fifth five year review reportfifth five-year review report for publicker industries superfund site...

Fifth Five-Year Review Report

For

Publicker Industries Superfund Site

Philadelphia, Pennsylvania

December 2014

Prepared by:

United States Environmental Protection Agency

Region Ill

Philadelphia, Pennsylvania

Approved by:

~~~-Q Cecil Rodrig:JI);ec;QfJ Hazardous Site Cleanup Division Region Ill

Date:

-This Page Intentionally Left Blank-

Publicker Industries Fifth Five-Year Review Report December 2014

Table of Contents

List of Acronyms ........................ .......................................................... .................... . Pg. ii

Executive Summary ....................................................................................... ........ . Pg. iii

Five-Year Review Summary Form .................................................... ...... ............. . Pg. iv-v

I. Introduction .......................................................................................... . Pg. 1

II. Site Chronology ........................................................................... ......... . Pg.2

Ill. Background .......................................................................................... .. . Pg. 3-5

IV. Remedial Actions ......... .......................................................................... . Pg. 5-7

V. Progress Since the Last Five-Year Review .......................................... . Pg.8

VI. Five-Year Review Process .......................................................... ........... . Pg. 8-9

VII. Technical Assessment ........................................................................... . Pg.9-11

VIII. Issues ...................................................... ................................................. . Pg. 11

IX. Recommendations and Follow-Up Actions ....................................... .. Pg. 11

X. Protectiveness Statement(s) ......... ....... ............... ........................... .. Pg. 11

XI. Next Review ........................................................................ ..................... . Pg.11

List of Figures

Figure 1- Satellite Overhead of Property ............................................. Pg. 3

List of Tables

Table 1- Chronology of Site Events ...................................................... Pg. 2

Publicker Industries

ACM

ARAR

BTAG

CFR

CERCLA

CIC

DAE

EPA

FCOR

FYR

GPRA

HSCA

NCP

NPL

ou PA

PADEP

PCB

PCOR

PPA

RAO

RI/FS

RPM

ROD

SWRAU

TBC

Fifth Five-Year Review Report December 2014

List of Acronyms

Asbestos Containing Material

Applicable or Relevant and Appropriate Requirements

Biological Technical Assistance Group

Code of Federal Regulations

Comprehensive Environmental Response, Compensation

and Liability Act

Community Involvement Coordinator

Delaware Avenue Enterprises

Environmental Protection Agency

Final Close-Out Report

Five-Year Review

Government Performance and Results Act

Hazardous Site Cleanup Act

National Contingency Plan

National Priorities List

Operable Unit

Pennsylvania

Pennsylvania Department of Environmental Protection

Polychlorinated Biphenyls

Preliminary Close-Out Report

Prospective Purchasers Agreement

Remedial Action Objective

Remedial Investigation/Feasibility Study

Remedial Project Manager

Record of Decision

Site-Wide Ready for Anticipated Use

To Be Considered

ii


Executive Summary

The remedial actions implemented at the Publicker Industries site were conducted in three separate Operable Units (OUs). The OUs included: site stabilization {OU-1), asbestos removal {OU-2), and (a) abandonment of on-site wells, (b) removal, treatment and off-site disposals of liquids and sediments in contaminated electric utilities, (c) removal, treatment and off-site disposal of liquids and sediments in contaminated storm water trenches and utilities, and (d) removal and off-site disposal of miscellaneous waste (OU-3). The remedial actions selected for the Publicker Industries Superfund Site {Site) in Philadelphia, PA have been completed.

The remedial actions implemented for Operable Units 1, 2 and 3 are protective. For OU-1, EPA stabilized conditions at the site by addressing various fire and explosion threats. Hazardous chemicals recovered as part of the site stabilization were disposed of off-site at permitted facilities. For OU-2, EPA had any Asbestos Containing Material secured in plastic bags and disposed of off-site to a permitted facility. For OU-3, EPA set clean-up levels based on risk assessment for non-residential uses at the Site. The Site is still used for its intended purpose (industrial) and no. excavation and/or construction has taken place on the property that would change exposure assumptions. Institutional controls required for the deed as part of the remedy for the OU-3 ROD require property owners to notify EPA should any construction or excavation activities takes place. Since the remedial actions implemented at all three operable units are protective, the site is protective of human health and environment. The Site was removed from the National Priorities list (NPL) on November 1, 2000 after the remedies implemented for all three OUs at the Site were concluded. This is the fifth Five-Year Review, and no issues were identified

Government Performance and Results Act Measure Review

As part of the Five-Year Review, the Government Performance and Results Act Measures have

also been reviewed. The GPRA Measures and their status are provided as follows:

Environmental Indicators

Human Health: Long Term Human Health Protectiveness Achieved

Groundwater Migration: Ground Water Migration Under Control

Site Wide Ready for Anticipated Use:

The Site was determined Site Wide Ready for Anticipated Use on June 26, 2006.

iii

I

Publicker Industries Fifth Five-Year Review Report

Five-Year Review Summary Form

SITE IDENTIFICATION

Site Name: Publicker Industries Superfund Site

EPAID: PAD981939200

Region: 3 State: PA

NPL Status: Deleted

City/County: City of Philadelphia,

Philadelphia County

SITE STATUS

December 2014

Multiple OUs? Has the site achieved construction completion?

Yes Yes

REVIEW STATUS

Lead agency: U.S. EPA

Author name (Federal or State Project Manager): Andrew Hass

Author affiliation: U.S. EPA Region 3

Review period:- March 2014- December 2014

Date of site inspection: May 6, 2014

Type of review: Statutory

Review number: 5

Triggering action date: January 15, 2010

Due date (five years after triggering action date): January 15, 2015

iv


Five-Year Review Summary Form (continued)

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the Five-Year Review:

OU-1, OU-2, OU-3

Issues and Recommendations Identified in the Five-Year Review:

None No issues, recommendations or follow-up actions were identified during this Five-Year Review

Protectiveness Statements

Operable Unit: Protectiveness Determination: Addendum Due Date: OU-1 Protective Not applicable

Protectiveness Statement: The remedial actions selected for Operable Unit (OU)-1 have been implemented and

are protective. For OU-1, EPA stabilized conditions at the site by addressing various fire and explosion threats. Hazardous chemicals recovered as part of the site stabilization were disposed of off-site at permitted facilities


Protectiveness Statement: The remedial actions selected for OU-2 have been implemented and are protective.

For OU-2, EPA had any Asbestos Containing Material secured in plastic bags and disposed of off-site at a permitted facility


Protectiveness Statement: The remedial actions selected for OU-3 have been implemented and are protective.

For OU-3, EPA set clean-up levels based on risk assessment for non-residential uses at the Site. The Site is still used for its intended purpose (industrial) and no excavation and/or construction has taken place on the property that would change exposure assumptions. The institutional controls required for the deed as part of the remedy for the OU-3 ROD require property owners to notify EPA should any construction or excavation activities takes place.

Five years after the date this Five-Year Review was signed (see cover)

v


I. Introduction

The purpose of the Five-Year Review is to determine whether the remedy at a site

continues to be protective of human health and the environment. The methods, findings, and

conclusions of reviews are documented in Five-Year Review reports. In addition, Five-Year

Review reports identify issues found during the review, if any, and identify recommendations to

address them.

The EPA is preparing this Five-Year Review Report pursuant to Section 121(c) of the

CERCLA and the NCP. CERCLA §121(c) provides:

"If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section {104} or {106}, the President shall take or require such action. The President shall report to the Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews. 11

EPA interpreted this requirement further in the NCP, at 40 CFR §300.430(f)(4)(ii) which

provides:

"If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation of the selected remedial action. 11

This is the fifth Five-Year Re~iew for the Publicker Industries Superfund Site (Site). The

action triggering this statutory review was the completion of the fourth Five-Year Review, which

is documented as January 15, 2010. This Five-Year Review was conducted from April 2014

through December 2014 by the assigned RPM. This report documents the results of the review.

This Five-Year Review is statutorily required because the implemented remedy resulted

in hazardous substances being left on the Site. Specifically, hazardous substances remain in the

soils on the former Publicker Industries property at concentrations which do not allow for

unlimited use and unrestricted exposure.

1


II. Site Chronology

Table 1-Chronology of Site Events

Event Date

Removal activities December 1987 to December 1988

Site proposed to the National Priorities List (NPL) May 1989

Record of Decision (ROD) OU-1- Site Stabilization June 1989

Final Listing on NPL October 1989

Remedial Action for OU-1 October 1989 to December 1990

ROD OU-2- Asbestos Removal June 1991

Final Remedial Investigation/Feasibility Study (RI/FS) January 1995

Remedial Action for OU-2 February 1995 to May 1995

ROD for OU-3- Abandon monitoring and production wells; removal,

treatment and off-site disposal of liquids and sediment in storm water December 28, 1995

trenches and utilities; and removal, treatment and off-site disposal of

miscellaneous wastes

EPA completes the first Five-Year Review October 1996

Prospective Purchaser Agreement (PPA) is signed December 1994 (revised December

1996)

Remedial Action for OU-3 August 11, 1997 to May 11, 1998

Preliminary Close-Out Report (PCOR) is signed December 2, 1997

EPA completes the second Five-Year Review February 15, 2000

Final Close-Out Report (FCOR) is signed March 19, 2000

Site Deleted from NPL November 1, 2000

EPA completes the third Five-Year Review January 18, 2005

EPA completes the fourth Five-Year Review January 15, 2010

2

Publicker Industries Fifth Five-Year Review Report December 2014 -----------------

Ill. Background

A. Physical Characteristics

The Publicker Industries Site is located at the corner of Packer Avenue and Christopher

Columbus Boulevard in Philadelphia, Pennsylvania (Figure 1) and is currently owned by Holt

Logistics. The Site is approximately 42 acres in area and bordered to the: 1) north by the Ashland

Chemical Company property; 2) south by the Packer Marine Terminal; 3) west by Christopher

Columbus Boulevard, and 4) east by the Delaware River. The site is adjacent to, and is partially

under the Walt Whitman Bridge operated by the Delaware River Port Authority. The site is mostly

covered by concrete, compacted gravel and asphalt. There is an earthen berm located on the

eastern edge of the property to keep runoff from entering the Delaware River. During the Five

Year Review site inspection, it was noted that the berm was intact.

Figure 1 - Satellite Overhead of Property

3


B. Land and Resource Use

The current and projected land use for the property surrounding the Site is commercial

and industrial. During the site inspection, it was noted that the property was being used to store

and repair cargo vessel container boxes as well as house new vehicles that could not be parked

at the primary car dealer lot across Christopher Columbus Boulevard. The immediate area

surrounding the Site consists mainly of commercial businesses, including chemical

manufacturing, food warehouses and cement manufacturing.

C. History of Contamination

Publicker Industries owned and operated a liquor and industrial alcohol manufacturing

plant at the Site from 1912 to 1985. The Site was also used as a petroleum product and chemical

storage facility during the late 1970's and early 1980's. Publicker Industries discontinued

operations in February 1986. Later that year Publicker Industries sold the property to the

Overland Corporation. Overland Corporation declared bankruptcy and abandoned the Site in

November 1986.

In 1994, Delaware Avenue Enterprises (DAE), Crestmont Limited Partnership, and Holt

Cargo Systems Incorporated entered into a PPA with EPA and PADEP. On January 9, 1995, DAE

purchased the Site from the bankruptcy estate of Overland Corporation.

D. Initial Response

EPA began investigating the Publicker Industries site just months after a five-alarm fire

ravaged the property in 1987. The Site contained the remains of approximately 440 structures

that were used for a variety of purposes. On the Site were tanks, chemical laboratories, reaction

vessels, production buildings, warehouses and power plants. In addition, to the manufacturing

of liquor and industrial alcohols, the Site was used as a petroleum product and chemical storage

facility. Many of the production and storage facilities were in poor condition as a result of fire

damage, weather and neglect.

From December 1987 to December 1988, EPA conducted an emergency removal action

which included the stabilization of Site facilities, characterization of the on-site drum/tanks

contents, bulking and securing of over 850,000 gallons of numerous waste streams, off-site

disposal of laboratory containers, and removal of liquids from above-grade process lines.

E. Basis for Taking Remedial Action

In May 1989, the Site was proposed for inclusion on the National Priorities List (NPL) and

was placed on the NPL in October 1989. Once on the NPL, EPA began Remedial

Investigation/Feasibility Study (RI/FS) activities in November 1989. In January 1995, the RI/FS

was finalized and used as the basis for OU-3 ROD (see Section IV C). As summarized below,

4


even before the RI/FS was completed, EPA issued two RODs to address the disposal of

hazardous materials from the site.

The Rl field efforts included two rounds of groundwater sampling from on-site and off

site wells; a soil vapor survey; surface and subsurface soil sampling; liquid and sediment

sampling from sewers, trenches and other subsurface lines; and ecological sampling of the

Delaware River and sediment in the vicinity of the site. The results of these samples are

presented in the January 1995 Rl.

The risks to human health were evaluated in the context of the then current land use, as

an industrial site and future land uses such as short term construction, industrial

redevelopment, and a playing field. No unacceptable risks were projected in the baseline risk

assessment for construction workers, long-term commercial/industrial workers and

recreational users (both adults and children). Even though no unacceptable risks were

projected, the Site sits on the banks of the Delaware River and much of the subsurface

contamination was discharging directly into the river. It was determined that an action was

necessary for OU-3 to protect aquatic receptors from potential harm. As a result, an earthen

berm was constructed and the sewers discharging to the Delaware River were cleaned and then

sealed. These actions help ensure that runoff from the Pub Iicker property will no longer impact

the Delaware River.

IV. Remedial Actions

The remedial actions at the site were conducted in three Operable Units (OUs). OU-1

dealt with site stabilization, OU-2 involved asbestos removal and OU-3 focused on well

abandonment and removal, treatment, and off-site disposal of liquids, sediments and other

waste.

A. Record of Decision OU-1

In June 1989, the Record of Decision (ROD) for OU-1 was issued. The OU-1 ROD

provided for the continuation of activities that had begun as a removal action. It

provided a mechanism to eliminate fire and explosion threats from hazardous chemicals

within on-Site tanks, vessels and pipelines. The remedial action consisted of

transportation and off-site disposal of known waste streams, draining of above grade

process lines, transportation and off-site disposal of wastes discovered in above-grade

process lines and demolition of above-grade process lines. During this remediation,

Asbestos Containing Material (ACM) was discovered on the process lines. This ACM was

bagged and stored on-site. Remedial activities associated with OU-1 began in October

1989 and were completed in December 1990.

5


B. Record of Decision OU-2

In June 1991, the ROD for OU-2 was issued. ROD OU-2 addressed the removal of

ACM from the Site. During the implementation of OU-1, ACM from the process lines

was removed, bagged and stored on site. The remedy for OU#2 included the collection,

removal, transport and disposal of the remaining asbestos at the Site. The material was

packaged and transported to permitted disposal facilities. The remedial action for OU-2

began in February 1995 and was completed in May 1995. A total of approximately 200

tons of ACM was disposed during this remedial action.

C. Record of Decision OU-3

The third ROD for the Site was signed on December 28, 1995. The major

components of the ROD were: 1) abandonment of on-site groundwater monitoring and

production wells; 2) removal, treatment, and off-site disposal of liquids and sediments

in contaminated electric utilities; 3} removal, treatment and off-site disposal of liquids

and sediments in contaminated storm water trenches and utilities; 4) and removal and

off-site disposal of miscellaneous wastes.

The OU-3 ROD did not require remediation of the surface soil or the subsurface

soil. However, during remediation ofthe electric and storm water utilities, some soils

were removed around the utilities. Industrial cleanup levels were used to remove

contaminated soils associated with these utilities. These cleanup levels were based on

protecting workers on-site. The three contaminants were: lead, benzo(a)pyrene and

PCBs.

As a precaution, monitoring would be conducted in accordance with

Occupational Safety and Health Act (29 CFR 1910.120) requirements should excavation

occur on-site. On-site monitoring is to be conducted to ensure worker safety and

minimize the release of potential contamination. This requirement was designed as a

precaution to owners of the Site in the event that unidentified contamination may exist

at the Site. The ROD further states that this requirement shall be included in a deed

notice.

However, as described below, pursuant to the 1996 amendment to the PPA, DAE

implemented the OU-3 remedy. DAE did not take any additional measures with regards

to filing of a deed notice to address the ROD requirement to file a deed notice. The

1995 notice in the deed which evidenced DAE's acquisition of the Site property, and

property use limitations, was deemed sufficient to address the institutional control

requirement.

The Site achieved construction completion status when the Preliminary Close

Out Report (PCOR) was issued by EPA on December 2, 1997. The Final Close-Out Report

6


(FCOR) was issued on March 9, 2000, and the Site was deleted from the NPL on

November 1, 2000.

D. Prospective Purchaser Agreement

In December 1994, prior to the signing of the OU-3 ROD, EPA and PADEP

finalized a Prospective Purchaser Agreement (PPA) for the Site. The primary purpose of

the PPA was to settle and resolve the potential liability of the prospective purchasers

DAE, Crestmont Limited Partnership and Holt Cargo Industries. In exchange for the

covenants not to sue, DAE, Crestmont Limited Partnership and Holt Cargo Industries

agreed to pay the EPA and PADEP $2.3 million.

A deed dated January 9, 1995, was filed with the City of Philadelphia. The deed

was issued to transfer the property from the bankrupt Overland Company to DAE. The

deed describes the hazardous substances and the existence of RODs at the Site.

Furthermore, the deed alerts any person who controls all, or a portion, of the Site that

they "shall not put the Site to any use that would disturb or be inconsistent with the

remedial response action being implemented at the Site." It further states that any

deed shall preclude "any use of the Site which would disturb or be inconsistent with the

remedial response action implemented at the Site" and shall provide access to EPA. The

disclosure of this information that was included in the deed was stated as being in

compliance with section 512(b) of the Pennsylvania's Hazardous Site Clean-up Act (PA

HSCA).

In 1996, an amendment to the PPA was signed allowing DAE to implement the

remedy for OU-3. The agreed upon value of such work would offset any balance of

payments still outstanding to EPA and PEDEP under this PPA. After completion of the

remedial action, EPA reviewed and accepted the costs associated with cleaning up the

Site. These accepted remedial costs provided a credit against the cost of purchasing the

property. EPA settled all financial aspects of the PPA in a letter dated May 1, 2002.

E. Operation and Maintenance

None of the remedies selected for the site require operation and maintenance or

post-remedial action monitoring. Originally, for OU-3 the storm water outfalls were to

be monitored to assess if the Delaware River was receiving any contamination. While

not specified in the ROD, during remediation, the storm water outfalls and connections

to the City of Philadelphia sewers were all sealed to eliminate the need to monitor the

outfalls. As a result, there are no direct discharges to the Delaware River from the Site.

7


V. Progress Since the Last Five-Year Review

The protectiveness determination in the 2010 Five-Year Review indicated that remedies

implemented at the site were protective. There were no issues or recommendations made in

the 2010 Five-Year Review.

VI. Five-Year Review Process

A. Administrative Components

The following personnel were involved with the fifth Five-Year Review: Andrew

Hass, RPM; Brian Nishitani, EPA Regional Counsel; Mindi Snoparsky, EPA Hydro

geologist; Larry Johnson, EPA Community Involvement Coordinator; Linda Watson, EPA

Toxicologist; Bruce Pluta, EPA Biological Technical Assistance Group; and Ragesh Patel,

PADEP.

B. Community Involvement

A notice appeared in the South Philly Review newspaper on September 25, 2014. The notice included information on EPA conducting the FYR for the Site. Information on

the report availability was part of the announcement.

C. Interviews

No interviews were conducted since there has been little interest in this site.

D. Site Inspection

A site inspection was conducted on May 6, 2014. Attendees included: 1) Michael Fluehr, representative from DAE; 2) Andrew Hass, RPM; 3) Mindi Snoparsky,

EPA and 4) Ragesh Patel, PADEP. The Site is currently being used for storage and repair

of marine shipping containers. In addition, the site is being used for 110Verflow" parking

for new cars when the main automobile facility across Christopher Columbus Boulevard

is full. A newer chain link fence has been installed. The fence is installed around the

majority of the property except for the side of the Site bordered by the Delaware River.

A guard is on duty 24 hours/day to ensure nothing happens to the new cars parked on

the Site. There are no plans for construction, excavation and/or below grade work at

the Site.

E. Document Review

The Five-Year Review provided the opportunity to review relevant documents

for the Publicker Industries Superfund Site. The Remedial Investigation/Feasibility

8


Studies, Record of Decision #1, #2, #3 and previous Five-Year Review documents

were all reviewed.

F. Data Review

There is no operation and maintenance required by any of the remedial actions.

As a result, no data is generated for EPA review.

VII. Technical Assessment

Question A: Is the remedy functioning as intended by the decision documents?

Answer: Yes, the remedies are functioning as intended by the three RODs for the Site. For

OU#l, the remedial actions that were conducted eliminated the threat of fire and or explosion.

This was accomplished by removing hazardous/flammable waste streams from the Site. The

OU#2 remedy called for the removal of Asbestos Containing Material from the site. During

demolition activities at the Site, all Asbestos Containing Material was contained and shipped to

a permitted off-site disposal facility. The OU-3 remedy called for the monitoring and

production wells to be sealed, electric utilities to be excavated and cleaned, storm water

utilities to be cleaned and sealed. These actions help ensure that discharge from the Publicker

property will no longer impact the Delaware River. All waste recovered was removed and

properly disposed off-site at a permitted disposal facility. In addition, a deed notice was placed

on the property so that any excavation and/or construction would be monitored to ensure

protectiveness was still achieved.

Question B: Are exposure assumptions, toxicity data, cleanup levels and Remedial Action

Objectives used at the time of the remedy selection still valid?

Answer: The cleanup levels for OU-3 ROD were based on risk assessment for non-residential

uses at the Site. The Site is still used for its intended purpose (industrial}, and no excavation

and/or construction has taken place on the property that would require the owners to follow

the monitoring requirements associated with excavation activities required as part of the ROD

OU-3.

Changes in Standards and To Be Considered (TBC's)

There are no changes to standards in the ROD that would call into question the remedy.

In addition, there are no newly promulgated standards that would call into question the

protectiveness of the remedy. There are no TBC's that have changed which could affect the

protectiveness of the remedy.

9


Changes in Exposure Pathways, Toxicity, Other Contaminant Characteristics and Risk Assessment Methods

The exposure assumptions used in the past are still applicable at this time. There had

been no change in the use of the property when the site inspection was performed in May,

2014. The site inspection confirmed that there had been no excavation or construction activity

since the last Five-Year Review. In addition, the ROD for OU-3 stated that the selected remedy

provided a high degree of long-term effectiveness and permanence because the removal,

treatment and off-site disposal of contaminated sediments and miscellaneous wastes would be

permanent and irreversible.

Expected Progress Towards Meeting Remedial Action Objectives

Remedial Action Objectives (RAOs) were not explicitly identified in ROD #1, #2, or #3.

Question C: Has any other information come to light that could call into question the

protectiveness of the remedy?

Answer: No other information has come to light that calls into question the protectiveness of

the remedy. However, due to the proximity ofthe Publicker site and the Delaware River, EPA

looked at the potential impacts from the effects of climate change for this Five-Year Review. In

a joint report from the EPA and the Delaware River Basin Commission, an estimated 21-inch

rise in global sea level by 2050 would imply a rise of 2.4 feet in the Delaware estuary. Also, an

estimated 7-foot global rise by 2100 would imply an 8.2-foot rise in the Delaware estuary. 1 The

Publicker property is located at an elevation of approximately 15-19 feet above sea level.

Technical Assessment Summary

The remedy is functioning as intended by the decision documents since the removal

actions conducted as a result ofthe RODs for OU-1 and OU-2 have ensured the remedy is still

protective. During the emergency removal action of OU-1, EPA stabilized conditions at the site

by addressing various fire and explosion threats. Hazardous chemicals recovered as part of the

site stabilization were disposed of off-site at a permitted facility. OU-2 had any Asbestos

Containing Material secured in plastic bags and disposed of off-site at a permitted facility.

Exposure assumptions, toxicity data and cleanup levels used at the time of remedy selection are

still valid. Cleanup levels for OU-3 ROD were based on risk assessment for non-residential uses

at the Site. The Site is still used for its intended purpose (industrial) and no excavation and/or

1. "Greenhouse Effect, Sea Level Rise and Salinity in the Delaware Estuary", pg. i, EPA-230-05-86-010, May

1986

10


construction has taken place on the property that would change exposure assumptions. The

institutional controls required for the deed as part of the remedy for the OU-3 ROD requires

property owners to notify EPA should any construction or excavation activities takes place. The

institutional controls appear to be working since no construction or excavation activities were

noted during the Five Year Review site inspection.

VIII. Issues

No issues were identified during this Five-Year Review.

IX. Recommendations or Follow-up Actions

There are no recommendations or follow-up actions identified as a result of this Five

Year Review

X. Protectiveness Statement

The remedial actions implemented for Operable Units #1, #2 and #3 are protective. For

OU-1, EPA stabilized conditions at the site by addressing various fire and explosion threats.

Hazardous chemicals recovered as part of the site stabilization were disposed of off-site at

permitted facilities. For OU-2, EPA had any Asbestos Containing Material secured in plastic bags

and disposed of off-site at a permitted facility. For OU-3, EPA set clean-up levels based on risk

assessment for non-residential uses at the Site. The Site is still used for its intended purpose

(industrial) and no excavation and/or construction has taken place on the property that would

change exposure assumptions. The institutional controls required for the deed as part of the

remedy for the OU-3 ROD require property owners to notify EPA should any construction or

excavation activities take place. Since the remedial actions implemented at all three operable

units are protective, the site is protective of human health and environment.

XI. Next Review

The next Five-Year Review for the Pub Iicker Industries site will be due five years from

the date of this review.

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