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FEDERAL ON-SCENE COORDINATOR'S REPORT
Halby Chemical Site600 Terminal Avenue
Wilmington, New Castle County, Delaware
5EPAEMERGENCY^RESPONSETEAM&
UNITED STATESENVIRONMENTAL PROTECTION AGENCY
REGION IIIPHILADELPHIA, PENNSYLVANIA
AR307**26
Federal On-Scene Coordinator's ReportHalby Chemical Site
TABLE OF CONTENTS
TABLE OF CONTENTS ..........................................'....... iFACT SHEET ......................................................... iiFOREWORD .......................................................... iii
I. INTRODUCTION .......................................................... lA. Initial Situation ...................................................... 1B. Site Location ........................................................ 1C. Efforts to Obtain Cleanup from Potentially Responsible Parties ................ 1
II. ROSTER OF AGENCIES, ORGANIZATIONS, AND INDIVIDUALS ............... 2i
A. Names and Addresses ................................................ 2B. Glossary of Abbreviations and Definitions ................................ 5
III. NARRATIVE OF EVENTS .................................................. 6
.IV. RESOURCES COMMITTED ............................................... 9A. Initial Funding Request ............................................... 9B. Additional Funding Request ........................................... 9C. Estimated Total Cost Summary ......................................... 9
V. EFFECTIVENESS OF THE REMOVAL ...................................... 'lOA. Activities of the Various Agencies ..................................... 10
1. Federal Agencies .............................................. 102. State and Local Agencies ....................................... 103. Contractors .................................................. 10
B. Analytical Synopsis ................................................. 11C. Disposal Methods and Quantities Removed .............................. 14
VI. CHRONOLOGY OF EVENTS ............................................. 16
VII. FUTURE CONSIDERATIONS ............................................. 27
' APPENDICESA. Site Maps ......................................................... AlB. CS2 Transfer Figures ................................................ B1C. Funding Documents ................................................. C1D. Photo Documentation ................................................ D1
AR3Q7t*27
REGION III PROJECT #[182]CERCLA REMOVAL ACTION__________.___________.__________________ FACT SHEET
SITE: Halby Chemical Site
SIZE: Total NPL Site of 14 acres; containing the former chemical production area of 3 acres.
LOCATION: Wilmington, New Castle County, Delaware
APPROVAL DATE: February 03, 1995
PROJECT DATES: February 03, 1995 through August 01, 1995.
DESCRIPTION: The Halby Chemical Site is an on-going U.S. EPA Region III NPL site. On February03, 1993 a Removal Assessment was performed in previously unidentified areas of theSite. An abandoned laboratory with deteriorating and incompatibly stored chemicals
, was found. Also noted during the assessment was an abandoned tank farm and aprocess building in extremely poor condition. Based on the assessment the OSCobligated 200K for Emergency Actions to stabilize the chemicals found in thelaboratory. On February 23,-1995 a second Funding Request was approved. Theadditional funding was used to address additional contamination and releases foundduring the initial actions. During the Removal, significant amounts, of soilcontamination was found on-site. The soils were determined to be hazardous wastes(flammable and reactive). On July 06, 1995, the third Funding Request was approved.This Action Memo defined the scope of work to address the hazardous wastes found in-situ at the site. After this Funding was approved, the PRP expressed an interest inpursuing clean-up operations at the Site. On-site Federal removal actions werecompleted on August 01,1995
HAZARDOUS MATERIALS: Combustibles, Compressed Gases, Corrosives, Flammables, Oxidizers, OrganicPeroxides, Poisons, Mixed Radioactive, Arsenic Contaminated Liquids, AsbestosContaining Materials, Sulfur Compounds, and Mercury Compounds.
QUANTITIES REMOVED: 178 drums, 31 cylinders/pressure vessels, 7,000 gallons of CS2, 15,000 gallons of CS2contaminated water, 36 lab-pack drums and containers, 214 bags' of ACM, 80 tons ofconcrete, 60 cubic yards of PPE/Debris, and 120 cubic yards of construction debris weresent off-site for disposal, recycling, or returned to the manufacturer.
OSC: Michael TowleEric Newman, RPM
REMOVAL CONTRACTOR: Earth Tech Remediation Services (formerly ETI) of Richmond, VA
DISPOSAL • ,SUB-CONTRACTOR: Capitol Environmental Services Inc., Bethlehem Apparatus, Inc., and
NSSI/Recovery Services, Inc.
PROJECT CEILING: $13,464,000
PROJECT COSTS: $ 1,268,193
COMMENTS: Removal Actions mitigated the threat to the public and the environment caused by thepotential threat for additional releases of hazardous substances at this site.
Michael Towle
AR307«8
Halby Chemical SiteFederal On-Scene Coordinator's Report
FOREWORD
The On-Scene Coordinator (OSC), as mandated by the National Oil and Hazardous Substances PollutionContingency Plan, 40 CFR Part 300 (NCP 1990), is required to provide a coordinated federal responsecapability at the scene of an unplanned or sudden discharge of oil or hazardous substance that poses athreat to the public health or the environment. In addition, the provisions of Section 106 of theComprehensive Environmental Response, Compensation and Liability Act (CERCLA), 1980, asamended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), promote acoordinated federal, state and local response to mitigate situations at hazardous waste sites that pose animminent and substantial threat to public health and/or the environment.
The site conditions at the time of the removal assessment presented an imminent and substantial risk ofhazard to human health and the environment. The potential for uncontrolled releases of hazardoussubstances from the tanks, vessels, drums, cylinders, laboratory bottles and other small containersprovides a legal basis for federal response activities. The provisions of the NCP and CERCLA wereimplemented by the U.S. EPA Region III, Philadelphia, PA.
The OSC would like to extend thanks to all of the agencies and individuals who provided valuableassistance and expertise to ensure the successful completion of this cleanup effort.
Michael TowleOn-Scene CoordinatorU.S. EPA Region IIIPhiladelphia, Pennsylvania.
ui AR307U29
I. INTRODUCTION
A. Initial Situation
Halby Chemical is an on-going U.S. EPA Region III National Priorities List site. On February 03,1993a Removal Assessment was performed by On-Scene Coordinator (OSC) Michael Towle and RemedialProject Manager (RPM) Eric Newman in accordance with the National Oil and Hazardous SubstancesPollution Contingency Plan (NCP), 40 CFR Part 300. Immediate and significant threats to human healthand the environment were found to be posed by the presence of various known and unknown chemicalslocated in tanks, process lines, reaction vessels, sumps, drums, pressurized cylinders, and other smallcontainers. Also assessed was an abandoned laboratory with deteriorating and incompatibly storedchemicals. Many of the chemicals in the laboratory showed signs of degradation, separation andcrystallization, indicative of chemical instability. The chemical process and laboratory buildings showedsevere signs of deterioration and extremely poor building integrity. Based on the assessment, the OSCobligated 200K for Emergency Actions to initiate removal/stabilization actions.
B. Site Location
The Halby Chemical Site (Site) is located at 600 Terminal Avenue Wilmington, Delaware,Although the surrounding area is commercial/industrial and located near the Port of Wilmington, thenearest residences are adjacent to the process area of the Site. The on-site lagoon and marsh areas aretidally influenced and directly connected to the Christina River. A site location map may be found asAppendix A.
C. Efforts to Obtain Cleanup from Potentially Responsible Parties
The Halby Chemical Site has been the subject of numerous negotiations and orders between identifiedPRP's and EPA. Efforts by the U.S. EPA to obtain recovery costs and clean-up actions from theidentified PRP's are continuing. Due to the sensitive nature of cost recovery actions, any inquiriesregarding potential responsible parties should be directed to the EPA Superfund Remedial Branch, U.S.EPA Region III, 841 Chestnut Building, Philadelphia, Pennsylvania, 19107. The PRPs were informedof Removal activities at the Site and ultimately assumed the project lead through an Order.
AR307U30
II. Roster of Agencies, Organizations, and Individuals
A. Names and Addresses
Agency Contact Brief Description of Duties
FederalU.S. EPA Region IIIOffice of Superfund Programs841 Chestnut St.Philadelphia. PA(215)597-9800U.S. EPA Region IIIOffice of Superfund Programs
Michael Towle, OSCEric Newman, RPM
James Wright, FAS
Coordinated site activities to the successfulcompletion of the project.
Assisted the OSC with cost tracking and otheradministrative duties associated with theproject.
State and LocalDepartment of Natural Resources andEnvironmental Control715 Grantham LaneNewcastle, DE 19720(302) 323-4540Department of Natural Resources andEnvironmental ControlEnvironmental Response Branch89 Kings HighwayDover. DE 19903(302) 739-3694
Holloway Terrace Fire Company(302) 656-6054
City of WilmingtonOffice of Emergency Management300 North Walnut StreetWilmington, DE 19801(302)571-4234
Jane Biggs-SangerProject Manager
John H. Mohrman, Jr.Program Manager
James BethardEnvironmental Scientist
Joe Cochran, Chief
Melissa HaverLEPC Assistant
Coordinated with the OSC and RPM andprovided background information and technicalassistance during the entire project.
Provided technical support during CS2 transferoperations.
Provided technical support during CS2 transferoperations.Local Emergency Planning Committee contact.
ContractorsEnvironmental Technology of NorthAmerica, (ETI)Emergency Removal Contractor3705 Saunders AvenueRichmond, VA 23227(804)358-5400
Roy F. WESTON, Inc.Technical Assistance Team5 Underwood CourtDelran, NJ 08075
William Brennan, RM
Joe Moulis, Chemist
Libby Levy, Site Leader
Responsible for coordinating manpower andequipment to mitigate the threats at this site.Coordinated sampling and disposal ofhazardous wastes.
Assisted OSC's with technical aspects of theproject, site safety, contractor monitoring, andformal reports.
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Major ERCS Sub-contractorsAbby Drum Company1900Benhill AveBaltimore, MD21226(410)355-3111Ace Fuel Oil Company201 Milltown RoadWilmington, DE 19808(302)998-2211
Active Crane Rentals103 Water St.Wilmington, DE 19804(302)998-1000American Environmental Network9151 Rumsey Rd, Suite 150Columbia, MD 21045-1992(800) 899-8525Austin and Pruitt Fire and SafetyEquipment, Inc.Wilmington, DE 19804(302) 654-2380Bennett Detective and Protective Agency,Inc.P.O. Box 344Dover, DE 19903-0344(302) 734-2480Bethlehem Apparatus Company, Inc.890 Front Street. P.O. Box YHellertown, PA 18055(610)838-7034
Browning Ferris IndustriesDelaware District1420 New York Ave.Wilmington, DE 19801(302) 658-4097ChambersCharles City County Landfill(410)747-8861Chesapeake Supply and Equipment Co.238 Railroad Ave.Dover, DE 19904.(302)674-2100Clean Harbors of Baltimore, Inc.;Environmental Services Lab Pack DivisionBaltimore, MD 21230(410)244-8200Delaware Solid Waste Authority,Cherry Island LandfillE. 1 2th St. and Hay Rd.Wilmington, Delaware(302)739-5361Eagle Investigators, Inc.525 Philadelphia PikeWilmington, DE 19809(302)764-8141
Jeanette Smitely
Karen A. Schmuesser,Rental Coordinator
Kristina YamarikService Representative
E. Bradford Bennett
Ken MacKaySales Representative
Col. Irvin B. Smith, Jr. Ret.President
55 Gallon and Overpack Drums
Diesel Fuel and Tank Rental
30 Ton Crane& Operator
AnalyticalLaboratory
Fire Safety PPE for CS2 Operations
Site Security
Disposal of Mercury and Thermometers,Nanometers
Construction Debris Rolloff and TrashDumpster
PPE Rolloff and Disposal
Excavator w/Mounted Shear
Lab-Pack (incineration) and T&DTransport by S.J. Trans Co.
Disposal Facility for Asbestos ContainingMaterials
Emergency Guard Service
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GE Capital Technology3500 Corporate WayDuluth, GA30136(404)813-7142Godwin PumpsOne Floodgate Rd.Bridgeport, NJ 08014(609) 467-3636GP Environmental Services202 Perry ParkwayGaithersburg, MD 20877(301)926-6802Hertz Equipment Rental9325 Rt 130Pensauken, NJ08110(609)665-5671Industrial Resource Network, Inc.707 S. Church St.Wilmington, DE 19801(302) 888-2905Keen Compressed Gas Co. P.O. Box 886 1Wilmington, DE 19899(302) 594-4545Lab Safety Supply, Inc.Janesville, WI 53547-1368(608) 754-2345 '
Lehigh Testing Laboratories, Inc.308 West Basin RoadNewcastle, DE 19720(302) 328-0500NSSI/Reco'very Services Inc.5711 Ethridge StreetHouston, TX 77087(713)641-0391Powerhouse Equipment and EngineeringCo., Inc.220 Mt. Ephraim Ave.Camden, NJ 08104-3201(609)966-0001Rhone-Poulenc BasicChemicals Co.One Corporate Drive Box 881Shelton, CT 06484(203) 925-3473and Disposal at:8615 Manchester Blvd.Houston, TX 770 12
S J TransportationU.S. Route 40, P.O. Box 169Woodtown, NJ 08098(609)769-2741Schneider Laboratories, Inc.104 Berrington CourtRichmond, VA 23221-2702(804)353-6778
Dale BrackenSales Engineer
Amy FriedlanderProject Manager
Thomas SwietanskiSales Representative
Steven Templin,Technician on-site
Ronald J. Lang, ManagerTechnical Services
Philip Kardenetz.Environmental Services
Raja AbouzakiRepresentative
Infared Thermometer for CS2 operations
Pumps and supplies for CS2 operations alsoemergency generator
Waste Stream Analytical Laboratory
Manlifts, Loader(Bobcat), jack-hammer, light towers, pressurewasher & air Compressor
Overpack Drums
Breathing Air, Oxygen, Acetylene, andNitrogen
PPE & Laboratory Equipment
Ultrasonic Inspection of CS2 Tank
Disposal Facility for Mercuric Compounds(DEALT, RMERC) and Thorium Nitrate(Treat, Landfill)
Boiler Rental
Assistance with CS2 Operations;Disposal of CS2
Transportation to Disposal Facility
Arsenic Air Samples Analytical Laboratory
AR307l*33
Simcom Electric Co.2033 Barry StreetWilmington, DE 19805(302)652-5521Tilcon Delaware, IncWilmington, DE(302) 655-0767Tri-State Motor TransitP.O. Box 1 13Joplin, MO 64802(417)624-3131
Whittington Sand & Gravel, Inc.P.O. Box 8Bear, DEI 9701(302) 834-3585
Electrical Service to Tank Farm
Concrete Recycling
Transportation of Thorium Nitrate
Provided backfill
B. Glossary of Abbreviations and Definitions
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act.EPA Environmental Protection AgencyERCS Emergency Removal Contracting ServiceFAS EPA Field Administrative SpecialistNCP National Oil and Hazardous Substance Contingency PlanNOS Not Otherwise SpecifiedORC EPA Office of Regional CounselOSC EPA On Scene CoordinatorPPE Personal Protective EquipmentPPM Parts per MillionRCRA Resource Conservation and Recovery ActRPM Remedial Project ManagerSARA Superfund Amendment and Reauthorization ActTAT Technical Assistance TeamTCLP Toxic Characteristic Leachate Procedure .
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III. NARRATIVE OF EVENTS
In summary, 178 drums, 31 cylinders/pressure vessels, 7,000 gallons of CS2, 15,000 gallons of CS2contaminated water, 36 lab-pack drums and containers, 214 bags of ACM, 80 tons of concrete, 60 cubicyards of PPE/Debris, and 120 cubic yards of construction debris were sent off-site for disposal, recycling,or returned to the manufacturer. A detailed summary of off-site transportation and disposal may be foundin Section V-C. Disposal Methods and Quantities Removed.
The operations approved in the Action Memo consisted of the following components;A) Provide Site security and mobilize/demobilize appropriate personnel and equipment.B) Assess and address on-site buildings with regards to physical and chemical hazards.C) Verify contents and integrity of tanks, process equipment, drums, cylinders, vessels and othercontainers.D) Demolition of buildings and removal of tanks. Actions to include decontamination and/or disposalof debris, structures, and tanks to facilitate access to containerized hazardous materials and to provideaccess for future remedial activities.E) Provide for the off-site transportation and disposal of hazardous substances and contaminants.
The Removal Actions listed above, were completed for the following areas:- Tank Farm,- Laboratory/Warehouse- Process Building Demolition- Sump and Ditch Area
Tank Farm and Carbon Disulfide Transfer:Removal Actions in the tank farm area consisted of the decommissioning and removal of 32 above groundstorage tanks, 1 underground storage tank, 8 process vessels, and 41 smaller tanks (including 19 tanks
• made of asbestos containing materials); 10 of the tanks and vessels were removed from the processbuilding. The residuals in the tanks and vessels were drummed for proper disposal; approximately 85 55-gallon drums were generated. In addition, 2 rail cars of carbon disulfide (CS2) and CS2 contaminatedwater were generated from the CS2 tank removal and decommissioning.
All of the tanks and vessels were decommissioned using a shear attachment on an excavator. Airmonitoring for explosive environments was conducted on all tanks prior to cutting. Decontamination ofthe tanks was performed by scraping out or otherwise removing the residual materials into drums forproper disposal.
Carbon Disulfide Tank Operations:The carbon disulfide tank presented special operational concerns. CS2 is both a poison and is extremelyflammable with a lower explosive level (LEL) of 1% vapor in air. It is best stored in a tank that is partiallysubmerged in water in order to prevent vapor build up in case of a release. The on-site tank was a verticalabove ground tank in fair condition. It was determined that the removal of this tank would include transferof the contents directly into rail cars. The details of the operation are described in the POLREPS and inthis report in Section VI. Chronology of Events. The schematic diagrams of the operation may be foundas Appendix B.
AR307U35
Preparation work included removal of extraneous lines attached to the tank and installation of new linesand valves into the tank to facilitate off-loading, water inlet, and steam injection. Safety measures 'included construction of an earthen dam down-gradient of the tank, bonding and grounding of the tworailroad cars, rails, the tank and all transfer lines, a 2 foot water blanket added to the transfer rail car,hydrostatic pressure test of all transfer lines, temperature and pressure gauges installed, secured andbraced piping, dike containment filled with water, fire/vapor control system implimented, air monitoringprogram was established, night-time lighting installed. As part of safety and communications, allappropriate state and local agencies were notified of the transfer event. Additionally, all site personnelwere in attendance for a special operation/safety meeting. All procedures and contingencies werereviewed and discussed.
The total CS2 operation consisted of 4 phases.Phase 1 - CS2 transfer by gravity drain and water pressure.Phase 2 - Boil of residual CS2 in tank.Phase 3 - Transfer remaining liquids after cooling.Phase 4 - Decommission and remove tank.
The critical temperatures of this operation were 115 F, the boiling point of CS2 and 212 F, the boilingpoint of water. The operation required maintaining the water temperatures in the tank at temperaturesabove 115 F but below 212 F for approximately 24-hours to ensure that residual CS2 in the tank bottomsand tank scale have been boiled out and the vapors collected through the piping and into the rail car.Outer tank temperature, water temperature, and tank head pressure readings were closely monitored. Novapor releases from the tank or piping system were detected.
Continued air monitoring detected the presence of CS2 vapor build-up near the rail car top port, at least95 ppm CS2. Regular applications of water fog succeeded in knock down and reduction of vaporconcentrations. Vapor concentrations remained below 1% CS2 (the LEL of CS2 is 1% vapors in air) inthe rail car by the continued use of water fog above the open port. During the late stages of Phase 2,elevated levels of hydrogen sulfide were detected in rail car #2; water fog applications were increased toreduce the build up of vapors. Periodic air monitoring continued while the tank cooled. Concentrationsof vapors in the tanks remained below the Lower Explosive Limit (LEL) and perimeter air monitoringlevels remained at background levels. At times the concentrations neared the LEL and water fogapplications continued.
Phase 4, the decommissioning of the tank was begun by allowing the tank to vent and dry. Air monitoringshowed the presence of 30-40 ppm CS2 in the tank. No residual material were found in the tank and nolevels of CS2 were detected in the perimeter of the work zones.
Both rail cars were placarded and inerted with nitrogen. Manifests were delivered to EdgemoorYardmaster of Conrail in order to transport cars to Rhone Poulenc disposal facility in Texas.
Laboratory/Warehouse:Initial actions consisted of decontaminating a staging and work area in the laboratory and clearing ofblocked areas to provide safe working areas. Initial inventory of chemicals and cylinders were completedand operations were continued in order to find and segregate laboratory chemicals and warehouse drumsinto compatible storage groups. Preliminary groups are lab-pack, corrosives, inorganics, organic/solvents,and unknowns.
AR307i*36
Removal Actions in the Laboratory and Warehouse consisted of stabilizing, recontainerizing, overpacking,sampling, consolidating, and preparing for off-site transportation and disposal, all drums, containers,cylinders, and laboratory bottles. Actions also included on-site hazard categorization (hazcat) analysis,determination of disposal groups and off-site laboratory analysis for disposal parameters. Many of the gascylinders were returned to their owners. Unknown laboratory containers were organized into basic groups,crushed, neutralized and repackaged for offsite disposal.
Process Building Demolition:An evaluation of the integrity of the warehouse, process area and laboratory was made and it wasdetermined that many sections of the process area were in very poor condition. It was also found that theseareas contained tanks, vats, and other storage vessels that contained unknown chemicals, corrosives andcarbon disulfide. Based on the OSC's evaluation, it was determined that demolition of the four-story steelstructure and first floor enclosed portion (pit) area would be the most plausible method of addressing boththe physical and chemical hazards associated with this area.
Demolition operations were completed, with the use of a sub-contracted crane and operator. Operationsalso included the cutting, dismantling and staging of beams and the removal of tanks, process vessels andprocess lines from the structure. The residual materials in the tanks, lines and vessels are drained anddrummed for proper disposal. During dismantling activities the pit area and four-story structure continuedto deteriorate with sections of concrete falling into the pit area.
The four-story structure was completely removed and two sections of the enclosed pit area were removed.Due to the removal of part of the pit area, cinder block patching of remaining walls was completed as partof site restoration activities.
Sump and Ditch Area:Analytical results from sludge samples in the Site drainage system (used for chemical disposal) showedelevated levels of CS2, cyanates, and reactive sulfides. Approximately 8-10 cubic yards of sludge wasremoved from the sump and stabilized with fly ash. The concrete sump was also removed. Soilsgenerated from underground pipe removal were mixed with the sump sludges. During initial removal ofsump solids, a large fireball erupted from the sump. Near continuous flare-ups occurred during the mixingof the sludges from sparks or heat generated during the'mixing process. Proper fire controls weremaintained throughout the operations.
During soil removal to gain access to the sump, small laboratory bottles, acid drum bung screws, burntsoils and wood, poly sheeting and pieces of large 1-5 gallon containers were encountered. Over 2,000bottles were excavated and haz-catted to determine proper disposal. All bottles were crushed, treated asnecessary, and drummed for proper off-site disposal.
During soil removal a 6-inch pipe was removed that was attached to the sump and led directly to the"ditch" that leads to the lagoon. 3 additional 6 inch pipes, and 2 0.5-inch, and 2 other metal pipes werefound in the area of the sump. These pipes were not attached to the sump but all led away from the areaand towards the marsh/lagoon. These pipes were not marked on any known site maps.
Extent of contamination sampling in the "ditch" was performed. Samples were collected along the ditchat 50 foot intervals for 300 feet along the ditch. Samples were also collected at trenches outside of theditch and at the sump overflow area. Heavily impacted soils and sludges were encountered in the ditch
8 AR307l*37
and extending at least 15 feet outside the ditch. In one area smoke was noted in exposed clay thatcontained green/yellow veins. A second area produced a flare/flame when the excavator moved surfacesoils. Samples taken from these areas were screened with a Photo-Ionization Detector (PID) and CS2colorometric tubes. Both instruments recorded levels above maximum instrument levels at this and othersampling locations. Results of the soil sampling are summarized in Section V-B. Analytical Synopsis.
In association with the sump, contaminated terra cotta, concrete and fiberglass underground piping wasencountered throughout the tank farm. The pipes were located, removed from the ground, decontaminatedand staged for disposal. The soils immediately in>and surrounding the pipes was also contaminated andstaged.
Extensive contamination of the "ditch" and soils associated with the former lagoon, in combination withthe locationof a water line in close proximity to the ditch and hydraulic communication between the Sitelagoons and the Delaware River, lead to increased dealings with the PRPs to continue removal activities.Analytical data, summarized below, was forwarded to the PRP. The PRP assumed removal actionspursuant to an Order.
IV. RESOURCES COMMITTED
A. Initial Funding Request
Halby Chemical is an on-going U.S. EPA Region III NPL Site, On February 03, 1993 a RemovalAssessment was performed in previously unidentified areas of the Site. An abandoned laboratory withdeteriorating and incompatibly stored chemicals was found. Also found during the assessment was anabandoned tank farm and a process building in extremely poor condition. Based on the assessment theOSC obligated 200K for Emergency Actions to stabilize the chemicals found in the laboratory.
B. Additional Funding Request
On February 23, 1995 a second Funding Request was approved bringing the site ceiling to $1,847,000.The additional funding was used to address additional contamination and releases found during the initialactions. During the Removal, significant amounts of soil contamination was found on-site. The soils weredetermined to be hazardous wastes (flammable and reactive). On July 06,1995, the third Funding Requestwas approved, bringing the site ceiling to $13,464,000. This Action Memo defined the scope of work toaddress the hazardous wastes found in-situ. After this Funding was approved, the PRP expressed aninterest in pursuing clean-up operations at the Site. Removal actions were completed on August 01,1995.
AR3G7I438
C. Estimated Total Cost Summary
ExtramuralERCS............................................... $ 1,082,047TAT.................................................. $ 66,531Extramural Subtotal......................... $ 1,148,578
IntramuralEPA Direct....................................... $ 38,175EPA Indirect..................................... $ 81,440Intramural Subtotal........................... $ 119,615
Total Project Cost (estimated).......... $ 1,268,193
Project Ceiling:................................. $ 13,464,000
10.6 percent of the total project ceiling was expended.
V. EFFECTIVENESS OF THE REMOVAL
A. Activities of the Various Agencies
1. Federal Agencies
Michael Towle, On-Scene Coordinator and Eric Newman RPM of the EPA Region III, Philadelphia,Pennsylvania office directed all of the removal activities. RPM Newman closely coordinated with otherEPA personnel, Federal agencies, state departments and local officials. The OSC directed the dailyactivities of the ERCS contractor and TAT personnel.
FAS James Wright assisted the OSC with cost tracking and other administrative duties associated withthe project.
The EPA Office of Regional Council (ORC) handled site-related legal matters and advised the OSCwhenever necessary.
The National Federal Trustees (NOAA and DOI) were informed of site activities. The DOI apprised theOSC of endangered plant and animal species in the area. USFWS, NOAA, and EPA EnvironmentalServices Division were on-site and apprised of removal actions and observed site activities.
2. State and Local Agencies
Coordination and assistance by Delaware Department of Natural Resources and Environmental Control(DNREC) contributed to the success of this project. DNREC Project Manager Jane Biggs-Sangercoordinated with the OSC and RPM and provided background information and technical assistanceduring the entire project.
10 AR3Q71439
3. Contractors
The Roy F. WESTON, Inc., Technical Assistance Team (TAT) personnel provided technical supportduring the removal activities. Responsibilities of the TAT included multi-media sampling, airmonitoring, site safety protocol, progress monitoring and documentation, and photo and writtendocumentation.
Environmental Technology, Inc. (ETI), served as the primary cleanup contractor under the EmergencyRemoval Cleanup Services (ERCS) mechanism. ETI was responsible for providing the manpower andequipment necessary to complete the project. ERCS also provided and supervised subcontractor servicesincluding the site security, laboratory analysis, and the transportation and disposal of hazardous wastes.
11 AR3Q7HQ
B. Analytical Synopsis
Extent of contamination sampling was performed in and around the "ditch" to determine the nature andextent of contamination in this area. The following tables present a selected synopsis of the laboratoryresults of the soil samples. Sample Location Maps may be found in Appendix A. The full analyticalpackage and results may be obtained from EPA Region III, Philadelphia, PA.
The following samples were collected from the ditch area and analyzed for carbon disulfideconcentration only. Results are in parts per million (ppm).
Sample Number
HCS-1
HCS-2
HCS-3
HCS-4
HCS-5
HCS-6HCS-7
HCS-8
HCS-9
HCS-10
HCS-11
HCS-1 2
HCS-1 3
HCS-1 4
HCS-15
HCS-1 6
HCS-17
HCS-1 8
HCS-20
HCS-2 1HCS-23 'HCS-24HCS-25
Carbon Disulfide(ppm)
79.0
2,100
5,900
120
8,100
6,400
49.0
110,000
5.00
11.0
140
7,300
28,000
1,300
107,000
39.000
11,000
430
62.0
ND12 '428
Depth(feet)
3.5
4.5
0.51.04.03.04.04.5
3.0
1.0
4.0
5.0
5.5
7.0
8.0
9.5
11.0
12.0
4.0
2.0
5.0
7.0
9.0
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The following samples were collected from the ditch area and analyzed for carbon disulfide (ppm),ignitability (°F), reactive cyanide (ppm), reactive sulfide (ppm), and ammonia (ppm).
SampleNumber
HAS-1A .
HAS- IB
HAS- 1C
HAS-2A
HAS-2B
HAS-3A
HAS-3B
HAS-4A
HAS-4B
HAS-5A
HAS-5B
HAS-6A
HAS-6B
HAS-6D
HAS-7A
HAS-7B
HAS-8A
HAS-8B
HAS-9
HAS-10BG
CS2• (Ppm)2
7
28
8,6006,600
410,000
8,800160,000
8,600
140
980,000
730
290
400
10
14
5
5
<1
ND
Ignitability(°F)*****
71.6**
*
71.6*
*
*
*
*
*
*
*
*
Reactive CN(ppm)
ND43.5
0.73
0.79
0.72
0.46
2.680.6
ND
1.09
ND
0.73
2.37
0.73
10.9
3
15
1.86
ND
0.84
ReactiveSulfide (ppm)NDND
ND
ND
3,440
ND
NDND
ND
ND
42,000
2,500
ND
ND
ND
350ND
950
ND
ND
Ammonia(ppm)
540
94
200
140
1,360
230
590
pH<7
pH<7
pH<7
8,900
1,280.
290
440
pH<7
410
pH<7
840
pH<7
pH<7
* : Ignitibility is greater than 140 °F.ND: Not Detected
13 AR307H2
The following samples were collected from the ditch area and analyzed for arsenic, cadmium,chromium, lead, mercury and zinc. All results are in parts per million (ppm).
SampleNumber
HAS-1AHAS- IB
HAS- 1C
HAS-2A
HAS-2BHAS-3A
HAS-3B
HAS-4A
HAS-4B
HAS-5A
HAS-5B
HAS-6AHAS-6BHAS-6D
HAS-7A
HAS-7B
HAS-8A
HAS-8B
HAS-9
HAS-10BG
Arsenic
193
959
148
924
851
340
3,590
4,470
114
4
4,2601,0101,5203,280
265
11 1
312
179
2
19
Cadmium
0.64ND
ND
ND
2.481.152.1ND
ND
ND
104
70.2
0.791.81.01
1.72
1.75
3.89 'ND
ND
Chromium
16.221.8
22.4
14.8
26.4
9.73
35.5
49.2
50.8
4.41
345
19.2
39.540.4
43.3
33.2
132
28.2
27.2
26.8
Lead
39412
63393,46065230
58
26
31875742228
158
331
122
7559107
Mercury
0.64ND
ND
1.570.4518.30
ND
ND
ND
ND
37.80
6.74
NDND
1.11
1.351.42
0.97
ND
ND
Zinc
25140
23
2,560
6,100
968
255
1,140
72
15
81,300
30,600
134136
198
706
723
847
28
95
ND: Not Detected
14
C. Disposal Methods and Quantities Removed
This section summarizes the types and quantities of hazardous materials that were identified andtransported off-site for proper disposal. The following information is presented according to wastestream and manifest number. Original manifests and related documentation are maintained at theEPA Region III office, Philadelphia, PA.
Disposal Summary Chart
ManifestNo.
9500195001
9500195001
95001
95001
95001
95001
95001
95001
95001
95001950029500295002
9500295003
95004
95005
Date
4/12/954/12/95-
4/12/954/12/95
4/12/95
4/12/95
4/12/95
4/12/95
4/12/95
4/12/95
4/12/95
4/t2/954/12/954/12/954/12/95
4/12/955/8/95
5/8/95
5/9/95
Quantity
1-DM1-DM
1-DF1-DF
1-DF
2-DF
1-DF
1-DF
1-DF
1-DF
4-DF
5-DF1-DF1-DF1-DF
1-DF1-TC
1-TC
1-DF
Waste Description
Sulfur Chlorides, HC-8,LTN1828, PIHSodium Borohydride, HC-4.5,UN14261Sodium Azide, HC-6.1, UN 1687Arsenic Compounds, Liquid, NOS,HC-6.1, UN 1526 (Arsenic Oxide)Mercury Compounds, NOS, HC-6.1,UN2025 (Mercuric Oxide)Flammable Liquids, Corrosives, NOS,HC-3, UN2924Waste Flammable Solids, NOS,HC-4.1,UN1325
Oxidizing Substances, Liquid,Poisonous, NOS, HC-5.1, UN3099(Silver Nitrate)Organic Peroxide, Type D,Solid,HC-5.2, UN3106Organic Peroxide, Type F Liquid,HC-5.2, UN3 109(Cumene Hydroperoxide)Poisonous Liquid, NOS, HC-6.1UN2810 (Nitroanaline, Chloroanaline)Corrosive Liquid NOS, HC-8, UN 1760Sodium Hydrosulfite,HC-4.2,UN1304Magnesium Powder, HC-4.5, UN1418Poisonous Liquid NOS, HC-6.1,UN2010 (Barium Thiocyanate)Flamable Liquid, NOS, HC-3 UN 1993Carbon Disulfide, HC-3, UN 1 1 3 1 ,Marine PollutantCarbon Disulfide, HC-3, UN 1 13 1,Marine PollutantCorrosive Liquids, Poisonous,NOS,HC-8, UN2922(Mercuric Compounds)
ApplicableRCRACodes
0003, D002D001,D003 ,
P105P012
D009
D001, D002U006, F003D001
D001,D011
D001
D001.U096
P024, P077
DOQ2, U190DOO 1,0003DOO 1,0003D005, D008
00010001,0016
D001.D016
D002, D009
Facility andDisposal Method
CHB - Lab PackCHB - Lab-Pack
CHB - Lab-PackCHB - Lab-Pack
CHB - Lab-Pack(BAI-RMERC)CHB - Lab Pack
CHB - Lab Pack
CHB-Lab-Pack
CHB-Lab-Pack
CHB -Lab Pack
CHB -Lab Pack
CHB -Lab PackCHB - Lab-PackCHB - Lab-PackCHB - Lab-Pack
CHB - Lab-PackRPI - INC EN
RPl - INCEN
NSSI-DEACT/RMERC
15 AR307IM
95006
95007
95007
95008
95008
95008
95008
95009
9500995010
9501195011
95012
95013
6/1/95
8/1/95
8/1/95
8/1/95
8/1/95
8/1/95
8/1/95
8/1/95
8/1/958/1/95
8/1/958/1/95
8/1/95
8/1/95
1-DF
26-DM
49-DM
2-DM
3-DM
4-DM
3-DM
5-DM
8-DM3-DM
1-DM1-DM
1-DM
3 1-DM
Thorium Nitrate, Solid, HC-7UN2976 (Mixed waste: Radioactiveand Oxidizer)Sulfur, Dried Tar
Oil/Petroleum Waste
Corrosive Solids, NOS, HC-8, UN 1759(Sodium Hydroxide)Corrosive Liquids, NOS, HC-8,UN 1760 (SodiuM Hydroxide,Tetrachloroethylene)Hazardous Waste Liquid, NOS,HC-9,UN3082 (Contains Arsenic)Hazardous Waste Liquid, NOS,HC-9,UN3082 (Contains Chromium)Hazardous Waste Liquid, NOSHC-9,N A3 082 (Contains Lead,Tetrachloroethylene)Petroleum Waste 'Corrosive Solids, NOS, HC-8, UN 1759(Acidic Solids)Mercury, HC-8, UN2809Hazardous Waste Solids, NOSHC-9, NA3077 (Mercury Compunds)Hazardous Waste Liquid, NOSHC-9, NA3082(Contains Sulfides, Arsenic)Sulfur, Dried Tar
D001
NDR
NDR
D002
D002, D039
D004
0007
0008, D039
NDRD002
D009D009
0004, 0003
NDR
NSSI-DEACT-A
CMSI-STABL+LFCMSI-STABL^LFCMSI -STABL-fLFCMSI-STABL+LF
CMSI-STABL+LFCMSI-STABL+LFHCC - FSUBS
HCC - FSUBSEMS - STBL+LF
BACI - RMERCBACI - RMERC
LWDI -1NCEN
CMSI-STABL+LF
The disposal facilities are as follows:
CHB - Clean Harbors of Baltimore, Inc.RPI - Rhone-Poulenc Basic Chemicals, Co.NSSI - NSSI/Recovery Services, Inc.CMSI - Chem-Met Services, Inc.HCC - Hukill Chemical CorporationEMS - Envotech Management ServicesBACI - Bethlehem Apparatus Company, Inc.LWDI - LWD Inc.
The treatment/disposal methods are as follows:
INCEN - IncinerationDEALT - DeactivationRMERC - Mercury RecoverySTABL - Solidification/Stabilization
• LF - LandfillFSUBS - Fuels Blending
16 AR3Q7H5
VI. CHRONOLOGY OF EVENTS
Friday February 03. 1995
Under delegation of authority 14-1-A, OSC Towle activates $200,000 of Emergency CERCLA Funding to initiate aRemoval Action to abate the immediate threats posed by the Site (See Special Bulletin A).
A Removal Assessment was performed by OSC Towle and RPM Newman. A chemical laboratory with numerous bottlesand other containers was found on the second floor of the main building. This laboratory had not been previouslydocumented and was found to contain improperly stored and deteriorating containers of hazardous substances.Approximately 10 pressurized cylinders were also found. .In addition to the laboratory the site contained a warehousewith deteriorating drums, a 4-story process building containing reaction vessels and process lines, and a tank farmcontaining approximately 40 tanks with many of the contents unknown at that time.
DNREC authorities contacted and arrive on-site; DNREC agreed on the need for immediate action to be taken by EPA. '
Brandywine Fire Department Chief was on-site during the inspection and reported that based on past fire-fightingexperience e at this site, that it would be doubtful if resources and/or personnel would be put in harms way to fight a fire atthis location.
TAT Chemist on-site to verify findings by OSC and RPM.
ERCS contacted and security guard service was in place by 1800 hours. Non-working hour security service remained in-place for the entire Removal Action.
Sunday February 5. 1995
A major snowstorm delayed mobilization operations until this date.
The laboratory building was found to be in poor condition with many roof leaks affecting the stored chemicals.
ERCS crew arrives on-site and begins segregating and securing chemicals that are incompatibly stored and/or under activeroof leaks.
Monday February 06 through Thursday February 09. 1995
ERCS and TAT inspect work areas for access and decontamination. Potentially contaminated areas in the laboratory aredecontaminated and blocked areas are cleared to provide safe working areas. Initial inventory of chemicals and cylindersfound in laboratory arid drums found in warehouse completed.
Operations continue to find and segregate laboratory chemicals and warehouse drums into compatible storage groups.Preliminary groups are lab-pack, corrosives, inorganics, organic/solvents, and unknowns.
Electrician on-site to assess integrity of existing service in the laboratory and warehouse and to determine improving thepoor existing lighting.
Evaluation of integrity of warehouse, laboratory, and process area is begun. Many sections of these areas appear to be invery poor condition. Residual chemical hazards in these areas are also evaluated. It is determined that the process linesmay contain carbon disulfide, which is very flammable, and other hazardous substances used during production.
Tuesday February 14 through Friday February 17. 1995
After OSC's evaluation of integrity of process area, it was determined that demolition of the 4-story steel structure wouldbe the most plausible method of addressing both the chemical and physical hazards associated with this area.
17 AR307H6
ERCS sub-contractor, Guardian Environmental Services (GES) mobed to site to begin process tower demolitionoperations.
114 drums, approximately 600 containers, and 12 cylinders have been found and securely staged in the warehouse andlaboratory. These items were found throughout the laboratory, storerooms, warehouse, maintenance areas, and the outdooryard.
Sampling and hazard categorization (hazcat) analysis of drums and small containers (labeled and unknowns) begins.
Mapping of process and tank lines is begun to facilitate safe removal of the tanks and vessels.Preparations begun to sample the tank of Carbon Disulfide, which is located adjacent to the process tower and warehouse.
DuPont's environmental services group on-site to retrieve seven small pressure vessels, possible containing halon firesuppressant.
Saturday February 18. through Friday February 24. 1995
Sampling and hazcat analysis continues. 117 Drum samples completed.
Investigation of CS2 tank decommissioning options continues with potential vendors on-site to observe the tank andsite/work access.
Investigation of de-energizing electric in process buildings while maintaining service to the tank farm continues withpotential vendors on-site to assess scope of work.
Monday February 27. through Friday March 03. 1995
Based on previous site information, and contaminants at the site, an air monitoring program for airborne paniculate arsenicwas established. The sampling was started this week. All results were well below OSHA levels for arsenic (the NIOSHrecommended TWA is 2ug/m3 and the OSHA TWA exposure limit is 10 ug/m3).
Decontamination station for outdoor work areas completed.
Removal of construction debris and process lines from the process buildings continued. The building continues todeteriorate and implementation of safety controls continue in the process building and "pit" area.
Investigation of CS2 tank decommissioning continued. A sample of the tank was obtained from an open pipe on top of thetank. It was determined that the tank holds approximately 5,000 gallons of CS2, 10,000 gallons of water and anundetermined amount of sludge.
Sub-contractor, Simcom Electric Company, of Wilmington, Delaware was selected to perform electrical work and beganwork this week.
Clearing of debris in the tank farm, which posed access restrictions and safety problems, completed.
17 additional small tanks and vessels found during investigation of tank farm for preparation for decommissioning actions.All tanks were inspected for integrity, samples of residuals collected and air monitoring performed.
Matheson Gas on-site to retrieve 12 cylinders of: ammonia (2), hydrogen sulfide (5), hydrogen chloride (2), sulfur dioxide(1), methyl chloride (1) and butadiene (1).
Hazcat analysis of drum samples completed and bulked samples collected to be laboratory analyzed.
18 AR307UU7
Monday March 06. through Friday March 10. 1995
Removal of construction debris and process lines from the process buildings continued. The building continues todeteriorate and implementation of safety controls continue'in the process building and "pit" area. During liquid transfer. operations in the pit area, portions of the process building collapsed into the pit. No personnel were in the immediate areaat the time. Based on the continued deterioration, it was determined that the solids remaining in the tanks in the pit wouldremain until the remainder of the process building is demolished. The tanks in the pit were covered with poly and the areawas then restricted from all access.
Pipe removal and tank isolation operations in tank farm area began. Both overhead and below ground pipes wereremoved. Organic and oxidizing substances were drained and properly containerized. Tanks 14, 38, and 39 were drainedand removed to outside the north fence.
Excavator with shear attachment arrived on site to begin tank decommissioning operations. Tanks two tanks (P-l and P-2)completed.
Electrical sub-contractor continues work'in tank farm. '
Investigation of CS2 tank decommissioning continued. Conrail inspector on-site to determine that rail-line within theproperty is suitable for expected tank car operations to transfer the CS2 off-site. Samples of CS2 sent to bidders fordecommissioning operations. Bid responses are received on March 24, 1995.
Sub-contract awarded to laboratory for disposal analysis.
Monday March 13 through Friday March 17. 1995
Tank decommissioning operations continued; 6 tanks (P-3, 20, 21, 29, 27, and 8) completed. 11 (drums of residualmaterials were generated from the tanks.
Electrical sub-contractor continues work in tank farm area.
Process building demolition operations with the crane began, Operations include the cutting, dismantling and staging ofbeams and removal of tanks and process vessels or other machinery. Process vessels and lines have been traced back tothe CS2 tank and removed from the building and secured. All tanks, vessels, and lines are drained and the materialsdrummed for proper disposal.
Preparation for disposal operations continue with bulking of compatible groups of small containers and drums. The 14drums generated from the tanks in the pit area are sampled for hazcat analysis.
Monday March 20. through Friday March 24. 1995
Process building demolition operations continued; the 4-story steel tower completed. The shear was used to assist withremoval of the lower beams and concrete.
Tank decommissioning operations continued; 3 tanks (41, 16, and 26) completed; tank 26 was removed from the processtower. Three drums of residual materials were generated from the tanks. Isolation of tanks continued with the cutting andremoval of overhead lines.
Material bulking operations continue with flammable, ammonium thiocyanate, and sulfide groups. Properly emptied andrinsed drums and small containers are crushed using shear excavator. During this week, 11 drums, 5 emptied oxygencylinders and numerous small containers were crushed and removed.
25 previously un-identified small containers were found in the warehouse and inventoried and sampled. The containersincluded poison, corrosives, flammable, combustible and unknown liquids and solids. Attempted to obtain samples fromthe north side sump. It was determined that the sump is at least 9 feet deep and filled with sludge with a strong odor.
Electrical work completed and installations inspected by local inspector.
Bids received for sub-contractor to perform CS2 tank decommissioning and off-site T&D. Only one company respondedwith a bid.
Monday March 27. through Friday March 31. 1995
Tank decommissioning operations continued; 5 tanks (13, 18, 7, 2, and 3) and one 12- foot long heating vessel completed.16 drums of residual materials were generated from the tanks and vessel.
Demolition of second half (enclosed portion) of process building began. Use of crane continued for removal of outerwooden structure of steel framed building. Deterioration of the structure and vessels continued. A 3-part reaction vesseltraced to the CS2 lines was removed and staged for decontamination.
Air products on-site to retrieve 4 cylinders; acetylene (3) and hydrogen bromide (1).
CS2 tank decommissioning work plan received from bidder (Rhone Poulenc) Review of plan begun.
Material bulking operations continue with drum bulking operations and crush pile. 348 small containers were crushedmixed with oil dry, lime, sodium bicarbonate and magnesium oxide (all found on-site); 3 55-gallon drums were generated.Container contents of the unknowns screened for mercury and arsenic; results negative. Compatibility testing for disposalgroups continues.
On-site meeting held with OSC, RPM, PRP, EPA-ORC, and DNREC. Site history discussed and observations made ofcurrent site activities.
Monday April 03. through Friday April 07. 1995
Tank decommissioning operations continued; 6 tanks (1, 5, 6, 51, 52, and 54), one 10- foot long process vessel fromprocess building, and the 3-part CS2 reaction vessel completed. 5 drums of residual materials were generated from thetanks and vessels. 30 small containers, 1 drum and 2 empty cylinders (MAPP gas and acetylene) were alsodecommissioned and removed. Removal of overhead piping and isolation of tanks in the tank farm continued.
Demolition of second half (enclosed portion) of process building completed and crane demobilized.. Deterioration of thestructure and vessels continued. 1 mixing vessel, 2 process vessels and other machinery removed. Due to removal of thetwo sections of the process building, cinder block patching is needed in some areas of the warehouse to maintain itsintegrity. This work will be completed as part of site restoration activities.
Sub-contractor Lehigh testing on-site to perform ultrasonic integrity test of CS2 tank. Results showed that the body of thetank is in fair condition, and that weak spots exist at pipe connections, additionally, the very top of the tank could not betested due to insulation on the tank.
A sample of the sludge from the sump was obtained. The sample exhibited elevated PID readings (300 ppm)approximately 500 ppm cyanate and the presence of sulfides.
Drum disposal operations continue with sample collection and determination of disposal groups and restating of drumsinto accessible groups.
Arrangements for sub-contractor from Rhone Poulenc Company (RFC) to be on -site to assist with planning for CS2 tankdecommissioning. Rail cars arranged to be on-site for transfer of CS2.
Monday April 10. through Thursday April 13. 1995
Tank decommissioning operations continued; 2 tanks (22A and 9,), one 6-ail excavated UST completed. 3 drums ofresidual materials were generated. Removal of overhead piping and isolation of tanks in the tank farm continued.
The 6-oil tank generated 5 drums and 1,200 gallons (vacuum-truck) of waste oil. The residuals exceeded fuels blendinglevels for chromium and were restaged into 22 55-gallon drums for proper disposal. DNREC was on-site to document °proper removal and closure of UST for the state UST program/
Site restoration activities continued and include wall patching and removal of tank cradles and other debris in the tankfarm.
Sub-contractor Clean Harbors on-site for T&D of lab packs. 20 containers (12 waste streams) were transported off-site.Off site T&D continued with disposal of 1 roll off of construction debris and 1 roll-off of PPE.
USFWS, NOAA, and EPA Environmental. Services Division on-site, apprised of removal actions to date, and observedsite activities.
Tuesday April 18. through Thursday April 20. 1995
Site restoration activities continued and include wall patching and removal of tank cradles and other debris in the tankfarm.
Off site T&D continued with disposal of 1 roll off of construction debris and 1 roll-off of PPE.*
DNREC representatives, Wilmington LEPC, local fire officials, EPA, ERCS, TAT, and RPC review the planned CS2operations and safety procedures. Appropriate comments from the group were incorporated into the plan.
Preparation for CS2 tank decommissioning operations completed. Tank work included removal of extraneous linesattached to the tank installation of new lines and valves into the tank to facilitate off-loading, water inlet, and steaminjection.
Safety measures included construction of an earthen dam down-gradient of the tank, bonding and grounding of the tworailroad cars, rails, the tank and all transfer lines, a 2 foot water blanket was added to the transfer rail car, hydrostaticpressure test of all transfer lines, temperature and pressure gauges checked, secured and braced piping, dike containmentfilled with water, fire/vapor control system checked, air monitoring equipment checked, operational status of generator,night lighting and water pumps checked, and all appropriate state and local agencies were notified of the transfer event.
Additionally, all site personnel were in attendance for a special operation/safety meeting. All procedures andcontingencies were reviewed and discussed.
Friday April 21. through Monday April 24. 1995 ;
The critical 24-hour continuous CS2 transfer operations were begun at 1600 hours on Friday and were concluded at 1500hours Monday, April 24, 1995. -
The total CS2 operation consisted of 4 phases:Phase 1 - CS2 transfer by gravity drain and water pressure.Phase 2 - Boil of residual CS2 in tank.Phase 3 - Transfer remaining liquids after cooling.Phase 4 - Decommission and remove tank.
Phase 1 was completed at 0440 hours on Saturday, approximately 7,600 gallons of CS2 was transferred. At 0500 hoursoperations switched to preparation for Phase 2; at 1325 hours all piping was switched and the boiling operations began.Both rail cars were "utilized for this operation. To maintain a 3 foot head space at the top of the tank water was periodicallydrained into rail car #1. The boiled/condensating CS2 was transferred to rail car #2.
The critical temperatures of this operation are 115 F, the boiling point of CS2 and 212 F, the boiling point of water. Theoperation required maintaining the water temperatures in the tank at temperatures above 115 F but below 212 F for
21
approximately 24-hours to ensure that residual CS2 in the tank bottoms and tank scale have been boiled out and thevapors collected through the piping and into the rail car. Outer tank temperature, water temperature, and tank headpressure readings were closely monitored. By 1930 hours the tank temperature had reached approximately 110 F. At2000 hours the generator for the boiler broke down. A replacement generator was procured and the boiler was back on-line at 0100 hours Sunday morning. By 0300 hours the tank temperature had reached 120 F, by 0730 hours the liquidtemperatures inside the tank had reached 140 F. No vapor releases from the tank or piping system were detected.
Continued air monitoring detected the presence of CS2 vapor build-up near the rail car top port, at least 95 ppm CS2.Regular applications of water fog succeeded in knock down and reduction of vapor concentrations. Vapor concentrationsremained below 1% CS2 (the LEL of CS2 is 1% vapors in air) in the rail car by the continued use of water fog above theopen port. During the late stages of Phase 2, elevated levels of hydrogen sulfide were detected in rail car #2; water fogapplications were increased to reduce the build up of vapors.
Samples of the transfer liquid were obtained via a sampling port installed near the rail car open port; the clear liquidsamples was determined to be nearly pure CS2 by on-site hazcat. By 1900 hours no CS2 was detected in the samples.Approximately 300 gallons of CS2 had been transferred to the rail car through the boiling process.
At 2100 hours on Sunday night, the water temperature in the tank had reached 197 F and the boiler was shut down. Anyremaining CS2 would continue to boil out of the tank and collect into rail car #2 until the tank temperature cools to below115 F. Air monitoring and fire watch were maintained until 1500 hours Monday afternoon, at this time the tanktemperature was 160 F. Phase 2 continued until temperatures reached below 100 F.
Tuesday April 25. through Friday April 28. 1995
Periodic air monitoring continued while the tank cooled. Concentrations of vapors in the tanks remained below the LowerExplosive Limit (LEL) and perimeter air monitoring levels remained at background levels. At times the concentrationsneared the LEL and water fog applications continued.
Phase 2 was completed at 1500 hours on Wednesday April 25 and the tank temperature was 97 F.
Phase 3 was completed on Friday, April 28. Approximately 16,000 gallons transferred.
Phase 4, the decommissioning of the beast tank was begun by allowing the tank to vent and dry. Air monitoring showedthe presence of 30-40 ppm CS2 in the tank. No levels of CS2 were detected in the perimeter of the work zones.
Tank removal and other site operations were continued. One tank (#10) completed and 2 drums of residual materialgenerated.
Drum bulking operations continue with acidic, organic, and inorganic groups.
Clean Harbors on site to complete disposal of lab-packs. 4 drums packed and transported off-site. One container ofThorium Nitrate rXDxidtzer & Radioactive) remains from the lab-pack group; arrangements being made to find a transporterand disposal facility.
Monday May 01. through Friday .May 05. 1995
Preparation of CS2 rail cars for transportation to disposal facility began. Placards placed on cars and manifests completed.The cars require an inert head space for transport. Rail car # 1 nitrogen gas inert completed.
Tank decommissioning operations continued, 3 tanks (4-oil tank un-numbered, R-5, and 11), 2 reaction vessels, and 5small tanks/vessels found along fence completed. 5 drums of residual materials generated from tanks and vessels.
Site restoration of warehouse building completed.
22 AR3G7t*5l
19 small un-numbered tanks of 250-500 gallon capacity were found along the fence line. 1 drum of residual solids- generated. The tanks are brand name of "Haveg" material; a 50% anthopnylite asbestos and 50% phenol resin mixture.This type of tank is no longer manufactured and disposal and decommissioning operations are being investigated.
Emptied drums from bulking operations cut-up, crushed, and/or properly decommissioned. This weeks total included 21fiber drums, 3 poly drums and 7 40-gallon drums, and 17 55-gallon steel drums.
Drum bulking operations continued with acidic solids group!
An underground fiberglass line leading from the CS2 tank dike was traced with the track-hoe. The line branches off andboth lines appeared to exit the site area and into the marsh area.
Monday May 08. through Friday Mav 12. 1995
Final preparation of CS2 rail cars for transportation to disposal completed. Both cars inerted with nitrogen. Manifestsdelivered to Edgemoor Yardmaster and Conrail on-site to transport cars to Rhone Poulenc disposal facility in Texas.
Tank decommissioning operations continued, CS2 (Tank 4) completed by dropping it and cutting it with the shearattachment, no residual materials were found in the tank.
Tank removal .of "Haveg" tanks completed. 19 tanks and 5 small collars completed. Operations included "wet methods",proper handling and bagging of materials and proper respiratory protection. A total of 214 bags of asbestos containingmaterial were generated.
All overhead lines in tank farm removed and site restoration and access operations continued. Site access improvementsare continued to facilitate future activities, consistent with remedial actions and current investigation and removal ofunderground pipes and sumps.
PRP Witco Corporation sub-contractor on-site to retrieve drums. 13 Drums of "Coherex" (organic liquid) sent for fuelsblending; 12 drums of ammonium thiocyanate liquid and 4 drums of ammonium thiocyanate solid transported as productto Witco Corp in Louisiana.
Approximately 60 small jars of cyanide compounds with American Cyanamid labels found in the warehouse area.American Cyanamid Cytec division contacted for technical information and possible return of materials.
Drum bulking, overpacking and sampling continues. A total of 159 drums are in the current inventory.
Emptied drums from bulking operations cut-up, crushed, and/or properly decommissioned. This weeks total included 135-gallon containers, 30 1-gallon containers, and 1 55-gallon steel drum.
One lab-pack drum of poison and waste corrosive liquids (mercuric compounds and sodium hydroxide) transported off-sitefor disposal.
Preparations made to begin to locate and excavate underground pipes and sumps.
Monday Mav 15. through Friday may 19. 1995
Bagged "Haveg" asbestos containing materials transported off-site for disposal at Delaware Solid Waste Authority(DSWA) Cherry Island Landfill in Wilmington, Delaware.
Began operations for locating and removing underground pipes in tank farm area. Contaminated terra-cotta, concrete, andfiberglass piping encountered. Piping was removed from the ground, decontaminated and staged for proper disposal. Thesoils around the piping was also noted to be impacted/contaminated.
23 AR307I*52
Continued site access operations. Concrete tank pads and cradles removed to gain access to underground piping.
Approximately 10 pounds of mercury containerized in a shipping flask for transportation to Bethlehem Apparatus Co. forrecycling/recovery. Approximately 50 mercury containing thermometers and manometers remain on-site until properdisposal is arranged.
Monday Mav 22. through Friday May 25. 1995
Completed operations for locating and removing underground pipes in tank farm area. Contaminated terra-cotta, concrete,and fiberglass piping and soils around piping continued. Soils that were excavated along with the pipes and soils fromwithin the pipes are being staged for proper disposal.
Continued site access operations. Concrete tank pads and cradles removed to gain access to underground piping.
Sump sludge removal operations began. Analytical results from the sludge samples showed elevated levels of CS2,cyanates, and reactive sulfides. Approximately 8-10 cubic yards of sludge removed from the sump and staged formixing/solidification with fly ash prior to disposal. Soils from the underground pipes are also being mixed with the sumpsludges. Near continuous flare-ups occur during the mixing of the sludges from sparks or heat generated during themixing process. Proper fire controls are in place during operations.
Site stabilized for holiday weekend demobilization.
Tuesday May 30. through Friday June 02. 1995
Removal of contaminated soils from excavated drain pipes completed; approximately 2 cubic yards of soil generated andadded to sump sludges. Decontamination and staging of pipes completed; approximately 10 cubic yards of pipesgenerated.
Operations at sump continued. Continue to turn pile of sludge to dry it. Sample of sludge collected for disposal analysis.
American Cyanamid Cytec Division sent Code Environmental to site to retrieve jars of cyanides. 9 5-gallon overpackbuckets generated.
Continued site access operations. Concrete from tank pads and cradles transported off-site to local recycling facility;approximately 80 tons of concrete transported off-site. Access operations began for continued work at sump area. Stagingareas cleared and prepared.
Off-site transportation of Waste Thorium Nitrate (oxidizer & radioactive) completed. The 8-oz. jar was packed in a 5-gallon bucket and shipped in a 8x8x8 foot mixed waste dromedary box to NSSI facility in Texas for proper disposal.Radiation levels (betta and gamma) were recorded at background outside of the lab-pack container.
Monday June 05T through Friday. June 09. 1995
Sump operations continue. The sump was completely drained in order to remove the concrete sump. During soil removalto gain access to the sump, hundreds of small laboratory bottles were encountered. Items found in the top 2-feet of soilwere: glass bottles were of various sizes, acid drum bung screws, burnt soils and wood, poly sheeting and pieces of large1-5 gallon containers. All bottles were unlabeled and at least one-half contained liquids and/or solids.
During soil removal a 6-inch pipe was removed that was attached to the sump and led directly to the "Ditch" that leads tothe lagoon. 3 additional 6 inch pipes, and 2 0.5-inch, and 2 other metal pipes were found in the area of the sump. Thesepipes were not attached to the sump but all led away from the area and towards the marsh/lagoon. These pipes were notmarked on any known site maps.
A mobile laboratory was mobed to site to facilitate hazcat analysis of containers bein g excavated. Approximately 1,000bottles were removed from the soils. Initial results show the presence of sulfides in many of the containers.
24 AR307U53
Extent of contamination sampling in the "Ditch" was performed. Samples were collected along the ditch at 50 footintervals up to 300 feet along the ditch. Samples were also collected at trenches outside of the ditch and at the sumpoverflow area. Heavily impacted soils and sludges were encountered in the ditch and extending at least 15 feet outside theditch. In one area smoke was noted in exposed clay that contained green/yellow veins. A second area produced aflare/flame when the excavator moved surface soils. Samples taken from these areas were screened with a PID and CS2Drager tubes. Both instruments recorded levels above their detection limits. Other sampling points exhibited these samereadings.
Storm water controls were completed at the ditch and near the sump to redirect surface water run-off at these areas tofacilitate investigation.
PRP Witco and its environmental contractor, Langan Environmental, on-site to discuss site activities with RPM Newman.
Monday June 12. through Friday June 16. 1995
OSC and RPM begin development of Request for Additional Funding and Change of Scope of Work Funding Request,based on the finding of previously unknown areas of significantly contaminated soils and sludges found at the surface, in aditch that extends from the sump to the lagoon approximately 350' feet away from the start of the ditch.
Complete excavation and backfilling of sump. Excavation of surrounding soils containing laboratory, bottles ofunknowns continues. Over 1,000 bottles excavated to date. Hazcat analysis of bottle contents continued and presence ofsulfides, and low pH (2-3) results continued.
Code Environmental on-site to retrieve lab pack of bottles from American Cyanamid.
Storm and surface water controls continued to be implemented in the ditch and sump areas.
Monday June 19. through Friday June 23. 1995
Staging area for contaminated soils prepared. Continued mixing of contaminated soils with fly ash and staging on-site.
Site restoration activities continue with installation of silt fencing.
Continue excavation of soils containing laboratory bottles of unknowns continues. Approximately 1,076 bottlesexcavated to date.
Hazcat analysis of bottle contents completed and presence of sulfides, and low pH (2-3) results continued. Preparationbegan for bottle crush operations.
Monday June 26. through Friday June-30. 1995
Site restoration activities continue with installation of silt fencing and chain link fence where needed.
Complete excavation of soils containing laboratory bottles of unknowns continues. Over 2,000 bottles excavated to date.
Bottle crushing operations began. Bottles containing reactive sulfides were treated with hydrogen peroxide prior tocrushing. The bottles.were then crushed (remote methods) into a bed of lime and fly ash. All materials were drummed forproper disposal.
Excavated area backfilled with approximately 400 cubic yards (21 truck-loads) of clean fill. The excavated soils havebeen staged and secured.
Treatment and/or disposal options for the staged soils are being investigated.
United Water Company of Wilmington, De. on-site to verify that pipe running parallel to, and in between the railroadtracks and "ditch", is 3-4 feet deep, 16 inch diameter, cast iron pipe used for potable water.
25 AR307U5U
RPM continues to apprise PRP Witco of site activities and new findings on-site. Representatives from PRP Witco'sconsultant, Langan Engineering and Witco's attorney were on-site to meet with EPA and DNREC.
Preparations begin for demobe from site for holiday weekend and final demobilization,
Thursday Julv 06. 1995
On this date, EPA Region III approved a request for Additional Funding and a Change in Scope for Removal Action toaddress the hazardous wastes in the on-site lagoon and ditch area. Exemption from the 12-month and S2 million statutorylimit was also approved. The estimated project ceiling is now 13,464,000.
Monday Julv 10. through Friday Julv 14. 1995
PRP Witco expressed an interest in completing the removal action. Witco and its consultants met with OSC to discusstake-over of site clean-up operations. EPA Enforcement and RPM will continue to coordinate completion of removalactivities with the PRP.
Sub-contract for off-site transportation and disposal of drummed hazardous wastes awarded to Capitol environmentalServices. Final T&D activities are completed after site demobilization.
Site secured and final demobilization activities completed. •
DNREC representatives on-site to observe final EPA operations and discuss ARARs concerns with EPA.
26
VII. FUTURE CONSIDERATIONS
The Halby Chemical NPL Site continues to be the subject of PRP-lead removal actions afterdemobilization of the Site by the OSC. The Fund-lead Removal Action resulted in the removal of allbulk and other chemical hazards found within the buildings, tank farm,, and Site drainage system(sump). The chemical hazards posed by the ditch and lagoon systems are the subject of ongoingremoval actions conducted by PRP Witco. The RPM provides oversight of PRP-lead activities. Sincethe Site is still undergoing removal actions and will undergo Remedial Actions after a Proposed Planand Record of Decision are issued by the PRP, no "post-removal" sampling was conducted todocument conditions after the Removal Action. The RPM, responsible for the Site and the proposaland implementation of Remedial Actions, was heavily involved in the Removal and assisted withdecision making toensure that removal activities were consistent with likely future actions.
27 AR3Q7l*56
APPENDIX A
SITE MAPS
AR307ti57
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AR307U59
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APPENDIX B
CARBON DISULFIDE TRANSFER FIGURES
AR307h6l
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AR307i*62
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AR307U63
APPENDIX C
FUNDING DOCUMENTS
AR307»»6I»
UNITS) STATES EMVIKMt-jrTAI. PROTECTION MBKT«EfiIal »1
841 Chestnut Buildir*Philadelphia. Pemylvania 19107-U31
.DL 0 6 1995SUBJECT: Approval of exemption from the $2 Million and
12-Month Statutory Limits and Additional Fundingand a Change in the Scope for a Removal ActionHalby Chemi£New Castle
FROM: Thomas C. Vo]Hazardous Was-te Management/ Division (3HWOO)
TO: Elliott P. Laws, Assistant AdministratorOffice of Solid Waste and Emergency Response (5101)
THRU: Stephen Luftig, Acting "DirectorOffice of Emergency and Remedial Response (5201)
ATTN: John Riley, Acting DirectorEmergency Response Division (5202)
ISSUE
The attached CERCLA Funding Authorization pertains to theHalby Cliemical Site in New Castle, Delaware (Site). The Site isan NPL Site. Funding in the amount of $11,571,590 above the$1,692,410, and $200,000 of CERCLA funding authorized by theRegion and the OSC pursuant to Delegation of Authority 14-1-A(see Action Memorandum, dated February 23, 1995, and SpecialBulletin A, dated February 3, 1995, attached), is required tocontinue a Removal Action to mitigate the imminent andsubstantial threat to human health and the environment posed byhazardous substances and other contaminants at the Site.
The On-Scene Coordinator has determined that the Sitecontinues to meet the criteria for conducting a Removal Actionunder the National Oil and Hazardous Substances Contingency Plan(NCP), 40 CFR 300.415. Delegation of Authority 14-2-B providesthat the Regional Administrator has the authority to approvefunding in excess of $2 Million for removal actions which areappropriate and consistent with remedial actions at NPL Sites.Pursuant to Delegation of Authority 14-2-B, Region III has thusapproved additional funds in the amount of $11,571,590, of whichapproximately $ 11,251,590 are" Extramural Costs. Approval ofthis request would raise the Estimated Project Ceiling to$13,464,000, of which $ 12,954,000 are Extramural Costs.
AR307U65
Attachments: 1) Request for Exemption from the $2 Million and12-Month Statutory Limits and Additional Fundingand a Change in the Scope for a Removal Action2) Request for Additional Funding and aClarification of Scope3) Special Bulletin A
6R307I466
LNITBO SWIES BWIKN«<IWL ROKTICN ABCYFffilCN 111
841 Chestnut BuiIdirgRii lactelphia, Pennsylvania 19107-4431
0 6 1995SUBJECT: Request for Exemption from the $2 Million and 12-Month
Statutory Limits and Additional Funding and a Change inthe Scope for a Removal ActionHalby Chemical NPL SiteNew Castle County, Delaware
FROM: Michael Towle,Eastern Response Sectiori (3HW3J:)
Eric Newman, RPM//1!Delaware/Mary landrRemediiTl Section (3HW42)
TO: Thomas c. Voltaggio, DirectorHazardous Waste Management Division (3HWOO)
THRU: Abraham Ferdas, Associate Divisionfor Superfund Programs (3HW02)
I. ISSUE
The Halby Chemical NPL site in New Castle, Delaware is thelocation of the Halby Chemical Removal Action which has beenunderway since February 3, 1995. Site conditions justifying theongoing Removal Action are described in Special Bulletin A, datedFebruary 3, 1995, and the Request for Additional Funding and aClarification of the Scope (Action Memorandum), dated February23, 1995. These documents are attached.
During the Removal Action, EPA found that the soil andsediments associated with the Site's drainage system, whichincludes a sump, discharge pipes, a ditch, and a former lagoonarea, are significantly contaminated with hazardous substancesthat exhibit RCRA hazardous characteristics of ignitability,reactivity, and/or corrosivity. EPA also found that ignitableand reactive sludge which is highly contaminated with hazardoussubstances is located within the drainage system. Thecontaminated media are associated with a drainage systea whichformerly conveyed chemical production wastes from the Site'schemical production area to the Site's lagoon. The environmentalmedia associated with the drainage system are significantlycontaminated with carbon disulfide, arsenic, and zinc, andcontain high concentrations of reactive sulfides. The drainagesystem continues to convey contaminated water and sediment andhazardous substances to the former lagoon area which in turn ishydraulically connected to area wetlands and waterways. Accessto the majority of the contaminated area is not restricted.Additionally, EPA has learned that a potable water main lies
AR3Q7l*67
within the contaminated area as well as an operating rail line,overhead electric lines, and other pipe systems.
Documentation obtained from the current owner of thebuildings on the Site, indicate that at one time a facilityreportedly produced or used a variety of chemicals includingammonium thiocyanate, zinc thiocyante, alkabane (containing highconcentrations of arsenic), and thioglycolate. Carbon disulfidewas used extensively in the facility's history. Carbondisulfide, ammonium thiocyanate, arsenic, and zinc, as well asother materials identified by EPA at the Site, are hazardoussubstances within the meaning of Section 101(14) of theComprehensive Environmental Response, Compensation and LiabilityAct of 1980, as amended, (CERCLA), 42 U.S.C. Section 9601(14),since they are listed as hazardous substances at 40 C.F.R. 302.4.Documentation obtained from the current owner shows that largeamounts of hazardous substances and pollutants were apparentlylost into the Site's drainage system. Analytical data indicatethat hazardous substances have migrated from the facility intothe environment, including ground water, surface water, areawetlands, and adjacent soils (inclusive of soils which envelopethe potable water line).
The Site poses a significant threat to human health and th*environment due to the presence of and the exposure to hazardouswastes and hazardous substances as well as from the uncontrolledreleases of hazardous substances from soil, sediment, and sludgeinto the environment. The contaminated media are located inareas, accessible to human and animal populations, which aresubject to continued erosion and migration of released hazardoussubstances to ground water, surface water, air, wetlands andwaterways. The release of hazardous substances is indicated bystressed vegetation, air monitoring, and analytical data. Asignificant health threat is posed to anyone traversing thecontaminated area, especially to a worker servicing or otherwisemaintaining utilities and rail service in the contaminated area.
Based upon the above-mentioned information, the OSC hasdetermined that the Site continues to pose an imminent andsubstantial threat to human health and the environment pursuantto Section 300.415 of the National Oil and Hazardous SubstancesPollution Contingency Plan (NCP). Additional funding, a changein the scope, and exemption from the $2 Million and 12-Monthstatutory limits are required to continue the Halby ChemicalRemoval Action.
Continuation of the Removal Action is needed to abate thethreats posed by the Site. All response actions will beconsistent with future remedial actions and will greatlyfacilitate future remedial activity at the Site. There are noprecedent setting issues associated with the response.
AR3071468
II. BACKGROUND
A. sita Description
The Halby Chemical Site is located at 600 Terminal Avenue inNew Castle, Delaware. A portion of the site is located withinthe limits of the City of Wilmington. The Site is within anindustrialized section of Wilmington's port area, but severalresidences and residentially zoned properties are located in theimmediate vicinity of the Site. Within 1 mile of the Site is theurban area of Wilmington, Delaware. The Site drains into theChristina River through a ditch and wetland area (including theformer lagoon area) northwest of the Site. The ditch runsparallel to a potable water main and railroad tracks adjacent toand north of the Site.
The defined NPL Site is approximately 14 acres and includesa former chemical production area located on the southernmost 3acres of the Site. The chemical production area included aconcrete building containing several offices and workshops, fourlaboratories, and a warehouse; a chemical processing area; and, atank farm. Chemicals were manufactured at the Site until thelate 1970's when the Site's use became primarily for chemicalstorage. The Site's chemical production area and tank farm weredismantled during the ongoing removal action while the hazardoussubstances contained therein were removed from tanks and vesselsand placed into secure containers. These wastes currently remainon the Site. However, hazardous substances discovered withincontainers and cylinders within the Site's abandoned laboratorywere repackaged during the removal action and transported off theSite for disposal.
An underground drainage system on the Site formerly servedto convey various chemical production wastes from the productionarea and warehouse area to a sump area. Several drain lines werealso discovered adjacent to the sump. The sump and adjacentdrain lines empty into a large wetland area (former lagoon area)via an unlined ditch. Vegetation is unable to grow in some ofthe soils adjacent to this ditch. The ditch and lagoon presentlydrain to the Christina River, in part, through a breach in aberm, piping under the railroad tracks and subsurface water.
B. Quantities and Types of Substances Present
The Removal Action has currently addressed the contents ofan estimated 600 small containers and 13 cylinders found in theabandoned laboratory area; an estimated 200 drums and 50 tanksfound in the warehouse area, chemical processing area, and tankfarm; and approximately 1000 small containers found haphazardlymixed with shallow soil. The hazardous substances and chemicalsin these containers and vessels such as carbon disulfide, thoriumnitrate, mercury, ammonium thiocyanate, sulfide, cyanide, and
AR307l>69
4 •
tetrachloroethene, have been stabilized, transported off the Siteand disposed, or repackaged and staged for future transportationand off site disposal.
During the removal of sediments from the Site's cloggeddrainage system, EPA discovered an estimated 15 to 20 cubic yardsof ignitable and reactive sludge within the sump. The sumpcollected some of production area discharges prior to furtherdischarge to the ditch. The sludge from the sump also containedelevated concentrations of carbon disulfide. The sump materialis ignitable (it easily flashes at ambient temperature),especially when dry, and contains high levels of reactivesulfide. As such, the sump sludge is a hazardous wasteexhibiting ignitable and reactive characteristics.
Adjacent to the sump, EFA discovered an estimated onethousand small bottles containing unknown chemicals mixed withthe shallow soil. The shallow soil in the sump area in which thebottles are located is highly contaminated, contains reactivesulfides, and, in places, corrosive. The bottles containcorrosive acids and bases, sulfide liquids, and other unknownmaterials. Also in this area EPA found several buried drainagelines, in deeper (1 to 2 feet) soil. Soils associated with thesedrainage lines contained high levels of reactive sulfides, zinc,arsenic, and carbon disulide.
The sump and drainage lines discharge into a ditch whichconveyed production wastes to the former lagoon area locatednorthwest of the production area. The soils and sediments in theditch area (which includes some area of the former lagoon)contain a large amount of sludge and concentrations of carbondisulfide as high as 110,000 ppm; arsenic as high as 30,900 ppa,and zinc as high as 31,000 ppm. In addition, the soil, sludgeand sediment associated with the ditch exhibit hazardouscharacteristics of ignitability and reactivity. Tasks such assampling in the ditch trigger flashes and smoke. The soil,sediment and sludge also contain reactive sulfide as high as14,000 ppm. The contaminated media extends into the wetland area(former lagoon area). The quantity of hazardous substances andhazardous wastes associated with the ditch and lagoon area isunknown. The ditch is approximately 350 feet long and 10 feetwide. The lagoon area extends approximately 6 acres, but may belarger aa some areas have been filled.
c. National Priorities List status
The Halby Chemical Site was promulgated to the NPL in 1986.Environmental media at the Site are being addressed by theremedial program in two operable units. The first operable unit
f (OU1) Remedial Investigation and Feasibility Study (RI/FS) was^completed in 1991. The resulting Record of Decision requires• stabilization and capping of surficial soils within the former
AR307«4?0
chemical production area. The selected remedy has not yet beenimplemented, as the remedy did not adequately allow for thepresence of deteriorating structures and tanks on the Site whichled to project delays. The Removal Action has thus far addressedthe tanks and structures potentially hindering soil remediationwhich is the subject of the OU1 remedy.
The second operable unit RI/FS, focusing on the contaminatedground water and wetland areas, is currently being performed byan Alternate Remedial Contracts (ARCs) contractor under thedirection of the remedial program. A review of the scope of theremedial process confirms that the scope of the RI/FS does notinclude the presence of reactive and ignitable soil, sediment andsludge (characteristic hazardous waste), hundreds of smallcontainers of unknown chemicals within the soil, and significantcontamination potentially affecting public utilities andrailroads and the maintenance thereof. Additionally, analyticaldata collected during the Removal Action indicate thatconcentrations of hazardous substances within the contaminatedmedia are much higher (at least one order of magnitude) thananticipated in the RI/FS. The draft Risk Assessment andFeasibility Study have thus been developed without the benefit ofnew information generated during the Removal Action.
A Removal Action is needed to abate the threats posed by theSite. All response actions will be consistent with futureremedial actions and will greatly facilitate future remedialactivity at the Site by removing significant threats andaddressing the significantly contaminated media and hazardouswaste on the Site. For example, it is likely that stabilizationof the highly contaminated soil, sediment and sludge, includingremoval of the hazardous characteristics and bottles of unknownchemicals, will be a component which is common to any remedialalternative evaluated by the remedial program.
D. State and Local Authorities' Roles
The local fire chief was notified of Site conditions andaccompanied by the OSC/RPM on an inspection of the Site. Thelocal fire chief has been updated during the removal action andhas participated in the planning of tasks posing a significantrisk of fire.
Emergency response personnel from the State of Delaware werenotified and accompanied the OSC/RPM on assessments of the Site.Delaware officials agree that immediate action is needed and haveindicated that EPA should undertake response activity to abatethe threats posed by the Site. The OSC and RPM will continue tocoordinate all Site activities with State and local officials.
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The OSC has communicated with United Water of Delawareconcerning the location of the water main within the contaminatedsoil. The Company has been notified of the hazard posed toworkers who may be maintaining the line. The OSC will continueto coordinate removal activities with the water company.
III. THREAT TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT
See Action Memorandum of February 23, 1995, and SpecialBulletin A, dated February 3, 1995, for additional information onThreats to Public Health or Welfare or the Environment.
Section 300.415 of the NCP lists the factors to beconsidered in determining the appropriateness of a RemovalAction. Paragraphs (b)(2)(i), (ii), (iv), (v), (vi) and (vii) ofSection 300.415 apply as follows to the existing conditions atthe Halby Chemical Site:
A. 300.415(b)(2)(i) "Actual or potential exposure to nearbyhuman populations, animals or the foodchain from hazardous substances orpollutants or contaminants."
The contaminated media (e.g., soil, sediment, sludge,surface water) associated with the Site's drainage system arelocated in an area without restricted access. The OSC haswitnessed people traversing the area of contamination. Hazardoussubstances have migrated from the sump, ditch, and lagoon systeminto surrounding soil, surface water, ground water, and air basedupon Site observations and analytical data. Because access tothe contaminated area is not restricted and the lagoon area ishydraulically connected to adjacent tidally influenced wetlandsand waterways (Christina River), there is a high potential forexposure to human and animal populations from hazardoussubstances and pollutants originating from the Site.
Toxicity testing indicates contaminated media pose fatalconditions to aquatic species affected by Site releases. Ammonia(potentially resultant from ammonium thiocyanate) is a suspectedcause of fatality. Carbon disulfide, arsenic, and/or zinc existat concentrations in solid or aqueous media which pose a threatto human and/or aquatic populations in the surface water/benthicenvironment (e.g., concentrations of arsenic and zinc above WaterQuality Criteria).
Since the contaminated media envelope a public water main(as well as at least two other pipelines of currently unknownuse) and extends into the right-of-way of the adjacent railroad,there is a significant risk to workers maintaining theseservices. Acute and chronic exposure to carbon disulfide whichis in the soil affects the central nervous system. The draftrisk assessment indicates that adverse health affects may occur
AR307147Z
when construction workers are exposed to concentrations of carbondisulfide as low as 5 ppm in soil. Ditch soil has been found tocontain carbon disulfide as high as 110,000 ppm. EPA hasdetected carbon disulfide between 100 and 1000 ppm in the airassociated with sampling activities near the ditch. Levels of500 ppm carbon disulfide are Immediately Dangerous to Life orHealth. It is important to consider that carbon disulfide isheavier than air and will accumulate at the base of an excavationor depression.
Combustion of carbon disulfide or oxidation of the highlevels of reactive sulfides may also result in uncontrolledreleases of potentially harmful, e.g., poisonous, gas such assulfer dioxide or hydrogen sulfide.
B. 300.415(b)(2)(ii) "Actual or potential contamination ofdrinking water supplies or sensitiveecosystems.N
Drainage from the Site, including liquid and sedimentmigrating through the area of the sump and ditch flows into awetland area. The wetland area is, in large part, coincidentwith the area formerly used as a lagoon to evidently catch liquidwastes and other materials flowing from the production area. Thewetland area is connected to the nearby Christina River. Thewetland area and Christina River are home to numerous aquatic andother plant and animal species and is considered to be asensitive ecosystem by Federal Natural Resource Trustees.
A water main passes through the contaminated area betweenthe ditch and the railroad tracks. Contamination of drinkingwater cannot be ruled out if pipe integrity is compromised withinthe contaminated area.
C. 300.415(b)(2)(iv) "High levels of hazardous substances orpollutants or contaminants in soilslargely at or near the surface, that may
i migrate."
The soil and sediment within the ditch and otherwiseassociated with the Site's drainage systems are co-mingled withsludge and highly contaminated with hazardous substances,including carbon disulfide, arsenic, and zinc. In addition, EPAhas determined, that highly contaminated media exhibit ignitableand reactive characteristics of hazardous waste. Because thecontaminated media are located within the Site's normal drainagesystems and within a tidal influence area, continued migration ofhazardous substances from the Site occurs during precipitationevents and daily tide fluctuation.
AR3Q7U3
8
The high levels of hazardous substances in the soil,sediment, and sludge continue to migrate to the ground water andsurface water. Aqueous media exhibit elevated levels of arsenic,zinc, and carbon disulfide which are significantly elevated inSite soil, sediment and sludge.
D. 300.415(b)(2)(v) "Weather conditions that may causehazardous substances or pollutants orcontaminants to migrate or be released."
The area of contaminated soil and sediment is located withina drainage system originally conveying chemical production wastesfrom the production area to the former lagoon area. The drainagesystem continues to convey stormwater from the Site. The area istidally influenced. As such, precipitation and tidal events mayconvey contaminants into adjacent waterways. Contaminantmigration is evidenced by areas with no vegetative cover, areasof chemical seeps, sheens, areas of strong chemical odor, andother Site observations.
E. 300.4l5(b)(2)(vi) "Threat of fire or explosion."
During removal operations, areas of highly reactive andeasily ignitable soils were encountered. Small explosions andsubsequent flash fire within the soil were initiated by contactbetween heavy equipment and rock or metal during sampling andexcavation activities. The extent of this ignitable and reactivesoil is currently unknown and the threat of fire continues.Carbon disulfide is concentrated at levels up to 110,000 ppm inthe ditch soil, sediment and sludge. The highly contaminatedsoil, sediment, and sludge may produce harmful gas duringcombustion, e.g., in a brush fire. Since carbon disulfide vaporis highly flammable and heavier than air, a significant risk isposed to any worker in an excavation or low spot, e.g., repairinga broken water main, since carbon disulfide is highly flammable,with a low flashpoint of -22 degrees and with a lower explosivelimit of 1%. Carbon disulfide vapors may be ignited by anordinary light bulb.
F. 300.415(b)(2)(vii) "The availability of other appropriatefederal or state response mechanisms torespond to the release."
The State of Delaware (Department of Natural Resources andEnvironmental Control) does not currently have the resources tocontinue response actions and has requested that EPA continue theresponse action. Although the Site is on the NPL, there is noremedial contractor presence capable of completing thestabilization of the Site in a timely manner. For example, theremedial program has not anticipated encountering the extent orseverity of the hazard posed by the soil, sediment and sludgewithin the Site's drainage systems and has not anticipated work
KR3Q7U714
affecting public utilities. All removal activities will,however, be consistent with any future remedial actions.
Additional threats may be posed by the Site's contaminatedsoil and/or ground water. These threats cannot be properly orsafely addressed until the immediate threats posed by thechemicals in the containers and the reactive and highlycontaminated soils, sediments, and sludges are addressed.IV. ENDANGERMENT DETERMINATIONS
Actual or threatened releases of hazardous substances fromthis Site, if not addressed by implementing the Response Actionidentified in this Action Memorandum, may present an imminent andsubstantial endangerment to public health, or welfare, or theenvironment.
V. EXEMPTION FROM STATUTORY LIMITS
Section 104(c) of CERCLA, 42 U.S.C. Section 9604(c),provides criteria for exemption from the $2 Million and 12-Monthstatutory limit imposed upon removal actions. Given the severityand nature of the threats posed by the Halby Chemical Site, thesimilarity between continued removal activities and futureremedial actions, and the time frame and cost associated withmitigating the threat posed by the large volume of hazardouswaste at the Site, exemption from the $2 Million and 12-Monthstatutory limit is warranted at this Site.
The Halby Chemical Site meets the consistency exemptioncriteria of Section 104(c)(l)(C) of CERCLA, 42 U.S.C. Section9604(c)(1)(C) to exceed the $2 Million and 12-Month limits forremoval actions. The remedial process is currently in the RI/FSstage. The risk assessment and feasibility study are beingdeveloped without information concerning the high levels ofreactive sulfides, the large volume of highly contaminatedsludge, and the ignitable, reactive, and corrosive characteristicof the sediments and sludge and soil of the drainage system andlagoon .area. As such, this information is not fully consideredin the current development of remedial alternatives. However,the OSC, RPM, and State representatives have had extensivediscussion concerning remediation of the Site and the scope ofthe removal action is entirely consistent with future remedialaction at the Site and would be a component of or wouldsignificantly enhance the effectiveness and implementability ofconsidered remedial alternatives. Stabilization of hazardouswastes and prevention of the migration and release of hazardoussubstances and exposure to these substances would be consideredto be appropriate in any remedial alternative. Continuation ofthe removal action would greatly facilitate implementation of theremedial action at the Site and must be completed in a timelymanner to be protective of public health and the environment.
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The removal action would continue utilizing, as appropriate,information generated during the RI/FS process.
VI. PROPOSED ACTIONS AND COSTS
A. Actions
The actions proposed for this Site are designed to mitigatethe immediate threat posed by exposure to hazardous waste andhazardous substances and by the threat of fire. The proposedactions are also designed to prevent releases of hazardoussubstances from the Site to adjacent wetlands and waterways. Theproposed actions, which are the subject of this request foradditional funding, change in the scope, and exemption fromstatutory limits, are also designed to be consistent withremedial options for the Site. The proposed actions are asfollows:
A. Conduct investigations and plans to control storm waterand other water, including tidal water, which mayhinder stabilization or removal of contaminated mediafrom the Site's drainage system including the ditch,former lagoon area, and associated areas.
B. Implement emission, erosion, sedimentation, stormwater,tide, and other water controls. Controls may includetreatment of contained or released water, as necessary.
C. Implement measures to prevent unauthorized access tothe contaminated area.
D. Assist with collection and analysis of samplesinclusive of samples to determine hazardouscharacteristics and other environmental sampling.
E. Stabilize contaminated soil, sediment, and sludge inditch, former lagoon area, and surrounding area toprevent exposure to and further migration of hazardoussubstances.
Actions may include excavation and treatment, asneeded, to remove hazardous characteristics fromcontaminated media, and stabilize hazardous substancestherein. Actions may include improvements to existingtidal berms and/or barriers and stormwater channels.
F. Isolate water main and other utilities and servicesfrom hazardous and contaminated media and provide cleanaccess to maintain these systems.
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G. Stabilize and stage soil, sediment, and sludge tofacilitate offsite transportation and disposal ofhazardous substances and media contaminated above ARARlevels.
H. Arrange and implement offsite transportation anddisposal of hazardous substances and media contaminatedabove ARAR levels in accordance with environmentalregulations.
I. Backfill excavated areas to existing grade. Backfillareas should provide for stability and use consistentwith area and use, e.g., railroad track stability,water main and utility protection.
J. Provide and implement a plan to relocate aquaticspecies impacted by removal activities to unimpactedareas.
At this time it is anticipated that the project will run longerthan the statutory 12-month time limit for Removal Actions.
B. Estimated Costs
Estimated costs associated with the proposed actions areitemized as follows and do not include off site transportationand disposal of the stabilized wastes:
CURRENT COSTS TO PROPOSEDCEILING DATE CEILING
E3EtraH|ural costs
Regional Allowance CostsERCS $1,652,410 963,209 $5,334,000T&D 7,400,000
Other Extramural CostsTAT 60,000 55,170 220,000
Total Extramural Costs $1,712,410 1,018,379 $12,954,000
Intramural CoatsEPA Direct 60,000 32,730 170,000EPA Indirect 120,000 69,824 340,000
Total intramural Coats $180,000 102,554 510,000
Estimated Total ProjectCeiling $1,892,410 1,120,933 $13,464,000
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C. contribution to Remedial Performance
The proposed removal action will greatly facilitate plannedand probable future remedial actions. A Record of Decision (ROD)for OU1 requires stabilization and capping of surficial soils inproximity to the production area and tank farm. The removalaction, thus far, has addressed the bulk chemicals and hazardoussubstances contained within the tanks and vessels associated withareas subject to the OU1 ROD. The ongoing action has alsoaddressed tanks and structures to facilitate implementation ofthe OU1 ROD.
The proposed removal action will also greatly facilitateremedial actions intending to address contaminants which havealready migrated beyond the production area and into the Site'sdrainage system, ditch, and lagoon as well as into adjacentwetlands and waterways and into ground water. The existingremedial process has not anticipated the magnitude of thesignificantly contaminated sediments and sludges and has thusdeveloped risk assessments and feasibility studies withincomplete information. Additionally, the current remedialprocess has not developed remedies to address large quantities ofhazardous wastes such as the ignitable and reactive soil,sediment, and sludge. The proposed removal actions are typicalcomponents of remedial actions which would be common to mostremedial alternatives addressing similar situations.
D. Compliance with Applicable or Relevant and AppropriateRequirements (ARARa)
The RPM/OSC has contacted Delaware regarding theidentification of ARARs for the Halby Chemical Site. Theproposed Removal Action set forth herein will comply with allapplicable or relevant and appropriate environmental requirementsto the extent practicable considering the exigencies of thesituation.
VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED ORNOT TAKEN
A delay in action or no action at this Site would fail toaddress the threat currently posed to the public and environmentby exposure to hazardous substances from the Site. Additionally,delayed action would allow continued migration of hazardoussubstances from the highly contaminated areas and pose asignificant threat to persons traversing or working within thecontaminated areas.