United States Environmental Protection Agency
Region III
POLLUTION REPORT

Subject: 

The site is located in a mixed industrial and residential area of Trainer, Delaware County, Pennsylvania. The site includes a chemical manufacturing facility consisting of about 200 tanks, several buildings, a laboratory, a wastewater treatment facility, and many processing vessels, equipment items, systems, and pipelines which were used in or are related to the chemical manufacturing processes. Chemicals at the facility included oleum, methanol, heptane, mineral spirits, sulfuric acid, and others including many mixtures.  On April 12, 2007, the OSC was notified by EPA Region III staff that the facility was in bankruptcy court and that chemical substances remained at the facility which may pose a threat. EPA issued Orders to Stoney Creek Technologies and other companies to remove the inventory at the site in order to reduce the potential threats posed by chemicals.

In October 2008, EPA initiated removal activities at the site since Stoney Creek Technologies and other companies which received orders from EPA had failed to remove the chemical inventory.  EPA removal activities included: removing chemicals from tanks, equipment, and piping; decontaminating exterior surfaces to prevent migration of chemicals off site via surface runoff; and decontaminating and reconfiguring the site storm sewer system and waste water treatment plant.  All removal activities were completed in December 10, 2012.

The OSC discovered that the property was sold to Trainer Custom Chemicals and that the company is currently demolishing sections of the plant including storage tanks and process equipment.  On September 25, 2013 EPA and PADEP conducted a site assessment at the property to ensure that activities undertaken by the current owner have not caused a release or threat of release of hazardous substances which might require a removal action.  

OSC Dominic Ventura and PADEP representative Colin Wade met the Mr. James Halkins, President of Trainer Custom Chemicals, LLC at the property at 11:00 on September 25, 2013.  EPA observed that numerous storage tanks and process equipment have been demolished.  Oil staining was observed on the ground in several areas where demolition was occurring.  However, no releases were observed which the OSC believes pose a threat of off site migration.  Mr. Halkins stated that site drainage in work areas has been blocked off and that any small spills that occurred during demolition would be cleaned up.  EPA and PADEP observed Stoney Creek and water discharging from the site storm water system to Stoney Creek.  No oil sheen was observed.  

The OSC asked Mr. Hawkins how he was characterizing any waste generated at the facility.  Mr. Hawkins replied that he was generally unfamiliar with the requirements in RCRA.  The OSC suggested that Trainer Custom Chemicals should become familiar with RCRA or hire a consultant who could help them with sampling and characterizing waste.  The OSC asked whether insulation on piping was being sampled for asbestos prior to demolition.  Mr. Hawkins stated that they had not sampled for asbestos and explained that significant asbestos abatement had been conducted at the facility by a previous owner.   The OSC responded that although some abatement may have been previously conducted, additional sampling should be conducted prior to disturbing insulation because it is not clear what areas were previously sampled/abated and what areas were not.  The OSC explained that targeted asbestos sampling was conducted by EPA prior to removing pipe wrap in some areas and that asbestos containing material was identified in several locations.  Mr. Hawkins responded that they would hire a contractor to sample pipe wrap and conduct abatement as needed.  

The OSC does not believe that a threat exists at the site which warrants a removal action.  However, as noted above, there are several waste management issues that may exist.  PADEP reported to EPA that PADEP's Hazardous Waste Program has been notified of potential issues at the site.

No removal action is planned

-EPA and PADEP are evaluating whether a remedial action is needed at the property.  A decision has not yet been made.

Disposal activities include disposal from individual tanks, tank consolidations, and a variety of drums.  Single manifests may include wastes from multiple sources.  Wastes are primarily disposed as corrosive (acids and caustics), flammable (items containing solvents), and non hazardous (primarily oil-based materials).