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Hazardous Waste Cleanup: Arkema Incorporated (Formerly: Sartomer Company) in West Chester, Pennsylvania

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Sartomer Company utilized the flexibility available under Resource Conservation and Recovery Act (RCRA) and highlighted in a recent EPA headquarters RCRA Reforms Initiative to move ahead with remediation activities without a permit or Order under Region 3's Facility Lead Program.  As part of the Facility Lead Program, Sartomer submitted a Letter of Commitment to EPA on April 9, 2001.

    Cleanup Status

    EPA Region 3 has determined that Monitored Natural Attenuation with Institutional Controls is the appropriate Corrective Action for the Facility. A public notice was posted in The Daily Local News newspaper on August 25, 2009 and was followed by a thirty (30)-day comment period that ended on September 24, 2009. The Corrective Action Final Decision and Response to Comments (FDRTC) became effective September 30, 2009. The Institutional Controls (ICs) required in the FDRTC have been established for this Facility in the  form of a Uniform Environmental Covenant (UEC) pursuant to, and enforceable against current and future owners, Pennsylvania’s Uniform Environmental Covenants Act, 27 Pa. C.S. § 6501 et seq. (UECA) signed by EPA on May 23 , 2012. The Facility is currently in compliance with all requirements of the UEC confirmed during a site visit by EPA on November 12, 2014.

    The Environmental Indicators (EIs) were completed on May 20, 1999. The two EIs are called "Current Human Exposures Under Control" and "Migration of Contaminated Groundwater Under Control." The EIs completed have status codes of "Yes, Under Control" for both.

    Arkema informed EPA that a merger/sale occurred sometime in late 2013 or early 2014 between Arkema Inc. and Sartomer USA, LLC.  Therefore, the information presented identifies the current owner as Arkema, Inc. but retains the use of Sartomer (formerly ARCO) as the entity that performed the remediation and enacted the Uniform Environmental Covenant.

    Cleanup Background

    In 1987 Sartomer (then ARCO) recognized there had been a release of volatile organic compounds (VOCs) such as benzene, toluene, and heptane to groundwater. In 1988 they began a groundwater pump and treat remediation program. At that time the system consisted on 23 wells and the VOC concentration at the facility boundary was more than 10,000 parts per billion (ppb). The remediation system has been modified and upgraded over time. In 1996, the groundwater testing at the facility boundary showed less than 10 ppb for benzene, less than one part per million (the drinking water limit) for toluene, and heptane could not be detected. Currently, all facility boundary wells are non-detect for the constituents of concern.

    Remediation activities are continuing within the facility boundaries. Contamination at the facility is now confined to two distinct areas which are being addressed through DPE. DPE was being performed only in the Area One, Area OneA, Pad A portion of the site until August 2003 when it was expanded to Area Two. The goal was to achieve additional source reduction in this area.

    Sartomer submitted a completed Corrective Action Program Work Plan in December, 2001. EPA evaluated the work plan and met with Sartomer in September, 2002. Sartomer conducted an Indoor Air Quality study in the Spring, 2003. EPA evaluated this report and concluded that the constituents are below the respective Occupational Safety and Health Administration (OSHA) permissible exposure limits (PELs), National Institute for Occupational Safety and Health (NIOSH) recommended exposure limits (RELs), and The American Conference of Governmental Industrial Hygienists (ACGIH) threshold limit value (TLVs) and do not present an unacceptable health risk to site workers.

    Sartomer shut down the groundwater pump and treat system and their dual-phase extraction (DPE) system to evaluate the effectiveness of natural attenuation processes. The monitoring for natural attenuation began in November 2004 and was performed for a period of two years (eight quarters) with the interim results being included in the annual progress report of the site.

    A meeting was held on March 21, 2007 to discuss the results of the natural attenuation evaluation even though the final report was not yet complete. The final Natural Attenuation Evaluation Results report was received electronically on August 28, 2007. The conclusions presented at this meeting and in the final report were that natural attenuation is occurring on the site based on the physical, chemical, and biological parameters measured and containing the plume on-site.

    EPA approved the report on November 21, 2007 agreeing with the conclusions that natural attenuation processes are occurring and allowing Sartomer to continue with this as a remedial measure.

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    Site Description

    Interactive Map of Arkema Incorporated, West Chester, Pennsylvania

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    The Arkema, Inc. Facility (formerly Sartomer Company and part of Atofina) is located in West Chester, Chester County, Pennsylvania.  It is located in an industrial area with a small stream and a high-density residential area to the west. The site consists of 12 contiguous acres of which eight are the industrial portion.  The area is served by a public water and sewer system.

    The facility began operations in 1967.  It is primarily a manufacturer of multi-functional acrylate and methacrylate monomers that are used in the surface coating industry.  Wastes generated by the site include various forms of wastewater or sludge containing acrylic or methacrylic acid, sodium hydroxide, and sodium salts.  A hydrocarbon waste stream includes benzene (until 1989), toluene, and heptane.

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    Contaminants at this Facility

    In 1987 Sartomer recognized there had been a release of volatile organic compounds (VOCs) such as benzene, toluene, and heptane to groundwater. Currently, all facility boundary wells are non-detect for the constituents of concern.

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    Institutional and Engineering Controls at this Facility

    Institutional /Engineering Control Summary
    Restrictions or Controls that Address: Yes No
    Groundwater Use
    Residential Use
    Vapor Intrusion
    Capped Area(s)
    Other Engineering Controls
    Other Restrictions

    Institutional Controls consist of:

    • Groundwater under the property shall not be used for drinking water; other domestic uses; agricultural purposes
    • Property shall not be used for agricultural, educational, health care, day care, recreational or residential use.
    • Soils from the property shall not be moved unless treated as hazardous waste or handled according to the Pennsylvania Management of Fill Policy (25 PA. Code Chs. 271 & 287).
    • Monitoring Wells as listed in Section 4 FLP Workplan (August 2001) maintained for monitoring groundwater natural attenuation of benzene and toluene.

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    Land Reuse Information at this Facility

    The site is under continued use.

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    Site Responsibility at this Facility

    RCRA Corrective Action activities at this facility have been conducted under the direction of EPA Region 3.

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