Landfill Area #1 Site Within the Governor Bacon Health Center I Ft

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Landfill Area #1 Site Within the Governor Bacon Health Center I Ft UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION Ill 1650 Arch Street Philadelphia, Pennsylvania 19103-2029 SUBJECT: Approval of a Request for Funding for a Time-Critical Removal Action at Landfill Area #1 Site within the Governor Bacon Health Center I Ft. DuPont State Park Delaware City, New Castle County, Delaware FROM: David Wright, Associate Director Hazardous Site Cleanup Division, Region III TO: Mathy Stanislaus, Assistant Administrator Office of Solid Waste and Emergency Response THRU: Lawrence Stanton, Director Office of Emergency Management ATTN: Gilberto Irizarry, Director Program Operation and Coordination Division ISSUE The attached Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Action Memorandum pertains to the Landfill Area #1 Site within the Governor Bacon Health Center I Ft. DuPont State Park located in Delaware City, New Castle County, Delaware. A removal site evaluation performed in accordance with Section 300.410 of the National Oil and Hazardous Substance Pollution Contingency Plan (NCP) has identified a threat to public health or welfare or the environment due to the uncontrolled presence and release of hazardous substances at the Site. The removal site evaluation found hazardous substances, predominantly lead, present within and migrating from the soil and sediment at the Site. The Region has determined that this Site meets the criteria for a removal action under Section 300.415 ofthe NCP. Pursuant to Regional Delegation of Authority 14-2, funds in the amount of$ 1,919,900, of which$ 1,8J4,900, are Regional Removal Allowance Costs, have been approved to mitigate the threats posed by the Site. The attached Action Memorandum documents approval of the Removal Action necessitated by Site conditions and threats. Attachment: Funding Request Printed on I 00% recycled/recyclable paper with I 00% post-consumer fiber and process chlorine free. 0 Customer Service Hotline: 1-800-438-2474 AR300001 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103-2029 ,l/\ 2 8 2018 SUBJECT: Request for Funding for a Time-Critical Removal Action at Landfill Area # 1 Site Located at the Governor Bacon Health Center I Fort DuPont State Park Delaware Cit , New Cast County, Delaware FROM: Micha~e,~ - cene Coordinator Eastern Removal Response Section (3~~ TO: David Wright, Associate Director ~~ Office of Preparedness and Response (3HS30) I. ISSUE The purpose of this Request for Funding ("Action Memorandum") is to request funding to initiate a Time-Critical Removal Action to address a release of hazardous substances from a landfill (Landfill Area #1 Site) located at the Governor Bacon Health Center I Fort DuPont State Park. The Landfill Area# 1 Site is located along the banks of the Delaware River near Delaware City, New Castle County, Delaware. The Removal Action herein is proposed only for the Landfill Area #1 Site and not the remainder of the Governor Bacon Health Center I Fort DuPont State Park. The Removal Action addresses the Landfill Area #I Site which was the location of a fire, from which some cylinders already have been removed. A portion of the Landfill Area #1 Site is currently exposed and eroding into the Delaware River. Elevated concentrations of hazardous substances are exposed, migrating into the environment, and posing a threat to human health and environment, as discussed below. A Removal Site Evaluation conducted by the On-Scene Coordinator (OSC) pursuant to Section 300.410 of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 C.P.R. § 300.410, revealed a release and threatened release of hazardous substances, primarily metals and most notably lead, as well as low levels of polychlorinated biphenyls (PCBs), from the Landfill Area #1 Site into the environment. Based upon information obtained from the Removal Site Evaluation, and upon consideration ofthe factors in Section 300.415(b)(2) ofthe NCP, 40 C.P.R.§ 300.415(b)(2), the OSC determines that a Removal Action, pursuant to Section 104(a) ofthe Comprehensive Environmental Response, Compensation, and Liability Act, as amended (CERCLA), 42 U.S.C. § 9604(a), is appropriate and necessary to mitigate threats posed by the release and threatened release of hazardous substances from the Landfill Area #1 Site. The OSC's evaluation of the Landfill Area #1 Site conditions indicates that removal of exposed waste items (e.g., cylinders and remnants of drums containing unknown materials), removal of exposed waste materials containing high concentrations of 1 AR300002 lead, removal of debris impeding response actions, removal of eroding and contaminated soil along the bank ofthe Delaware River, consolidation and covering of remaining contaminated soil, and implementation of measures to protect users of the Park from exposed hazardous substances are the primary response actions required to mitigate the release and threatened release of hazardous substances from the Site. A Removal Action Project Ceiling of$1,919,900, ofwhich $1,814,900 are from the Regional Removal Allowance, is necessary to mitigate the threats identified in this Action Memorandum. II. BACKGROUND AND SITE CONDITIONS A. Site Description Some of the information contained herein was obtained from the documents identified in paragraph A.4.a below. 1. Physical Location The Governor Bacon Health Center I Fort DuPont State Park is generally located along the Delaware River south of Delaware City, New Castle County, Delaware. The Governor Bacon Health Center I Fort DuPont State Park includes over 380 acres and numerous buildings and features originating from military operations. The Governor Bacon Health Center I Fort DuPont State Park is generally bounded by the Delaware River to the east, the Chesapeake and Delaware (C&D) Canal and associated lands to the south, and a branch of the C&D canal to the west and north. After the foriner military reservation (Fort DuPont) was transferred to the State of Delaware (in 1946), it was turned into the Governor Bacon Health Center. In 1992, portions were then turned into the Fort DuPont State Park. The Landfill Area #1 Site is within Fort DuPont State Park and is generally located adjacent to the Delaware River and south of the eastern terminus of Wilmington Avenue (a road within Fort DuPont State Park). The full size of the Landfill Area #1 Site is not known, but has been estimated to be approximately between 10 and 20 acres. The OSC believes, after review of all available information, that the Landfill Area #1 Site is about 12 acres in size. The eastern portion of the Landfill Area # 1 Site is located along a tidal reach of the Delaware River and is submerged by the high tide. The Landfill Area # 1 Site is located generally east of two former gun batteries associated with Fort DuPont- Battery Ritchie and Battery Elder- as well as a former rapid fire gun emplacement. Battery Ritchie is now demolished. The guns have been removed from Battery Elder, but the structure remains. The structure of the rapid fire gun emplacement also remains. An incinerator was built near the location of former Battery Ritchie. The incinerator does not appear on available plans of Fort DuPont dating up to 1943. An aerial photograph from 1937 indicates the presence ofthe structure of Battery Ritchie, but not the incinerator. The incinerator is visible on an aerial photograph from 1946 at which time it is also apparent that Battery Ritchie had been demolished. A 1941 plan and a 1943 plan of Fort DuPont depict a "dump area" in the present location of the Landfill Area #1 Site. Aerial photographs from 193 7 and 1940 and 1946, which indicate the location of various features ofFort DuPont, also depict what appears to be disturbed ground at the location of the "dump area". 2 AR300003 2. Site History Guns were emplaced at the present position of Fort DuPont during the 1860s to protect the cities of Wilmington, DE, Chester, PA, and Philadelphia, PA, from enemy invasion. Fort DuPont was completed in 1902 and became the headquarters ofthe harbor defense ofthe Delaware River and Bay and Coast Artillery Regiments. Prior to World War I, Fort DuPont was used as a mine laying and destroying location on both land and water. During World War I the Coast Artillery Corps would spend time at Fort DuPont engaging in field training and target practice. In 1922 and until World War II the First Engineers occupied Fort DuPont. They used the facility as a proving ground for pontoon equipment. At the start of WWII, the importance ofFort DuPont increased with the transfer of the 261 st Coast Artillery of Delaware and the 122nd Coast Artillery Anti-Aircraft Battalion from New Jersey. By the end ofWWII, Fort DuPont housed over 1,000 German prisoners ofwar. On December 31, I945, the U.S. government declared Fort DuPont to be surplus and it was decommissioned. In I946, the military reservation and all of its buildings were transferred to the State ofDelaware, who on October 28, 1948, converted Fort DuPont into the Governor Bacon Health Center. The Governor Bacon Health Center has been occupied by several Delaware state agencies. Historically, many of these occupants have used the former military reservation and buildings for office space or storage for surplus goods, including potentially hazardous substances. The Department of Health and Social Services uses facilities at the Governor Bacon Health Center for residential treatment of patients. There is also an active sewage treatment plant, operated by New Castle County, located on approximately three (3) acres in the northeast comer of the Governor Bacon Health Center property. In 1985, a fire occurred in the area known as Landfill Area #1. This area had reportedly been used as a dump by the U.S. Army and possibly subsequently by the State of Delaware. The cause of the fire is not known.
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