground in area Al, road #4.

November 29. 1989 - DPO Van Fossen on site to revise site-specific disposal contract with OSC and TAT.

OSC Powell contacted EPM Thomas to advise that dismantling would begin on lines containing glycol.

OSC, TAT and EHRT discuss sampling protocol for process lines with suspected asbestos insulation and proper decontamination procedures.

OSC, TAT and EHRT continued to use the report submitted by No. 6 oil expert to pursue options on the decommissioning of process lines containing oil. Novgnber 30. 1989 - EHRT began continuous draining of molasses line on road #2 into stainless steel tank salvaged from site. Options for disconnecting pipelines containing No. 6 oil were pursued from the oil expert's report.

December 1. 1989 - TAT asbestos expert was on site to discuss sampling protocol for process lines covered by suspected asbestos insulation. TAT and EHRT began sampling suspected asbestos insulation on No. 6 oil pipelines along road #2,

December 2. 1989 - Manual disconnecting of pipe continued in alcohol area B-l; 175 feet of process lines were vented and disconnected and 40 new locations were tapped yielding 440 gallons of product that was recovered and staged by suspected waste stream. Shearing operations continued in area A-l and A-2 along road #4; 4000 feet of pipeline was sheared and lowered to the ground. December 4. 1989 - Additional TAT members were on site to continue sampling the process lines with suspected asbestos insulation.

Manual disconnecting of pipes continued in area B-l. One new location was tapped and materials collected were staged by suspected waste stream. Shearing continued in area A-l and A-2 along road #4.

Pecsnber S, 1989 - Asbestos from pipe rack that had fallen overnight was bagged, and pipes were covered with poly to prevent fibers from becoming airborne. Sampling of process lines with suspected asbestos insulation continued.

Manual disconnecting of pipe continued in alcohol area; pipes were vented then disconnected. Tapping continued and materials collected were staged by suspected waste stream.

December 6. 1989 - TAT and EHRT completed sampling of process lines with suspected asbestos insulation.

EPA RPM Winegar met on site with Hart Environmental (PRP consultant) to discuss site status.

Manual disconnection and venting of process lines continued in section B-l. Five locations were tapped, yielding 40 gallons of material which was generically waste streamed. December 7» 1989 - Construction of decontamination shed for asbestos removal personnel began at the end of road #4.

Manual disconnection and venting of process lines continued in sections B-l, B-3 and B-4; 12 locations were tapped and 535 gallons of material was recovered and staged by suspected waste stream.

December 8^1989 - Manual disconnection and venting of process lines continued. Three locations were tapped and 365 gallons of material was recovered and generically waste streamed. Heavy snowfall created adverse site conditions, causing activities to be suspended at 1500 hours. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 53

December 9.1989_^Tracuig and marking continued for process lines to bj tapped and disconnected. No lines were tapped or manuaUy disconnected; however, shearing operations continued. Site activities were discontinued at 1030 hours due to extremely poor site conditions from the previous day's snowfall and from cold temperatures.

December 11.1989 - Shearing and manual dismantling of process lines con inued. Eight locations were tapped in area B-l ,B-2, B-3 and B-4, yielding 1070 gallons of material which was recovered and staged by suspected waste stream.

Dgcgnber 12T 1989 - Disconnection of process lines in area B-l was completed, except for those with suspected asbestos insulation. Shearing and manual dismantling of process lines continued. Eleven locations were tapped in area, B-2, B-3, B-4, and C-3, yielding 1245 gallons of material that was staged by suspected waste stream.

Pjjcember_13j^l9Sjjj - Suspected asbestos insulation samples delivered tp lab for PLM analysis. Construction of asbestos decontamination shed that began 12/7/89 was completed, and the shed was in operation with the exception of minor modifications. Wrapping and securing process lines of suspected asbestos insulation continued.

Shearing and manual dismantling of process lines continued. Thirteen locations were tapped in areas B-l, B-2 and B-4, yielding 140 gallons of material which was staged by suspected waste stream.

December Jt^JgSj; - EPA=Safety Officer Joe Arena was on site to rei/iew the Site Safety Plan and provide recommendations for addressing site-specific areas.

Shearing and manual disconnection of process lines continued in sections B-l, B-2, and B-3. Six taps were made, yielding 375 gallons of material which was generically waste streamed. Process lines with suspected asbestos insulation continued to be wrapped and secured as removed.

_^_.^_^_^_z__ - Shearing, manual disconnection*;,* and tapping of process lines continued in sections B-l, B-2, B-3, and B-4. Seven locations were tapped, yielding 365 gallons of material, process line decommissioning generated 32 bags of asbestos. Process lines with asbestos continued to be wrapped and secured as removed.

December 16. 1989 - EHRT sampled 19 drums of material recovered from the decommissioning of process lines for compatibility analysis. Shearing, manual disconnection, and tapping of process lines continued in sections B-l, B-2, B-3, and B-4. Five locations were tapped, yielding 5 gallons of material.

December 18* 1989 - Shearing, manual disconnecting and tapping continued in areas B-l, B-2, B-3 and B-4. 20 "gallons of unknown product was recovered and staged by suspected waste stream. Process line dismantling generated 60 bags of asbestos, 150 feet of asbestos pipe insulation was wrapped and secured.

Decgnber 19. 1989 - Compatibility analysis samples from process lines Were packaged and shipped. Shearing operations continued; 2200 feet of process line were dropped. Tapping and draining of pipelines continued; 10 gallons of suspected cutting oil were collected and 1660 feet of manually disconnected pipe were lowered. Shearing of process lines generated 15 bags of asbestos from an additional 650 feet of suspected asbestos-insulated pipe were wrapped and secured. Asbestos decontamination was placed in operation.

DecemberL2QJ.9S9 - The grain trestle on road #4 was removed to eliminate the overhead hazard during removal of piping beneath the trestle. Shearing and manual dismantling of process lines continued. Sixteen locations were tapped yielding 405 gallons of material which was staged by suspected waste stream.

Process line shearing generated 184 glove bags of asbestos. Process lines with suspected asbestos insulation continued to be secured as they were removed and staged.

December 21. 1989 - Trailer mobilized to the site as an equipment trailer for EHRT.

RRU00266 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 54

Shearing and manual dismantling of process lines continued in areas B-3 and B-4. Drums were staged in area on road #4. Three locations were tapped, with no material recovered. Process lines with suspected asbestos insulation continued to be secured as they are removed and staged.

EHRT began temporary demobilization for the holiday break.

December 22. 1989 to January 2T 1990 - No on-site operations due to Christmas break.

January 3^1990 - EHRT remobilized to the site after the holiday break. Shearing and manual dismantling of process lines continued in areas B-3, B-4, C-3 and C-4. Five locations were tapped and 70 gallons of material were recovered. The recovered material continue to be generically staged by suspected waste stream: Process lines with suspected asbestos insulation continued to be secured as they were removed and staged.

Analytical data from suspected asbestos insulation received and reviewed by TAT and EHRT. Presence of asbestos was confirmed. The logistics of asbestos air monitoring and air sampling operations were discussed. All materials of suspected asbestos, whether or not confirmed, were handled as if confirmed asbestos.

January 4. 1990 - EHRT began three-bid process for a subcontractor to conduct asbestos air monitoring and air sampling.

Shearing and manual dismantling of process lines continued in areas B-3, B-4, C-3 and C-4, Six locations were tapped anda total of 615 gallons of material were recovered. The recovered material continues to be staged in the drum staging area on road #4. Process lines with asbestos insulation continue to be secured as they are removed and staged. Two separate pipes were leaking in shear area between pier #106 and pier #108. The quantity of spill was unknown, but not substantial.

January 5^1990 - Process line shearing and manual dismantling continued ill areas B-3, B-4, C-3 and C-4. Sixteen locations were tapped; 490 gallons were generically staged in the drum staging area on road #4. Asbestos collection yielded 35 glove bags of asbestos. Process lines with asbestos insulation continued to be secured as they were removed and staged.

January 6. 1990 - Process line shearing and manual dismantling continued in areas B-2, B-3 and C-l. Fifteen locations were tapped; 600 gallons were generically staged in the drum staging area on road #4. Asbestos collection yielded 200 s of asbestos. Process lines with asbestos insulation continued to be secured as they were removed and staged.

January S, 199Q - Process line shearing and manual dismantling continued in areas B-2, B-3 and C-l. Seven locations were tapped; 175 gallons were generically staged in the drum staging area on road #4. Asbestos collection yielded 85 glove bags of asbestos. Process lines with asbestos insulation continued to be secured as they were removed and staged.

January 9. 1990 - Subcontractor (Envirogenics) was selected to conduct on-site asbestos air monitoring and air sampling during operations which require the handling of suspected asbestos insulation.

Process line shearing and manual dismantling continued in areas B-l, B-2 and C-l. Three locations were tapped, yielding 465 gallons which was generically staged in the drum staging area on road #4.

January IQ, 199Q - Envirogenics conducted asbestos air monitoring and air sampling.

Process line shearing and manual dismantling continued in areas B-l and B-2. Three locations were tapped, yielding 745 gallons which were staged in the drum staging area on road #4. Consolidation of like materials continued in the drum staging area. A charged line was accidentally cut, spilling several barrels of material, which was recovered; and the spill area was cleaned up with sorbent pads. Process lines with, asbestos insulation continued to be secured as they were removed and staged. Publicker Industries NPL Site Federa On-Scene Coordinator's Report Page 55 Two-man, 24-hour fire watch team discontinued. One additional guard was hired for the night shift to maintain a fire watch during non-work hours. All fire watch concerns were discussed with Chief Jerry Janda of the Philadelphia Fire/Hazardous Material Unit.

TAT reviewed analytical (compatibility) data for drum samples sent out just before Christmas (Material collected into drums from pipelines). A compatibility data base is being formed by TAT.

EPA RPM Winegar and Hart Environmental, consultants for the PRP, visited the site to observe/document site removal activities.

January 11. 1990 - Envirogenics continued asbestos air monitoring and air] sampling for operations which require the handling of suspected asbestos material.

Process line shearing and manual dismantling continued in areas B-l and B-2. Four locations were tapped yielding 145 gallons. The recovered material continues to be generically segregated and staged in the drum staging area on road #4. Process lines with asbestos insulation continue to be secured as they were removed and staged.

Elevated FID and LEL readings were detected in area B-I. OSC, TAT and EHRT responded immediately and found a small leak on one of the pipelines. About 5 gallons of material drifted out on the concrete pad; the material was absorbed and drummed.

TAT received basic compatibility analysis of the drum samples of the material collected to date. TAT initiated a data base to sort the samples by waste stream.

OSC followed up with ERT Santuro regarding site safety issues (wearing of bard hat and respirators).

January 12. 1990 - Philadelphia Fire/Hazmat Unit Chief Janda and Lt. Kerrigan visited the site to discuss planned hazmat simulations in the spring and to'receive an update on site removal activity.

Envirogenics continued asbestos personnel monitoring and air sampling for operations requiring the handling of suspected asbestos insulation.

ERT Turpin informed OSC Powell thafmodified level "A" personal protection did not meet OSHA, EPA Fit Test requirements, and that this kind of technical issue may not be best addressed on site. The current site safety plan would be enforced stringently. OSC conducted conference call with DPO Van Fossen, Contract Officer Murphy and contract specialist Bowen to discuss site safety issues and the OJSC's jurisdiction under the ERCS contract. The conclusion of the conversation was that the OSC had .the right to require the ERCS response manager to make an on-site entry into the "hot zone".

Shearing and manual dismantling of pipes continued in areas B-l and B-2. Approximately 2,500 feet of pipeline were dismantled. Pipelines in areas B-3 and C-3 were drained at four locations. The materials collected (approximately 125 gallons) were staged in drum staging area on road #4. Consolidation of like materials continued in the drum staging area. - •------

Process pipelines were dismantled, with 300 feet being dropped in place. Those lines having suspected asbestos insulation were secured as they were removed and staged; 60 bags of asbestos material were collected and staged. Draining of No. 6 oil into holding tank adjacent to drum staging area continued.

January 13^1990 - Pipelines in areas B-3 and C-3 were drained at three locations; 15 gallons of unknown materials were collected and staged in the drum staging area on road #4. Consolidation of like materials continued in the drum staging area. 600 feet of process line dismantled. Those with asbestos insulation were secured as they were removed and staged; 140 bags of asbestos material were collected and staged. PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page 56

January 15. 1990.- Approximately t.200 feet of pipeline dismantled in area C-3. Pipelines were drained at three locations in areas B-3 and C-3; 55 gallons were collected and staged in the drum staging area on road #4. Consolidation of like materials in drum staging area continued. A total of 875 feet of process lines dismantled. Lines with asbestos insulation were secured as they were removed, and staged; 47 bags of asbestos material collected and staged.

January 16. 1990 - Approximately 450 feet of pipeline dismantled in area C-4. Pipelines in area B-3 and C-3 was drained at one location and the material collected (80 gallons of oil sludge) was staged in drum staging area on road #4. Consolidation of like materials continued in the drum staging area. 1,420 feet of process lines dismantled. Those with asbestos insulation were secured as they were removed, and staged; SO bags of asbestos material were collected and staged.

January 17. 1990 - Approximately 1,200 feet of pipeline dismantled in area C-4, and 800 feet of process lines were dismantled. Lines with asbestos insulation were secured as they were removed and staged; 300 bags of asbestos material collected and staged. Draining of No. 6 oil into collection tank on road #4 continued.

January 18, 1990 - Approximately 500 feet of pipeline sheared and dismantled, and 965 feet of process lines were dismantleded. Lines with asbestos insulation were secured as they were removed, and staged; 68 bags of asbestos material were collected and staged.

Janugry 19^1990 - ESD- O'Brien performed an asbestos inspection and was satisfied with fee operations; written inspection report to follow.

Approximately 1,000 feet of pipeline and 1,275" feet of process lines were sheared and dismantled. Those process lines with asbestos insulation were secured as they were removed and staged; 62 bags of asbestos material were collected and staged.

TAT delivered previously collected samples of unknowns to Environmental Testing Laboratory for identification.

January 20. 1990 - Approximately 1,200 feet of pipeline dismantled in area C-4. Pipelines in areas B-3 and C-3 were tapped at three locations; the pipes were empty. Consolidation of like materials continued in all the drum staging areas. 600 feet of process lines were dismantled. Lines with asbestos insulation were secured as they were removed and staged; 145 bags of asbestos material were collected and staged.

January 22. 1990 - Approximately 1.300 feet of pipeline dismantled in area C-4. Pipelines in areas B-3 and C-3 were tapped at one location, and found to be empty. A total of 975 feet of process lines dismantled. Lines with asbestos insulation were secured as they were removed and staged; 187 bags of asbestos material were collected and staged.

Samples of suspected ether delivered to lab for confirmation analysis.

Januajrv 23,. |990 - An EHRT worker was struck in the head (hard hat) by a piece of falling debris during the removal of a large pipeline. He was sent to the hospital for examination, and was diagnosed to have no serious injuries or concussion.

OSC conducted site tour for OPA personnel (Peterson, Burrage, Brown, Deitzlr DiCosmo, and Nurse).

Tappmg/draining of pipelines continued; 25 gallons collected. A total of 1150 feet of process lines dismantled and dropped in place. 200 feet of process lines with suspected asbestos insulation were secured and staged; 92 bags of suspected asbestos were collected and staged.

24. 1990 - TAT provided video documentation of the dismantling of pipelines surrounding grain trestle. Due to the threat of overhead hazards, the grain trestle was demolished. PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page 57

Pipeline dismantling continued; approximately 1200 feet sheared and 1350 manually disconnected and dropped in place. 200 feet of suspected asbestos on process lines wrapped; 157 bags of asbestos materials was collected.

January 25. 1990 - TAT continued video documentation of pipeline dismantling surrounding grain trestle. Consolidation of like materials continued in drum staging areas.

Disconnecting/shearing of process pipelines continued; 1000 feet of pipeline sheared, 1125 feet manually disconnected. Four locations tapped without recovering any material. Due to heavy rain, no pipeline with asbestos were wrapped because the tape would not stick; 92 bags of suspected asbestos were collected.

January 26. 1990 - OSC held teleconference with Dr. Sabnarwal and EHRT regarding site safety issues. Tapping, draining and manually disconnecting of pipelines continued; 820 _ feet of pipeline was manually disconnected, and two locations were tapped and found empty. 50 feet of suspected asbestos pipeline wrapped, and 75 bags of suspected asbestos materials were collected.

JgjmaryL2g^J9gQ - Suspected 10-15 gallons of ether found on site was :ested by TAT for peroxide, using peroxide strips. The ether was found to contain less than 1 ppm peroxide.

Shearing, manual dismantling, tapping and draining of pipelines and consoli iation of like materials in drum staging area continued. Asbestos air monitoring and sampling continued, although all perimeter readings remained below OSHA standards of 0.2 fibers/cc,. the safe level, with a level of 0.01 fibers/cc.

January 30^ 1990 - TAT photographed asbestos decontamination equipment for EPA contracting officers.

Shearing, manual disconnecting, tapping and draining of pipelines and consolidation of like materials in drum staging area continued. Asbestos air monitoring and sampling of site perimeter remains below OSHA standard, with a level of 0.01 fibers/cc. ^ ------—-

January 31,1990 - Molasses_ pumping operation completed on pier #106. TAT provided photo documentation of site activities.

Shearing, manual disconnecting, tapping and draining of pipelines and consolidation of like materials in drum staging area continued. Site perimeter asbestos arr monitoring and sampling continued.

February 1. 1990 - OSC Powell, TAT and DPO Van Fossen met todiscusssite-specific disposal contract. Riiss Bowen contracts office was on site to discuss contracting issues with EHRT and FAS Henry.

Shearing, manual disconnecting, tapping and draining of pipelines and consolidation of like materials in drum staging area continued. Site perimeter asbestos air monitoring and sampling continued.

FgbruarY 2, 1990 - Shearing of process lines continued, with 1,500 feet dropped, 1,375 feet dismantled and dropped in place. 600 feet of suspected asbestos material wrapped and staged; 5 glove bags were set up and used to remove suspected asbestos for shearing operation. A total of 125 gallons of solids (drum dry, pads,) debris were generated from cleaning up a spill.

February^. 1390- QSC remained in contact with EPA contracting officer!; regarding site-specific disposal contract:

Shearing, manual disconnecting, tapping and draining of pipelines and consolidation of like materials in drum staging area continued. Airborne asbestos monitoring continued.

February 5. 1990 - ACU Wynne Hill was on site to prepare for an upcoming asbestos inspection. PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page 5S

A total of 2000 feet of process lines sheared and 450 feet manually disconnected. A total of 250 feet of suspected asbestos insulation on pipes were wrapped and secured; 75 bags of asbestos debris were collected and staged. 6. 1990 - An American flag was presented to be flown on the site, by the request of Congressman Foglietta.

Shearing, manual disconnecting, tapping and draining of pipelines and consolidation of like materials in drum staging area continued. Ninety gallons of materials were collected, 50 of suspected alcohol and 40 of suspected acetone. Airborne asbestos monitoring continued.

Fehruqry 7. 1990 - Section Chief Crystall visited the site to observe activities. A total of 2000 feet of process lines sheared and 1460 feet manually disconnected. 200 feet of suspected asbestos insulation on pipes were wrapped and secured; 92 bags of asbestos debris collected and staged.

February 8. 1990 - TAT and RPM Winegar accompanied Ms. Harper of Hart Environmental on site to inventory bulk storage tanks by correlating the various numbering systems used to identify tanks and vessels.

The OSC contacted Joe Maffei of Holt to schedule pipe dismantling across road #8 leading to the south side of the site and was informed that Holt's operations at the refrigerated warehouse were shut down and would remain closed for at least one month.

Shearing, manual disconnecting, tapping and draining of pipelines and consolidation of like materials in drum staging area continued.

9, 1990 - John Cushman, Ashland Chemical Plant Manager, was on site to discuss site activities with OSC Powell.

A total of 1500 feet of process lines were sheared and 1350 feet were manually disconnected. No new locations were tapped; however 2050 gallons of suspected No. 6 oil was collected from a pipeline labeled P-106E. 200 feet of suspected asbestos insulation on pipes were wrapped and secured; 70 bags of suspected asbestos debris were collected and staged.

February 10. 1990 - A total of 200 feet of process lines were sheared and 300 feet were manually disconnected. 30 bags of suspected asbestos was collected and staged. Site work was suspended at 1200 hours due to persistent heavy rains.

12* 1990 - Dismantling of process lines continued; 300 feet were sheared and 1000 feet were manually disconnected and dropped in place. Two new locations were tapped; no product was recovered. 200 feet of process line with asbestos insulation was wrapped and secured; 105 bags of material with asbestos. was generated.

OSC Koob notified the Delaware Port Authority that the dismantling of process lines spanning across Packer Avenue was scheduled to take place during the week of February 19, 1990.

Febru3j*y_13«-.1990 - Dismantling of process lines continued; 600 feet sheared and 750 feet manually disconnected and dropped in place. Two new locations were tapped; no product was recovered. A total of 250 feet of process line with asbestos insulation was wrapped and staged; 105 bags of material with asbestos material was generated.

February 14. 1990 - Dismantling of process lines continued; 2000 feet sheared and 525 feet manually disconnected and dropped in place. 250 feet of process line with asbestos insulation was wrapped and staged; 102 bags of material with asbestos material was generated.

February 15. 1990 - A major spill simulation was performed; a clean process line was filled with water and discharged to resemble a release of product. The results of the staged emergency indicated that EHRT needed to correct their response in regard to providing proper equipment and related safety issile compliance. RRltQ027 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 59

Process line dismantling continued; 1500 feet sheared and 1000 feet manually disconnected and dropped in place. 250 feet of process fine with asbestos insulation was wrapped and staged; 130 bags of asbestos material generated.

February 16. 1990 - Dismantling of pipelines continued: 1500 feet sheared and 625 manually disconnected and dropped in place. 200 feet of suspected asbestos on process lines wrapped; 90 bags of asbestos materials collected.

17^990 - Dismantling of process lines continued; 1500 feet sheared and 505 feet manually disconnected and dropped in place. 300 feet of process line with asbestos insulation was v /rapped and staged; 109 bags of asbestos material generated.

February 18. 1990 - Dismantling of process lines continued; 1500 feet sheared and 725 feet manually disconnected and dropped in place. Five new locations were tapped; no material was recovered. A total of 150 feet of process line with asbestos insulation was Wrapped and staged yielding 135 bags of material.

February 20, 1990 - Dismantling of process lines continued; 350 feet sheared and 400 feet manually disconnected and dropped in place. Five new locations were tapped; 50 gallons of No. 6 oil were collected and transferred to the oil bulking vat on road #4. 20 feet of process line with asbestos insulation was wrapped and staged yielding 1 10 bags of material.

February 21. 1990 - A leaking process line was observed by TAT, wlio notified EHRT. EHRT. collected the material. TAT determined the material to be a caustic solution.

Shearing of process lines continued; 1500 feet dropped. 450 feet of pipeline were dismantled and dropped in place. Seven new locations were tapped; no material was recovered. 90 feet of process line with asbestos insulation was wrapped and staged yielding 140 bags of material.

February 22, 1990 - While lowering a No. 6 oil line on road #6, material started leaking. TAT immediately provided air monitoring and safe zone delineation.

EHRT continued dismantling process lines over Packer Avenue; none were sheared as shears were being used to assist with the leaking line on road #6. Manual dismantling of process lines continued; 450 feet dismantled and dropped in place. Three locations were tapped; 220 gallons of No. 6 oil was collected and staged. 20 feet of asbestos pipe wrapped and secured; 16 bags of asbestos material collected and staged.

-_ EEA .Headquarters and Regional personnel were on site to observe removal operations. The OSC provided a site tour to provide them with a better understanding of removal operations.

Shearing and manual disconnection of process lines continued; 500 feet dropped and 450 feet dismantled and dropped in place. Five locations were tapped and 500 gallons of No. 6 pil was collected and . placed in a storage tank. 200 feet of asbestos pipe was wrapped; 47 bags of asbestos material was collectt

February 24. 1990 - Shearing and manual disconnection of process lines continued; 1000 feet dropped and 450 feet dismantled and dropped in place. Ten locations were tapped; no product was recovered. 50 feet of asbestos pipe was wrapped; 30 bags of asbestos material collected.

Februsr^26^1$3Q, - EHRT continued dismantling process lines over Packer! Avenue; 800 feet sheared and dropped in place, and 725 feet manually disconnected and dropped in place. Eight locations tapped; no material recovered. 25 feet of asbestos pipe wrapped; 60 bags of asbestos material collected.

February 27T 1990 - EHRT continued dismantling lines across Packer Avenue; 600 feet sheared and dropped in place and 825 feet manually disconnected and dropped in place. Three locations tapped; no material collected. 50 feet of process line with asbestos insulation was wrapped; 105 bags of asbestos material collected.

HRWQ272 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 60

Febryjar^j^, 1 9j% - EHRT continued dismantling lines spanning across Packer Avenue; 800 feet sheared and dropped in place and 1030 feet manually disconnected and dropped in place. Six locations tapped; 150 gallons of No. 6 oil collected and staged in an on-site storage vat. 50 feet of process line with asbestos insulation was wrapped; 43 bags of asbestos material was collected.

March Ji. 1990 - EHRT continued dismantling lines spanning across Packer Avenue. Shearing of process lines continued; 600 feet dropped and 550 feet manually disconnected and dropped in place. Three locations tapped; no material collected. 200 feet of process lines with asbestos insulation was wrapped; 60 bags of asbestos material collected.

March 2....19£jj - U.S. EPA Administrator William K. Reilly was on site to be briefed on current site conditions and removal actions at the Publicker Industries NPL Site. Also on site were Don Clay, Ted Erickson, Steve Wassersug, Tom Voltaggio, Bruce Smith and other high-ranking officials from EPA.

EHRT continued dismantling lines spanning across Packer Avenue. Shearing of process lines continued; 900 feet dropped and 750 feet dismantled and dropped in place. Three locations were tapped; 500 gallons of No. 6 oil collected and placed in a vat for bulk storage. A total of 190 feet of process lines with asbestos insulation were wrapped; 120 bags of asbestos material collected. Asbestos air monitoring continued on a daily basis.

March 3,19^ - Manual disconnection of process lines across Packer Avenue continued; 350 feet dismantled. Shearing of process lines continued; 750 feet dropped. Three new locations were tapped; 100 gallons of No. 6 oil collected and placed in a vat for bulk storage. A total of 160 feet of process lines with asbestos insulation were wrapped and secured; 140 bags of asbestos material were collected and staged.

March 5_._J99ft - Dismantling of pipelines continued; 750 feet sheared and 775 manually disconnected and dropped in place. Five new locations were tapped; 50 gallons of No. 6 oil collected and transferred to vat for bulk storage. A total of 175 feet of suspected asbestos on process lines were wrapped; 117 bags of asbestos materials collected. Asbestos air monitoring continued on a daily basis.

March 6. 1990 - OSC directed EHRT to demobilize excavator/drum grappler (205), one operator, three cleanup technicians, and the site control officer.

Dismantling of pipelines continued; 650 feet sheared and 555 manually disconnected and dropped in place. Five new locations were tapped; 1 10 gallons of No. 6 oil collected and transferred to vat for bulk storage. 200 feet of suspected asbestos on process lines were wrapped; 80 bags of asbestos materials were collected. Asbestos air monitoring continued on a daily basis. '

March 7, 1990 - Dismantling of pipelines continued; 1000 feet sheared and 880 manually disconnected and dropped in place. Five new locations were tapped; no material collected. A total of 325 feet of suspected asbestos on process lines were wrapped; 30 bags of asbestos materials collected. Asbestos air monitoring continued on a daily basis.

8. 1990 - OSC submitted items to be address in the dismantling of the "Old Hickory" sign and storage tank, to RM Brennan, which would be subcontracted.

Shearing of process lines continued; 750 feet dropped and 750 feet dismantled and dropped in place. Five locations were tapped; no material collected. 400 feet of asbestos pipe was wrapped; 290 bags of asbestos material was collected.

March 9. 1990 - OSC Powell met with Philadelphia City Councilman Tyoune and EPA Remedial Program representatives to discuss past, present and future site operations.

SFU00273 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 61

OSC Powell met with Chief Janda of PFD Hazmat Unit to organize a jointsimulation on site for PFD and EPA-OSC Powell also met with OSC Jarvela to finalize the evaluation criteria for the site-specific contract.

Shearing, manual disconnecting, tapping and draining of pipelines and consolidation of like materials in drum staging area continued. Asbestos air monitoring continued on a daily basis.

March JOj 1990 - EHRT site control officer demobilized; TAT assumed site tracking/control officer responsibility per OSC request.

Shearing of process lines continued; 750 feet dropped. Work crew cleared Packer Avenue where dismantled process lines were dropped. Manual disconnection of lines continued; 500 feet dismantled and dropped in place. Four locations were tapped; no material was collected. A total of 350 feet of asbestos pipe was wrapped; 225 bags of asbestos material was collected. Asbestos air monitoring continued on a daily basis.

March 12, 199ft - Dismantling of process lines continued; 800 feet manually disconnected and dropped. Four locations were tapped; no material collected. 40 feet of suspected asbestos insulation were wrapped and secured; 254 bags of asbestos material was collected and staged. Asbestos air monitoring continued on a daily basis.

MardiJ3^199fl - Dismantling of process lines continued; 770 feet manually disconnected and dropped. Three locations were tapped; | no material collected. 100 feet of suspected asbestos insulation 'were wrapped and secured; 210 bags of asbestos material was collected and staged. Asbestos air monitoring/sampling continued.

March 14« 1990 - Shearing of process lines continued; 400 feet dropped. Manual disconnection of lines continued; 800 feet dismantled and dropped in place. One location tapped; no material was collected. 50 feet of asbestos pipe was wrapped; 125 bags of asbestos material collected. Asbestos air monitoring/sampling continued.

March 15. 1990 - EPA Region III management review team (Tralie and Pandzo) on site to review administrative site files.

Shearing of process lines continued; 300 feet dropped. Manual disconnection of lines continued; 950 feet dismantled and dropped in place. 100 feet of asbestos pipe wrapped; 65 bags of asbestos material was collected. Asbestos air monitoring/sampling continued.

- Region III EPA management review team (Tralie and Pandzo) continued to review site administrative files.

Shearing of process lines continued; 800 feet dropped. Manual disconnection of lines continued; 1025 feet dismantled and dropped in place. 50 feet of asbestos pipe was wrapped; 85 bags of asbestos material was collected. Asbestos air monitoring/sampling continued.

MardLlT^lgjjQ - Shearing of process lines continued; 800 feet dropped. Manual disconnection of lines continued; 710 feet dismantled and dropped in place. 30 feet of asbestos pipe wrapped; 85 bags of asbestos material collected. Asbestos air monitoring/sampling continued.

- OSC Powell and TAT inspected the south side of site to determine the structural integrity of buildings and housing for process lines. It was determined that the structures' integrity were poor and that worker safety was of greater concern than the hazards posed by the material in the pipeline.

PFD Inspection Unit and L&I personnel were on site to discuss the structural integrity of the "Old Hickory" sign and boiler house buildings. Due to asbestos hazards, access was denied to the boiler house. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 62

TAT conducted tank assessment to determine areas of the site that would need to addressed before removal operations were completed.

Shearing, manual disconnecting, tapping and draining of pipelines and consolidation of like materials in drum staging area continued.

Region HI EPA management review team (Tralie and Pandzo) continued to review site administrative files.

March 20. 1990 - Shearing of process lines continued; 1200 feet dropped. Manual disconnection of lines continued; 725 feet dismantled and dropped in place. Two locations were tapped; no material collected. A total of 150 feet of asbestos pipe was wrapped; 170 bags of asbestos material was collected. Asbestos air monitoring/sampling continued.

March 21. 199Q - OSC contacted ERT Royal Nadeau to discuss the possibility of utilizing a small video camera or fiber optics camera to inspect the process lines on the south side, since they were suspected to be empty.

Shearing of process lines continued; 900 feet dropped. Manual disconnection of lines continued; 800 feet dismantled and dropped in place. A total of 150 feet of asbestos pipe wrapped; 117 bags of asbestos material collected. Asbestos air monitoring/sampling continued.

March 2^T JftgQ - Shearing of process lines continued; 800 feet dropped. Manual disconnection of lines continued; 400 feet dismantled and dropped in place. 100 feet of asbestos pipe wrapped; 100 bags of asbestos material was collected. Asbestos air monitoring/sampling continued.

TAT continued tank assessment to determine site areas to be addressed to ensure removal completion. EHRT continued to pursue bids for the dismantling of "Old Hickory" sign.

March 23j-4^Sfi - Shearing of process lines continued; 800 feet dropped. Manual disconnection of lines continued; 835 feet dismantled and dropped in place. A total of 125 feet of asbestos pipe wrapped; 85 bags of asbestos material was collected. Asbestos air monitoring/sampling continued.

TAT continued tank assessment to determine site areas to be addressed to ensure removal completion. EHRT continued to pursue bids for the dismantling of "Old Hickory" sign.

MiarcJlJjS,JlJ?9fl - Shearing of process lines continued; 800 feet dropped. Manual disconnection of lines continued; 1175 feet dismantled and dropped in place. A total of 375 feet of asbestos pipe wrapped; 105 bags of asbestos material collected. Asbestos air monitoring/sampling continued.

TAT continued tank assessment to determine site areas to be addressed to ensure removal completion. EHRT continued to pursue bids for the dismantling of "Old Hickory" sign.

March 27. 1990 - Shearing of process lines continued; 800 feet dropped. Manual disconnection of lines continued; 950 feet dismantled and dropped in place. A total of 175 of asbestos pipe wrapped; 130 bags of asbestos material collected. Asbestos air monitoring/sampling continued.

EPA Region HI management review team continued review of site administrative files. TAT continued tank assessment to determine site areas to be addressed to ensure removal completion. EHRT continued to pursue bids for the dismantling of "Old Hickory' sign. The crew trailer demobilized.

March 28. 1990 - Shearing of process lines continued: 825 feet dropped. Manual disconnection of lines continued; 700 feet dismantled and dropped in place. 100 feet of asbestos pipe wrapped; 95 bags of asbestos material was collected. Asbestos air monitoring/sampling continue. Approximately 90 gallons of suspected cutting oil was collected. Because an EHRT employee was working without his face mask in the hot zone, OSC Powell requested RM Bill Brennan to enforce on-site safety regulations. SRUGQ275 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 63

EPA Region ffi management review team continued review of administrative site files. TAT continued tank assessment to deter-mine site areas to be addressed to ensure removal completion.

March 29>1990 - OSC, TAT, and EHRT continued pursuing options for process lines supported or housed by structures that were unsafe for dismantling operations. Shearing of process lines continued; 1,200 feet dropped. Manual disconnection of lines continued; 835 feet dismantled and dropped in place. 95 bags of asbestos material was collected and staged. Asbestos air monitoring and sampling continued. Approximately 150 gallons of suspected cutting oil was collected.

EPA Superfund Branch Chief (D. Carney) met with OSC Powell and observed site removal activities. EPA Region 111 management review team continued review of administrative site files, TAT continued tank assessment to determine site areas to be addressed to ensure removal completion.

March J?QT 1990 - Shearing of process lines continued; 2500 feet dropped. Manual disconnection of lines continued; 863 feet dismantled and dropped in place. 95 bags of asbestos material collected and staged. Asbestos air monitoring and sampling continued. Approximately 150 gallons of suspected cutting oil and 55 gallons of No. 6 oil were collected. OSC, TAT, and EHRT continued pursuing options for process lines supported or housed by structures that were unsafe for dismantling operations.

April 2. 1990 - Shearing of process lines continued; 2500 feet dropped. Manual disconnection of lines continued; 660 feet dismantled and dropped in place. Approximately 25 gallons of suspected No. 6 oil collected. OSC, TAT, and EHRT continue7pursing'options for process lines supported or housed by structures that were unsafe for dismantling operations. TAT continued tank assessment to deter-mine site areas to be addressed to ensure removal completion.

April.3 T 1990 - Shearing of process lines continued: 400 feet dropped. Mi inual disconnection of lines continued; 650 feet dropped in place. Approximately 65 gallons suspected No. 6 oil was collected. OSC, TAT, and EHRT continued pursuing options for process lines supported or housed by slructures that were unsafe for dismantling operations.

April 4. 1990 - Shearing of process lines continued: 1200 feet dropped. Manual disconnection of lines continued; 275 feet dismantled and dropped in place. 80 bags of asbestos material were collected and staged. Asbestos air monitoring and sampling continued. Allstate Power Vac, an EHRT subcontractor, began video monitoring of process line contents on the south side of the facility.

.EPA Region III management review team continued review of site administrative files.

April 5. 1990 - Shearing of process lines continued; 1200 feet dropped. Manual disconnection of lines continued; 350 feet dismantled and dropped in place. 200 feet of suspected asbestos pipe wrapped and placed and secured. 50 bags of asbestos material collected and staged. Asbestos air monitoring and sampling continued. Allstate Power Vac continued video monitoring of process line contents on the south side of the facility.

EPA Region IH management review team continued review of administrative site files.

April fr, 1990 - Shearing of process lines continued; 2600 feet dropped. Manual disconnection of lines continued; 270 feet dismantled and dropped in place. 91 bags of asbestos material collected and staged. Asbestos air monitoring and sampling continued. Allstate Power Vac continued video monitoring of process line contents on the south side of the facility.

EPA Region 111 management review team continued review of administrativ site files.

A reporter from WHYY radio was on site to interview the OSC and discusssite operations. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 64 Ann'1 7. 1990 - Shearing of process lines continued; 1800 feet dropped. Manual disconnection of lines continued; 275 feet dismantled and dropped in place. Two process line locations tapped. 75 feet of pipe with asbestos material wrapped and secured; 70 bags of asbestos material collected and staged. Asbestos air monitoring and sampling continued. Allstate Power Vac continued video monitoring of the contents of process lines on the south side of the facility.

EPA Wassersug met with OSC Powell and observed removal activities.

ApriJ £,1990 - Shearing of process lines continued; 2800 feet dropped. Manual disconnection of lines continued; 505 feet dismantled and dropped in place. One process line location tapped. A total of 120 feet of pipe with asbestos wrapped and secured; 115 bags of asbestos material collected and staged. Asbestos air monitoring and sampling continued. Allstate Power Vac continued video monitoring of the contents of process lines on the south side of the facility.

April IJ^J 990 - Shearing of process lines continued; 2800 feet dropped. Manual disconnection of lines continued; 500 feet dismantled and dropped in place. One process line location tapped. A total of 125 feet of pipe with asbestos wrapped and secured; 160 bags of asbestos material collected and staged. Asbestos air monitoring and sampling continued. Allstate Power Vac continued video monitoring of the contents of process lines on the south side of the facility.

April Ui 1990 - Shearing of process lines continued; 4000 feet dropped. Manual disconnection of lines continued; 295 feet dismantled and dropped in place. Two process line locations tapped. 100 feet of pipe with asbestos wrapped and secured; 210 bags of asbestos material collected and staged. Asbestos air monitoring and sampling continued. Allstate Power Vac continued video monitoring of the contents ~of process lines on the south side of the facility,

TAT performed sampling and compatibility analysis on 28 drums from Phase II for future bulking.

April 12. JJJ90 - Shearing of process lines continued: 2600 feet dropped. Manual disconnection of lines continued; 295 feet dismantled and dropped in place. One process line location tapped. 100 feet of pipe with asbestos wrapped and secured; 210 bags of asbestos material collected and staged. Asbestos air monitoring and sampling continued. Allstate Power Vac continued video monitoring of the contents of process lines on the south side of the facility.

Hart Environmental (Harper) was on site to review POLREPs and current site activities.

April 13j_J990 - Shearing of process lines continued: 3500 feet dropped. Manual disconnection of lines continued; 480 feet dismantled and dropped in place. One process line location tapped. A total of 115 feet of pipe with asbestos wrapped and secured; 25 bags of asbestos material collected and staged. Asbestos air monitoring and sampling continued. Allstate Power Vac continued video monitoring of the contents of process lines on the south side of the facility.

April 14. 1990 - Shearing of process lines continued; 2800 feet dropped. Manual disconnection of lines continued; 640 feet dismantled and dropped in place. One process line location tapped. 75 feet of pipe with asbestos wrapped and secured; 70 bags of asbestos material collected and staged. Asbestos air monitoring and sampling continued. Allstate Power Vac continued video monitoring of the contents of process lines on the south side of the facility.

ApriLiS. 1990 - Shearing of process lines continued; 2800 feet dropped. Manual disconnection of lines continued; 640 feet dismantled and dropped in place. One process line location tapped. 75 feet of pipe with asbestos wrapped and secured; 75 bags of asbestos material collected and staged. Asbestos air monitoring and sampling continued. Allstate Power Vac continued video monitoring of the contents of process lines on the south side of the facility. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 65

April 16. 1990 - Manual disconnection of lines continued; 320 feet dismantled and dropped in place. Five process line locations were tapped; 10 gallons of suspected cutting oil and 65 gallons of suspected No. 6 oil were recovered. 75 feet pf asbestos material wrapped and securedj 125 bags of asbestos material collected and staged. Asbestos air monitoring and sampling continued,

Ecrecon/Burga began preparing for dismantling "Old Hickory" sign ;ind the tank connected to the building.

April 17.. 1990 - Shearing of process lines continued: 2000 feet dropped. Manual disconnection of lines continued; 300 feet dismantled and dropped in place. Three process line locations tapped; 10 gallons of suspected cutting oil and 50 gallons of suspected No. 6 oil were recovered. 100 feet of pipe with asbestos wrapped and secured; 175 bags of asbestos material collected and staged. Asbestos air monitoring and sampling continued.

April 18.1990 - Shearing of process lines continued; 2,500 feet dropped. Manual disconnection of lines continued; 330 feet dismantled and dropped in place. Three process line locations tapped; 45 gallons of suspected cutting oil and 130 gallons of suspected No. 6 oil were recovered. 50 feet of pipe with i asbestos wrapped and secured; 70 bags of asbestos material collected and staged. Asbestos air monitoring and sampling continued. Ecrecon/Burga continued preparing for dismantling "Old Hickory" sign.

Aprij_19Jg9fl. - Shearing of process lines continued; 1,800 feet dropped. Manual disconnection of lines continued; 300 feet dismantled and dropped in place. Three process line locations, tapped. 100 feet of pipe with asbestos wrapped and secured; 85 bags of asbestos material collected and staged. Asbestos air monitoring and sampling continued. Ecrecon/Burga continued preparing for dismantling "Old Hickory" sign.

ApriL20^1990 - Shearing of process lines continued; 1,800 feet dropped. Manual disconnection of lines continued; 285 feet dismantled and dropped in place. Three process line locations tapped; 40 gallons of suspected No. 6 oil were recovered. 95 bags of asbestos material^ collected and staged. Asbestos air monitoring and sampling continued. Ecrecon/Burga continued preparing for dismantling "Old Hickory" sign,

April 21. 1990 - Shearing of process lines continued; 1500 feet dropped. Manual disconnection of lines continued; 570 feet dismantled and dropped in place. Two process line locations tapped; 10 gallons of suspected No. 6 oil were recovered. 45 bags of asbestos material collected and staged. Asbestos air monitoring and sampling continued. Ecrecon/Burga continued preparing for dismantling "Old Hickory" sign.

April-22,-1990 - Shearing of process lines continued; 1500 feet dropped. Manual disconnection of lines continued; 570 feet dismantled and dropped in place. Two process line locations tapped; 10 gallons of suspected ' No. 6 oil were recovered. 45 bags of asbestos material collected and staged. Asbestos air monitoring and sampling continued. Ecrecon/Burga continued preparing for dismantling "Old Hickory" sign1.

April 23. 1990 - EHRT sheared 1800 feet pf process line, dismantled 340 feet manually, and recovered 10 gallons of suspected No. 6 oil. 90 bags of asbestos material were collected and staged, and 50 feet of asbestos insulated pipe were wrapped. Asbestos air monitoring and sampling continues during site operations. Ecrecon/Burga continued mobilizing equipment to dismantle the "Old Hickory' sign. A 1125-ton crane was mobilized and boom and jib were assembled.

April 24. 1990 - RPM Winegar provided a tour for members of the Senate Budget Committee.

EHRT sheared 2300 feet of process line, dismantled 775 feet manually, i and recovered 20 gallons of suspected No. 6 oil. 25 bags of asbestos material was collected and staged, and 225 feet" of asbestos insulated pipe were wrapped. Asbestos air monitoring and sampling continues during site operations. Ecrecon/Burga began to dismantle the "Old Hickory" sign. PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page 66

April 25. 199Q - EHRT sheared 1.000 feet of process line, dismantled 570 feet manually, and recovered 95 gallons of suspected No. 6 oil from two locations. 85 bags of asbestos material were collected and staged, and 225 feet of asbestos insulated pipe were wrapped. Asbestos air monitoring and sampling continues during site operations. Ecrecon/Burga continued to dismantle the "Old Hickory" sign, bringing down letters 0, L, D, and Y.

Evidence of the poor structural integrity of the sign was photodocumented and brought to the attention of OSC Powell by Ecrecon/Burga personnel.

April 26. 1990 - EHRT sheared 1200 feet of process line. 52 bags of asbestos material collected and staged; 75 feet of asbestos-insulated pipe was wrapped. Asbestos air monitoring and sampling continued during operations.The letters H, I, C, OT R, and Y were removed from the sign and brought to the ground by Ecrecon/Burga.

Hazmat Chief Whalen and Philadelphia Fire Marshall Donnely investigated the cause of a fire on the roof of the "Old Hickory" building during the dismantling of the sign. The fire was extinguished by Ecrecon/Burga at 1345 hours. The fire, determined tp.be a result of debris ignited by the cutting torch, which had fallen into a pile of cork insulation. PFD responded to the alarm and were on site at 1742 hours. The fire was extinguished at 1815 hours. All appropriate permits (i.e., hot work) had been obtained for the work. No chemicals were involved, and the debris would be removed prior to any further cutting operations.

April 27. 1990 - Cleanup operations continued; weekly total of 7800 feet of process line sheared, 2787 feet manually disconnected, and 250 gallons of material were recovered. A total of 350 bags of asbestos debris collected and staged in building #168; 575 feet of asbestos-insulated pipe wrapped. Asbestos monitoring was conducted during site operations. Dismantling of the "Old Hickory" sign continued.

April 30. 1990 - PA DER David Burke and PWD James Downs were on site to discuss operations with OSC Powell.

EHRT sheared 1500 feet of process line and manually disconnected an additional 430 feet; 5 gallons of suspected No. 6 oil was recovered.

Per OSC request, six crew members, one man lift, and one site vehicle were scheduled to demobilize on 05/02/90. OSC Powell tasked EHRT to sample drums and to pursue disposal options for Phase n .wastes.

Mav 1. 1990 - OSC Wright directed cleanup efforts.

EHRT sheared 250 feet and manually disconnected 130 feet of process line. A total of 150 feet of asbestos-insulated pipe was wrapped; 70 bags of asbestos material was collected. EHRT began clearing debris from diked area in section #C-2 in preparation for staging process lines containing" No. 6 oil.

May_2*_J3JjO - No process lines were dismantled or sheared this date. EHRT concentrated efforts to remove tank and debris from diked area In section #C-2 in preparation for staging "sheared No. 6 oil lines. 35 bags of asbestos material was collected and staged in building #168. Only the water tank remained atop the "Old Hickory" building. EHRT Vice-president Alan Fredericks initiated disposal of Phase II wastes.

May 3. 1990 - OSC Heston directed cleanup efforts.

No process lines were dismantled or sheared this date. EHRT concentrated efforts to remove tank and debris from diked area in section C-2 in preparation for staging sheared No. 6 oil lines. 100 bags of asbestos material was collected and staged in building #168.

Mav 4. 1990 - OSC Wright directed cleanup efforts.

Weekly update: EHRT sheared 1750 feet and manually disconnected 560 feel of process line, recovered 5 gallons of suspected No. 6 oil, wrapped 250 feet of asbestos-insulated pipe and collected and staged 250 bags of asbestos material Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 67

OSC directed EHRT to obtain bids on concrete to be used to secure the containment area in section C-2. EHRT continued clearing containment area of section C-2.

Mav 5.1990 - No process lines dismantled this date. EHRT continued to blear the containment area in section C-2. 60 bags of asbestos material collected and staged in building #168. Asbestos air monitoring and sampling continued during site operations.

Mav 7. 1990 - OSC Fox coordinated removal activities.

EHRT sheared 1,400 feet of process line. Work continued on the containment pad in section C-2. A total 475 feet of asbestos-insulated pipe wrapped and secured; 15 bags of material collected and staged.

The water tank atop the "Old Hickory" building was removed by Ecrecon/Burga. The tank would be cut into smaller pieces before being removed from site.

TAT compiled data from the Phase II tank assessment into a database.

Mav 8. 1990 - OSC Fox directed cleanup efforts.

EHRT dismantled or sheared 850 feet of process line. A cement mixer unloaded concrete to reinforce the staging area pad in section #C-2. 325 feet of asbestos-insulated pipe wrapped and secured;- 60 bags of asbestos material collected and staged in building #168. Ecrecon/Burga continued cutting the water tank into smaller pieces in preparation for removal.

Mav 9. 1990 - OSCs Powell and Fox directed cleanup efforts.

EHRT dismantled or sheared 300 feet of process line, lined containment pad with visqueen, and began staging No. 6 oil lines. 200 feet of asbestos-insulated pipe wrapped and secured; 60 bags of asbestos material collected and staged in building #168. Ecrecon/Burga continued cutting the water tank in to smaller pieces in preparation for removal.

May 10. 1990 - EHRT continued to stage No. 6 oil lines in the containment pad along road #5.

OSC, TAT, arid EHRT discussed protocol for disposal analysis. EHRT provided OSC with preliminary bids for disposal of Phase n .wastes. TAT checked facilities for RCRA compliance; all were found to be in compliance to accept site waste. Tentative sampling date scheduled for 05/14/90.

Mav 11. 1990 - Weekly update: 2890 feet of process line sheared and 50 feet manually disconnected, 1250 feet of asbestos insulated pipe wrapped and secured, and 275 bags of asbestos material collected and staged in building #168. EHRT constructed a containment area for the storage of No. 6 oillines. Ecrecon/Burga continued to cut the sign and water tank into smaller pieces in preparation for removal.

OSC, TAT, and EHRT discussed progress in obtaining disposal analysis. OSC Powell expressed displeasure with the lack of progress to date; sampling postponed until 05/15-90.

May 12. 1990 - OSC Powell coordinated removal activities.

EHRT sheared 600 feet of process line. 225 feet of asbestos-insulated pipe wrapped and secured; 10 bags of asbestos material collected and staged in building #168. EHRT continued to move No. 6 oil line to the containment area on road #5. TAT finalized Phase II tank assessment into a database. TAT Emergency Response Team and PFD Hazmat Unit conducted level A Simulation on site. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 68

Mav 14. 199Q - EHRT wrapped and secured 250 feet of asbestos-insulated pipe; 60 bags of asbestos material collected and staged- EHRT continue to stage No. 6 oil lines in containment area along road #5. EHRT Phase II disposal sampling postponed until 05-16-90.

15r 199Q - TAT and EHRT cross referenced drum waste stream data to ensure all drums were sampled for compatibility. TAT recommended that an additional nine drums be sampled because of incomplete compatibility data.

EHRT sheared and lowered 2,000 feet of process line; 50 gallons of suspected No. 6 oil recovered. A total of 225 feet of asbestos-insulated pipe wrapped and secured; 80 bags of asbestos material collected and staged in building #168. EHRT continued to stage No. 6 oil lines in the containment area along road #5.

May 16. 1990 - TAT performed sampling on nine drums in the Phase H staging area. The samples were analyzed using the HAZCAT kit to determine compatibility.

EHRT completed drum sampling on all Phase n wastes in preparation for disposal. EHRT .sheared 1200 feet of process line. 300 feet of suspected asbestos-insulated pipe wrapped and secured; 65-bags of debris collected and staged in building #168. EHRT continue to stage No. 6 oil lines in the containment area along road #S, generating 550 gallons of No- 6 oil solids, which was collected and drummed.

Mar 17. 1990 - Contracting officers Murphy and Bowen onsite to begin solicitation for Phase II waste disposal. Disposal contractors on site as part of the solicitation process. OSC Powell provided a site tour of all waste staging areas. A court reporter was provided to take minutes of the meeting.

OSC directed TAT to obtain the approximate volume of asbestos waste in building #168 and the amount of used protective equipment temporarily staged in the buildings on site. TAT was also tasked to obtain the amount of empty poly drums being stored in building #149.

EHRT sheared and lowered 800 feet of process line. A total of 150 feet of asbestos-insulated pipe wrapped and secured; 50 bags of material collected and staged in building #168. EHRT continue to stage No. 6 oil lines in the containment area along road #5.

Mav 18. 1990 - Ten members of EPA-RCRA staff toured the facility. Staging of No. 6 oil continued along road #5; 40 bags of asbestos material collected and staged in building #168. '. filay 1^,^990 - Activities included staging No. 6 oil into the containment pad along road #5, wrapped 40 feet of asbestos lines wrapped, and six bags of asbestos material.

Mav 21. 1990 - Staging of No. 6 oil into the containment pad along road #5 continued; 25 feet of asbestos pipe wrapped, and forty bags of asbestos material collected.

Mav 22. 1990 - OSC Koob directed site activities. EHRT continued wrapping and securing of No. 6 oil lines. 180 feet of asbestos pipe wrapped; 35 bags of asbestos material collected.

Mav 23. 1990 - EHRT sheared 600 feet of process line dropped in place, collected 30 gallons of suspected No. 6 oil and stored it within a vat, continued to wrap and stage No. 6 oil lines in the containment area, wrapped and secured 300 feet of asbestos-insulated pipe, and collected 35 bags of asbestos debris.

May 24. 1990 - The following activities were completed this date: 800 feet of process line sheared, No. 6 fuel lines wrapped and staged in the containment area along road #5, 200 feet of asbestos-insulated pipe wrapped, and 20 bags of asbestos material collected.

Mav 25. 1990 - EHRT allocated an additional $500,000. '. AFU0028! Publicker Industries NPL Site FederaJ On-Scene Coordinator's Report Page 69 Actions taken included: 1100 feet of process lines sheared, No. 6 fuel linss wrapped and staged in the containment area along road #5,150: feet of asbestos-insulated pipe wrapped and staged,and 10 bags of asbestos material collected.

Mav 29. 1990 - EHRT sheared 800 feet of process line and continuedto wrap and stage No. 6 oil lines in the containment area along road #5.

May-.3QJ.99Q-- EHBuLsheared 600 feet of process lines, wrapped and secured No. 6 oil lines in the containment area, and collected 46 bags of asbestos material.

31. 1990 - ERCS sheared and/or disconnected No. 6 oil lines being staged in containment area on road #5 (diked area). Asbestos insulation removed from piping being collected and staged in building #168.

RM Brennan reported tank #238 no longer contained water; only oily sludge in tank bottom remained. No point source leak was found.

June Ij 1990 - ERCS sheared and/or disconnected No. 6 oil lines being staged in containment area on road #5. Weekly update of removal activities: 1,400 feet of process line disconnected with the hydraulic shears; 91 bags of asbestos debris collected and staged in building #168.

June 2. JL990 - ERCS continued to transfer disconnected No. 6 oiljines to diked containment area, on road #5. ERCS collected 15 bags of asbestos debris and staged them, in building #168.

June 4j 1990 - ERCS re-piled crushed drums along road #7; crane crew staged the last of the large No. 6 oil lines into containment on road #5. ERCS continued to prepare for the removal of Phase II wastes.

OSC requested a reduction of manpower and equipment no longer necessary for removal activities. As of COB 06/05/90 crane would be demobilized, airborne asbestos monitoring would be discontinued, asbestos crew would be demobilized, and the asbestos decontamination area would be broken down. '

JuneJgjJl.990 - ERCS began constructing framework for roof on No. 6 oil containment pad and addressing molasses pipelines along road #2. ERCS demobilized 50-ton crane and continued decontamination of asbestos decon building.

June 6. 1990 - ERCS framed roof on No. 6 oil containment area, continued breaking down and decontaminating asbestos decon building, sheared 200 feet of mojasses pipeline along road #2, and removed debris from around tank #238 looking for a suspected leak. No point source was found.

June 7, 1990 - ERCS continued to frame roof of the No. 6 oil containment area. Asbestos decon building completely, decontaminated. ERCS sheared 1800 feet. of molasses lines from along road #2.

.Tune 8. 1990 - Weekly update of removal activities: 2900 feet of molasses pipeline removed from along road #2 and construction of roof of No. 6 oil containment area continued. ERCS continued to make arrangements for removal of Phase H wastes. The OSC requested that all waste (ethylene glycol) that is contaminated with methylene chloride be shipped as hazardous waste.

JuneJ). 1990 - ERCS began to secure site in preparation for demobilization. Gates and fences on the south side of the plant were repaired and blocked; windows and doorways were also boarded up. Shearing operation along road #2 resulted in 75 feet of molasses pipeline sheared and staged.

June 11, 1990 - QSC Wrigfat directed removal activities. FAS MarzuHi provided cost tracking. Shearing operation continued; 300 feet oTp"rocess line sheared and staged. Road #2 was washed down in preparation for molasses stabilization. The molasses from the sheared pipe would be solidified with fly ash. ERCS continued construction of No. 6 oil containment area and securing buildings in area #G-2* Pubiicker Industries NPL Site Federal On-Scene Coordinator's Report Page 70 .Tune 12. 1990 - ERCS sheared 150 feet of molasses pipeline and continued to secure site; windows and doorways boarded up to prevent unauthorized access. June 13. 1990 - FAO Messimer assisted with cost tracking and administrative tasks.

Shearing operations continue 200 feet of molasses piping removed and staged. The first of several loads of fly ash arrived for molasses solidification. A rubber tire loader would be mobilized to facilitate mixing molasses and fly ash. ERCS continued securing building and doorways and framing of roof for No. 6 oil line containment area.

Juqe 14 j J99Q - ERCS completed shearing operations on road #2. A total of 1200 feet of molasses pipeline was sheared, molasses was solidified and staged on poly in the courtyard of section A-2. ERCS began addressing molasses tanks on pier #106. Tanks were sheared open and mixed with fly ash to solidify contents. ERCS continued to secure building and doorways and complete construction of roof frame on containment building.

June 15. 1990 - Molasses solidification continued on pier #106. ERCS continued construction of containment area and boarding up of buildings and windows to prevent unauthorized access.

June l&J 990 " Shearing operations on pier #106 completed; ERCS awaited additional fly ash deliveries to further solidify molasses for ease of transport to staging area. ERCS completed framework for No. 6 oil pipeline containment area.

S. 1390 - Shears were decontaminated and moved off site to await transport. Additional fly ash delivered to solidify molasses on. pier #106. ERCS continued to secure site buildings by boarding up all entrance ways. luneJL9. 1990 - AH molasses solidification operations completed; a berrn was completed on the staging area to secure molasses. Case loader was decontaminated for demobilization. Stout Environmental representative on site to pick up samples to accompany waste profiles. Per OSC review of the profiles and analytical, changes in the profiles were required. ERCS continued to secure site building.

June 20, 1990 - OSC Powell spoke to CRES Vem Butler to inquire why Waste Conversion was out of RCRA compliance. CRES Butler told the OSC that Waste Conversion had incurred a Class 1 violation; however, PA DER inspection on June 1 1 1 1990 , fotmd the violation corrected and paperwork was being expedited to reinstate Waste Conversion as a RCRA facility, and assured this would not interfere with Phase II waste disposal.

ERCS received the tarp covering for the roof of the No. 6 oil line containment area and secured three sections. ERCS continued to secure entrances of site buildings and wash down road #4 to clear it of fly ash and molasses. ERCS continued to make disposal arrangements for Phase II wastes.

.Tune 21. 1990 -The OSC contacted CRES Butler to advise that Waste Conversion was back in compliance per RCRA regulations and could accept Phase II wastes. ERCS continued to secure tarp roof on containment area and entrance ways to site buildings.

Juflg-22. 1990 - Weekly update of removal activities: ERCS continued site demobilization preparation, buildings, completing No. 6 oil line containment area and preparing Phase II wastes for disposal.

ERCS finalized tarp roof installation. Securing of site buildings continue. ERCS RM will demobe 6 RT's on Saturday 06/23/90.

.Tune 25. 1990 - EPA/FAS Marzulli continued cost tracking. ERCS continued to prep site for demobe and to make arrangements for disposal of Phase II wastes. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 71

June 26. 1990 - ERCS continued to prepare site for demobe. Per OSC request, TAT will prepare a report documenting remaining on site material with corresponding analytical information. Although these materials will be disposed during site specific work, this information will be useful to the Remedial Program personnel.

JuneL.27T 1990 - ERCS completed boarding up entrance ways to prevent unauthorized access.

June 2^19% - A total of 5,300 gallons of No. 6 oil and 80 drums of various oils, solvents, corrosives and acids transported off site via Waste Conversion truck and trailer. ERCS heavy equipment (215) with shears, office trailer, and rented furniture demobed off site this date.

.Tune 29. 1990 - Waste Conversion truck pumped and transported 5200 gallons of contaminated cutting oil, No. 6 oil, alcohol, acetone and ethylene glycol off site for disposal. ERCS completed removal of Phase II wastes, with the exception of eight 55-galIon drums containing No. 6 oil. TAT finished preparing final tank assessment with corresponding analytical per OSC request.

June 30T 1990 - All fences and gates completely secured around the site. ERCS demobed from the site with both of the decon trailers and remaining equipment.

JuiyJLS* 1990 - RM Brennan and TAT met with OSC Powell and discussed the disposal of the eight remaining . drums on site. The OSC approved mobilizing two RTs to accomplish disposal operations.

July 19. 1990 - ERCS RTs arrived on site. A Waste Conversion truck was loaded and transported the remaining eight drums to disposal. ERCS demobilized.

July 30. 1990 - The OSC requested ERCS to complete general site cleanup and maintenance. ERCS mobilized with one backhoe and one stake body.

July 31 j J990 - During an irispectibri'of '&hk #238. the QSC noticed that oil was seeping from the ground on the northeast side of the tank. No point source for the release was found. Thp level of contents had been found low in that tank during a previous inspection. The OSC briefed Removal Branch Chief Carney and Section Chief Crystall about the incident. The OSC decided to pump die contents of tank #238 into tank #306 and men address the contaminated soil. Tank #306 also contained a No. 6 oil that was contaminated with a low level of pesticide. Both tanks. #238 and #306 remained to be addressed under a site-specific transportation and disposal contract and transferring of contents of tank #238 into taflc #306 would not affect the scope of work under the contract.

The OSC contacted the USCG/LAST Strike Team and requested technical help for anticipated pumping operations. USCG/LAST assured the OSC a pump specialist would be sent to provide technical help. The OSC also contacted EPA Contracting Officer Murphy and notified her of the situation.

August 2. 1990 - OSC. USCG. TAT, and ERCS inspected tank #238 and affected seepage area. A valve on a semi- buried line was suspected to be the leak source. Further inspection revealed that the valve level was above the level of the tank contents. The integrity of the tank bottom remained unknown at this point. USCG/LAST Wyatt recommended to the OSC to use of a viscous oil pumping system for the transfer operation.

August 3. 1990 - OSC Powell briefed Removal Branch Chief Carney oq tank #238 situation, proposed work plan, and associated costs. It was determined the work would be performed under a separate ERCS delivery order.

ERCS completed cleanup and site mainteriance. The OSC again requested USCG/LAST technical assistance during transfer of tank #238 contents.

August 7j 1990 - ERCS mobUizedjwith a CAT 200 excavator to address tank #238; a separate delivery order was issued. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 72

August 8, 1990 - RPM DiNardo and Philadelphia HAZMAT Chief Janda were on site for a site activities update. ERCS began removing all process lines and debris from around tanks #238 and #306.

August 9. 1990 - ERCS completed removal of all process lines connected to tank #238.

August 10. 1990 - ERCS completed clearing debris from around tank #306. OSC directed ERCS to secure and plate close all valves and flanges originating from tank #306. Since the roll-off containers received were inadequate to properly store and transport the contaminated soil, the OSC directed ERCS to construct a temporary storage area for the soil near building #171 on toad #4. The OSC also directed the ERCS to obtain a four inch double diaphragm pump for the oil transfer operation.

August 11. 1990 - ERCS completed securing all valves and flanges originating from tank #306.

August 13, 1990 - Section Chief Crystal! and Region III ERD Coordinator Weigel were on site to discuss site operations. USCG/LAST Team Wyatt and Grant were on site to monitor pumping operation.

ERCS set up pump with hoses and performed leak test. ERCS also began construction pf soil storage pad near building #171.

August 14. 1990 - ERCS completed construction of storage area and lined it with a 6-mil poly liner. ERCS began pumping the contents of tank #238 into tank #306.

August 15. 1990 - ERCS transferred 78,000 gallons of oil and water from tank #238 to tank #306. ERCS then excavated oil-contaminated soil from around tank #238 and staged it in the prepared storage area.

& 1990 - ERCS changed pumps to one with larger capacity and continued excavation. Contaminated soil was removed and staged in the prepared area.

August 17. 1990 - Senior OSC Jarvela, along with USCG/MSO Philadelphia Corcoran, Aheme, and Hofrman were on site to discuss site issues. After observations and discussions, EPA and USCG agreed that EPA would attempt to locate and plug storm drains leading to the Delaware River believed to contain oil and debris. TAT was directed to prepare a contingency plan to address potential discharge of #6 oil into the Delaware River.

8^ 1 990 - ERCS continued pumping operations; approximately 100,000 gallons of oil and water transferred to tank #306 to date. OSC requested TAT to sample contaminated oil and soil.

August 20. 1990 - ERCS continued pumping process: approximately 1 10.000 gallons transferred to tank #306. Cold weather and debris slowed excavation process. ERCS continued 24-hour on-site security.

August 21. 1990 - ERCS ceased pumping operations as cool weather solidified oil rendering it unpumpable. ERCS began procurement process for a boiler to steam heat the oil to allow pumping to continue.

August 2JL_1990 - ERCS was successful in using existing steam lines to heat sludge and oil inside tank #238. Excavation of all contaminated soil from around tank #238 and along #2 containment wall was completed. TAT completed sampling; samples were packaged and prepared for shipment.

August 2£L 1990 - ERCS continued transfer; 24-hour shifts were maintained to generate steam to heat oil in tank #238.

August 24. 1990 - OSC Matlock directed removal efforts for OSC Powell. ERCS continued 24-hour shift so oil in tank #238 was sufficiently heated to continue pumping efficiently. ERCS demobed heavy equipment, one operator and one RT by COB,

August 26. 1990 - ERCS continued to heat contents of tank #238 and completed oil transfer to tank #306." AR1+OQ285 PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page 73

ERCS reported thaiym increasing number of unauthorized personnel were entering the site. OSC contacted Maloney Security about orrtnSis to prevent site access.

. 1990 - ERCS began decon of pumping equipment: mobile bciler would be used to assist in decon of heavily oiled pipes.

" ERCS continued to decon pumping equipment. OSC expressed concern about increased trespassing to Philadelphia HAZMAT Chief Janda. PFD Lt. Sideras informed the OSC that he would send two plain-clothes officers to discuss a stakeout operation. OSC intended to prosecute trespassers.

August 29. 1990 - ERCS continued to decon pumping equipment and cut brush along the fence line of Packard Avenue. GAO auditors on site to obtain information about die OSC's duties and the process of appropriating monies to activate a site. Two PFD plain-clothes officers discussed a stakeout under the Walt Whitman Bridge in order to arrest trespassers on the site.

August 30. 1990 - ERCS. completed decon of pumping equipment and prepared to demobe pump, generators, and steam boiler. ERCS continued to cut brush along Packard Avenue and the site.

Augygt_jiL_199fi - ERCS completed response to tank #238 emergency" ERCS secured the site for the weekend and demobed the pump, generators, and steam boiler.

Septembgfi4,J.99g - ERCS continued to secure fences and doorways of buildings to limit access by unauthorized persons. ERCS notified OSC that an unidentified person was seen exiting the site. Information concerning the incident was turned over to PFD. OSC informed PFD that he intended to prosecute any unauthorized persons apprehended on the site.

Sep-tember_5_. 1990 - ERCS continued to secure fences and doorways of buildings to prevent unauthorized access. ERCS also continued to clear brush from fence lines. PFD Lt. Feldmire suggested to the OSC that, due to the extent of the trespassing problem, an additional security guard be posted at the site. OSC took the suggestion under advisement.

September 6. 1990 - ERCS continued to secure fences and doorways of tuildings to prevent unauthorized access. ERCS also continued to clear brush from along fence line of property.

CRES officer Thomas informed the OSC that Ecrecon would remove thetank trailer from the site. OSC had no objection, as long as operations were, carried out in accordance with site safety protocol.

September 7f 1990._-.ERCS demobed from the site. OSC received approval for removal ceiling increase of $162,060 and an emergency removal ceiling of $150,000".

September 14.1990 - PECO removed a power line that ran along fenced border with Ashland Chemical. GSX Laidlaw was awarded site-specific contract for T&D of Phase I wastesL OSC and TAT accompanied GSX representatives on a site tour to take pictures and sample tanks in question for disposal.

September 16. 1990 -_ QSC Matlock conducted a tour for a group from EPA HQ and briefed them on site operations to date. Remedial Program contractor reviewed Publicker blueprints for possible locations of underground process lines. GSX arranged for mobilization of men, material, and equipment to tlie site. geptetnber23, 1990 - GSX began mobilizing necessary men, equipment and materials to facilitate disposal of Phase I wastes. TAT delivered GSX waste disposal profiles to Section Chief Crysall for approval and signature after review and signature by OSC Matlock. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 74

October 9. 1990 - Six drums that were shipped to Stout on June 28, 1990, as non-hazardous were re-manifested today as hazardous ac Stout determined that the material was flammable (D001). Rather than turn the shipment around, the drums remained and the manifests reissued.

GSX set up for pumping operations of • liquids from tanks. TAT updated safety plan, tank assessment, and chronology of events, and performed other site-related activities.

October 1QT 199Q - Two tank trucks arrived to begin T&D of base neutral liquids to Casie Ecology for disposal. TAT checked compliance of Casie Ecology and found they had no significant violations that would prohibit acceptance of Superfund waste. TAT inspected tankers to ensure they were empty/clean before loading. TAT also inspected volume of loaded tanker for manifesting. Due to conflicting analytical results, the two loads were returned. GSX sampled tankers upon their return.

Q^Qfaffr^!J^J990 - Two tank trucks arrived for T&D of flammable liquids. TAT checked the vehicles to ensure they were empty before loading and full after loading. Disposal facility informed GSX there was a conflict in the water content of the flammable liquids. T&D temporarily on hold until these conflicts could be resolved.

TAT took inventory of tanks that needed verification for tank assessment report.

Week ending October 19. 1990 - T&D of 4,900 gallons of No. 6 oil occurred this week. GSX continued to heat oil in tank #306 on a 24-hour basis to make the oil pump more easily.

The site continued to be plagued by vandals who pilfered copper wiring and aluminum to sell to scrap yards. OSC and TAT investigated building #153 where the door had been forced open. Broken hacksaw blades were found and other doors within the building were also forced open.

Week ending October 27. 1990 - GSX continued to remove waste from tank #186 (46,148 gallons), tank #189 (15,500 gallons), tank #190 (46,500'gallons), and tanks #238 and #306 (144,977 gallons).

GSX exceeded the base quantities and would soon exceed the option quantities (CLIN 015, 029 and 030) authorized under the site-specific contract for the T&D of contaminated No. 6 oil. GSX had anticipated that maximum would have been reached fay the middle of the week ending October 29, 1990; however, the maximum was reached on October 27. GSX would prepare a proposal on the estimated cost of removing the remaining No. 6 oil for review by the OSC. Based upon GSX's proposal, the OSC would make recommendations to the Contracting Office for an amendment to the contract.

October 29, 1990 - GSX continued to remove waste from tanks #185, #186, #189, #190, #238 and #306. A total of 45,000 gallons of waste were removed from tanks.

OSC Powell contacted GSX and EPA Finance, Contracts, Remedial and Removal Programs to initiate change order in site-specific contract with GSX to allow for T&D of the remaining No. 6 oil in tanks #238 and #306, which would exceed the quantities specified in the contract. GSX was to submit estimated volumes remaining in tanks #23 8 and #306 and additional costs for the removal of the No. 6 oil.

October 30, 1990 - GSX continued to remove waste from tanks #185, #186, #189, #190, #238 and #306. A total of 31,000 gallons of waste was removed from tanks. October 31. 1990 - GSX continued to remove waste from tanks #185, #186, #189, #190, #238 and #306. A total of 22,867 gallons of waste was removed from tanks.

EPA Contracts prepared a change order to the site-specific contract which allowed an additional 35,000 gallons of No. 6 oil to be removed from tanks #238 and #306. A copy of the change order was sent to GSX corporate offices for review and approval. ftRLi00287 Publicker Industries NPL Site Federa On-Scene Coordinator's Report Page 75

November 1. 199ft-.GSX continued to remove waste from tanks #185, #186, #189, #190, #238 and #306. A total of 43,569 gallons of waste was removed from tanks.

Per OSC request TAT made two tank entries with GSX to monitor GSX volume estimation efforts in tanks #238 and #189. Volume estimates were 2,000 gallons for tank #189, and 5,140 gallons for tank #238.

November 2. 1990 - GSX continued to remove waste from tanks #185, #186, #189, #190, #238 and #306. A total of 35,400 gallons of waste was removed from tanks.

GSX expressed a desire to dispose of bulked base neutral liquids at the DiiPont Deep Water facility after treatment at Casie Ecology. However, the Deep Water facility did not meet the requirements of the EPA off-site disposal policy. While the contents of tanks #185 and #186 were not RCRA hazardous, hazardous constituents were present. Therefore, while the off-site policy was not applicable, it was both relevant and appropriate. The OSC informed GSX that these materials could not be sent to the Deep Water facility.

November 3. 1990 - GSX continued to remove" waste from "tanks #185. #186, #189, #190, #238 and #306. A total of 29,713 gallons of waste was removed from tanks. Per OSC request, TAT entered tank #306 to monitor GSX in volume estimation.

November 5. 1990 - GSX continued to remove waste from tanks #185, #186, #189, #190, #238 and #306. A total of 35,200 gallons of waste were removed from tanks. GSX submitted a proposal for the removal of remaining waste in tanks #189, #238 and #306 based on measurements taken by GSX and TAT. These estimates were to be used for invoicing purposes.

November 6. 1990 - GSX continued to remove waste from tanks #185. #18J5. #189. #190, #238 and #306. A total of 45,150 gallons of waste were removed; from tanks. GSX consolidated drums of No. 6 oil from the staging area along road #5; a total of 2,450 gallons were removed.

November 7. 1990 - GSX continued to remove waste from tanks"#185. #185. #189. #190, #238 and #306. A total of" 25,300 gallons of waste were removed from tanks. GSX sawed in half poly drums previously containing No. 6 oil along road #5 in preparation for later disposal.

November 8. 1990 - GSX continued to remove waste from tanks #185. #186. #189. #190, #238 and #306. A total of 35,000 gallons of waste was removed from tanks. GSX began compacting and baling poly bags of used PPE;TAT monitored operations to confirm count of bags compacted.

November 9. 1990 - GSX continued to remove waste from tanks #185. #186. #189. #190, #238 and #306. A total of 24,100 gallons of waste were removed from tanks. GSX continued to compact and bale bags of used PPE.

NovembenJO. _1990 - Compaction and baling operations were suspended due to inclement weather as the compactor ran on electricity and the motor was exposed to the elements.

OSC discussed options for addressing contaminated soil staged on site and expressed displeasure at not having received the analytical data on the soil.

November 12. 1990 - GSX continued to remove waste from tanks #185. #18i5. #189, #190, #238 and #306. A total of 10,000 gallons of waste were removed from tanks. Tank #185 was emptied and steam cleaned, and access ways cut into tanks #190 and #186. GSX continued to compact and bale! bags of used PPE. GSX received two open-top roll-off boxes in preparation for solidification process of waste in tank #306.

OSC directed EHRT RM Brennan to draft a scope of work for the T&D of staged contaminated soil. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 76

November 13. 1990 - GSX continued to remove waste from tanks #186. #189. #190. #238 and #306. A total of 2,375 gallons of waike were removed from tanks. Compaction and baling operations continued. GSX received four closed-top roll-off boxes. Solidification and removal of waste from tank #306 began.

Analytical data on soil pile received from EHRT RM Brennan this date.

November 14. 1990 - GSX continued to remove waste from tanks #186, #189, #190, #238 and #306. A total of 2,000 gallons of waste was removed from tanks. To date, GSX removed 3, 200 gallons of liquid from tank #189; 2,000 gallons waste and 1,200 gallons rinsate. Compaction and baling operations completed, yielding 2001 bags for a total of 346 cubic yards.

TAT contacted Regional RCRA compliance officers for information on TSD facilities considered for disposal.

NoTember 15, 1990 - GSX continued to remove waste from tanks #185, 186, #189, 190, #238 and 306. A total of 300 gallons were removed from all tanks this date.

Approximately 300 gallons of waste were removed from tank 106 this date. Tank #106 is now prepared for steam cleaning.

GSX's cleaning of tanks #185, #186 and #189 is nearly complete.

TAT continues to attempt contact with Regional RCRA Compliance Officers.

November 16. 1990 - GSX continued to remove 'waste from tanks #185, #186, #189, #190, #238 and #306; to resolidify and remove material from tank #306, and to clean tank #238 this date.

TAT continues to attempt contact with Regional RCRA Compliance Officers.

17. IgpO - GSX continued to remove waste from tanks #238 and #306. Cleaning operations on tanks #185, #186, #189 and #190 are complete this date. Final waste volume totals for tank #185 was 200,531 gallons, for tank #186 was 118,673 gallons, for tank #189 was 43,000 gallons.

GSX continued to remove waste from tank #306 and clean tank #238. The materials generated were solids which had already been accounted for or rinsate from cleaning operations.

November 19, 1990 - GSX removed 73 cubic yards of material from tank #3Q6 this date for a total of 73, cubic yards. • GSX continued efforts to clean up tank #238 this date.

November 20.1990 - GSX removed 12 cubic yards of material from tank #306 this date for a total of 95 cubic yards. Due to a change in pH levels of material in tank #306 no more roll-offs will be transported until the material is re- profiled and totally solidified for transport. GSX continued clean up efforts on tank #238.

23_«_19jjQ - GSX evaluating methods for further removal of product from tank #306. GSX continued clean up efforts on tank #238.

NoyenibeL2jS.Jl99Q - GSX continued clean up efforts on tank #238. Bulking/consolidation of drummed material began this date.

GSX transported two loads of crushed metal drums offsite this date. A total of 89 cubic yards of crushed drums from Phase I activities were 'transported off site this date. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 77

November 27. 199fe- GSX continued clean up efforts on tank #238. Rinsate from tank #238 was bulked with compatible drum materials. This 5000 gallons of material was transported to OSCO, Columbia, TN, for treatment. Baled PPE (15,200 Ibs) was transported to Pinewood, SC, for disposal] OSC Powell contacted Contractin Officer Murphy to discuss quantity of crushed metal drums because the volume exceeded that allowed for in the contract. Appropriate modifications were made.

November 28. 1990 - GSX continued clean up efforts on tanks #238 and #306 this date. GSX transported 132 cubic yards of crushed metal drums this date for a total of 212 cubic yards to date. GSX also transported 44 cubic yards of crushed plastic drums this date for a total of 44 cubic yards to date.

November 29. 1990 - GSX continued to clean and solidify residual No. 6 loil remaining in tanks #106, #238 and #306. GSX solidified and removed 36 cubic yards of material from tank #306 fora total of 176 cubic yards to date. GSX transported 32 cubic yards of solid material offsite this date for a total of 55 cubic yards to date. GSX transported 44 cubic yards of crushed drums offsite this date for a total of 88 cubic yards to date. GSX transported 7200 pounds of baled PPE offsite this date for a total of 22,400 pounds to date.

November 30. 1990 - GSX continued to solidify residual No. 6 oil and steam clean tanks #106, #238 and #306. GSX continued to dispose of remaining waste.' 'Material removed this date is; crushed metal drums (126 cubic yards), sludge from tank #238 (12 cubic yards), and cut poly drums (56 cubic yards) transported to Pinewood, SC for disposal.

RPM Nick DiNardo was onsite this date with consultants from Woodward-Clyde (WWC) who represented Holt Shipping Inc. WWC will be performing environmental assessment (soil borings and installation of two monitoring wells) on a parcel of Publicker Industries property in an attempt to construct a right of way to access the warehouses of the Philadelphia Port Corporation.

December 1. 1990 - GSX continued to solidify residual No.: 6 oil and steam clean tanks #106, #238 and #306. GSX continued to dispose of remaining waste, 88 cubic yards of crushed metal drums were transported to Pinewood, SC for disposal.

OSC Powell notified USCG/MSO Philadelphia, that a 50 foot pilot has been tied off to pier 103. The boat is secured to moorings but appears abandoned.

Decgnber 2.1990 - No waste was removed from site this date. GSX concentrated on steam cleaning the interior of tank #306. "" _ "--' " " - - ;:- -"- :: - -"

December 3.1990-GSX continued to d|spose of remaining waste. Tank #238 rinsate (10,000 gallons) was transported to OSCO for treatment. Fourteen drums were transported to Laurel, MD.

Eighty-six cubic yards of crushed metal drums were transported to Pinewood, SC for disposal. This represented the final load of drums, for a total of 521 cubic yards transported offsite for disposal.

GSX continued to steam clean and solidify residual No. 6 oil remaining in tanks #106, #238, and #306.'. RPM Nick ' DiNardo onsite with Tetra-Tech and Woodward-Clyde. All Remedial site operations and safety considerations were coordinated with OSC Powell.

December 4^1990 -No waste was removed from site this date.GSX continued to solidify residual No. 6 oil from tanks #106, "#235 and~#3Q6. Remedial contractors Tetra Tech began removing and capping onsite deep production wells.

OSC Powell discusses final volume of crushed metal drums with R. Bowen (Contracts) and will prepare a justification for ontract modification # 4. _ •RR1400290 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 78

December S. 199Q - No waste was removed from site this date. GSX continued to solidify residual No. 6 oil from tanks #106, #238 aadJ306.

December 6. 1990 - GSX continued to dispose of remaining waste this date. Tank #238 rinsate (5,000 gallons) was transported to OSCO for disposal.

OSC Powell, TAT and GSX made a visual inspection of tanks #106 and #306. OSC satisfied with cleaning efforts on both tanks. GSX committing resources to finish clean-up of tank #238.

RPM Nick DiNardo onsite with Tetra-Tech this date.

7^1990 - No waste was removed from site this date. GSX continued efforts to clean up tank #238 continue this date.

The recent return of cold weather has solidified the oil in tank #238. GSX has remobed boiler to heat oil/water mixture so the mixture can be pumped from the tank.

December 8. 1990 - No waste was removed from site this date. GSX continued efforts to clean up tank #238.

December 10. 1990 - GSX continued to dispose of remaining waste. Consolidated drum material (12 cubic yards) was transported to Pinewood, SC, for disposal,! Tank #238, rinsate (3,045 gallons) was transported to Casie Ecology for treatment. GSX continued to steam clean tank #238.

ERCS contractor (EHRT) mobed onsite this date. Crew began to secure and prep site for demobe.

ERCS completed dismantling of outdoor break area and weather monitoring station this date.

U - 199JJ - No wastes were removed from site this date.

GSX continued efforts to effect a clean up of tank #238.

ERCS completed covering and securing of excavated soil pile onsite.

Philadelphia HazMat Chief G. Janda onsite at the request of the OSC to coordinate closure activities at the Publicker Site. OSC relayed his concerns of onsite trespassing and site access to the Philadelphia Fire Department in the event of fire or other emergency.

Decsnber 12. 1990 - GSX continued to transport waste offsite this date. Twelve (12) cubic yards of consolidated drum material was transported to Pinewood, SC for disposal. Additionally 5,000 gallons of rinsate from tank #238 was transported to Casie Ecology for treatment.

GSX continued efforts to clean up tank #238. Due to the asphalt-like consistency that the oil has taken, GSX, with OSC approval, GSX will add Mineral Spirits (P-Naphtha, Flashpoint > 145 degrees Fahrenheit) to the tank to emulsify the oil and expedite the cleaning process.

ERCS crew continues to secure and prep site for demobe.

ERCS completed removal of all barricades along Delaware Avenue. Delaware Avenue is now open to vehicular traffic.

fl-RltOOZ9l Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 79 December 13.1990 - GSX continued to dispose of remaining waste. Twelve (121 cubic yards of consolidated drum material was transported to Pinewood, SC for disposal. 1,987 gallons of mineral spirits rinsate from tank #238 was transported to Delaware Container Company for treatment.

ERCS crew continuing to secure and prep site for demobe. ERCS will be demobed at COB today.

December 14. 1990 - GSX completed steam cleaning and disposal of all waste associated with tank #238. 5100 gallons of oil and rinsate were transported to Casie Ecology for treatment. Fourteen (14) cubic yards of material was shipped to Pinewood, SC for disposal.

OSC Powell making all necessary arrangements to transfer site operationsto the Remedial Program.

ERCS made final arrangements to demobe all site trailers and to seal equipment inside tank #189.

VIL PROBLEMS ENCOUNTERED AND RECOMMENDATIONS As with any unplanned emergency situation involving hazardous materials, the weather, logistics, materials involved and type of incident determined the number of problems that had to .be overcome to bring the Publicker Industries Site to a successful completion. This section will highlight the most significant problems that occurred during the removal efforts and recommendation/solutions in response to these problems. First and foremost, the weather played an important role in the day-to-day operation of the Site. Heavy rains, electrical storms and snow events suspended or delayed site activities on a number of occasions and made footing treacherous on overhead pipe racks and around tanks. Cold weather froze or solidified pipe and tank contents causing breaks in pipes around flanges and valves. These were discovered upon thaw when material began to leak during warmer weather. Unfavorable wind direction and speed postponed lab container crushing and overhead pipe decommissioning and caused debris to be blown from structures onsite. However, the threat of heat stress from working in level B protection during the summer months was primarily responsible for slowing site operations (see Special Bulletin "X"). In response to these hazards the OSC suspended operations during heavy weather and parts of the site were restricted to prevent access and injury from falling debris. In two cases the OSC, fearing catastrophic collapse and in response jto worker safety issues ordered the demolition of an overhead grain trestle and the familiar "OLD HICKORY" sign above building 161. The demolition of these structures was carried out only after a certified structural engineer condemned the structures as unsafe and a threat to workers' safety. In order to prevent injuries from heat exposures, an EMT was provided to monitor for heat stress. Additional and extended breaks were provided and a break area was constructed to provide shelter. Initial cleanup activities centered on the stabilization and cleanup of the five onsite laboratories. These labs contained thousands of common and special laboratory chemicals in various types and sizes of containers. A multi-agency assessment team consisting of ERT, ERCS, TAT, ThermalKem was organized to inventory each lab and divide the chemicals into known and unknown categories in preparation for labpacking operations. During these actions, the team identified a potentially extremely dangerous situation involving the lab chemicals. [These labs had remained virtually unchanged since Publicker abandoned the facility in 1983. These chemicals, past their active shelf- lives, were left to be degradated by the affects of temperature, s jnlight and moisture. Such was the Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 80 case in respect to the ethers that had been left onsite. Ethers when allowed to react with air (dry out) over a period of time will form peroxides, and the potential exists for the substance to become shock sensitive/explosive. In response to this threat, the OSC notified the Philadelphia Police Department Ordinance Disposal Unit to help in the assessment of this situation and directed ERCS to subcontract a explosives expert. As a result of these actions, 14 container were police escorted using Philadelphia bomb disposal equipment to the Philadelphia Police Academy for a controlled detonation. A secondary problem related to the overpacking operations was the total number of containers in need of labpacking. Over 300 labpack drums of known containers containing thousands of bottles were transported from the site for disposal, leaving 212 drums containing unknown containers. The OSC determined that the safest and most cost effective way to handle the chemicals was to remotely open the containers. Using a specially constructed roll-off box with a see-through blast shield at one end, the operator of an excavator would crush the lab containers placed by a RT in a layer of drum- dri to neutralize any reactions. The bucket of the excavator was out-fitted with a steel plate to allow a wider, flatter surface area to crush the containers. A transparent blast shield on one end of the roll-off allowed the operator to see inside the box; this also allowed the operator, in case of a reaction, to mix the chemical with the drum-dri to snuff the reaction. The entire operation was conducted in "level B" PPE with continuous air monitoring and monitoring of wind direction and speed. Operations were halted during unfavorable wind direction and for ship traffic on the Delaware River. In the end, 212 labpack drums were crushed for a total of 4,483 containers. As part of the Phase n stabilization efforts at the site the hundreds of miles of overhead pipes were to be drained of any contents, sheared and decommissioned. Two noteworthy problems that arose during this operation were the significant number of the pipes wrapped with asbestos insulation and secondly the vast amount of overhead pipes. To reduce the exposure from asbestos a special decon building was built for workers assigned to this task. A contractor was hired to monitor for airborne/friable asbestos. Pipes wrapped with asbestos were wetted with water, a section of asbestos was removed (glove-bagged) and then the entire section of pipe was wrapped with plastic. The pipe was then cut at that section and lowered to the ground. In an effort to expedite the pipe decommissioning, the OSC requested that sub-contractor be hired to video the inside of the pipelines, particularly on the south side of the site. Upon videoing the pipelines, none were found to contain any liquid. The pipeline posing no fire or explosion threat were abandoned in place. This technique saved thousands of dollars for the project and decreased the potential for accidents since workers did not have to perform tasks on the seriously dilapidated south side of the site. In addition to the obvious hazards presented by the chemicals abandoned onsite and the physical hazards from the poor integrity of the structures, another problem was the unauthorized trespass of vagrants and personnel wishing to steal copper wire, stainless, aluminum and other valuable scrap metal for profit. This presented an obvious problem for site security since these individuals would routinely enter the site, cut, in some instances burn with a torch, and vandalize the property searching for the metal. The OSC has documented many instances of trespass, forced entry, and unauthorized removal of metal and copper wire. The OSC has written Special Bulletins, POLREPS and other memorandums seeking advice and guidance in an effort to lessen the extent of the problem. However, solutions were less than effective in solving the problem. Additional guards were added at a significant cost to the project; buildings were boarded/secured and in most cases resecured on flRU00293 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page 81 a regular basis.^The Philadelphia Police Department was notified but the manpower and resources necessary to aefa£a significant deterrent could not be committed. The suggestion to have guards or police officers patrol the site was rejected due to the potential for provoking an unnecessary incident, putting personnel at risk. The suggestion was also rejected because of the potential for exposure of personnel to chemicals and physical hazards at night since proper lighting was unavailable given the site conditions. APPENDICES Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report Page ASS A. Site Map and Sketch

TDD Number- :9210-145B

SITE LOCATION MAP PUBLICKER INDUSTRIES NPL SITE I* 0 0 2 9 6 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page AS6"

flR°°297 Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report Page A87 B. Kioto Documentation

i June 26, 1987 - Publicker Industries fire; emergency response.

flR400298 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page ASS

June 26, 1987 - Publicker Industries fire; eastward toward pier #105. Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report Page A89

June 26, 1987 - Coast Guard/Philadelphia FireTrJept. boats applying fire streams^ " ~"="=" " T --.-—-- ^ Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page A90

July 9, 1987 - Fire impacted area.

mooao Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report Page A91

December 1, 1987 : Onsite lab building #118 luring lab packing operations. PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page A92

February 6, 1988 - Onsite lab building #118; same lab table upon completion of lab packing operations.

AR^OOSOS Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report Page A93

December 16, 1987 - Onsite lab building #153 in "Old Hickory" building during lab pack operation. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page A94

December 16, 1987 - Onsite lab building #153 in "Old Hickory" building cleared of chemicals. Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report Page A95

December 16,1987 - Potentially shock sensitive chemicals found in lab #162. J ._:. :_ - .:..

HRI400306 PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page A96

December 16, 1987 - Additional shock sensitive chemicals found in lab #162 (primarily ethers). Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report Page A97

February 6, 1988 - Cleared lab area in building #162. PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page A98

December 19, 1987 - Ordinance disposal unit onsite to remove shock sensitive materials (14) for controlled detonation. Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report 1 Page A99

September 21, 1988 - Contractor onsite to nitrate. remove radioactive uranyl

'URU003I0 PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page A100

February 1988 - Reaction during remote' crushing of thousands of unknown lab containers. ;

AR^OOS Pubulicker Industries NPL Site I Federal On-Scene Coordinator's Report I Page A101

January 15, 1988 - Staging of known and unknown cylinders found throughout the site. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page A102

May 15, 1988 - discovery of buried cylinders on pier #106.

HRI*003I3 PubuUcker Industries NPL Site Federal On-Scene Coordinator's Report Page A103

April 1988 - Recovery trench for highly flammable n-butyl chloride that released from tank #252. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page A104

June 1, 1988 - ERCS acid neutralization operations.

RR400315 Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report Page A105

July 15, 1988 - ERCS begin neutralization operations of flammable acetaldehyde with ferrous sulfate. PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page A106

August 30, 1988 - Treatment of spent grain mash with fly ash and cement.

flRU003!7 Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report Page A107

November IT," 1988 - Securing of onsite building nUr the end of Phase

SRUQ03I8 PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page AI08

December 9, 1988 - Removal of rail cars containing ethylene glycol. PubuUcker Industries NPL Site Federal On-Scene Coordinator's Report Page A109

September 9, 1988 - Unauthorized personnel apprehended attempting to salvage metal from the south side of the site. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page A110

December 1, 1989 - Phase II plant decommissioning. Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report Page Alll

f v ; ERCS **«* 9f drum^ waste collected from dismantling of process lines. PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page A112

March 1990 - Dismantling of the "Old Hickory" sign.

flRl*QQ323 PubuUcker Industries NPL Site Federal On-Scene Coordinator's Report Page A113

March 1990 - Dismantling of the "Old Hickory" sign. Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page A114

March 1990 - Completion of dismantling of "Old Hickory" sign. PubuUcker Industries NPL Site Federal On-Scene Coordinator's Report Page A115

September 2, 1988 - Road #5 before decommissiomng. PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page A116

September 2, 1988 - Road #5 after decommissioning.

ARi*QQ327 Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report Page A117

April 27, 1988 - Grain trestle piperack before decommissioning PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page A118

April 27, 1988 - Grain trestle piperack after decommissioning.

AR4 0-0329 PubuHcker Industries NPL Site Federal On-Sceue Coordinator's Report Page A119

August 15, 1990 - GSX site specific contract; inside tank #238.

ARlf 0-0330 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page A120

August 15, 1990 - GSX site specific contract; inside tank #238 after completion of contract.

A-RUO-033 Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report i Page A121 C. Newspaper Articles

Page 10 ...... -—- PHILADELPHIA DAILY MEWS______Friday. July 24. 1987 •"'"• CITY & REGION "' "• s' - '•''"' Probes Old S. F'hila. Distillery

By RAMONA SMITH After giving Publicker two weeks on the ground. "We're inventorying Daily News Staff Writer . to launch its own investigation, the what we see." said Cardinal. EPA investigators are working EPA moved in under the federal Su- The intense heat slowed the work, their way acrois the 37-acre former Porfu^ Program that deals with po- which has been suspended in the Publicker Industries distillery in tcnnal hazardous waste sites.! hottest hours of ihc day. Workers South Philadelphia in search of 7J>c.re wf a s

flRUO-0332 Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page A122

Firef ight ers Stem Pubiicker By RAMONA SMITH wiih num.- lhati ftOO lanks. as well as ins Co. in I98ft, lie said the leak posed and JOE O*DOWO numerous dm ins. pipes and .small no threat n| pollution tn the nearby Daily News Staff Writers uaK , Delaware Ri\cr. nrcfightors yesterday were able tn "We hadn't e\en inspected iliisone The cleanup began after a'li^u- stem a leak of a highly UnmmnWc yd." KPA spokesman Harold Y. Vales alarm fire and .series ol' explosions chemical 01 the problem-plagued ^lul wulier yt-su-rday. "One <>Mhe_____that ripped pan ol ilic complex in Pnblieker distillery sue IP Sm»li workers happened to notice .the June. The KPA last month an- Philadelphia. " si aims tin Hie snow." " ; iwiineeii. it "would put up 51,75 mil- Environmental officials had leareti Kir(t)w;lilcrs. summoned shortly af- lion and look nvcr ihe ck-amip, dt- the leak would tmich offa tn;i]nr tire. i«.r 1 P-"i.. MKKX! h> as a hazardous scnhmij the site ;is a viniuil mm: The twu-gallon-a-minule it-ak in u m;ticruils iL-am worked with the KPA bomb that "poses 11 threat «t lire ami tank oi N-bmyl chloride ofi Dela- '" lr> l" pnipoini the source of.the explosion." ware,-\vcnuc near the Walt U'liitman Ic.-ikni a 12.000-jjall( mum k half-filled On Nov. 7. i an .exp!»- noon. the Knvirnnmenial Projection Tanker tniuks waited to vacuum up sion app'areiiity caused when a cut- Ascnc> saitl. There ux-rc nn injuries, ilu-chvtisu-al nnru ihc leak could be- itllg torch jointed oil !e!( m a pipe- no evacuations and no iur/ards I'm in topped line iliey were1 disiiKintling. atrbnrnu vapors, officials said Vales ->;m! oilicLat* luid no idea The KPA lias c.siimntcd ihu site "We were able to stem ifu- leak and wl>;it 'In' ctu-itunil mi^h.l luive been iuchides more tban 2 mi-llion gallons are in Hie process nl pnminnj;'MI-\ u-.i'd l«.r ;ii I'nMirlsor. ^'hicli soli| llie n[ ;icids. en!-: ami nllu-r liaxardnns binyl chloride mi., tankers lor irvat innniTui^illn^ tol'iiyiihinjaU't^ek- siihsiam-i-i mctil and disposal." Ann Cardinal, an KPA spokeswoman, said last m&nt. ' ' i / "We imend in remove ihc tnnkert; ^ " /15/ from tliu site as early as possible '^j tomorrow," -^ The F.I*A last month look o\er lag- ging cleanup operations ai 'he \ sprawling complex below ^attiwm A\enue. The 37-aero site is crammed

AR400333 Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report Page A123

EPA team cleaning solventJly>£LcA/i*—t' lea., .k, By Mark Wagenveld . ,The Philadelphia Fire Department $1.75 million cleanup of the site in inau.r«r stair vMur ^ood by with fire equipment as the the 3200 block of South Delaware A cleanup team from the U.S. Envi- EPA workers brought a vacuum Avenue, which PubUcker sold in ronmental Protection Agency was pump truck to the site to empty the 1986 to the Cuyahoga Wrecking Corp. brought into the old Publicker In- tank and clean up the spillage. of New York. dustries distillery site in South Phila- The leak of about two gallons a delphia yesterday to empty a storage minute was discovered yeste'rday irj The cleanup was prompted by a tank that was leaking a flammable a 12.000-gaIlon tank that was half-full five-alarm fire on the site in June industrial solvent, agency officials and contained n-butyl chloride, offij during which there were several said- cials said. They said the leak may! chemical explosions. After the fire, They said the work would continue have been caused by the recent cold EPA inspectors found numerous into the night and probably would be wave. , | drums and tanks of unidentified completed by today. ... . EPA is currently .conducting a| chemicals being stored there.

A R4 0-0 3 3 It Publicker Industries NPL Site Federal On-Scene Coordinator's Report Page A124

Price of cleanup setat$20 million Former distillery site needs years of work says the EPA ______i immediate damage to near- By Sonia UH1 by locations and residents. Ha said the $20 million The former PubBcker prica tag for the daanup distillery —• labeled as B firs includes $S million already and explosion threat by spam to stabilize Publicker federal officials —• recently Industries Ina Dangerous SUPER was placed on the official chemicals currently are Superfund "national priori- secured and stored at the fContinueo torn pag* t) ties list, "clearing the way for site. The removal process is facility was usad to produce the U.S. Environmental continuing, he said, and various alcohols by fermen- Protection Agency (EPA) to could take an additional tation and distillation. Jk? investigate and cleanup the nine months to a year to 1970s, production site. complete. and tha company usea EPA spokesperson By tha EPA approving to some tanks to stora fuel oils Albert Petarson said the pfaca Publicker on tha for othar companies. In defunct distillery satisfies national priorities list, tha 1986, the Overland Corpo- the Cfitiria to be placed on complex now is designated ration of Philadelphia the ntiional priorities fiat — under the federal Remedial purchased Publicker. 'and meaning the agency Program, which deals with later abandoned the araa suspects there is a long- locations posing a possible whan the owners declared term environmental threat (ong-tarm environmental bankruptcy. at the site, located 3223 S. threat. According to a reoort Delaware Ave. The racant action obtained from U.S. Rap "The situation was so ensures additional funding Thomas Fogliatta's office. extensive down there that it for the complex and an the site, at tha time. posed a serious ana immi- unspecified amount will be cont?;"3d more than 400 nent threat," he sard. needed for the remedial tanks, rail cars and tank cars With the £=A's anoroval process, he said, to "return "holding approximately two to designate the area as a the site to a safe condition." million gallons of hazardous priority, a two-year investi- materials. . .. Security gation will be conouaed to m^oLrSn^:S AW3T'n9?iS"P°?S°n'he,!e"^f"n?"n-?J"9'he measures were establish if any environmen- inadequate." tal damage to ine surround- be deared of dangerous Avenue near tha Walt Whitman Bridge. An Aug. S, 1987 Review- ing land and water occurred chemicals currently storsc Photo by Tom Mlhalek Chronicls article, reported on the 37-ecre complex. there. Following its ramovai that PubJicker was Tha study wilt determine the aggncy is sat co conduct EP£ officials suaoecttna begins to flake. purchased in April 1986 by the extent 01 the damage as an indabtn study tc deter- Diurr.tJtnc contains Hazard- Peterson sa;d the federal Cuyahoga Wracking well as iden:tfy the chemi- mine if extensive environ- ous W3s:ss. T^s o'celines agency currently is p~aymg Company of Great Neck. cals invoived, Pstenson satd mental damage on and ware used :o Transport i'CLiid for tha claan-up, but wouic N. Y. In November that year. some hazardous chamtcais around tha sue, Peterson from one tank to ancmer sue those responsible tor two Cuyahoga workmen «the srte are "known" and anc .1 could stiii hcic danger- the damage. Ths agency ware killed in an explosion others are "unknown." "They are davetaoing m ous substances. names Fublicker industries allegedly caused when 3 He said more than £20 warkptan so that the remov- Inc. and Cuyahoga Wreck- torch ignited oil left in a million Is needed to dean al phase is comoleta [and In addition, asbestos was ing'Company of Great Neck. pipeline. the site under the federal tha site] can move to the detecteo in buildings that N.y. The araa became the Suparfund law's Removal remedial phase." he said. are boarded up, Peterson "That doas not rule out target of s federal grand jury Program classification. Currently. dangerous said. In a solid form, asces- ether potential responsible investigation in 1987 wh' The broad-based Super- materials stored at Pubfick- tcs is not dangerous. Only parties," said Patarson.'Wg was allagad that off] fund law deals with hazard- er indude flammable liquids when the material becomes will, under the law. recover from Cuyahoga and ous waste srtes. Under its contained in galfon drums, "airborne" is ft a threat. He tha money from these land shipped hazardous nmpvai phase, ma EPA asbestos in the buildings, added tha substancs must responsible.." materials from Maryland to stabilizes contaminated and 300 miles of ba removed because it, In tha aariy 1900s. the West Virgins. Pufalidcaralso areas so it does not cause "processed" plumbing. "deteriorates overtime* and (Contrnuea on pace 38\ was charged, .with unlawful storage . of dangerous chemicals. Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report 1 Page A125 EPA could list former distillery as a priority site Will allow for more funding to be appmpriatediforcleanvp By Sonla LeIU:1 ',•.- --^ mor«. than tZ million at a ' Reprasantativasfromtha • Yatasaaidthatbyptidng Environmental Protection- .iho Silo on the uodated Agancy told public official 5*3^ national priorities list, which and residents last week of '? "is expected to coma out in plans to officially place th« sbc to ;18 months. puclfckar defunct.-' Publicker Indus- will be da signaled und a r the trigs. Inc; distiliaiy on ina-^Superiund's Remedial . Superiund "national priori^) Program, wnich is d*sig- 11183 lisC-liran: aBempt gar • nated for locations thai OOSB •mote:1 funding.-;- tor-r Iha*:;..chronic or tang-tango continued .-cleanup. ;"«f' '.'problems.1 • \ .hazardous materials at lh».f ^ -you can stiil hav» a fir* ,.,,i . ~ -.Wedrtesday.at tha Winner-1- 'irrigaa, two woiKera for ..So«lh-y ;..

trials said that the-art*. >Slnoa than, tha art* nas had currently is classified under several fires and a hazard- theRemovaiProgratnofthe ous chemical soill. j federal. Superfund. law. _._____..]-.._ •wMcn deals withppWntiaUy.v: THESTTE BECAME th« 'hazardous waste sites....--..- targ«ofafaderatg«nd|ury In an interview this week. -.Investigation two v^s ago EPA spokasman Harold . whan officials from; two Yates sari the site still is • companies affiliated w*h "extremely1 dangerous' and Pubiickef. Cuyahoga thatlhecleanuohascosl$7. Wrecking Corp. and the • minion. He added-that at Overland Corp., oi Ph|ladel- laast S3.5 million more is Pnia- wor» '"dieted w^h an neadedtoclearhoidanger-. alleged, illegal scheme to •ous materials, including ship hazardous wastes to flammabieiiagids.asbestos Maryland and West from inside the buildings. Virginia. I and savafal miles of plumb- '" connafflion witfi the ing That is susoected of investigation. Publicker containing hazardous . • Industries inc. was cnargad wastes.' .' . with illegal storage o! ;l >r hazardous wastes. 1 "THEPUBUCX6HSITE" .. Yates said.ii would tak» is costing us a tat of money. -. about: five-more years to lodean up,' said Yatss.'AP ,clear trt» .37-acre Pub I teker present, it is a removal (pro-, sitaof.tntdangarousrnater- gram}. . .itoosesapoten-' ials. Undar-.tna.Remedial ttai threat of (fro and expto- listing, lh» ar«a-could gtt sion. We can only gat $2 unsDOcilied •-.". addiltanal miilion at a snot for removal funds lonthe deanup. sites. .- • , •* He said that the danger- "Wq'r*t honing that •Houswasteremovaitinocas- Publicker will maka" tha [na- ' sary before tha EPj* can tionalDiiotitmsliist.'hesaid. cqnduct a two-year invasti- "Hitdoas.uwillbealigibiefor (CommuflO en 0399 39) "~~ ——— — ^-|

WASTE P IConiintieti Imm paqo I) ' ' ... |. gallon on tha safety at the employee in charge of tha disposed, including raborat- sakj gat to wotk." he said. — site, . :-_=fr_.— =...removal opnration al ory chemical materials and "They've1 don* a considar- 3- Publicker. said that various flammable solids. In addi- able amount of work thare uj IN AN INTERVIEW this • hazardous chamicats have tbn.sevaralhundredqrums already to aliminat* the > week. Lisa Yates, an EPA been removed and of material that is constd- lmmeoiat» threat The rr ered'notpriority'havebflfln threat that originally was stored in the araa. and van- there has bean greatly ous buildings 'were diminished, but (thinkthere boatded-up because! thay Is more work that has to- are suspected to contain done." asbestos. I However. DiBerardinis In an interview mis week, said on* of!teat staled that aide to U.S. Reo. Thomas the moating should have Fogiialta, Michael OiBerar- bean held closer to the dimdinis^ said that thee officialof|tcials Publickersite.lnaddition.iPublickersSa.lnaddition.it art! JAfTl'iJQC and residents who aitanded c»uW hav» r«cerved batter flK*4UUOwD Ihe mooting suoporied the no til i cation. " EPA's decision, "B wasn't a big crowd. 'srvbody Cloartv it was not publicixvd PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page A126

Numerous projects , ... EPA is proceeding apace with local sites To tha Editor: that EPA has solved urgent sue way at over 8SO and essentially liealth and environment, Born m 1981 after the gnm les- contamination problems at al- completed at about 40 sites, in- Superfund sites present tin- sons of Love Canal, the Super- most 1.200 emergency sites na- eluding Enterprise Avenue in structured engineering problems fund program for cleaning up nonwide. The Inquirer has cov. Philadelphia and ASM Wade in with the amounts, locations and hazardous waste sites has long ered many of the emergency Chester. . origins of contaminants not usu- been controversial. Most re- actions, such as the soil removal Also, on a national scale, we arc -3fiy well-known. Sites range vast- cfcnlly. The Inquirer reported on from back yards in Paoli. the re- on track toward meeting key ...jy m size, are situated in highly 'WO critical assessments — one moval of dangerous materials mandates of the Superfund Jaw. urbanized areas as well as deso- by the Office of Technology As- from the Publicker site in Plitla- Furthermore. legal. settlements jate locations and involve a large sessmcnr, the other by a coalition delphia and from the ASM Wade :otaling almost $700 'million have variety of chemicals Superim- MI environmental groups and sup- --i*e rnCf.L-ster.i he excavation of been reached with; responsible nose on this the many" important pliers of hazardous waste ircai- -aicnals releasing explosive gas- panics, such as Harvey & Knoti faclors tnat must be weigned in meat systems. These critic* «.sinmnome$ m Rajn;ree Village in Delaware, the Paoli site and reacnin« decisions about rcmedi charge that the Environmental .=. Delaware and many more. Tyson's Dump. EPA has devel- a=d ' * h comnjex Protection Agency is not mce:ing A; sites undergoing larger- oped cases valued at about S260 ^ ^mandn becomes tht; new law's mandates for -xrm remediation, we are also million against those liable for -^' *t seieCTPd rpmedie-; achieving permanent remedies making considerable progress, the agency's past costs. nWr'fff «:tr«i«inc In th» ^it- through treatment technologies Locally, we are beginning to dis- Turning to the issue of perma- °. r lr; 00, , V ",. and that the remedies are incon- manile the Unsdowne radiation nent remedies, sinfce the 1986 na in tne^iyae law. uur remedies •iiwcnt from sue to site. While the house, and a responsible pany is amendments, we have used treat- are Dased on careiui tecttmcai operation of Superfund is by no using a new technology to re- ment in about 70 percent of the equations o>.experienced engi- means perfect, the Washington move solvents from the soil at site remedy decisions. This per- neers and scientists in the field. insiders and lobbyists attacking Tyson's Dump Site. centage is right on target consid- And *ney are arrived at only after tb.« program would lead you to From the national inventory of ering we are also required by law those citizens most affected have bsli*ve that very little is getting some 29,000 potential Superfund to be cost effective., to consider been involved. don«. This ts not only untrue, but sites. EPA has completed prelimi- state and community reaction, to J- Winston_ Porter also a disservice to thousands of nary assessments at over 26,000. abide by other siate.and federal Assistant Administrator dedicated federal and state em- More than 1,150 of these have environmental requirements . Environmental Protection ployees and private contractors, been placed on the National Pri- and, most important, to ensure Agency The unequivocal good news is orities List, where work is under overall protection of human Washington.

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The defunct Publicker Industries distillery complex, located under and north of the Walt Whitman Bridge, contains caustic and potentially explosive chemicals. A boiler house next to the bridge, wild stx 75-foot smokestacks, has been found to be structurally unsound. The complex was designated a Superfund cleanup sits in 1987. ost photo trf Curt Hudson

4Abandone A . COURIER-POST, Friday.d Hay 1tdistiller. 1989 y under bridge called public safety threat Contjnowi from Page 1A cautious but not worried. Ho snid the report allows the Jeffery P. Winegar. EPA to say it warned the appropri- Tne federal government will ate agencies, and thus absolve spend an estimated $22 million itseiffromliabitlty.incaseacatas- before the property IB safe enough trophe occura. for a: thorough remedial study, and But Woodruff also said he has even then, more wastes may need no real way of determining the to bi removed, he said. likelihood of an explosion that An 'EPA Superfund fact sheet would damage the bridge because released In March says that just the EPA. which keeps the site before a fire and explosion at the under 24-hour (tuard. has not site In June 19S7. Inspectors disco- invited the DRPA engineers to vered1 «hock -sensitive and expio- inspect the facility. sive; •materials throufhout the '______facility. r- ———— "-" ' ————————— Six months later, the EPA undertook a yearlong project that included removing some of the more reactive chemicals and hous- ing the wastes in tanks and drums at Piibllcker for future removal to permanent sites. Today, the temporary 'Contain- ers, .which still contain the chemi- calst have grown dilapidated with age and wear and could break or teak: If chemicals from damaged containers mix, they could explode. "£ndm« of the waste materials from^hese drums and tanks are incompatible, and if mixed together, could result in the forma- UonXrf dangeroua compounds." the study saya. Aside from the known chemicals stored in the tanks and drums. more than 20,000 gallons of unknown waste chemicals are stored in 300 miles of surface plumbing at the site. Yatas said some of the chemicals in the pipes are flammable, but the EPA doesn't know exactly what's them "We don't know what's in it, so we Mew it is a hazard," Yatea John R. Woodruft chief engineer for tha Delaware River Port Auth- flRti00339 ority ' (DRPA), which owns the Wait Whitman Bridge, said the - Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report Page A129

fhe controversy sions has largely die|d American bishops suggested ca- ling the meeting. B.ut the Pop*. wanted to go ahead with the meeting

EPA TO HOLD PUBLIC MEETING FOR COMMENTS QH THE PUBLICKES StJPERFOND SITE PROPOSED PUN What EPA To HJDld Public Mealing On Comments Concerning the Publicker Superfund Site Where: Winnet Sjouth Philadelphia Community Center located at 2600 S, ,Broad Street at Shunk Avenue Whare March 15,1989 Time: 7:00 pm PirtJdpautt: Representatives of tha Envi- ronmental Protection Agency Purpose: To Discuss, and Accept Com- ments on the Proposed Plan to Remove Hazardous Mate- rials Storedi on the Site Anyone wishing to be placed on the mailing list, or seeking information re- garding the Publicker, Superfuna Site. should contact Harold Yates at the follow- ing address: Harold Yates Office of Pubiice affairs (3PAOO) EPA Region ill 841 Chestnuti Building Philadelphia, PA 19107 215/597-^825 PubUcker Industries NPL Site Federal On-Scene Coordinator's Report Page A130

Council. election whether tie received the But Kelly denied, that. "I told him I Thai policy comramee is to meet GOP endorsement or not. and that he could not endorse him or HopKins." onlgfatai the home of Commissioner mignt cross-file to run in both the he said. "They would have to come can Gemhert. who represents the Republican and Democratic prima- before the policy committee."

THE IKS. ENVIRONMENTAL PROTECTION AGENCY (EPA) SEEKS COMMENTS ON .PROPOSED REMEDIAL ACTIONS TO STABILIZE CONDITIONS AT THE PU3UCXEH INDUSTRIES SITE LOCATED ON DELAWARE AVENUE, IMMEDIATELY NORTH OF THE WALT WHITMAN BRIDGE \H SOUTH PHILADELPHIA. The EPA has prepared a Proposed Plan describing Interim remedial actions intended to minimize risks posed by the site to human hedth and the environment and to prevent the occurrence of an emergency situation caused by a fire or explosion which could occur if no action is taken. Copies of the Proposed Plan may be reviewed by appointment at the U.S. EPA Region 111 Library, 841 Chestnut Street, Philadelphia, PA. Interested parties desiring to meet with EPA representatives to discuss the proposed plan should submit written requests to the officials listed below, no later than March To, 7939. From 1912 to late 1985, the Publicker Industries Site served as a liquor and industrial alcohol product distillery. During the late ]970's and early 1980's, the facility was also utilized for petroleum product storage. In 1986, site activity ceased and on-site demolition began. In June 1937, a portion of the facility was destroyed in a multi-alarm fire during which numerous explosions and fire flares were reported. Following the fire EPA Emergency Response Personnel evaluated the site and determined immediate measures were required to control and itabltze conditions. Subsequent action by the EPA's Removal Program haj resulted in a significant surface cleanup at the site and the bulk staging of various waste streams in tanks and drums. The threats to public health and the environment remaining on the site can be separated into five categories: I. Fife end/or explosion. 2. The presence of potentially hazardous chemicals stored on site. 3. The potential migration of oils and other hazardous wastes into the Delaware River. .-f4. The presence of friable asbestos. . ' , . S. Air release* from deteriorating storage vessels. EPA is considering the interim remedial alternatives described below to address the imminent threat posed fay current site conditions: 1. NO ACTION: This alternative would not minimize or elfminorte, to any extent, the immediate, and possibly catastrophic threat to human hedth and the environment that currently exists. In addition, this alternative does not satisfy the statutory mandate to utilize permanent solutions, nor does it comply with current statutory requirements. 2. COMPLETION OF SITE STABILIZATION ACTIVITIES: Under this alternative, the issues that continue to pose the fire end/or explosion threat will be eliminated by the following actions: 1. The transportation and disposal of the known remaining waste streams on site: 2. The demolition of above-grade process lines that traverse the site including the potential recovery of unknown hazardous chemicals and the removal of pipe insulation materials. 3. The proper packaging of the insulation materials removed from the process lines. „ A. The transportation and disposal of any hazardous materials recovered from the process lines. No other alternatives were considered at this time because of the severe threat posed by current site conditions. However, EPA anticipates initiating, in approximately April 1989, a Remedial Investigation/ Feasibility Study to further evaluate any soil or groundwater contamination. EPA's preferred interim remedial action Is Alternative 2, because it will; 1} permanently reduce the volume, mobility, and toxicity of contaminated materials; and 2) reduce or eliminate the current threat to public health and the environment. No final decision has been made. EPA encourages concerned parties to review the Proposed Plan and other site-related materials at the EPA Region HI library and to make comments in writing during the thirty (30) day comment period beginning March 1, 1989 and ending March 30, 1989. Comments may be addressed to: Harold Yates Public Affairs Specialist (3PAOO) (J.S. Environmental Protection Agency S4J Chestnut Street Philadelphia, PA 19107 Jeffrey WTnegor Remedial Project Manager (3HW2I) U.S. invirenmentaJ Protection Agency , S41 Chwtnut Street fl'R U 0 0 3 U S Philadelphia, PA 19707 H 11 <* U U U H \ Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report Page A131

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THE _NEW YORK TIMES NAT

Fire Guts an Old Philadelphia Distillery and Closes a Bridge at Rush Hour Smoke from a four-alarm fire at the abandoned fear smoke would blind motorists. The Eire was a Publicker Industries distillery billowing in to the setback for the cleanup of chemicals, at the water- sky over the Walt Whitman Bridge in Philadelphia, front site, the federal Environmental Protection Trie blaze shut the bridge for about two hours for Agency said. Cause of the fire_was undetermined. Pubulicker Industries NPL Site Federal On-Scene Coordinator's Report Page A135 D. Funding Documents and Declaration For The Record Of Decision

OflG (Re, SPECIAL BULLETIN A SUBJECT: PUBLICKER INDUSTRIES SITE DELAWARE AVENUE, PHILADELPHIA, PA

DATE: DECEMBER 8, 1937 TO: STEVEN R." WASSERSUG, DIRECTOR, HAZARDOUS WASTE MANAGEMENT DIVISION

THRU: ROBERT CARON, ACTING CHIEF, EMERGENCY RESPONSE AND PREPAREDNESS SECTION ATTN: TIM FIELDS I. INTRODUCTION -

A PRELIMINARY ASSESSMENT WAS PERFORMED . B|Y THE U.S. EPA ON-SCENE COORDINATOR IN ACCORDANCE WITH THE NATIONAL CONTINGENCY PLAN AT THE PUBLICKER INDUSTRIES SITE ON DELAWAREJ AVENUE IN PHILADELPHIA, PA WHICH RESULTED IN A RESPONSIBLE PARTY SITE STABILIZATION VIA AN ENFORCEMENT ORDER.

UPON COMPLETION OF THE STABILIZATION, A SITE INSPECTION WAS MADE BY THOMAS MASSEY .(SUPERFUND BRANCH), DR. WALTER LEE (ENFORCEMENT BRANCH LEAD) AND THE ' ROY F.. WESTON TECHNICAL ASSISTANCE TEAM. DURING THIS VISUAL ' INSPECTION THE FOLLOWING SITE CONDITIONS WERE OBSERVED: -- - -- ..-.-.-—— ------

- LARGE VOLUME STORAGE TANKS HAVE NOT BEEN CERTIFIED AS EMPTY, .... - - - - - ' - A LEAKING TANKER WAS OBSERVED ON SITE. - THE DRUM STAGING AREA IS CURRENTLY NOT BEING PROPERLY MAINTAINED. | - - UNKNOWN LABORATORY CHEMICAL ARE STAGED IN AN UNSTABLE BUILDING. - WORKERS WERE OBSERVED SMOKING ON SITE. - NO FIRE FIGHTING EQUIPMENT IS AVAILABLE ON SITE.

II. BACKGROUND

THE PUBLICKER INDUSTRIES SITE CONSISTS OFJ AN ABANDONNED CHEMICAL PROCESSING FACILITY. WHICH CONSISTS OF OVER^ 400 BULK STORAGE TANKS SPREAD OVER APPROX. 36 ACRES. AN INTENSE FIRE RESULTED IN THE CLOSURE "OF THE WALT WHITMAN BRIDGE AND THE EVACUATION OF THE LOCAL RESIDENTS. FOLLOWING THIS FIRE, AN EPA ASSESSMENT RESULTED IN A RP- ACTION TO STABILISE THE SITE WITH EPA ENFORCEMENT AS.' LEAD. FOLLOWING THE STABILIZATION EFFORTS BY THE RP, 'THE PREVIOUSLY MENTIONED OBSERVATIONS WERE MADE QW t/1/3*7 VISUAL INSPECTION. III. THREAT THE PUBLICKER INDUSTRIES SITE CONTINUES TO PRESENT A FIRE AND EXPLOSION THREAT DUE TO UNSTABLE CHEMICAL STORAGE AND LEAKING TANK AND PROCESS LINES. THIS FIRE AND EXPLOSION THREAT HAS BEEN CERTIFIED BY THE PHILADELPHIA FIRE MARSHALL'S OFFICE.

IV. SCOPE OF WORK

UNDER THE $ 50,000 EMERGENCY FUNDING, THE OSC PROPOSES TO STABILIZE THE THREAT PRESENTED BY MOVING LABORATORY CHEMICALS TO A STABLE AREA, ESTABLISHING FIRE FIGHTING CAPABILITY ON SITE, OBTAIN PROFESSIONAL CERTIFICATION OF THE PROCESS LINE AND TANK INTEGRITY, AND ESTABLISH A MAINTENANCE SCHEDULE FOR THE DRUM STAGING AREA.

V. OSC ACTION

BECAUSE CONDITIONS AT THIS SITE MEET THE CERCLA CRITERIA FOR INITIATION OF EMERGENCY ACTIVITIES, THE OSC HAS ACTIVATED THE $ 50,000 EMERGENCY FUND FOR THIS SITE AT 0900 HR, 12/8/87.

DAVID WRIGHT, OSC U.S. EPA, REGION III UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 841 Chestnut Building "-' Philadelphia. Pennsylvania 19107

SUBJECT: Additional Funding Request for the Publicker DATE' Industries Site, Philadelphia, Philadelphia County, Pennsylvania FROM; /James M, Seif ^••Regional Administrator (3RAOJJ) TO: / Dr. J. Winston Porter, Assistant Administrator for waste ana Emergency Response (WH-ObiiAJ

ISSUE

The attached CERCLA Funding Request pe::tains to the Publicker Industries Site, Philadelphia, Philadelphia County, Pennsylvania.

A preliminary assessment performed in accordance with the National Contingency Plan by my staff and_che Technical Assistance Team staff has identified potential threats to human health and the environment posed by fire, unknown' potentially hazardous chemicals, unknown waste oils migrating off site into the Delaware River, and significant amounts of friable asbestos.

BACKGROUND

Subsequent assessments revealed conditions at the Publicker Industries site meet the criteria in Che NCP Section 300.65, pursuant to the Delegation of Authority 14-1-A (5-1-85) as amended by Superfund Amendments and Reauthorization Act (SARA) of 1986, which authorizes the Regional Administrator to approve CERCLA Removal Actions with a total cost of less than 52,000,000, I have approved CERCLA funds to mitigate the threat to public health presented by this site.

Attachment UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 111 841 Chestnut Building Philadelphia, Pennsylvania 19107

SUBJECT Additional Funding Request for the Publicker Industries Site, Philadelphia, Philadelphia County, Pennsylvania FROM: David Wright, Sr. On-Scene Coordinator/ Emergency Response and Preparedness TO: James M. Self Regional Administrator (J&AUU) .-• THRU: Stephen R. Wassersug, Director, ' \/ Hazardous Waste Management Division (3HWOCO y

I. PURPOSE

This is a request for additional funding to continue the removal actions at the Publicker Industries Site, Philadelphia, Philadelphia County, PA. A site assessment, performed in accordance with the National Contingency Plan, has revealed potential threats to human health and the environment at the Publicker Industries Site, Philadelphia, Philadelphia County, PA. The threats include potential fire and explosion, unknown potentially hazardous laboratory chemicals, unknown chemical compounds migrating off site into the Delaware River, and significant amounts of friable asbestos.

Ac this time, EPA Region III is requesting CERCLA funding in che. aaounc of $1,702,000 to determine the structural integrity of tanks and process lines on the premises, inventory and secure laboratory chemicals, determine the identity and amounts of hazardous materials present, determine the extent of asbestos debris and potential airborne public health threat due to this asbestos, and establish security and fire'watch.

II. BACKGROUND

The Publicker Industries Site is located adjacent to the Walt Whitman Bridge and Ashland Chemical on Delaware Avenue in Philadelphia, PA. The area is primarily industrial. Several major transportation routes are located within a half-mile radius.

The site consists of a chemical distillation process which has been inoperative for approximately two years. The site is approximately 37 acres in size including nearly 440 large storage tanks, drum storage, product stock and chemical laboratories. Many of the existing structures have been compromised by weathering, fire and neglect. The facility has three waterfront piers that extend into the Delaware River. -2-

In June of 1987, the carbon dioxide utilization portion of the facility was destroyed ia a multi-alarm fire. Du.ring this fire, numerous explosions and fire flares were observed leading fire officials and EPA Emergency Response personnel to believe that chemical product-was still present at the facility.

An initial site entry was performed by EPA and their support staff on July 9, 1987. City of Philadelphia representatives were also on site to inspect portions of the site which were not affected by the fire. Numerous spill areas, improper drum storage and leaking process lines were observed by the entry team.

EPA Enforcement secured a Consent Agreement/Order with the responsible party for immediate site stabilizanion. Upon completion of the responsible party's stabilization efforts, a site inspection was .performed by Thomas Massey, Superfund Branch, Dr. Walter Lee (Enforcement Branch Lead), and Technical Assistance Team (TAT) staff. During this visual inspection, the following conditions were observed on the site:

o Large volume storage tanks have not been certified as empty; o a leaking tanker was observed on-the site; o the drum staging area is not being properly maintained or secured; o unknown laboratory chemicals are staged within an unstable facility; o workers were observed smoking on the site; o no fire fighting equipment is available on the site.

On December 8, 1987, OSC activated the $50,000 emergency funding pursuant to the Delegation of Authority 14-1-Alin order to mitigate the threat posed by conditions at the site.

III. THREATS

The threats to human health and the environment can be separated into four catregbries:

1) Fire and explosion with the associated hazardous, i.e. smoke, harmful vapors, explosion, associated with residue tank and process lines;

2) presence of potentially hazardous unkncwn chemicals stored in unstable building; -3-

3) potential for the migration of oils and chemical mixtures into the Delaware River;

4) friable asbestos in the buildings and on various process pipes throughout the facility.

5) vapor-emissions from the on-site drum staging area, which is in disrepair.

The potential threat cf fut^ri fine e~ the r-bltckcr Sice is extreme. There have been fires in the past and the fire threat is deemed to be very high by the City of Philadelphia Fire Marshall Office. The facility is in very poor condition due to past fires, demolition on the site, neglect and vandalism. These are all contributing factors to the occurrence of future fires at the'site. Many of the process and storage buildings contain considerable amounts of wood construction, some of which are over 50 years old. There are many spill areas of unknown composition, some of which may have the potential to ignite. A fire could easily cause drums staged on site to rupture or even explode, releasing unknown chemical contaminants into the environment.

During the demolition of several buildings in the facility, over 140 bags of asbestos waste were generated. These bags of waste asbestos were found stored in.two areas of the facility as well as a large (25 cubic yards) asbestos disposal rolloff container. This material was disposed of during responsible party activities; however, process asbestos remains throughout the facilty.

Triable asbestos has been proven to cause lung carcinoma and lung mesothelioma after significant personal exposure. At present, asbestos exists in such a condition where it can migrate off site, thereby posing a human health threat off site.

IV. ENFORCEMENT See attached "Confidential Enforcement Status". V. PROPOSED PROJECT AND COSTS Proposed costs are as follows:

CURRENT CEILING: ERCS $ 35,000 TAT _ 10,000 ' EPA - 5,000

SUBTOTAL: 50,000

REQUESTED ADDITIONAL FUNDS:

ERCS Stabilization and Control 500,000 Line and tank survey 200,OOu Inventory, "segregation "and lab packing of 60,000 laboratory chemicals Fire prevention and control measures 230,000 Analytical services 240,000 Emergency disposal 100,000

TAT 100,000

EPA 50,000

PROJECT COSTS SUBTOTAL: 1,480,000 EPA HQ 15% 222,000

TOTAL PROJECT COSTS: 1,702,000

NEW CEILING:

ERCS 1,365,000 TAT 110,000 EPA 55,000 HQ 222,000'

TOTAL PROJECT CEILING: $1,752,000 -5-

VI. CONTRIBUTION OF REMEDIAL PERFORMANCE As part of the removal action at the Publicker Industries Site, this action memorandum Is consistent with Section 104(b)' of SARA, which requires that removal actions contribute to the performance of long-terra remedial action. -Through this assessment, EPA personnel will be able to properly categorize the wastes on the site. With this new information (Identification of unknowns, extent of contamination, determination of structural Integrity of tanks and process lines) it will be possible to define appropriate future remeaiaj. measures and to better determine the public health threat posed by the site. The activities outlined in this removal action provide a plan, which is consistent with and "contributes to efficient performance" of future remedial actions as outlined In Section 104(b) of SARA.

VII. REGIONAL RECOMMENDATION

Because the conditions at the Publicker Industries Site meet the criteria set forth in the National Contingency Plan, I recommend your approval of this funding request. The total estimated removal project cost is $1,752,000 of which $1,475,000 is for extramural costs.

You may indicate your approval or disapproval by signing below:

APPROVAL _^3>_ *• H-- •_ L^t. xTV>^^^ DATE

DISAPPROVAL " DATE

AR400353 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. ;»0460

APR 6 1988 OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE

MEMORANDUM SUBJECT: Region Ill's $2 Million Exemption ant| Ceiling Increase Request For Continuation of Removal Activities for the Publicker Industries Site, Philadelphia, PA — TRANSMIT^!. MEMpRANDUJ FROM: Timothy Fields, Jr., Director // i Emergency Response Division THRU: Henry L. Longest II, Director Office of Emergency and Remedial Response TO: J. Winston Porter . Assistant Administrator

Attached is a request from the Region III Regional Administrator for a ceiling increase of $4,912,500 to continue removal actions at the Publicker Industries site. If approved, the total project ceiling will be raised to $8,239,500, of"which $6,995,000 isjfor extramural cleanup contractor costs. Also attached'is the Publicker Industries Site, Philadelphia, PA, $2M Exemption Request memorandum, dated March 11, 1988, documenting your authorization for the Region to expend $1,375,000 above the $2 million limit to continue onsite activit'es .until the original exemption request was processed. The Regional exemption request and addendum will provide funds to stabilize this site, not to perform a complete cleanup. The proposed actions, described in option number seven, include addressing the fire and explosion threats, leaking tanks and piping, migration of hazards into the Delaware River, -and the bulking of chemical wastes. The Region will stabilize materials and seek-disposal through the issuance of 106 orders to potential responsible parties. The option being recommended by the Region is, consistent with your direction at the March 29, 1988, briefing on this site. We recommend that you approve this request by signing the April 6, 1988, Addendum to the Region's Action Memorandum. Attachments (2) Within 3/4 of a mile are the cities of Gloucester and Camden, New Jersey. Estimated population within 1 mile is approximately 400,000. Three schools and two hospitals are located within a one and one half miles radius of the site. The OSC considers the site to be a time-critical removal/ and at times it has become a classic emergency. Examples of these emergency occasions include the fires of 1985 and 1987 (involving chemicals), the discovery of explosive and shock sensitive compounds, and the January 1988 release of n-Butyl Chloride. Since the early 1900's Publicker Industries operated this 37-acre site, primarily as a manufacturer of alcohol products. The site has also been used as .a Petroleum Product Storage Facility (late 1970's-80Ts). Over the last several years hazardous wastes from this site have been discovered in four States (Maryland, Delaware, Virginia and West Virginia). The Removal Program took action at sites in three of the four states. Several individuals have been indicted and entered guilty pleas in reference to the illegal storage, transportation and disposal of hazardous wastes that were generated at 'the Publicker facility and transported to the sites in Maryland and West Virginia, (Oakland Site and Cummings Site) . Currently the site is inactive. The following is a list of manufacturing processes conducted at the site and the approximate year when each process was terminated: Butyl Ether 1981 . -,- ,- - Butyl Chloride 1981 ...... _ Ethyl Acetate 1978 Synthetic Alcohol 1982 Butyl Acetate Early 1970's Acetic Acid 1977 Fermentation Alcohol 1977 Distilled Dried Grains Mid 1970's Ethyl Ether 1982 Ethyl Alcohol 1980-1981 In addition to the above activities, the site was used as a petroleum product 'storage facility from the late 1970's to the early 1980's. The following observations and physical characteristics of the site are noted: (3) * An estimated 450 storage-tanks, rail..cars and tank cars, ranging in size from several hundred gallons to five million gallons exist on sits. Approximately lief of these tanks contain wastes which are estimated at a total of two million gallons. Among the waste streams are base neutral liquids and solids, acids and acid solid^, flammable liquids, organic liquids, oxldizers, peroxides and chlorinated compounds * There are four chemical laboratories with an estimated four thousand containers of known compounds and two thousand containers of unknown material. The known compounds include organic and inorganic acids, shock sensitives, explosives, bases, organic peroxides, flammable solids and liquids, water reactives, air |rea'ctives, light sensitives and poisons". * There are 100 gas containing cylinders containing poisons and highly flammable/reactive gases.. .Numerous cylinders also on site- contain unknown materials. * An estimated 150 pieces, of electrical equipment are on site, 25 of which contain PCBs at concentrations above 500ppm. * There are several hundred miles of above and below ground piping and transfer lines that may contain1 hazardous materials. The nature and type of hazardous materials is unknown at this time. The City of Philadelphia has reported that some of the lln.es ,run to other portions of the city (former" Publicker sites,) . * An estimated 800 drums with product-exis: onsite (acids, bases, flammable organic liquids, poisons, PCBrs, etc.). * Asbestos-covered tanks and prpces.s l_in_ss exist throughout the site . ' * The site, is- adjacent to an estimated eleven hundred feet of the Delaware River. There are several discharge pipes of unknown origin from the facility along the waterfront. One of the discharge points has a continual sheen associated with it Within 3/4 of a mile (across the river) are the Cities of Gloucester and Camden, New Jersey. In the pvent of an air release, fire or explosion and with the right meteorological conditions. Region II could potentially be affected. (4) * There'are approximately 20 deep production watef^wells on the site (100-200 ft.). These wells were constructed 40 years ago and have not been decommissioned. Several of the wells penetrate the Raritan Formation (a major aquifer). There is documented contamination of the shallow aquifer, however, it is unknown at this time if the deeper wells are contaminated. The Commonwealth of Pennsylvania is currently in the PA/SI stage of the Remedial Process. The Region is actively working with Pennsylvania to expedite the pre-remedial investigations and rank the site for possible inclusion on the NPL. The city of Philadelphia -supports the removal action and is so concerned about the site it has developed a Site Specific Emergency Plan, which addresses evacuation of residents and businesses as well "as shutdown procedures for the Walt Whitman Bridge and Interstate. 95. - - Following a fire in June of 1987, EPA emergency response personnel responded to the scene to evaluate the situation. At that time the OSC performed a site assessment and determined that the site required immediate control and stabilization measures. Activation- of the Fund was not needed at this time because of the willingness of a PRP (Publicker) to perform the necessary actions. Publicker responded to the OSC's verbal notice and agreed to enter into a CERCLA Section 106 Order with the Agency to address the site. From June to December of 1987 this PRP performed activities pursuant to the CERCLA Section 106 Order. At the end of this period, the Enforcement Compliance Officer requested Thomas Massey (Superfund Branch) to assist in evaluating the PRP'S actions. The PRP's actions' included a site assessment, drum staging, some lab chemical segregatipn, disposal of some flammable liquids, site security,'and securing of some leaking pipes. - - - : ...... The' evaluation of the PRP's actions was performed on' 12/1/37 by Thomas Massey and the TAT. A brief list of what was noted is as follows: *Tanks were not certified as empty *A leaking tanker was observed on site *The drum staging area was not being, properly maintained *0nknown laboratory containers were located in unstable buildings *Workers were observed smoking on site *No fire fighting equipment was available on site

flRlt00357 (5) The results o5 Thomas Massey!s evaluation were documented in a December 1, 1987 memo and the memo is included as an attachment to this document. After the evaluation was completed the OSC determined that the site required immediate action. The -PRP's actions did not adequately address the threats at the site and the OSC determined., that it was in the best interest of protection of public health, welfare and the environment to activate the Fund and address the issues identified in the 12/1/87 memo. The PRP's-were no'tified of the findings and the Agency's .intent to proceed.with a Removal Action,, The OSC met with "the Office..of Regional Counsel, Enforcement, PRP representa- tives .and the EPA ERT. At the meeting it was determined that the Federal Government would remain lead and focal, and continue with the clean up. The OSC initiated an emergency response on December 8, 1987. This action was initiated by the OSC using £50,000 Delegation of Authority (1J4-1-A, 9/13/87). On December 9, 1987 the Regional Administrator approved a Funding Increase of $1,702,000, bringing the Removal Ceiling to $1,752,000. In March, 1988, the Regional Administrator approved an Intermin Funding Request for $200,000 bringing the Removal Ceiling to $1,952,000. On March 11, 1988, the 'Assistant Administrator of the Office of Solid Wastie and Emergency Response gave verbal approval to exceed the $2M statutory limit and authorized an additional $1,375,000 bringing the total project ceiling to $3,327,000.

The site is not currently on the National Priorities . List (NPL) but as noted the Region is working towards that goal in an expeditious manner. In spite of the Region's effort 'it. is-possible that the NPL listing process tak-e several years s may :...... -'----— ' -•--——• •-

III. STATUTORY CRITERIA ^ .... ~ • - The manner in which the. former Publicjker Industries Site meets the criteria for the $2,000,00^ Exemption under Section 300.65 of the NCP is as follows: 1) Continued response actions are immediately required to prevent, limit or to mitigate an emergency. (6) The former Publicker Industries site is in such a state of disrepair that many of the buildings are falling down or have collapsed. Site personnel have witnessed bricks and other building materials actually falling off buildings. Collapse of buildings and other structures, could damage tanks and process lines to the point of1 causing a release of hazardous substances, pollutants and contaminants into the environment. Tanks and process lines have probably not been maintained for 10 years or more. Many tanks are not diked and are in danger of collapse. Process lines are hanging on by a thread. Some of the areas on site have a direct conduit (e.g; pipes and drains) to the river. Soils and g'round water in the area of the site are grossly contaminated. Some of the levels of contamination have been reported as follows: * Soil Wood preservatives/coal tar compounds up to 17ppm (Benzo-a-Pyrene, Naphthalene etc.) Volatile organics . up to 110ppm (Toluene, Xylene etc.) Ethanol up to 31ppm * Ground water Toluene u? to 60ppm A recent on site tank release of n-Butyl Chloride (1/14/88) resulted in the OSC directing the ERCS contractor to trench the area surrounding the tank. This resulted in the discovery of several inches of product, floating on the ground water which seeped into the trench. Analytical results of this material indicated a flashpoint of, less than 33 degrees F and concentrations of 200 ppm of n-Butyl Chloride, 30,000 ppra of Chlorides, 37,000 ppm Total Organic, Carbons, and a BTU value of '13, 769 BTU/lb. These results indicate that there have been several spills in this area. In 1985, two people were engulfed in flames and killed while cutting process lines approximately 75 feet from the n-3utyl Chloride Spill area. The individuals killed in the fire were dismantling process lines for one of the previous property owners. These events and others exemplify the extreme fire and explosion threat. Attached is a copy of a memo written by the Philadelphia Fire Marshalls Office (12/4/87) that supports the OSC's concerns. Ground water and surface water from the site discharge into the Delaware River. This is quite obvious during a rainfall when one can observe a sheen leaving the property. There is no containment on the shores or piers on the river. City officials are unsure as to where subsurface drains-flow.

flRU00359 (7) Prior to the arrival of the Rem.o_val Program, there was inadequate"security at the site. Fences and windows were unsecured, and the police responded frequently to theft and vandalism problems at the site. A security guard was on site the day (June 1987) of the five alarm pibr fire and was. unaware o-f-the fire. The cause of the fire was [later determined as arson. The sits...still presents an extreme fire and explosion threat. Despite current 24-hour securit^ and fire watch personnel .the potential for direct contact still exists. . In the event funds are.not approved for the'control and stabilization of this.situation, a catastrophic event, such as a major fire or atmospheric release of chemicals could occur, unnecessarily endangering the lives of thousands of people, not to mention the threat to ground water and surface waters. The site.is literally falling apart. Failure to take action could result in the recurrence of past incidents and perhaps, given the^ track .record at tne site, the creation of additional sites and future response actions by EPA. 2) There is an immediate risk to public health or welfare or the environment. Several hundred thousand people live in close proximity to the site. In addition, there are hundreds of businesses, several schools, two hospitals, and two putdoor sports arenas in close proximity to the site. Major transportation routes border the site. The. .Delaware River borders this site for approximately 1100 feet. Four of the operating businesses are located immediately adjacent to the site and operate 24 hours a day. One of these facilities is the largest shipping terminal in the Philadelphia area. A portion of the site lies directly under the Walt Whitman Bridge, which is one of the most heavily used bridges connecting New Jersey and Pennsylvania. There are .currently an estimated 2,000,000 gallons of ..waste"., on site in tanks, trailers and tbnk cars. Most of these containers are in poor shape, and many could discharge their contents at any time. This situatipn was aggravated with the freezing and thawing by recent winteri weather. Recently one spill occured due to tank failure, ana SPA has had to pump another tank off". Spring and summer may present problems of their own (runoff and hot temperatures causing releases). Process lines are,actively leaking. Several thousand known and unknown lab containers are stored on site. We are currently assessing the threat posed by the hundreds of cubic yards of potentially friable .asbestos.

0360 Releases from tanks and lines continue to directly enter the ground water and the Delaware River. A water intake is located several miles downstream. Both the soil and ground water at the site are contaminated by hazardous substances, pollutants and contaminants. Since the sita is not contained or capped, these materials are most likely migrating off site...... The potential for a fire/explosion, spill, or air release from the site is great. A major incident may necessitate the evacuation of large numbers of people and/or businesses, or the closure of major transportation routes (Delaware river, Walt Whitman Bridge, railroads, or Interstate 95). Fumes released from a fire and/or explosion could significantly affect residents of Philadelphia and New Jersey depending on meteorological conditions. 3) Assistance will not otherwise be provided on a timely basis. At this time there are no Federal, State or local resources to address this immediate threat to public health, welfare and the environment. In particular, the State.and the City do not have the resources to handle an incident of this magnitude. As noted earlier in Section II-Background, Publicker's previous efforts did not stabilize the site and to date, the PRPs have declined to take on the actual removal work deemed necessary by the OSC. (see attached confidential enforcement status.) The Region is working towards getting the site listed on the NPL so that future remedial actions could address problems at the site outside the scope of this proposal (ie. contaminated soil and groundwater). However, due to the time ^ critical nature of this site a removal action is needed to fully stabilize the above ground problems in the interim. This'request is not for a complete cleanup. If the site ranks on the NPL, the Remedial program will most likely deal with the full cleanup (i.e. soil and groundwater contamination).

1 v.• ENFORCEMENT STATUS

(See attached confidential enforcement status) (9)

Y.- CONTRIBUTION TO REMEDIAL PERFORMANCE The site currently poses an immediate threat to public health and welfare and the environment. The OSC forsees that a year or more will be required to address removal concerns and.to control and .stabilize the site. The current problem areas have.been identified as follows: * Laboratories .-. ------* Tanks (includes rail and motor carriers) * Gas Cylinders ------* Process Lines * Drums * PCB-containing equipment * Asbestos * Grossly contaminated soil The OSC is proposing to address the aboveground threats, and additional threats as appropriate, pursuant to the National Contingency Plan 40 C.F.R. Section 300.6J.5. The OSC deems this removal action to be consistent with Section 104 of CERCLA. This requires .that, removal acti'ons contribute to the performance of long-term remedial, actions. As mentioned earlier.the site is not currently on the NPL, however, the Removal program is working closely with the Remedial program to assist with data gathering to rank th|e site. Since the site is .not on the NPL, the RI/FS process has not been started. The long term removal cleanup plan is basically to address the site ..as...a_.__"_surface cleanup". which would leave the contaminated soil and groundwater is.sues for the Remedial program to address at a later date (see section VII). The threats requiring immediate action are outlined in Section III (Statutory Criteria). As previously stated, the proposed removal action is to address the site as a surface cleanup only. It is -believed these actions will abate the most immediate threat. Although it is difficult to predict future remedial actions, it is reasonable to presume that control and stabilization of the site would rank high among remedial priorities. Therefore, the OSC considers the proposed actions to be consistent with future remedial actions. .

'SRI4QQ362 (10) VI. ___ACTIONS TAKEN TO DATE _ ... _. Approximately $ 2 million has been expended to date from the current authorized ceiling to begin the following: * Site stabilization. * Inventory, segregation and lab packing of laboratory chemicals. Further assessment uncovered the presence of at least 2r000 unknown lab chemicals as well as many shock sensitive/explosive materials. * Fire prevention and control measures. * Analytical services (evaluation of data collected to date)

* Emergency disposal of shock sensitives/explosives

* Extensive site zone, assessment : * On site emergency recovery of spilled chemcials due to the weakened and deteriorated condition of one of many such tanks at this site. * Process line and tank survey. As outlined below in Section VII the long-term plan is to control and stabilize the threats and potential threats to public health and welfare and the environment. This will include assessment of problem areas, consolidation and removal of hazardous substances, pollutants, and contaminants that " are presently being released or posing a'threat of release,

VII. PROPOSED. ACTIONS AND COSJT

A. ASSUMPTIONS Scope of Work and cost estimation are based upon most accurate available information, but this may .change significantly when final costs are known. The following assumptions have been made in regard to the scope of work at this site: 1. All operations are based on a one-ryear time frame. for completion of work.

AR4QQ363 (11) 2.. Costs are estimated using 12-hour work days, seven days a week. 3. In light of time and cost, considerations, several operations can be performed s Lmultaneously. 4. A response manager will be on :site for the anticipated, one year project duration. 5. EPA and TAT costs are also faasod on a one year project duration. 6. Time/Removal data for pipeline:; contain the .greatest amounts of estimation uncertainty and may significantly increase or decrease when actual costs become known.

B. OPTIONS The objective., of . the proposed removal action is to address imminent and substantial threats to human health and welfare and the. environment. At this point in time the OSC proposes a "surface'cleanup" although some aspects such as grossly contaminated IsoJJL, groundwater contamination, and most below ground piping may need to be addressed at a later date. Actions at this site must continue[without delay to ensure maximum protection of public health, welfare and the environment. It is difficult to give a schedule for the many aspects .of this emergency action. Conditions change minute by minute, hour by hour and. day by day..depending on weather conditions, new discoveries .(leaks, spills etc.), and funding constraints. It must be stressed that it is difficult to efficiently and productively manage a removal site of this size .and complexity given the current funding constraints. The following options, which do not address a total cleanup, along with.-the projected costs have been considered (preliminary estimates, include ERCS costs only): 1... No Act ion: This option was considered and discarded immediately as it affords no protection to public health and welfare and the environment. If the Agency does not act, the immediate threats identified in Section 111(2) of this document would not be addressed. Preliminary Estimate - $50,000 (Demobilization) 2. No Action Except 24-Hour Fire Watch/Security: This option essentially involves the removal of all personnel and equipment from the site, with the exception (12) of security and fire watch personnel, fire equipment and a skeleton command post. Pro: Ability to detect and address random problems which could develop (leaking tanks, fires, explosions). A deterrent to arsonists, vandals, etc. Con: Does not abate the threats/potential threats to-public health, welfare and the environment. Public remains at great risk due to the fact that, as in option #1, the - threats identified in Section 111(2) would not be adequately addressed. This option puts the OSC in the detection mode as opposed to the more desireable prevention/cleanup mode, in that the operation would only allow for detection of a release and not active prevention and cleanup of the site. Preliminary Estimate - $750,000 - $1,000,000 per year until the remedial program gets to the cleanup stage. Cost includes emergency contingency ta address fire, tank release, - explosion, etc. 3. Consolidation and Bulking of Wastes With No Disposal: This option involves bulking of wastes on site and leaving them on site for the Remedial program to address In addition, this option could include 24-hour fire watch/security. Pro: Consolidates the wastes into a smaller area which may make it easier to respond to an incident. Con: Only slightly reduces the risk to the public. Does not.. address pipelines, PCBs, or asbestos threats which were previously identified and'may be an immediate risk to public safety. Additionally, this' option is not cost effective as security/fire watch would have to be maintained for up to 6 years, until cleanup under the remedial program. Preliminary Estimate - $3,000,000 plus an additional .$750,000 per year for fire watch until final cleanup. 4. Disposal of All Identified Threats to Public Safety: This option is designed to address, to the greatest extent practicable, threats to'public health, pursuant to the NCP, 40 C.F.R. Section 300.65. This option would address tanks, process lines, lab wastes, cylinders, PCBs, and asbestos survey. In short, the operation-would be geared towards removing and disposing of wastes from the site. &RHQ0365 (13) Pro: Most protective of public healt' and welfare and the 'environment. Con: Still may not address below ground pipes, tanks, ground water and soil. Preliminary Estimate - $14,212,000 5. Same as.Option 4, but Excluding Base Neutral Liquids: Only difference between this option and the previous option is that the base neutral liquids would not be addressed and would remain on site. Pro: This option is offered as a way to address some of the major threats "while ^leaving .a less hazardous waste stream on site for future action by the removal or remedial program. It should be noted that this option was developed in light of the current funding situation and the fact that .sufficient, monies may not be available. Con: Still leaves materials on site, that may pose a threat to public health, welfare and the environment. These materials would most likely have to be dealt with at a later .date, anyway. Preliminary Estimate - $10,612,000

6. Same as Option 4 Using On Site Treatment of Base Neutral Liquids: (carbon filtration, chemical treatment etc.) Pro: Option protective of public health. Con: On site treatment may not.be as cost effective as off site disposal. Preliminary Estimate. - $12,000,000

C. RECOMMENDED OPTION - - • The OSC recommends option |4 as it is the option that is most- protective of public health, welfare and 'the environment. Th.e "surface cleanup" -concept would be. consistent with the long term remedy as stated in Section V of this document. The OSC would have the flexibility to possibly institute alternative treatment and disposal methods that may reduce costs.

flRlj00366 (14)

D. COST PROJECTIONS FOR RECOMMENDED OPTION 1. Tanks (transportation and disposal): " estimated cost of the approximately 2 million gallons of - $6,000,000 liquid on site 1 million gallons are . " aqueous liquid, 1/2 million gallons are potentially contaminated oils and tars., and 1/2 million gallons are solid and liquid miscellaneous wastes. Cost estimates are based on off site disposal (worst case). An estimated 800 drums are staged on site for future disposal Options to decrease these costs may include bulking of wastes or on site treatment of waste materials. 2. Laboratories (transportation and disposal) : estimated cost An estimated $112,000 to handle 4 truck $192,000 loads of knowns in on site lab packs ($28,000 per load). An estimated $80,000 to handle unknowns. 3. Cylinders: Many unknown cylinders estimated cost remain on site which manufacturers $10,000 may not recover. 4. PCBs: Approximately 1,200 gallons of .PCB- _ estimated cost containing waste on site. * $10,000 5. Asbestos: Many bags of collected asbestos . estimated, cost (previously collected and staged by PRP's) " $100,000 remain on site. A consultant will be required to address the miles of asbestos wrapped pipelines on site, as well as . the friable asbestos hazards in building and'tank structures. Some disposal of asbestos may be needed. However, the OSC will.'. evaluate the consultants report and confer with the ERT, ATSDR and other personnel as to the need to further address the potential asbestos threats. 6. Analytical estimated cost $900,000 7. Process piping: Large quantities of estimated cost product suspected in many of the process $2,000,000 lines on site. Asbestos problem will have to be addressed, as well as the integrity of the structures in which the lines are connected. (15) during most of the pipeline decommissioning. 8. Labor/Equipment/Materials: One year estimate. estimated cost Estimated $15,000 per day operations cost. $5,00"0,000 •Includes the operation of fire control/fire. watch and security personnel

E. WORK SCHEDULE/COST EXPENDITURES- Consistent with good site operations and the current limited funding available with the removal program, the OSC has outlined the proposed sequencing of work to occur at the site and the projected cost expenditures in the "attached Special Bulletin. PROPOSED COSTS ARE AS FOLLOWS: CURRENT CEILING- __.. E'RCS $2,795,000 TAT 224,000 EPA 96,000 COAST GUARD 10,000 EPA/INDIRE(TT1 202,000 TOTAL CEILING $3 ,327p000 REQUESTED ADDITIONAL FUNDS

ERCS 12,912,000 TAT COSTS 550,000 (Contingency of Above Costs 2,221,800 TOTAL EXTRAMURAL COSTS 15,683^8.00 EPA DIRECT COSTS 162,200

EPA INDIRECT 3.74,400

TOTAL INTRAMURAL COSTS 536,6£0 TOTAL PROJECT FUNDING REQUEST 16,220,400

ESTIMATED PROJECT COSTS

CURRENT CEILING 3,327,000

NEW TOTAL PROJECT CEILING $19,547,400 VIII. REGIONAL RECOMMENDATION I recommend that you approve the $2 million exemption request for the Publicker Industries Site because .conditions at the site meet the National Contingency Plan, 40 C.F.R. Section 300.65 (bj (2) , and CERCLA Section 104 (c) criteria for a removal. Your approval will raise the total project ceiling from $3,327,000 to $19,547,400 of which $15,707,020 are for extramural cleanup contractor costs. You may indicate your approval or disapproval by signing below

APPROVAL

DISAPPROVAL DATE

ATTACHMENTS UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 841 Chestnut Building Philadelphia. Pennsylvania 19107

SUBJECT: Publicfcer Industries Site. $2,000,000 Exemption Addendum DATE APR 6 1988 FROM: David p. Wright, Senior OSC Emergency Response and preparedness Section (3HW22) TO: Dr« J- Winston Porter, ..assistant Administrator Office of Solid Waste a//d* Emergency Response (WH-562A-)

THRO: James M. Seif^-WJSJt. J%*f & Stephen R. Wassersug, Regional Administrator (3RAOO) Hazardous Waste Management Division (3HWOO)

I. purpose Per your request of March 29, 1988, tie OSC is submitting an additional clean-up option for your review and consideration. This memo should serve as an addendum to the previously submitted $2,000,000 exemption.

II. Background The option being offered in the addendum is in addition to the six options already presented in the preceedinp document. For all intents and purposes we will consider this option #7. Option #7 as proposed involves continuing the on-going removal action to the point of arranging for and. conducting the transportation and disposal of most major waste streams on-site. PRP's will then be given an opportunity to perform the necessary disposal, should disposal by PRP's be unattainable other alternatives for doing so will be considered and recommended by the OSC, including'using the remedial or removal programs. The OSC may then have ti submit an additional funding request to address the transportation and jaisposal aspects of the project.

III. Proposed Option A. Description of option |7 is as follows: 1. All wastes in tanks, pipelines, drums and other vessels will be consolidated, bulked and stored on-site. This may entail tank testing and repair as well as other structural modifications to the site. 2. Compatibility testing of all waste streams to ensure proper bulking. Disposal of some priority waste streams (such as flammables, acids, etc.). 4. Asbestos assessment with possible limited removal or encapsulation. 5. Addressing of piping and materials contained therein. 6. Fire watch and security during the performance of this option. 4 ("•••„ »• NOTE: All work and costs incurred are based on a three month time frame. The preliminary estimate for this optiori is $5,500,000. You have already approved an additional $1,300,000 in extramural clean-up costs, via your temporary approval dated March 11, 1988. Therefore, only $4,200,000 in extramural clean-up costs would be needed to carry out the option. IV. Costs for Proposed Action proposed Costs Current Ceiling $2,795,000 TAT 224,000 EPA 96,000 USCG 10,000 EPA/Indirect . 202,000 Total Ceiling $3,327,000 Requested Additional Funds

ERCS $4,200,000 TAT 50,000 15% Contingency 637,500 (ERCS and TAT Costs) Total Extramural Costs $4,887,500 EPA Direct Costs '25,000 Total Project Funding Request $4,912,500 Current Ceiling $3,327,000 New Total project Ceiling $8,239,500 NOTE: Above figures do not include security/fire watch costs beyond the estimated three (3) month time frame.

flRU0037 V. Regional Recommendation ^1 recommend that you approve the $2 million exemption request for the Publicker Industries site because conditions at the site meet the National Contingency Plan, 40 CFR Section 300.65(b)(2), and CERCLA Section 104(c) criteria for a Removal. Your approval will raise the 'total'project ceiling from $3,327,000 to $8,239,500 of which $6,995,000 are for extramural clean-up contractor cos:s. You may indicate your approval or disapproval by signing below; Approval______/, .A " Date Disapproval Date UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION HI 841 Chestnut Building Philadelphia, Pennsylvania 19107 Continuation Of Removal Activities For The Publicker Industries Site, PIATP SUBJECT: Philadelphia^ Philadelphia County, Pennsylvania"*'t: \\f\\j James M. Sei FROM: Regional Adm. Dr. j. Winston porter. Assistant Administrator For Solid Waste and Emergency Response ISSUE The attached CERCLA Additional Funding Request pertains to the Publicker Industries site, Philadelphia, Pennsylvania* This is a request for additional .funding to continue twenty-four (24) hour site security and fire watch in order to retain U.S. EPA control over the Publicker industries Site until such time that remedial activities can be initiated. The Region is currently working towards listing the site on the National Priority List and all indications are that remedial activities should begin in March 1989. The po- tential threat to public health continues to exist and EPA control would minimize the threats resulting from unauthor- ized entries or unforeseen/unreported incidents. Previous funding in the amount of $8,239,500 was approved on April 8, 1988 for the control and stabilization of the Publicker site, which included but was not limited to, address- ing the fire and explosion threats, leaking tanks and piping, migration of hazards into the Delaware River, and the bulking of chemical wastes, potential responsible parties or private parties have not been responsive to the Region's attempts for enforcement actions for addressing the above-mentioned items as well as the transportation and disposal of the remaining large volume bulked waste streams. The continued removal actions meet the criteria of the National Contingency plan, 40 C.F.R. Section 300.65 and Section 104 (c) (1) of CERCLA. I recommend that you approve this request for the additional funds in the amount of $587,500, of which $517,500 are for ERCS costs. Attachment UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION ill 841 Chestnut Building Philadelphia, Pennsylvania 19107 Ceiling Increase Request for the Publicker Industries Site, Philadelphia, SUBJECT: Philadelphia County, Pennsylvania DATE: NOY C 3 1988 FRHM- Lisa Marie Price, On-Scene Coordinator•- FROM: Emergency Response and Preparedness Section (3HW22) -Q. Dr. J. Winston porter. Assistant Administrator Office of Saflid Waste and Emergency Response (WH-562A) / THRU: James M. SeisflT/ Stephen R. Wassersug, Director Regional Adnyi'nistratQr Hazardous Waste Management ATTN:, Timothy Fields, Jr., Director Emergency Response Division

I. PURPOSE This is a request for additional funding to continue twenty-four (24) hour site security and fire watch at the Publicker Industries Site, Philadelphia, Philadelphia County, Pennsylvania. The continuation of site security and fire watch will serve to retain ul.S. EPA control over the site until such time that remediajl activities can be initiated. Current estimates are tha^: the remedial program will begin its activities in March 1989. The OSC originally recommended that the .transportation and disposal (T&D) aspects of this removal project be per- formed as soon as possible. T&D conducted under, the removal program would be consistent with future remedial actions. The Region is, however, currently wording towards listing the site on the National Priority List (NPL) and due.to limited Removal funds, the remedial program and its monies will per- form the T&D in addition to the full remediation of the site. The continuation of twenty-four (24) hour site security and fire watch at the Publicker Industries Site is recom- mended by the OSC in order to retain control of the thirty- seven (37) acre property. The reasons for the recommenda- tions are,as follows: 1* Past incidences of death and fire (the most recent' being June 26, 1987) and documented attempts at entry by unauthorized personnel. (2) 2. Although the site is enclosed on the north, south, and the west by a fence, access cannot be completely controlled. 3. Large volume liquid waste streams were bulked and staged in four (4) bulk storage tanks onsite. Prior to the staging, repairs were made to the four (4) bulk storage tanks, and the tanks were then hydrostatically tested. Although repairs and test- ing were done, the structural integrity can in no way be certified for any definite period of time; consequently, the potential threat of release exists. Collectively the four (4) bulk storage tanks contain approximately 1,000,000 gallons of hazardous mate- rials. 4. The physical condition of the site is poor. During the course of our removal action, it has been doc- umented that portions of buildings, including' steel beams, brick wall sections, and boards from overhead wooden structures have collapsed. A structural survey of the site conducted by a structural en- gineer documented the areas of concern due to the deterioration of several large structures onsite. Although consolidated wastes have been secured in tanks and in drums, the potential threat of a re- lease remains high due to the deteriorated condi- tion of the structures surrounding the consolidated wastes. 5. The removal action concentrated only on a surface cleanup. Issues such as contaminated soil and groundwater, fuel oils, vapors remaining in and decommissioning of lines and tanks, tank bottoms, and an asbestos removal have not been addressed dur- ing this removal action. These hazards (i.e. direct contact, fire/explosion) continue to pose a threat to public health if unauthorized personnel enter the site. For the above-mentioned reasons, the continuation of twenty-four (24) hour security and fire watch is essential. Security will be able to control access to the site and deter unauthorized entries. Fire watch currently conducts and will continue to conduct air monitoring and visual inspections on the half-hour, twenty-four (24) hours a day.

SRU00375 (3) In the event of a release, fire, or unauthorized entry, fire watch would be able to initially cortrol the situation until such time that the appropriate response individuals arrive onscene. Quick attention to an incident and the notification to response personnel is critical, given the close proximity of the site to residences in Philadelphia and/or Camden, New Jersey, major highways (Walt Whitman Bridge, 1-95, 1-295, 1-76) and businesses.

II. BACKGROUND The Publicker Site Emergency Action was initiated by the OSC on December 8, 1987, using the $50,000 Delegation of Authority (14-1-A, 9/13/87). On December 9, 1987, the Regional Administrator approved a funding increase of $1,702,000, raising the removal ceiling to $1,752,000. Monies were jatilized for the following removal actions: 1. Stabilization and control (i.e. fire watch, security) 2. Line and tank assessment/inventory 3. Inventory, segregation and lab packing of laboratory chemicals 4. Fire prevention and control measures 5. Analytical .services 6. Emergency disposal In March, 1988, the Regional Adirinistrator approved an Interim Funding Request for $200,000, bringing the removal ceiling to $1,952,000. On March 11, 1988, the Assistant Administrator of""the Office of Solid Waste and Emergency Response (OSWER) gave verbal approval to exceed the $2,000,000 statutory limit and authorized an additional $1,375,000 bring- ing the total project ceiling to $3,327,000 (see Attachment A- $2,000,000 Exemption Funding Request Jfor the background of this interim document). (4) This funding was used to mitigate: 1. Fire and explosion threats 2. Leaking tanks and pipes 3. Migration of wastes into the Delaware River Funding was also used for: 4. Initial bulking and disposal of chemical wastes

On April 8, 1988, an additional $4,912,500 was approved by the Assistant Administrator of OSWER to continue the stabilization of this site, (not to perform a complete cleanup), and brought the total ceiling to $8,239,500. This money is being utilized to con- tinue the ongoing removal action to the point of arranging for and conducting the transportation and disposal of most major waste streams onsite. As described in option t7 (see Attachment A), current funding is being used as follows: 1. All wastes in tanks, pipe lines, drums and other vessels will be consolidated, bulked and stored onsite. Tank testing and repair as well as other structural modifications to the site are being addressed. 2. Compatibility testing of all waste streams to ensure proper bulking. 3. Disposal of some priority waste streams (such as flammables, acids, etc.) . 4. Asbestos assessment with possible limited removal or encapsulation. 5. Addressing of piping and materials contained therein. 6. Fire watch and security during the performance of this option. Completion of the above-mentioned items, and the incurred costs, were originally based on a three (3) month time frame. At this time, this work is still ongoing. Delays in the completion

flRi»00377 (5) of.this work have been caused by: 1) discovery of additional material to be addressed; 2) addition of items due to analyt- ical documenting contamination (i.e.contaminated oils); and 3) work slowdowns due to hot or inclement weather.

III. ACTIONS TO DATE This is a request for additional funding, to continue twenty-four (24) hour site security and fire watch in order to retain EPA control over the site until such time that remedial actions can be initiated, purrent estimates are that remedial activities will begin in March 1989. The following items have been or currently are being addressed" during the ongoing removal action: 1. All known and unknown laboratory containers disposed of offsite. 2. All PCB contaminated electrical equipment containing PCB levels greater than 50 ppm disposed of offsite. All electrical equipment containing PCB levels less than 50 ppm appear to be secure, at this time. 3. A major portion of the gas cylinders .were removed from the site by private parties at no cost to the project. Some that were not retrievedjwere remotely opened onsite vented, crushed and staged onsite. 4. Acid liquids neutralized onsite. 5. Liquids bulked and stored onsite in reconditioned tanks The liquid waste streams are, but not limited to: base neutral liquids, oxidizing liquids, and organic liquids 6. Flammable liquids and solids bulked/disposed of offsite 7. Solid waste streams bulked and. secured onsite. 8. Acid solids disposed of offsite. 9. Mercury and mercury containing compounds transported offsite to a reclamation or disposal facility. (6) 10. Radioactive laboratory compounds disposed of offsite, 11. There are approximately 200 miles of above-ground pro- cess lines throughout the site. These lines contained the following waste streams: flammable liquids, caustic liquids, oxidizing liquids, fuel oils, contaminated fuel oil, spent grain, ethylene glycol,* acids, organic liquids, cutting and lubricating oils, and water. The age of .the lines and associated hardware (bolts, flanges, valves, etc.) and the physical condition of the lines has made draining of hazardous wastes and substances difficult. However, approximately 7,000 gallons of material have been removed from these above-ground process lines and bulked with appropriate streams. 12. An asbestos survey was conducted by an.independent asbestos contractor in order to identify all areas in which asbestos was found to be an immediate hazard. Based on the findings of the survey the OSC contacted EPA/ERT for recommendations based on current EPA asbestos policy. The recommendations are included in Attachment C. Based on EPA/ERT recommendations, the following asbestos abatement has been or will be accomplished: A. Piles of asbestos will be bagged and secured onsite, B. Buildings containing asbestos will be posted and secured to restrict access and to prevent the release of airborne asbestos fibers from the build- ings into the ambient atmosphere. C. Some overhead piping with asbestos insulation was wrapped with plastic and secured to prevent the asbestos insulation from being released-into the environment. 13. A structural inspection was conducted onsite due to worker and operational safety concerns (see Attachment D) . On several occasions overhead piping and building supports have collapsed or deteriorated to such a state that they were partially demolished. The City of Philadelphia and Delaware Port Authority (Walt Whitman Bridge) have been apprised of the structural issues and concerns onsite.

(\RttOQ379 (7) 14. Fuel oil and contaminated oil are located throughout the 37-acre site (see Attachment E) . Approximately 255,000 gallons of contaminated oil has been identified in tanks, pits, and pipe lines onsite. The contaminated oil will be handled as a CERCLA issue due to the nature of the contaminants (see Attachment F, Scope of the CERCLA Petroleum Exclusion...) and disposed of offsite. Uncontaminated oil does exist onsite. This issue is being discussed with the U.S. Coast Guard and will be addressed as a coordinated effort between the U.S.EPA and U.S.Coast Gaard utilizing 311K Funding.

IV, STATUTORY CRITERIA The Publicker Industries Site continues to meet the following criteria, as prescribed in1 CERCLA 104 (c) necessary to exceed the $2,000,000 funding lirnit for removals. 1.Continued response actions are immediately required to prevent, limit, or mitigate an emergency. The integrity of many of the structures onsite is poor due to past fires and to the age of the facility. The structural concerns have been documented (see Attachment D). Although many of the onsite waste streams have.been consolidated, the potential threat of release remains high. The wastes were secured in tanks and in drums, however, the deteriorated condition of the structures surrounding the consolidated wastes pose a threat to these storage vessels. In addition although temporary repairs have been made to and testing has been done on the. 35-year old storagetanks, their structural integrity can in no way be certified for any definite period of. .time. These risks are compounded by the condition of the concrete-containment wall surrounding, the storage tanks. In the event of rupture or collapse of the storage tanks, the wall could not contain a catastrophic release. For these reasons, the continuation of twenty-four (24) hour fire watch and security is Essential. In the event of a release, fire, or unauthorized entry, fire watch and security would be able to initially control the situa- tion until such time that the appropriate response individ- uals arrive onscene. The quick attention to an incident and the notification to response personnel is critical. 2. There is an immediate risk to public health, welfare or| the environment. Due to the close proximity of residences, major highways, waterways, schools, hospitals and transportation routes to the site, any release could potentially affect hundreds of thousands of lives. The consolidated waste streams currently stored onsite in drums and in tanks include, but are not limited to, base neutral liquids and solids, organic liquids and solids, oxidizing liquids and solids, peroxides, sulfides, and contami- nated oils. A major release caused by the rupture or collapse of the storage vessels onsite could force the evacuation of large numbers of people, close down businesses, and possibly shut down the City of Philadelphia for an indefinite period of time due to disruption of public transportation and major highways (Walt Whitman Bridge, 1-76, 1-295, 1-95, etc.). A major release from the site could possibly affect residences due to air releases as far away as New Jersey, depending on meteorological conditions. For these reasons, the continuation of twenty-four (24) hour fire watch and security is essential. In the event of a release, fire, or unauthorized entry, fire watch and security would be able to initially control the situation until such time that the appropriate response individuals arrive onsite. Quick attention to an incident and the notification to response personnel is critical. 3. Assistance will not otherwise be provided on a timely basis. At this time there are no other Federal, state, local, or other mechanisms or resources capable of providing twenty- four (24) hour security and fire watch to aid in minimizing threats to public health, welfare, and the environment. The Region is currently working towards listing the site on the NPL in the order to address problems outside the scope of this removal action (i.e. contaminated soil and groundwater, fuel oils, vapors remaining in and decommissioning of lines and tanks, tank bottoms, and an asbestos removal). Given. that this removal action concentrated only on a surface cleanup, the T&D of the remaining large volume bulked waste streams and a total cleanup of the site will be performed by the remedial program. However, the estimated time frame for the initiation of remedial activities could be in March 1989. "-'//: (9) If the additional funds needed to continue with fire watch and security are not approvedJ no other source of funds are available in a timely fashion.

V. ENFORCEMENT See attached "Confidential Enforcement Status"

VI. PROPOSED ACTIONS This is a request for additional funding to continue twenty-four (24) hour site security and fire watch at the Publicker Industries Site. The continuation of site secu- rity and fire watch will serve to retain U.S. EPA control over the site until such time that remedial activities can be initiated. Current estimates are that the remedial program will begin its activities in March 1989. The continuation of security antj fire watch is essential Security will be able to control access to the site and deter unauthorized entries. Fire watch will continue to conduct air monitoring and visual inspections of the site, in the event of a release, fire, or unauthorized entry, fire watch would be able to initially control the situation until such time that the appropriate response individuals arrive onscene The quick attention to an incident and the notification to response personnel is critical. (10)

VII. COSTS FOR PROPOSED ACTIONS Current Ceiling Proposed Costs ERCS $7,395,000 $ 517,500

TAT $ 329,500 $ 25,000

USCG $ 2,000 $———————— Extramural Contingency $ 200,000 $——————— Total Extramural Costs $7,926,500 $ 542,500

EPA Direct $ 111,000 $ 15,000 EPA Indirect $ 202,000 $ 30,000 Total intramural Costs $ 313,000 $ 45,000 Total $8,239,500 $ 587,500

Total Current Ceiling $8,239,500 Proposed Additional Costs $ 587,500 Needed as of C.O.B. 11/15/88 New Total Project Ceiling $ 8,827,000 *Note: These proposed costs are based on a five month time frame, by which time remedial activities should have begun.

VIII. CONTRIBUTION OF REMEDIAL PERFORMANCE The Region is currently attempting to rank this site on the NPL. This removal action concentrates only on a surface cleanup; however, once the site is ranked, the remedial pro- gram will perform a total cleanup of the site. The activities outlined in this removal action provide a plan, which is con- sistent with and will "contribute to efficient performance" of future remedial actions. (11) IX.. REGIONAL RECOMMENDATION Because the conditions at the Publicker Industries Site continue to meet the NCP Section 300.65 (b) (2) and CERCLA Section 104 (c) criteria, I recommend your approval of this additional funding request for the continuation of site security and fire watch at the Publicker Site. Your approval will raise the total project ceiling from $8,239,500 to $8,827,000, of which, $7,912,500 are for ERCS contractor costs. You may indicate your approval or disapproval by signing below.

APPROVAL DATE

DISAPPROVAL DATE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 841 Chestnut Building Philadelphia, Pennsylvania 19107 Request for Twelve-Month Exemption for the SUBJECT: Publicker Industries Site, Philadelphia, DATE: NQV t 7 1988 Philadelphia County, Pennsylvania FROM: Lisa Marie Price, On-Scene Coordinator -/iHT Emergency Response and preparedness Section (3HW22) TO: James M. Seif Regional Admiistrator (3RAOO) THRU: / InHazardous waste Management Division (3HWOO) / I. ISSUE Immediate response actions to control and stabilize the site cannot be continued unless an exemption to Section 104 {«) of SARA [104 (c) (1) of CERCLA 1980 as amended] is granted. This is a request for a twelve-month exemption to continue twenty-four (24) hour site security and fire watch at the Publicker Industries Site, Philadelphia, Philadelphia County, Pennsylvania. CERCLA Emergency Removal activities began at the Publicker Industries Site on December 8, 1987, and the one-year time limit will expire on December 8, 1988. The continuation of site security' and fire watch will serve- to retain U.S. EPA control over the site until such time that remedial activities can be initiated. Current estimates are that the remedial program will begin its activities in March 1989.

II. BACKGROUND A. Incident/Response History The EPA Region III Emergency Response and Preparedness Section initiated a removal action on December 8, 1987, to abate an immediate and substantial threat to public health and the environment posed by the presence of thousands of laboratory containers, some of which were shock and photo sensitive; over one million gallons of hazardous materials contained both in overhead process lines and tanks; and over one thousand (1000) drums containing hazardous materials. (2) On December 8, 1987 the OSC, using. t;he $50,000 Delegation of Authority (14-1-A, 9/13/87), initiated an emergency action at the Publicker Industries Site. Oh" December 9, 1987, the Regional Administrator approved a funding increase of $1,702,000, raising the removal ceiling to $1,752,000. In March, 1988 the Regional Administrator approved an Interim Funding Request for $200,000, bringing th|e removal ceiling to $1,952,000. On March 11, 1988, the Assistant Administrator of the Office of Solid Waste and Emergency Response (OSWER) gave verbal approval to" exceed the $2,000!,000 statutory limit and authorized an additional $1,375',000 bringing the total project ceiling to $3,327,000. On April 8, 1988, an additional $4,912,500 was approved by the Assistant Admini- strator of OSWER to continue the stabilization of this site. The total project ceiling after the Aprilj 8, 1988 additional approved funding was $8,239,000. -All of this funding has been utilized to conduct the following removal activities: 1. Stabilize and control (i.e. firewatch and security) 2. Drain overhead process lines containing hazardous materials (i.e. flammables, acids, etc.) 3. Bulk all compatible liquid and solid waste streams 4. Dispose of priority waste streams (i.e. acids, laboratory containers, flammables, PCB contaminated materials, radioactives, mercury compounds) 5. Conduct limited asbestos abatement operation. Additional funding in the amount of $587,500 was requested of EPA-Headquarters by Region III on November 3, 1988 in order to maintain fire watch and security until March 1989. This additional funding brings the current project ceiling to $8,827,000. The Region is currently attempting to rank this site on the National Priority List (NPL). Current estimates are that remedial activities should begin in MarchJ1989. (3) %** B. Site Conditions The Publicker Industries Site is thirty-seven (37) acres in size and portions of the plant are over one hundred (100) years old. The deteriorating condition of the structures on site pose not only a threat to the bulked waste streams that remain onsite but also to surrounding businesses and thorough- fares (i.e. Ashland Chemical, Philadelphia Port Corporation, and the Walt Whitman Bridge) . This removal action only concentrated on a limited sur- face cleanup. Threats posed by those issues outside of the authorized removal scope of work (i.e. contaminated soil and groundwater, fuel oils, vapors remaining in and the decommis- sioning of overhead process lines and tanks, tank bottoms, and asbestos removal) are ever present. Given the incidence of fires, attempts at unauthorized entries to the site and the above-mentioned issues, the re- tention of U.S. EPA control over this site until remedial activities begin necessitates this twelve-month exemption request.

III. CRITERIA FOR EXEMPTION FROM STATUTORY. LIMITS A. There is an Immediate Risk to Public Health, Welfare or the Environment. Due to the close proximity of residences, major highways, waterways, schools, hospitals and transportation routes to the site, any release could potentially affect hundreds of thousands of lives. The consolidated waste streams currently stored onsite in drums and in tanks include, but are not limited to, base neutral liquids and solids, organic liquids and solids, oxidizing liquids and solids, peroxides, sulfides, and contaminated oils. A major release caused by the rupture or collapse of the storage vessels onsite could force the evacuation of large numbers of people, close down businesses, and possibly shut down the City of Philadelphia for an indefinite period of time due to disruption of public transportation and major highways (Walt Whitman Bridge, 1^76, 1-295, 1-95, etc.). A major release from the site could possibly affect residences due to air releases as far away as New Jersey, depending on meteorological conditions.

ft.R 1^00387 (4) For these reasons, the continuation of twenty-four (24) hour fire watch and security is essential. In the event of "a release, fire, or unauthorized entry, fire watch and security would be able to initially control the situation until such time that the appropriate response individuals arrive onsite. .The quick attention to an incident and the notification to response personnel is essential. B. Continued Response Actions are Immediately Required to Prevent, Limit, or Mitigate an Emergency. The Publicker Industries Site continues to meet the following criteria, as prescribed in CERGLA 104 (c) necessary to exceed the twelve-month exemption requirement for removals, The integrity of many of the structures onsite is poor due to past fires and to the age of the facility. The struc- tural concerns have been documented. Although many of the onsite waste streams have been consolidated, the potential threat of release remains high. The wastes were secured in tanks and in drums, however, the deteriorated condition of the structures surrounding the consolidated wastes pose a threat to these storage vessels. In addition, although temporary repairs have been made to and testing has been done on the 35 year old storage tanks, their structural integrity can in no way be certified for any definite period of time. These risks are compounded by the conditipn of the concrete containment wall surrounding the storage tanks. In the event of rupture or collapse of the storage tanks, the wall could not contain a catastrophic release. For these reasons, the continuation af twenty-four (24) hour fire watch and security is essential. In the event of a release, fire, or unauthorized entry, firt watch and security would be able to initially control the situation until such time that the appropriate response individuals arrive onsite. The quick attention to an incident and th<2 notification to response personnel is essential. C. Assistance Will Not Otherwise be Provided on a Timely Basis. At this time there are no other Federal, state, local or other mechanisms or resources capable of providing twenty-four (24) hour security and fire watch to aid in minimizing threats to public health, welfare, and the environment. (5) The Region is currently working towards listing the site on the NPL in order to address problems outside the scope of this proposal (i.e. contaminated soil and groundwater, fuel oils, vapors in and decommissioning of lines and tanks, tank bottoms, and asbestos removal). Given that this removal action concentrated only on.a surface cleanup, the T&D of the remaining large volume bulked waste streams and a total cleanup of the site will be performed by the remedial program. However, the time frame for initiation of remedial activities could be in March 1989, by all in- dications. If the twelve-month exemption needed to continue with fire watch and security are not approved, no other source assistance will be available in a timely fashion. D. Continued Response Actions are Otherwise Appropriate and Consistent with The Remedial Action to be taken. The continuation of twenty-four (24) hour fire watch and security is consistent with and will aid the remedial program, The retention of EPA control over the site will serve as a deterrent to unauthorized entries and unauthorized salvaging of potentially contaminated equipment.

IV. PROPOSED ACTIONS This is a request for a twelve-month exemption to continue twenty-four (24) hour site security and fire watch at the Publicker Industries Site. The continuation of site security and fire watch will serve to retain U.S. EPA control over the site until such time that remedial activities can be initiated. Current estimates are that the remedial program will begin its activities in March 1989. The continuation of security and fire watch is essential Security will be able to control access to the site and deter unauthorized entries. Fire watch will continue to conduct air monitoring and visual inspections of the site. In the event of release, fire, or an unauthorized entry, fire watch would be able to initially control the situation until such time that the appropriate response individuals arrive onscene The quick attention to an incident and the notification to response personnel is critical.

RRl*00389 (6)

V. RECOMMENDATION Because the conditions at the Publicker Industries Site continue to meet the NCP Section 300.65 (b) (2) and CERCLA Section 104 (c) criteria, I recommepd your approval of this twelve-month exemption request for the continuation of site security and fire watch at the Publicker Industries site, Philadelphia, Philadelphia County, Pennsylvania until remedial activities begin. You may indicate your approval or disapproval by signing below s~\ _ APPROVAL DATE /'/T/s*r

DISAPPROVAL DATE UMTED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460

A/QV 2 8 OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE

MEMORANDUM SUBJECT: Ceiling Increase Request for the Publicker Industries Site, Philadelphia, PA--Transmittal Me^srandv

FROM: Timothy Fields, Jr., Director Emergency Response Division

TO: Dr. J. Winston Porter Assistant Administrator

THRU: Henry L. Longest II, Directo Office of Emergency and Remediatj^Sfs'p'onse

Attached is a request from the Region III Regional Administrator for a ceiling increase of $587,500, to continue removal actions at the Publicker Industries site. If approved, the total project ceiling will be $8,827,000, of which $7,912,500 are for extramural cleanup contractor costs.

The Regional ceiling increase request will provide funds to continue site stabilization activities, which include site security and fire watch, until the site is ranked on the National Priorities List (NPL). Once the site is ranked it is expected that the Remedial program will take over activities at this site. U& recommend that you approve this request by signing the November 3, 1988 ceiling increase request from Region III.

Attachment

A-RU0039 Fact Sheet - Region III Ceiling Increase Request for Publicker Industries Site. Philadelphia. PA

IgSUg: Region III is seeking AA/OSWER approval of a ceiling increase request. The Region is requesting an additional $587,500, to continue removal activities at this site. If approved the total project ceiling will be raised from $8,239,500, to $8,827,000, of which $7,912,^00 are for extramural cleanup contractor cos.ts. These additional funds are entered in CERCLIS as a first quarter FY''89 projected removal obligation.

BACKGROUND: The site is .an abandoned chemical processing facility covering approximately 37 acres. This site is situated in a business and residential section of Philadelphia, with Camden, NJ, located a half mile away across the Delaware River. This site is also located,directly under the Walt Whitman Bridge, a major"transportation route between the state of NJ and the city of Philadelphia, There have been two fires at this site, in the past, resulting in the loss of-life. The site continues to be in' poor physical condition. During the course of the removal action, it has bjeen documented that portions of buildings, processing lines, and steel beams have collapsed. To date, the removal program has inventoried and segregated hazardous materials and lab packs onsite. It is anticipated that transportation and disposal will be addressed by the Remedial program when the ROD is signed.

PROPOSED ACTIONS: The proposed activities to be taken with this ceiling increase will be to continue 24 hour security and fire watch. The fire/explosion and direct contact threats continue due to the large volume of waste streams remaining onsite, poor condition of structures, which include tanks which hold bulked waste, and the many other unaddressed hazards such as contaminated, soils, groundwater, fuel oils, and vapors from decommissioned lines and tanks.

OPTIONS: Headquarters generally has four options when handling these types of Regional requests. The AA/OSWER can approve the request, partially approve the request, disapprove the request, or request more information, clarification, etc., before making a decision on the Regional request.

CONSISTENCY WITH_REMEP_IAL MEASURES TO BE TAKEN: The Region is currently performing a surface, cleanup to stabilize the site'. These activities will not interfere with any potential future remedial action which may be undertaken at this site; The Region is anticipating that this site will be ranked on the NPL in the near future.

TIMING: This action memorandum proposes to mitigate the continued threats posed to public health and the environment by fire/explosion and direct contact. The proposed additional funds are for security and fire watch through March 1989, when it is expected that the remedial program will assume responsibility for this site. ENFORCEMENT: Publicker Industries (PRP) entered into a 106- Consent Agreement with EPA. It was requested that the PRP do the work outlined in the original action memorandum. The PRP declined to begin work stating that their financial position prevented them from conducting ::he work. After a meeting -2- with the PRP and a review of the company's financial situation, EPA decided to assume control of the cleanup of the site. Region III enforcement continues to search for additional PRP's.

RECOMMENDATION: OERR recommends that the AA/OSWER approve this ceiling increase request to continue emergency removal activities at this site. The scope of work remains the same. These actions continue to satisfy .the three criteria of section 104(c) of CERCLA.

AR£f00393 Declaration For Hie Record Of Decision

Site Name ?ryl Location Publicker Industries Site City of Riiladelpiua, Philadelphia County, Peamsylvania Site Stabilization Operable Unit Statement of Purpose This decision document represents the selected remedial action for .this, site developed in accordance with the Compre- hensive Environmental Response, Compensation ana Liability Act of 1980 (CERCIA) , as amended by the Superfund Amendments and Keauthorlzation Act of 1986 (SARA) , and to the extent practicable, the National Contingency Plan (KCP). Statement-. This decision is based upon the administrative record (index attached). The attached index identifies the .items which comprise the administrative record upon which the selection of a remedial action is based. The Commonwealth of Pennsylvania concurs with the selected remedy. A copy of the concurrence letter is attached. Description of the" Selected Remedy This initial operable unit was developed to protect human health and the_ea^ronment by eliminating the [present threat of fire anoyor"explosion as a result of known potentially hazardous chemicals and other chemical compounds en-site. The selected remedial action will enable the site cleanup, which began as a removal action, to continue, utilizing remedial program funding in^ place of emergency removal program dollars. BuUced hn/^rdous/flaninabie waste streams will be transported off-site and will undergo treatment and disposal at permitted Resource Conservation and Recovery Act (RCRA) facilities,- ...... Subsequent investigations into other operable units addressing the soil, ground water and asbestos contamination at the site are forthcoming.

Rl*0039if The major consonants of the selected remedy are as follows: * Transportation and off-site disposal of the known remaining on-site waste streams to permitted RCRA facilities. * Demolition of above-grade process lines that traverse the site. This may include the recovery of unknown hazardous chemicals and the removal of pipe insulation materials such, as asbestos-containing materials. Dismantled process lines will remain on-site until future site remedial actions are performed. * Proper packaging of the insulation materials removed from ' the process lines. Insulation materials, including asbestos, will be properly stored on-site until future site remedial actions are performed. * Transportation and off-site disposal of hazardous chemicals recovered from within the process lines to permitted RCRA facilities.

Declaration The selected remedy is protective of human health and the environment, attains Federal and State requirements that are applicable or relevant and appropriate for this remedial action and is cost-effective. This remedy satisfies the statutory preference for remedies that employ treatment that reduces toxicity, mobility, or volume as a principal element and utilizes permanent solutions and alternative treatment (or resource recovery) technologies to the maximum extent practicable.

Date Edwin B. Erickson Regional Administrator Region III ' r.iT

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 204«0 MAR ii

OPFICI Of •OLIO WAJTf AND BMtnOINCV

MEMORANDUM SUBJECT: Publicker Industries. Site, Philadelphia PA — $2M Exemption Request FROM: Henry L. Longest II, Director Office of Emergency and TO: J. Winston Porter Assistant Administrator

Region III will be submitting a request for continuation of .removal activities at the PubUcker Industries .site. This site 1s an abandoned chemical processing facility, covering approximately 37 acres. Presently, this 1s a non-NPL site; however, the Regional removal program 1s working closely with their pre-remedlal program for the possible NPL ranking of this site. The $2M exemption and celling Increase request 1s currently at the Superfund Branch Chief level 1n the Region III concurrence chain. The memorandum 1s requesting $17,5M in additional funding, which will bring the total project celling to $19.5M. These funds will be used to address a fire and explosion threat, leaking tanks and piping, migration of hazards Into the Delaware River, and the bulking and disposal of chemical wastes* Expenditures for removal activities will reich the $2 million level sometime around March 11, 1988. The Region Is late In submitting a waiver request because of the complex nature of the s;lte. They are requesting your verbal authorization to expend $1,375K to continue removal operations for the next four weeks, until a final decision can be made on their exemption request* Should the current removal action be(Stopped, an emergency situation will be created. The fire and explosion threat still exists at this time. There have been two fires at this site 1n the p|ast, which resulted in the loss of life. If another fire occurs at this site, the fumes released from the site would affect businesses and residential sections of Philadelphia and/or Camdan, NJ, which is located a half milej across the Delaware River. This site is also located directly under the Walt Whitman Bridge. This bridge is a major transportation route connecting the State of New Jersey with the city of Philadelphia. Should another ftre and/or explosion occur at this site, this major throughway would be shutdown to commuter traffic, and cause significant public health Impacts*

flRl400396 U '88 15-11 £=« -2-

It should be noted that the Region's exemption request will be to stabilize the Publicker Industries site, not to perform a complete cleanup. Thus, this removal will concentrate on just a surface cleanup of the site. The documented groundwater and soil contamination will have to be addressed as a long-term cleanup effort. If the site ranks on the NPL, the remedial program will most likely deal with this portion of the cleanup. Due to the potential health and environmental threats arising from the current situation, OERR recommends that you give verbal approval to expend $1,375K to continue removal operations at this site for the next four weeks, until a decision can be reached on this request* You may indicate your approval or*d1sapproval

APPROVE

DISAPPROVAL: DATE: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 641 Chestnut Building Philadelphia, Pennsylvania 19107 Justification for Continuation of a Removal Action at the Publicker Industries Site SUBJECT; Philadelphia, Philadelphia County, DATE; Pennsylvania ' MAR l «» FROM: James M. SeifJ_^( ^A Regional Admir/istrato^/ (3RA00) TO: Dr. J. winston Porter, Assistant Administrator for Solid Waste and Emergency Response (WH-562A)

ISSUE The attached CERCLA Funding Request pertains to the Publicker Industries Site, Philadelphia, Philadelphia County, Pennsylvania. Continued removal operations are necessary to control and stabilize the threat to public health, welfare, and the environment posed by this site.

BACKGROUND Subsequent assessments and removal actions revealed that conditions at1 the Publicker industries Site meet the criteria in the NCP Section 300.65. This is pursuant to the Delegation of Authority 14-1-A (5-1-85) as amended by Superfund Amendments and Reauthorization Act (SARA) of 198^, which authorizes the Regional-Administrator to approve CERGLA Removal Actions with a total cost of less than $2,000,000. | I have approved CERCLA funds in the amount of $200,000, which raises the total project ceiling to $1,952,000. Attachments UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 841 Chestnut Building Philadelphia. Pennsylvania 19107

Interim Additional Funding Request for the PIATP- UAD SUBJECT: Former, Publicker Industries Site, Philadelphia, PA. WAR • /* -j~* *""*" ' David w'fTg'Et, Sr. On-Scene Coordinator • FROM: Emergency Response and Preparedness Section (3HW22) James M. Seif TO: Regional Administrator THRU Stephen R. Wassersug, DirercTspr/^. Hazardous Waste Management Division (3HW00)

I. PURPOSE This is a request for Interim Funding to continue, removal actions at the former Publicker Industries Site, Philadelphia, Philadelphia County, Pa. At this time, EPA Region III is requesting CERCLA funding in the amount of $200,000 to continue removal operations while a $2 Million Exemption is being evaluated by the Region and Headquarters. The $200,000 requested in this memo will a the OSC to ensure continued control and stabilization of the site. Without these interim funds, the project will incur the costly interruption of demobilization and remobilization. Current funds are expected to expire the last week of February/ first week of March,

II. BACKGROUND ;• ,;- See the attached draft Additional Funding Request,

III. THREATS During the two months of CERCLA Removal Actions, many of the threats which led to activation of funding for site clean-up have been stabilized by the following: 1). An onsite, 24-hour fire watch and fire fighting equipment 2). Around-the-clock security 3). Segregation and lab packing of known lab chemicals 4) . An operation to remotely open unknown lab chemicals 5). Securing of leaking tanks and tank cars 6). Maintenance of drum staging area 7). Ground sweep to collect all drums, cylinders and lab waste on the 37-acre site.

aRl+00399 If demobilization were to occur, these threats would not remain controlled. No fire watch or equipment would remain onsite to mitigate the fire/explosion threat. No security could be maintained to prevent trespassing onsite. Although the known lab chemicals have been lab packed, funding limitations have prevented their disposal offsite. The 'remote opening operation would cease and disposal of these unknowns would not occur. The drum staging area would not be maintained, n'or would immediate response be possible if another tank or tank car begins leaking. All of these threats reinforce the necessity of continued EPA onsite presence during the evaluation of the $2 Million Exemption. The additional $200,000 requested in this memo will provide approximately an additional 10-15 days of operations before funding up to the $2 Million Ceiling is reached. With the time extension, this Additional Funding may allow continued EPA onsite presence until the third week of March.

IV. ENFORCEMENT See attached "Confidential Enforcement Status"

V, PROPOSED PROJECTS AND COSTS

PROPOSED COSTS ARE AS FOLLOWS:

CURRENT CEILING $ 1, 752,000

ERCS 1, 365,000 TAT 150,000 EPA 65,000 US COAST GUARD 10,000 EPA INDIRECT 162,000 1, 752,000

REQUESTED ADDITIONAL FUNDS 200->000

ERCS ... 130,000 TAT 24,000 EPA 6,000 EPA INDIRECT 40,000 200,000

NEW CEILING 1, 952,000

ERCS 1, 495,000 TAT 174,000 EPA 71,000 US COAST. GUARD EPA INDIRECT 202,000

TOTAL CEILING 1, 952,000 VI. CONTRIBUTION OF REMEDIAL PERFORMANCE As part of the Removal Action at the Former Publicker Industries Site, this Interim Additional Funding request is consistent with Section 104 (b) of SARA which requires that Removal Actions contribute to the performance of long-term Remedial Action. The activities outlined in this Removal Action provide a plan, which is consistent with and "Contributes To Efficient Performance" of,future remedial actions as outlined in Section 104 (b) of SARA.

VII. REGIONAL RECOMMENDATION Because the conditions at the Former Publicker Industries site meet the criteria set forth in the National Contingency Plan, I recommend your approval of this Interim Funding Request of $200,000, which will raise the total estimated Removal Project Cost to $1,952,000. tou may indicate/yoor approval or disapproval by signing below. /\;2lJ J 6^^4 j APPROVAL X//^^^^ / DATE $// .

DISAPPROVAL " DATE