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Hazardous Waste Cleanup: Monroe Energy LLC (Formerly: BP Oil Incorporated) in Marcus Hook, Pennsylvania

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Resource Conservation and Recovery Act (RCRA) Corrective Action activities at the former British Petroleum (BP) are being conducted under the direction of a joint lead by EPA and Pennsylvania Department of Environmental Protection (PADEP). The investigation and any necessary cleanup activities are being implemented in accordance with an EPA Facility Lead Agreement.

Cleanup Status

The BP Oil Refinery (the ‟Facility") in Trainer, Pennsylvania is now run by Monroe Energy LLC (subsidiary for Delta Airlines). In 1989, EPA initiated a RCRA Facility Assessment (RFA) at the Facility.  In 1991, EPA finalized the RFA Report and required 27 Solid Waste Management Units (SWMUs) and 15 Areas of Concern (AOCs) for further action/investigation.

Cleanup History

Since 1991, EPA and the Pennsylvania Department of Environmental Protection (PADEP) have been involved in an extensive evaluation of the Facility’s SWMUs and AOCs in order to determine their potential for environmental contamination. The time line below illustrates what has been accomplished at the Facility to date:

2013: PADEP approves the “Cleanup Plan, Sheen Mitigation, Marcus Hook Creek and Stony Creek” (Cleanup Plan January 2013) in May. BP will monitor the stream for sheening during a 1-year period following the construction of barriers in two areas along Marcus Hook Creek. PADEP further recommends post-remediation surface water sampling of Marcus Hook Creek to determine if installation of the remedies (Sheet Pile Wall Remedy and Cap) also resolves the surface water exceedences. It is estimated that the construction of barriers should be completed in early November 2013.

2013: BP provides report documenting the Point of Compliance Groundwater Sampling at the former BP Marcus Hook Refinery site during the period October 2012 through March 2013 (32nd and 33rd POC Sampling Events).

2013: EPA issues a determination that no further action is required regarding the suspected lead tank bottom disposal areas (SWMU No.88) at the Facility in February.

2013: BP provides PADEP a proof of publication of a notice in the Delaware County Times and a copy of certified mail receipt and letter submittal of a public notification to the Borough of Trainer in February.

2013: BP provides PADEP a Cleanup Plan in accordance with standards and procedures established under the Pennsylvania Land Recycling and Environmental Remediation Standards Act (Act 2) and identifies remediation that will be perform at the Facility to mitigate petroleum hydrocarbon sheening on the surface water of Marcus Hook Creek in January. The Cleanup Plan is one of a series of Act 2 reports BP is planning to submit for the Facility.

2012: BP requests EPA issue a determination that no further action is required regarding the suspected lead tank bottom disposal areas (SWMU No.88) at the Facility. A 2012 October investigation report that summarizes and documents previous investigations and findings associated with suspected leaded tank bottom disposal areas (SWMU No.88) is also submitted.

2012: PADEP approves the submitted Sitewide Remedial Investigation Report (RIR) in July. BP will submit a Risk Assessment Report/Cleanup Plan.

2012: PADEP considers the Sheet Pile Wall is an engineering control for establishing a Site Specific Standard under Act 2 (Pennsylvania Land Recycling and Environmental Remediation Standards Act). A Post Remediation Care Plan will be required and will be included with the submittal of the Final Report for the Lube Plant Riverfront Area.

2012: BP completes the Sheet Pile Wall project in June.

2012: BP provides report documenting the Point of Compliance Groundwater Sampling conducted at the refinery during October 2011 through March 2012 (28th and 29th POC Sampling Events). POC sampling will continue on a quarterly basis while the RIR (Sitewide Remedial Investigation) and the planned path forward for groundwater monitoring are reviewed by the PADEP.

2012: Delta Air Lines announces in April that it has entered into an agreement of sale with ConocoPhillips to purchase the refinery. The refinery will be operated by a wholly owned Delta subsidiary called Monroe Energy.

2012: BP provides report documenting 26th and 27th Point of Compliance Sampling Events. The Sitewide Remedial Investigation (RIR) submitted to the PADEP in November 2011 details the characterization of the Site, evaluates potential exposure pathways, and details a path forward which includes the planned groundwater monitoring activities for the Site. POC sampling will continue on a quarterly basis while the RIR and the planned path forward for groundwater monitoring are reviewed by the PADEP.

2011: Pursuant to PADEP Act 2 requirements, BP provides a Sitewide Remedial Investigation Report (RIR) for the environmental investigation and remediation activities BP is performing.

2011: BP provides report documenting 24th and 25th Point of Compliance Sampling Events.

2011: BP begins Lube Plant Riverfront Area Sheet Pile Wall construction/remedy.

2011: PADEP approves the RIR/Cleanup Plan in accordance with the provisions of Act 2 in June.

2011:  Pursuant to PADEP Act 2 requirements, BP provides Lube Plant Riverfront Area Remedial Investigation Report and Cleanup Plan in March. The Report addresses potential impacts to surface water in the Delaware River related to the discharge of diffuse groundwater and petroleum sheens from a portion of the Lube Plant Riverfront Area. BP also states that all other environmental conditions and potential exposure pathways within remainder of the Lube Plant Area and other Site areas, as they relate to BP’s former operations, will be addressed in a Sitewide Remedial Investigation Report and Cleanup Plan thereafter.

In summary, the basis of design for the planned Sheet Pile Wall Remedy is as follows:

  1. An approximately 606-feet long sheet pile wall will be constructed, between the existing cellular steel cofferdams in the Lube Plant Riverfront Area; this will create a containment area (moat) between the sheet pile wall and existing low-deck structure;
  2. The sheet pile wall will utilize an underflow piping system to allow the flow of water through the sheet pile wall while blocking the discharge of petroleum sheens to the river. The underflow system is designed to: a. Limit the hydraulic head differential across the sheet pile wall in order to enhance structural stability of piles by limiting uplift force on the piles; b. Prevent the flooding and overflow of the moat during periods of excessive precipitation; c. Allow the natural wetting of the existing relieving platform structure to prevent accelerated degradation of the structure due to drying;
  3. A solidifying, sorbent-boom system will be constructed within the moat to manage and recover petroleum sheen in the containment moat area behind the sheet pile wall.

2011: BP submits an NIR (Notice of Intent to Remediate) to PADEP in February and a summary of the NIR was published in the Delaware County Times. No comments or requests were received during the 30-day public comment period.
2010: BP provides Progress Report for the Lube Plant Area Sheet Pile Remedy Design and Construction. Based on the remedial action selection process, a sheet pile wall with flow through pipes is selected to meet the primary remedial objective of preventing migration of the petroleum sheen from the Lube Plant Riverfront Area into the Delaware River.

2009: In response to PADEP, BP provides Ecological Evaluation Report and Sheen Mitigation Investigation Report. The Sheen Investigation Report describes environmental investigations of the Site to better understand the sources and mechanisms of hydrocarbon sheening observed on surface water in the three target areas of Marcus Hook Creek. The Report also outlines BP’s plans to implement interim remedial measures and describes supplemental evaluations BP plans to undertake as part of its efforts to mitigate hydrocarbon sheening on surface waters at the Site.

2008: BP provides report documenting the 12th and 13th Point of Compliance Groundwater Monitoring Event.

2007: BP provides report documenting the 11th Point of Compliance Groundwater Monitoring Event.

2006: BP provides the Site Characterization Summary Report. The Report summarizes the findings of environmental investigations during the period from 1996 through 2005. The Report includes a site-wide evaluation of soil and groundwater conditions and a limited evaluation of surface water, sediment, and soil-vapor conditions. The characterization data will be utilized to determine if the PADEP Medium Specific Concentrations (MSCs) under the Statewide Health Standard are appropriate or if additional evaluation is necessary to assess exposure pathways and develop site specific standards.

2003: BP initiates SWMU 88 Leaded Tank Bottom (LTB) Pits investigation as part of the site-wide characterization at the Facility.

2002: Phillips Petroleum Company merges with Conoco, forming ConocoPhillips.

2001: BP initiates site characterization activities.

2000: Phillips Petroleum Company acquires Tosco Corporation, which operates the Facility.

2000: BP submits a Letter of Commitment along with the Site Wide Approach Work Plan BP Former Marcus Hook Refinery Marcus Hook, Pennsylvania (Facility Lead Agreement) to PADEP and EPA.

1998: PADEP approves the work done by BP. One Solid Waste Management Unit (SWMU), (#37-the Alkyl Basin) will require a closure plan as it was once a permitted unit with the PADEP Bureau of Waste Management. TOSCO and BP officials expect to address any further clean-up issues for the Facility under Act 2, which is administered by the PADEP Environmental Clean-Up Program. BP also submits SWMU and Area of Concern (AOC) Final Cleanup Status Report to EPA for review and comment.

1997: TOSCO purchases the Facility and operates it as Bayway Refinery; work related to the Facility SWMUs and AOCs that needs additional attention is completed. The only SWMU that cannot be determined is SWMU 88, the Lead Tank Bottom Pits.

1996: Under the EPA-PADEP Work Share Program, PADEP performs a follow-up SWMU/AOC examination at the Facility in order to further define which of the Facility’s SWMUs and AOCs would require additional work. In the end, 3 AOCs and 3 SWMUs are found to require further action. The work to address the actions needed for specific Facility SWMUs and AOCs commence.

1994: Joint EPA and PADEP Multi-Media Inspection at the Facility; all areas of the Facility are examined in terms of their potential for releases to air, water and soil media.

1991: BP conducts clean-up activities at the Facility.

1991: EPA finalizes the RFA Report and requires 27 SWMUs and 15 AOCs be addressed for further action/investigation.

1989: EPA conducts a site-wide RCRA Facility Assessment (RFA).

Quarterly sampling events are monitored currently to support the Facility’s ongoing investigation and remediation activities.

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Site Description

Interactive Map of Monroe Energy LLC, Marcus Hook, Pennsylvania

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The main plant of the Facility is located adjacent to Interstate 95 and Route 291 in Ridley Township, Delaware County, Pennsylvania. The location of the Facility is shown in Attachment 1. The Facility is bisected by Route 291, with approximately 240 acres located north of Route 291 and approximately 107 acres located south of Route 291. Crum Creek, Darby Creek, and the Delaware River are the major surface waters near the Facility. Crum Creek and Darby Creek are receiving waters for the Facility's National Pollution Discharge Elimination System ("NPDES") permitted outfalls. They are tributaries to the Delaware River, which borders the Facility on the south. Local industrial groundwater users have been identified and are listed in the Facility's Preparedness, Prevention, and Contingency Plan (1993). According to recent investigation reports, no private or public groundwater supplies or surface water intakes are known to exist in the vicinity of the Facility.

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Contaminants at this Facility

The main contaminants in the Facility are typical hazardous petroleum constituents such as benzene, toluene, ethyl benzene, total xylene, semi-volatile organic compounds, arsenic, chromium and lead.

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Institutional and Engineering Controls at this Facility

    The need for Institutional Controls has 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

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

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