Pollution Report Profile - EPA OSC Response

Metro Container Corporation
Trainer, PA - EPA Region III
POLREP #85 - Completion of Field Activities

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On-Scene Coordinator - Michael Towle, On-Scene Coordinator	9/24/2014
Time-Critical - Removal Action	Pollution Report (POLREP) #85
Start Date: 9/30/2013

Site Description
The Site is comprised of two tax parcels located south of the intersection of West 2nd Street and Price Street in the Borough of Trainer, Delaware County, Pennsylvania. For more than 100 years, the property has been used exclusively for industrial and commercial purposes, including the distillation of lubricating oil and paraffin wax, carbon disulfide manufacturing, and steel and fiber drum reconditioning.  The parcels are currently owned by an entity that did not conduct the original operations at the Site and occupied by an entity involved in industrial painting. The Site is surrounded by a chain-link fence and covers an estimated 10.4 acres.  Refer to POLREP #50 for more detailed background information.

A. The Metro Container Corporation Site was listed to the National Priorities List on March 15, 2012.  See POLREP #50 for background information considered in the removal site evaluation leading to current removal actions.

B. The Site was the subject of a Removal Action initiated by EPA in June 1988 and completed by Potentially Responsible Parties pursuant to an EPA Order on Consent.  The primary goals of the Removal Action were to address contaminated liquids pooled at the Site and migrating from the Site towards Stoney Creek alongside the Site and removal of thousands of drums containing residuals. The Removal Action was restarted in 1990 to address drums unearthed during investigations at the Site. The investigations were conducted in response to learning of drum burial activities during legal proceedings.

C. On August 26, 2013, EPA Region III approved an Action Memorandum  for a Time-Critical Removal Action pursuant to Section 104(a) of the Comprehensive Environmental Response, Compensation, and Liability Act, as amended (CERCLA), determining it is appropriate and necessary to mitigate threats posed by the release and threatened release of hazardous substances from the Site. A Removal Action ceiling of $4,051,100, of which $3,923,600 is from the Regional Removal Allowance, was approved by Region III. The Removal Action generally entails the elimination of migration pathways (buried pipes), removal of soils impacted by greater than 50 parts per million PCBs and high concentrations of NAPL, and threats posed by the historic crushed drum area. Actions will be consistent with future anticipated remedial actions and will contribute to the efficient performance of any future remedial action.

D. The Site includes multiple systems of underground pipes and other drainage systems.  The pipes are of unknown purpose.  Two of these pipes are known to have discharged unknown substances directly into Stoney Creek for unknown reasons.  The removal of these systems which convey hazardous substances are the subject of the initial removal actions.

Current Activities
A. ERRS completed final grading and placement of cover material.  The area was rolled and compacted to support existing property use.

B. On 08/19/14, a 20-cubic yard roll-off container (Container #01124) containing an estimated 3,700 pounds of PCB remediation waste (soil and debris) and Galbestos material were shipped for disposal via licensed courier to Wayne Disposal Company in Belleville, Michigan.  Galbestos is a trade-name material that contains PCBs and asbestos.  The material was received and disposed of by Wayne Disposal Company on September 5, 2014.

C. On 08/29/14, a 5-gallon pail of PCB-containing oil and sludge contents withdrawn from Pipe NN was shipped to Veolia ES Technical Solutions in Port Arthur, Texas for incineration.

D. On 08/29/14, seven 55-gallon drums containing D003 reactive sulfide wastes (hazardous waste, n.o.s. (sulfide), 9 PGIII, D003) were shipped to Envirite of Pennsylvania (d/b/a EQ Pennsylvania, a US Ecology Company) in York, Pennsylvania.  The total weight of the drums was estimated at 3,500 pounds.  The wastes were scheduled to be chemically deactivated, stabilized, and disposed by Envirite.  Ultimately, treatment and disposal of the waste may take place at EQ Detroit.

E. All stockpiled waste has now been shipped off-site for disposal.  The OSC is receiving manifests and coordinating to compile the CERCLA disposal reports for this Removal Action.

F. EPA and ERRS are finalizing costs associated with the Removal Action.

G. EPA and START are coordinating to summarize the action, update conflicting information in the record (e.g., identification of pipes in more than one way), and evaluate the environmental information collected from beneath or alongside the main building.

H. ERRS completed decontamination and demobilization of all remaining machinery and equipment. The utility company has de-energized power to the command post. As of 09/05/14, the command post and all equipment have been demobilized from the Site.

Next Steps
A. The OSC and RPM are summarizing and evaluating the analytical information collected during the Removal Action and the observations relating to work which could not be completed (mainly due to the presence of the main building and its deteriorated condition). The information is being considered in the context of whether continued removal actions are necessary to mitigate identified releases of hazardous substances.
B. Complete summary of Removal Action.

Disposition Of Wastes

Waste Stream	Quantity	Manifest #	Disposal Facility
Non-RCRA, non-DOT-regulated material (soil)	6,425.02 tons (estimated)	Various (289 shipments)	Republic Conestoga Landfill, Morgantown, Pennsylvania
Non-RCRA, non-DOT-regulated material (debris)	712.73 tons (estimated)	Various (30 shipments)	Republic Conestoga Landfill, Morgantown, Pennsylvania
TSCA-regulated PCB remediation waste	4,184.34 tons (actual)	Various (175 shipments)	Heritage Environmental Services Landfill, Roachdale, Indiana
Non-hazardous liquid waste (purged ground water)	68.002 gallons (estimated)	Various (12 shipments)	Environmental Recovery Corporation, Lancaster, Pennsylvania
Liquid waste (purged ground water, PCBs 4.1 ppb)	15,542 gallons (estimated)	Various (3 shipments)	Environmental Recovery Corporation, Lancaster, Pennsylvania
Suspect non-friable ACM (transite pipe)	15 tons (estimated)	1 shipment (MCS-ASB-0001)	Republic Conestoga Landfill, Morgantown, Pennsylvania
PCB Remediation Waste and Asbestos-Containing Material (Galbestos)	3,700 pounds (estimated)	1 shipment (012265068JJK)	Waste Disposal Company, Belleville, Michigan
Reactive sulfide wastes (hazardous waste, n.o.s. (sulfide), 9 PGIII, D003)	3,500 pounds (estimated)	1 shipment (012094953JJK)	Envirite of Pennsylvania, York, Pennsylvania
PCB Remediation Waste	75 pounds (estimated)	1 shipment (000558359 VES)	Veolia ES Technical Solutions, Port Authur, Texas