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Hazardous Waste Cleanup: Dow Chemical (Formerly: Rohm and Haas Chemicals LLC) in Philadelphia, Pennsylvania

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Cleanup Status

The Rohm and Haas Philadelphia Plant (currently owned by Dow Chemical Co.) achieved a "Yes" determination for the Current Human Exposures Under Control Environmental Indicator (EI) in June 2005. The Migration of Contaminated Groundwater Under Control EI determination will be further evaluated after the expected October 2014 submittal of a Sitewide Groundwater Report prepared for Dow. On March 30, 2009, the Rohm and Haas Philadelphia Plant enrolled in the One Cleanup Program between EPA and the Pennsylvania Department of Environmental Protection (PADEP) which means that Dow will address the concerns of both agencies simultaneously and at the end of the process will seek a release of environmental liability under PADEP's Land Recycling Act (a.k.a. Act 2) program.

Cleanup  Background

There was an Act 2 Final Report for Soil in East Area 1 submitted in February 2011 and approved on May 11, 2011, which demonstrated that no soil data exceeded the non-residential non-use-aquifer statewide health standards in East Area 1.  Based on further investigations in East Area 2 (see below), this report requires revision and will be resubmitted in fourth quarter 2014 with revised site boundaries.

An Act 2 Human Health Risk Assessment for East Area 2 submitted in February 2011, an Act 2 Remedial Investigation Report (RIR) for East Area 2 submitted in May 2011, an Act 2 Cleanup Plan for East Area 2 submitted in June 2011, and a Pilot Test Work Plan to evaluate in situ chemical oxidation  (ISCO) for soil constituents in East Area 2 submitted in September 2012.  The above reports indicated relatively little contamination along the portion of the site along the Delaware River (East Area 2A).  There were some isolated lead and arsenic hotspots located in soils along a former railroad track that basically divided the Former East Production Area between where its manufacturing buildings were located on the west and the land closer to the river on the east.   

In late Fall 2013, a contractor for Dow implemented full scale ISCO treatment utilizing Cool-Ox® in East Area 2 in an attempt to reduce the mass concentration of dense non-aqueous phase liquid (DNAPL) in the subsurface in that portion of the site. Dow met with EPA and PADEP on August 12, 2014 to discuss the results of the ISCO treatment.  The mass of the DNAPL beneath East Area 2 has been reduced by approximately 67% and the DNAPL is believed to no longer be mobile.

The Former West Production Area has industrial roots that go back to the early 1700's, when tanneries moved to that location from Center City Philadelphia.  Manufacturing operations in this area have included the production of herbicides, pesticides, biocides, ion exchange resins, alkylphenols, surfactants, specialty monomers, amberchrome precious metals recovery, and orthochrom leather tanning products.  In the years before closing the Philadelphia Plant, Rohm and Haas manufacturing operations in the Former West Production Area were focused on Ion Exchange Resin and Goal herbicide production.  There are currently no active operations in the Former West Production Area and the structures in this area have been demolished since 2011, except Building 13 which currently serves as the guardhouse and security center.

In February 2011, an Ecological Risk Assessment (ERA) was submitted to EPA and Pennsylvania Department of Environmental Protection (PADEP) for the Philadelphia Plant.

Active groundwater remediation has been ongoing in the vicinity of a contaminated plume that had traveled beneath several properties on the south side of Bridge Street across from the West Production Area.  The most prevalent contaminants in the plume are ethylbenzene, toluene and xylene.  Rohm and Haas installed a well recovery system in 1994, a soil vapor extraction system in 1996 and a 250-foot groundwater recovery trench in 1998.  Groundwater movement in the area of the plume is currently controlled solely by the recovery trench.  A chronological look at the plume shows that it has been steadily shrinking in size.

Rohm and Haas is expected to submit a Former West Production Area Remedial Investigation/Human Health Risk Assessment Report in September 2014, a Sitewide Groundwater/Human Health Risk Assessment Report in October 2014, a Sitewide Soil Cleanup Plan in December 2014, and a Sitewide Groundwater Cleanup Plan to EPA and PADEP in spring 2015.   

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Site Description

Interactive Map of Dow Chemical, Philadelphia, Pennsylvania

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Dow Chemical Co. bought Rohm & Haas in April 2009 and operated the Philadelphia Plant until its closing in 2011.  Rohm and Haas Company purchased the Philadelphia Plant in 1920 from Charles Lenning and Company, one of the oldest chemical manufacturers in the U.S. at that time.  Prior to closing the facility, Rohm and Haas manufactured two main products:  Ion Exchange Resins (a uniform bead size copolymer) and Goal® (an herbicide for pre-emergence and/or post-emergence control of certain annual broadleaf and grassy weeds).  Goal® had been manufactured by Rohm and Haas for Dow AgroSciences. 

The Rohm and Haas Company’s Philadelphia Plant is divided into the Former East Production Area and the Former West Production Area.  A Former Warehouse Property located along the Delaware River in the Port Richmond Section of Philadelphia was sold in 2001.  Corrective Action at the Former Warehouse Property has been managed under PADEP’s Land Recycling (Act II) Program and is not currently included in the work being done under the One Cleanup Program.  

Historical activities in the Former East Production Area have included chemical manufacturing operations, materials and product storage, steam and electricity production, wastewater management, and both hazardous and non-hazardous waste management.  Historic Former East Production Area manufacturing operations in addition to Ion Exchange Resins include solvent recovery, Tritons manufacturing, and Dithane manufacturing.  Some of the chemicals associated with these manufacturing processes included surface active agents, DDT, mancozeb, octhilinone, dicofol dinocap, chloro methyl isothiazolin, sulfuric acid, 1,2-dichloropropane, 1,2-dichloroethane, chlorobenzene, toluene, amines, acids, methylene chloride and zinc.  There are currently no active operation in the Former East Production Area and the structures in this area have been demolished since 2007. 

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Contaminants at this Facility

In April of 2001, a released. fuel oil (unknown amount) occurred into Bushkill Creek.  A surface soil sample collected from inside the former containment area of the tank contained concentrations of benzo(a) pyrene (51mg/kg) and naphthalene (14mg/kg) which are above their respective PA DEP Maximum Soil Contamination Levels.

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Institutional and Engineering Controls at this Facility

The need for Institutional Controls is yet to be determined.  

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Land Reuse Information at this Facility

The facility is under continued use.

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Site Responsibility at this Facility

Resource Conservation and Recovery Act (RCRA) Corrective Action activities at this facility have been conducted under the direction of EPA Region 3 with assistance from Pennsylvania Department of Environmental Protection.

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