PB99-963806
EPA541-R99-084
1999
EPA Superfund
Record of Decision:
Imperial Oil Company/Champion
Chemical Company Site OU 3
Morganville, NJ
9/30/1999
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DECLARATION FOR THE RECORD OF DECISION
IMPERIAL OIL COMPANY/CHAMPION CHEMICAL COMPANY SUPERFUND SITE
SITE NAME AND LOCATION
Imperial Oil Company/Champion Chemical Company Superfund Site
Marlboro Township, Monmouth County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S. Environmental
Protection Agency's selection of a third remedial action to
address on-site soil, including the waste filter clay pile and
the subsurface floating product, at the Imperial Oil Company/
Champion Chemical Company 'Superfund Site, in accordance with
the requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended (CERCLA). [42
U.S.C. §9601-9675], and to the extent practicable, the National
Oil and Hazardous Substances Pollution Contingency Plan, as
amended, 40 CFR Part 300. This decision document explains the
factual and legal basis for selecting the remedy for the third
operable unit of the site.
The New Jersey Department of Environmental Protection (NJDEP)
has been consulted on the planned remedial action in accordance
with CERCLA §121 (f) [42 U.S.C. §9621 (f)]. NJDEP concurs with
EPA's selected remedy for the site. The information supporting
this remedial action is contained in the Administrative Record
for the site, the index of which can be found in Appendix B of
this document.
ASSESSMENT OF THE SITE
Actual or threatened release of hazardous Substances from the
Imperial Oil Company/Champion Chemical Company Superfund Site, _
if not addressed by implementing the response action selected in
this ROD, may present an imminent and substantial endangerment
to public health, welfare, or the environment.
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DESCRIPTION OP THE SELECTED REMEDY "*
The remedial action described in this document represents the pri
third of three planned operable units of the Imperial Oil
Company/Champion Chemical Company Superfund Site. The initial
remedy for the site, designated operable unit 1, included the
remediation of off-site soils. The remedy for the second
operable unit involved the remediation of contaminated ground
water in the underlying aquifer. The remedy described in this
ROD addresses contaminated soil and other materials (including
waste filter clay and floating product) present on the main site.
The major components of the selected remedy include:
• Excavation of an estimated 83,000 cubic yards of soils
containing contaminants above the selepted remediation goals
and disposal of this material at appropriate off-site
facilities.
• Transportation of an estimated 27,000 cubic yards of the
above soils which pose the principal threat (hot spots) to
Resource Conservation and Recovery Act/Toxic Substances
Control Act (RCRA/TSCA) hazardous waste disposal facilities.
An estimated 19,000 cubic yards of this soil will be
transported to a TSCA-permitted landfill and the other 8,000
cubic yards shipped to a RCRA-permitted landfill where the
soil will receive appropriate treatment prior to disposal
in accordance with RCRA requirements.
• Transportation of an estimated 56,000 cubic yards of the
soils containing contaminants above the selected cleanup
goals to an appropriate landfill. A portion of this soil
be recycled as asphalt base material.
• Removal of an estimated 5,000 gallons of floating product
via vacuum truck and transportation of this material to a
TSCA-licensed incinerator.
• Dismantling of site buildings and tank farms, as necessary
to complete the selected soil excavation and floating
product removal activities.
• Backfilling of all excavated areas with clean fill.
• Restoration of the wetlands affected by cleanup activities.
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DECLARATION OF STATUTORY DETERMINATION
The selected remedy meets the requirements for remedial actions
set forth in CERCLA §121 in that it: (1) is protective of human
health and the environment; (2) complies with Federal and State
requirements that are legally applicable or relevant and
appropriate; (3) is cost-effective; and (4) utilizes alternative
treatment (or resource recovery) technologies to the maximum
extent practicable.
However, the selected remedy for this operable unit does not
satisfy the statutory preference for remedies that employ
treatment as a principal element. The complex nature of the
waste material at the site with elevated levels of both organic
and inorganic contaminants, together with the limited space on
the site property to construct a treatment plant limit the cost-
effectiveness and implementability of the on-site treatment
technologies available to treat all the waste. However, part of
the principal threat waste, that is the floating product, will be
thermally treated at a TSCA-licensed incinerator. In addition,
an estimated 8,000 cubic yards of the principal threat soils
will receive stabilization treatment to reduce the mobility of
contaminants prior to disposal in a secure landfill. Although
the selected remedy will treat a portion of the principal threat
materials, the majority of the contaminated soils will be
disposed of in a landfill.
Because this remedy will not result in hazardous substances,
pollutants, or contaminants remaining on-site above levels that
allow for unlimited use and unrestricted exposure, a five-year
review will not be required for this remedial action.
Jeanne/ft. ^$I Date
Regional
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THE RECORD OF DECISION
DECISION SUMMARY
Imperial Oil Co., Inc./Champion Chemicals Superfund Site
. Marlboro Township, Monmouth County
New Jersey
Operable Unit 3
United States Environmental Protection Agency
Region II
New York, New York
September 1999
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Table of Contents
Site -Name, Location and Description 1
Site History and Enforcement Activities 2
Highlights of Community Participation 9
Scope and Role of Remedial Action 10
Summary of Site Characteristics - • . -11
Summary of Site Risks . 16
Remedial Action Objectives 23
Description of Remedial Action Alternatives 25
Summary of Comparative Analysis of Alternatives 30
Principal Threat Wastes 39
Selected Remedy 40
Statutory Determinations 42
Documentation of Significant Changes 44
Appendices
Appendix A. NJDEP Letter of Concurrence
Appendix B. Administrative Record Index
Appendix C Responsiveness Summary
Figures
1 Site Location Map
2 Site Layout Map
3 OU-1 Off-site Soils Location Map
4 Distribution of VOCs in On-Site Surface Soil
5 Distribution of VOCs in On-Site Subsurface Soil
6 Distribution of SVOCs in On-Site Surface Soil
7 Distribution of PCBs and TPH in On-Site Surface Soil
8 Distribution of PCBs in On-Site Subsurface Soil
9 Distribution of TPH in On-Site Subsurface Soil
10 Distribution of Inorganics in On-Site Surface Soil
11 Distribution of Inorganics in On-Site Subsurface Soil
12 Distribution of Pesticides in On-Site Soil
13 Distribution of SVOCs in On-Site Subsurface Soil
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Figures
14 Distribution of Inorganics in Subsurface Soil in the Fill
Area South of the Fire Pond
15 Principal Areas of Soil Contamination
16 Distribution of Floating Product
17 Soil Areas Exceeding Remediation Goals
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SITE NAME, LOCATION AND DESCRIPTION
The Imperial Oil Co., Inc./Champion Chemicals (IOC/CC)
Superfund Site (the site) is located in the Morganville
section of Marlboro Township in northwest Monmouth County,
New Jersey (Figure 1). The Champion Chemical Company is the
owner of the real property located on Lot 29, Block 122,
Orchard Place in Morganville. The premises are currently
leased to the Imperial Oil Company, Inc., which operates an
oil blending facility.
Imperial Oil Company's operations occupy approximately 4.2
acres of the entire 15 acres of the site. A chain-link
fence surrounds the active portion of the site. There are
seven buildings on-site used for production, storage, and
maintenance and there are also numerous above ground oil
storage tanks located within four separate tank farm areas
(see Figure 2). One of the buildings on-site, the Masonry
Building, is no longer being used in any site operations.
This building is almost 100 years old, in very poor
condition, and is in danger of collapse. The western
property line abuts the abandoned Central Railroad of New
Jersey's Freehold and Atlantic Highlands Branch Main Line.
There are approximately 30 scattered residential properties
along the surrounding roads. A small commercial center
(Morganville) is located approximately two miles southeast
of the site at the junction of Route 3 and Route 79. Two
areas, known as Off-site Areas 1 and 2, - are located
approximately 220 feet and 700 feet northwest of the
facility, respectively. The soil in these areas is
contaminated with arsenic, lead, and polychlorinated
biphenyls (PCBs) from the IOC/CC site. Two automobile scrap
yards are located just to the northeast of the site
boundary. Lake Lefferts, a swimming and recreational area,
is located approximately 1.25 miles north of the site. Lake
Lefferts has been identified as a potential potable water
source for the area.
The site is located within the Matawan watershed of the
Atlantic Coastal Drainage Basin. The topography of the site
ranges from 120 feet above mean sea level (MSL) in the
southwest corner of the site to 97 feet above MSL at the
northern boundary. Surface water runoff at the site is to
the north. During periods of heavy rainfall, water
accumulates in a catchment area in the northern section of
the site. This water and site runoff is contained by an
earthen berm that extends along the northeastern fence line
of the site. Three oil/water separators and an arsenic
treatment unit are used to treat any runoff that collects in
the area of the earthen berm. To the east of the berm is a
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man-made pond, known as the Fire Pond, which discharges to
Birch Swamp Brook. Birch Swamp Brook, an intermittent
stream in the vicinity of the site, flows through a bog
northwest of the site, through a culvert under the rail line
and through Off-site Areas 1 and 2, where the flow becomes
constant. The stream empties into Lake Lefferts. Lake
Lefferts empties into Raritan Bay. As a result of
contaminant runoff from the IOC/CC site, sediments in Birch .
Swamp Brook contain elevated levels of contaminants
including PCBs and total petroleum hydrocarbons (TPHs).
Wetlands are located in the vicinity of the Fire Pond, Birch
Swamp Brook and areas north of the IOC/CC facility.
The Englishtown Aquifer underlies the site. It is
classified as GW-2 (Current and Potential Potable Water
Supply) and is an important source of water supply for
Monmouth and northern Ocean Counties. Twenty-eight
residential wells were identified within a 1-mile radius of
the site, none of which are used for potable drinking water.
The Marlboro Township Municipal Utilities Authority supplies
potable water to the residents in the vicinity of the site,
and their supply wells, which draw water from the deeper
Raritan-Magothy Aquifer, are located approximately two miles
south (upgradient) of the site.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Historical Site Use
Industrial activities have been ongoing at the site since
approximately 1912. Initially, ketchup and tomato paste was
manufactured at the facility until approximately 1917, at
which time it was converted to a chemical processing plant.
The products of the chemical plant may have included arsenic
acid and calcium arsenate, followed by the manufacturing of
flavors and essences. In approximately 1950, the plant was
purchased by Champion Chemical and became an oil reclamation
facility. The oil reclamation process used diatomaceous
earth, also known as filter clay, -and caustic solution to
remove heavy metals and PCBs from waste oil. The waste
products of the oil reclamation process, including the
contaminated waste filter clay and caustic solution, were
disposed of on the site. This operation continued until
approximately 1965. Imperial Oil Company leased the site
from Champion Chemical in 1968 and began conducting oil
blending operations, including mixing and repackaging unused
(clean) oil for delivery. Currently, raw products (refined
clean oil) are delivered by truck and transferred to above-
ground tanks. Imperial Oil mixes and blends the oil for its
customers.
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Compliance History
In April 1981, a New Jersey Department of Environmental
Protection (NJDEP) site inspection found oil-contaminated
soils and numerous large puddles at the base of Tank Farms 1
and 2. The outfall area for the three oil/water separators
was also inspected. This area showed oily surface water and
oil-stained surface soils. The catchment area for the site
surface1 water runoff, north of the separators, was also
stained with oil. The results of NJDEP's 1981 analyses of
soil and waste filter clay samples revealed high
concentrations of TPHs, lead, arsenic, and PCBs.
In May 1981, the U.S. Environmental Protection Agency (EPA)
conducted a limited sampling program at the off-site areas,
Birch Swamp Brook and the waste filter clay pile. Results
of analyses of the sediment samples from the stream bed of
Birch Swamp Brook confirmed the presence of PCBs, TPHs,
lead, and arsenic. The analytical results of the samples
from the waste filter clay indicated that this material
contained significant concentrations of PCBs.
In June 1981, a letter to EPA from Imperial Oil's
consultant, Harold Seldin, indicated that in 1976, Imperial
Oil had excavated contaminated soil and replaced it with
clean sand in the area of the oil/water separators. An
earthen berm was constructed and one oil/water separator was
cleaned and repaired.
In June and August 1981, NJDEP conducted two site
inspections and identified a number of potential sources of
contamination. In August 1981, NJDEP conducted an
inspection of the off-site waste oil contamination areas.
During the inspection, two distinct areas of contamination
were identified.' The areas are located north of the
'Imperial Oil facility along the banks of Birch Swamp Brook
'and are referred to as Off-Site Areas 1 and 2. In both
areas, the surface soils were visibly stained with oily
material. The banks of the stream were also observed by
NJDEP to be stained with oily residue. Vegetation in these
areas was visibly stressed.
In December 1981, IOC/CC entered into an Administrative
Consent Order (AGO) with the NJDEP in which IOC/CC agreed to
cease discharging hazardous waste and other pollutants into
the waters of the state and agreed to comply with specified
discharge limits set forth by the New Jersey Pollutant
Discharge Elimination System (NJPDES). In addition, the ACO
required IOC/CC to repair the oil/water separators and
dispose of the oil/water separator sludge in a manner
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acceptable to the NJDEP. Further, the AGO required the
company to conduct an environmental assessment of the site
to determine the nature and extent of contamination and
implement a remedial plan for cleaning up the site.
In May 1982, the Imperial Oil Company contracted with
Princeton Aqua Science (PAS) to conduct an evaluation of the
site. During this investigation, seven test pits were
excavated and sampled. In addition, four monitoring wells
were installed. The purpose of the investigation was to
assess the nature and extent of contamination in the soil
and ground water at the site. The results of this
investigation were presented in a report issued by PAS in
January 1983. The analyses performed on the selected
samples confirmed the presence of TPHs, PCBs, arsenic, and
volatile organic compounds in the ground water and soil. A
petroleum-like product layer was detected floating above the
water table in certain monitoring wells during sampling.
This material has contaminated soils, as well as groundwater
that it has come into contact with. This material is
referred to as floating product.
During the period 1983 through 1986, NJDEP maintained an on-
going inspection and monitoring program of the site and
surrounding areas. In addition, EPA and the Monmouth County
Prosecutor's Office conducted investigations at the site,
confirming that heavy metals, PCBs, and petroleum
hydrocarbons were present in soil and ground water.
Removal and Remedial Response Actions to Date
The IOC/CC site was proposed for inclusion on EPA's National
Priorities List (NPL) of Superfund sites on December 1,
1982. The site was formally added to the NPL on September
1, 1983.
A remedial investigation (RI) of the site was conducted by
NJDEP. The RI was divided into multiple phases. The first
phase was conducted in 1987 and a second phase in 1989/1990.
The purpose of the RI was to: determine the nature and
extent of contamination resulting from historic site
activities; identify potential contamination migration
routes; identify potential receptors of site contaminants;
and characterize potential human health and ecological
risks. The Final RI Report was issued in December 1996.
This report describes the nature and extent of contamination
in on-site soils, off-site soils, sediments, and ground
water.
In September 1987, in order to evaluate an innovative
technology for potential consideration for the cleanup of
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the site, EPA initiated a Superfund Innovative Technology
Evaluation (SITE) demonstration program at the IOC/CC site.
The technology demonstrated was the solidification/
stabilization process developed by Soiltech, Inc. of
Houston, Texas. The results indicated that the
solidification technology was effective in remediating
elevated concentrations of metals in soil, but was
ineffective in remediating PCBs and other organic compounds.
A Technology Evaluation Report for the project was released
in February 1990.
Removal Actions
Several removal actions have been completed by EPA at the
IOC/CC site. In November 1991, as part of a removal action,
EPA excavated the waste filter clay down to ground level.
The waste filter clay was contaminated with PCBs, arsenic,
lead, and TPHs. The excavated material (approximately 660
cubic yards) was disposed of at an approved Resource
Conservation and Recovery Act (RCRA) landfill. Also, in
1991, EPA installed extraction wells to remove the floating
product layer which lies above the ground'water beneath the
waste filter clay disposal area. The extraction wells and
floating product removal system were installed as part of a
removal action. The extracted floating product is
temporarily stored in a 5,000 gallon on-site storage tank
and properly disposed of off-site on a periodic basis, as
necessary. In 1996, NJDEP assumed responsibility for the
operation and maintenance of the floating product removal
system. To date, approximately 15,000 gallons of floating
product have been extracted and disposed of at a Toxic
Substance Control Act (TSCA) regulated incinerator.
In April 1993, EPA began the removal of buried drums. These
drums were found during the preparation of the ground
surface for the installation of the wastewater treatment
units for the floating product extraction system. Initial
identification of the material from the buried drums
indicated contaminated waste oil and sludge. The action
involved the excavation and removal of the.buried drums to
minimize the possibility of further migration of
contaminated materials already in the ground.
Remedial Actions
First Record of Decision
The first Record of Decision (ROD) for the site was signed
in September, 1990 and selected a remedy for the first of
several anticipated remedial actions, known as operable
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units (OUs). It addressed what is known as Off-site Areas 1
and 2. The major components of the ROD included: the
installation of fencing to control access to the
contaminated soil areas; the excavation and appropriate off-
site disposal of contaminated soil from within the wetlands;
and the restoration of affected wetlands. In September 1991,
as part of the OU1 remedy, EPA installed the fence around
Off-site Areas 1 and 2 to control access1to the contaminated
soil. The remedial design of this remedy was initiated in
1991.
From October 1994 through February 1995, as part of remedial
design activities for OU1 of the site, NJDEP performed
extensive soil sampling in areas adjacent to Off-Site Areas
1 and 2, including a number of residential properties
bordering Birch Swamp Brook. These results indicated that a
large area adjacent to Off-Site Areas 1 and 2 contain
elevated levels of arsenic and lead. These soil sampling
results are presented in the May 1995 report entitled, Field
Sampling and Analysis Report (Kimball).
In January 1996, EPA entered into an Interagency Agreement
(IAG) with the U.S. Geological Survey (USGS) for the
performance of a study to determine the sources of arsenic
contamination in soils in the vicinity of the site. Areas
sampled included undisturbed wooded areas, former and
existing orchard properties, on-site soils, and residential
properties in the vicinity of the site. The study was
completed in July 1996 and concluded that arsenic
concentrations in the soils on four residential properties
located adjacent to the Imperial Oil facility were related
to operations previously conducted at the site. Other areas
of arsenic contamination were attributed to the widespread
application of arsenic-based pesticides on former orchard
properties, as well as geological background and regional
atmospheric distribution.
In September 1997, EPA issued an Explanation of Significant
Differences (BSD) to modify the September 1990 ROD to
include the remediation of four residential properties
located adjacent to the Imperial Oil facility. The BSD also
provided for the implementation of engineering controls in
the vicinity of the Fire Pond and forested wetland areas of
the site as a precautionary measure against potential
recontamination of Off-site Areas 1 and 2, once remediated.
In March 1998, EPA initiated the excavation and disposal of
the arsenic-contaminated soil found on the four residential
properties. EPA excavated and disposed of approximately
6,488 cubic yards of soil from the properties. This work
was completed in August 1998.
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Second Record of Decision
A second ROD was signed in September 1992 to address the
contaminated ground water and is referred to as OU2. The
major components of the ROD included: the installation of
extraction wells to extract the contaminated ground water ;
the treatment of extracted ground water via precipitation
of inorganic contaminants and carbon adsorption of organic
contaminants; the discharge of the treated ground water to
Birch Swamp Brook; the continuation of the floating product
removal action that was initially undertaken by.the EPA; and
the appropriate environmental monitoring to ensure the
effectiveness of the remedy. The NJDEP is currently
operating the floating product- extraction.system. In
addition, as part of remedial design activities, NJDEP has
performed groundwater sampling activities to further define
the nature and extent of the groundwater contaminant plume.
Design activities related to the implementation of the
ground water extraction and treatment system" are ongoing.
Third Record of Decision
In November 1996, NJDEP collected and analyzed 40 additional
soil samples at the site co fill data gaps in the remedial
investigation of on-site soils. As stated above, the RI
Report was issued in December 1996 and the Source Control
Feasibility Study Report for Operable Unit 3 was completed
in August 1998. An Addendum to the Feasibility Study Report:
was completed by NJDEP in January 1999 to address various
modifications to the August 1998 Source Control Feasibility
Study Report. These documents were used as the basis for the
selection of a remedy for the contaminated soils at the
facility and is the subject of this ROD which is also known
as OU3.
Additional Studies
In August 1996, through the IAG with USGS, EPA tasked USGS
to perform additional investigations to determine the source
of contamination located within the floodplain of Birch
Swamp Brook including two residential properties located
adjacent to Birch Swamp Brook which contained elevated
levels of arsenic. This study was performed to gather more
information regarding the contamination on these properties,
including whether the contamination was related to the
IOC/CC site. The study concluded that some of the arsenic
contamination on these properties is likely to be IOC/CC
related, particularly those soils closest to Birch Swamp
Brook and subject to the impacts of flooding and, therefore,
deposition of contaminated sediments from the Brook.
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From September through October 1997, NJDEP collected
additional sediment samples in Birch Swamp Brook to further
characterize the nature and extent of sediment
contamination. The results of this sampling event are
presented in the January 1998 report entitled, "Field
Sampling and Analysis Report, Birch Swamp Brook Sediment
Sampling". A total of 270 samples were collected from 193
locations and analyzed for PCBs and THPs.
Enforcement History
In September 1984, EPA issued General Notice letters to
three potentially responsible parties, Imperial Oil Company,
Champion Chemical Company and Mr. Emil Stevens pursuant to
Section 107(a) of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980, as amended (CERCLA)
notifying them that they may be ordered to perform response
actions deemed necessary by EPA to protect public health,
welfare or the environment.
In 1987, Imperial Oil Company and the owner of the facility,
Champion Chemical Company entered into a plea agreement,
after being criminally indicted by the Monmouth County
Prosecutor's Office for violations of environmental laws of
the State of New Jersey. That same year, the case was
settled with Imperial Oil Company and Champion Chemical
Company entering into a plea agreement with the Monmouth
County Prosecutor's Office. Part of the Plea Agreement
required Imperial and Champion to contribute certain monies '
"payable to the.Environmental Protection Agency through the
office of the Monmouth County Prosecutor" to pay for
environmental work to be performed at the Site. Originally,
these monies were paid into an escrow account maintained by
the Monmouth County Probation Department. In October 1994,
the monies in the escrow account were transferred to the
Superior Court of New Jersey Trust Fund Account. EPA
received reimbursement from this Monmouth County fund in the
amount of $251,685 when it removed and disposed of a
contaminated waste filter clay pile at the facility. In
September 1998, the Monmouth County Prosecutor's Office
agreed to transfer the remainder of the money, $369,750,
plus accrued interest, into an EPA special account for the
site for the purpose of paying toward required building
demolition.
In September 1989, EPA issued a Unilateral Administrative
Order (UAO) to Imperial Oil Company and Champion Chemical
Company for the delineation, characterization, removal
and/or treatment and disposal of the on-site waste filter
clay pile. This UAO was ultimately not complied with and
EPA funded this action.
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In August 1990, EPA sent General Notice letters to four
potentially responsible parties (PRPs), Imperial Oil
Company, Champion Chemical Company, Jersey Power & Light,
and J and M Land Company, pursuant to Section 107(a) CERCLA,
notifying them that they may be ordered to perform response
actions deemed necessary by EPA to protect public health,
welfare or the environment.
In September 1991, EPA issued UAOs to the above four PRPs to
conduct the remedial design and remedial action for Off-site
Areas 1 and 2. The PRPs declined to do the work required by
the'UAO. Utilizing CERCLA funds, the NJDEP is currently
designing this remedy pursuant to a Cooperative Agreement
with EPA.
On March 29, 1996, EPA filed a complaint against Champion
Chemical Company and Imperial Oil Company in the Federal
District Court of New Jersey to recover EPA's past costs
incurred at the site. The complaint was later amended to
include Mr. Emil Stevens as a defendant. The litigation is
ongoing.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Imperial Oil Company has consistently received attention
from area residents, municipal, state, county and federal
officials as well as the local print media. In 1981,
concerned residents organized the Burnt Fly Bog/Imperial Oil
Company Citizens Advisory Committee (CAC). The CAC includes
citizen representatives from Marlboro and Old Bridge
Townships as well as officials from Monmouth and Middlesex
Counties. NJDEP representatives have met regularly with
this group since 1981 and continue to do so. In 1998, the
Monmouth County Environmental Coalition received a Technical
Assistance Grant from EPA to hire technical advisors to
review documents and offer input into the remedial decision-
making process.
Issues voiced over the years by the CAC and other members of
the community include the operating status of the Imperial
Oil Company, the potential for the IOC/CC site to contribute
contamination to Lake Lefferts (located approximately 1.25
miles downstream of the IOC/CC site); the contamination of
off-site properties by the IOC/CC site; and, the length of
time it has taken to investigate and remediate the site.
Several public meetings have been held to present the
findings of various studies conducted for the Site. In
1991, a public meeting was held to discuss the remedial
alternatives that were evaluated for Off-site Areas 1 and 2
and to receive public comments. In 1992, a public meeting
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was held to discuss the alternatives for remediation of the
ground water at the site and also to receive public comment.
A public meeting was held in August 1396 to discuss the
findings of the study by the USGS regarding the nature and
source of off-site arsenic soil contamination.
The December 1996 Final RI Report, the August 1998 Source
Control Feasibility Study Report and January 1999 Addendum,
and the February 1999 Proposed Plan for the remediation of
on-site soils were released to the public for comment on
February 19, 1999. The public comment period ended on April
6, 1999. These documents were made available to the public
at the following information repositories:
NJDEP
Bureau of Community Relations
401 East State Street, 6"" Floor
Trenton, NJ
Monmouth County Library
1 Library Court
Marlboro, NJ
US EPA
Superfund Records Center
290 Broadway, 18"''' floor
New York, NY
On March 13, 1999, NJDEP conducted a pubic meeting at the
Marlboro Township Municipal Building to inform local
officials and interested citizens about the Superfund
process, to discuss the findings of the Remedial
Investigation, the Source Control Feasibility Study and the
proposed remedial activities at the site, and to respond tc
any questions from the area residents and others who
attended. NJDEP's written responses to the comments
received at the public meeting and the written comments
received during the public comment period are included in
the Responsiveness Summary (see Appendix C).
SCOPE AND ROLE OF REMEDIAL ACTION
As with many Superfund sites, the problems at the IOC/CC
site are complex. As a result, EPA and-NJDEP have organized
the cleanup of this site into three phases, or operable
units.
Operable Unit 1: This includes the wetlands and off-site
soils located in what is known as Off-site Areas 1 and 2 and
also 4 residential properties located near the facility.
Contamination associated with Birch Swamp Brook's sediment
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and floodplains is currently being evaluated for inclusion
in OU1.
Operable Unit 2: This includes contaminated ground water
and the continuation of the floating product removal action
that was initially undertaken by EPA.
Operable Unit 3: This is the subject of this ROD and
includes the contaminated site soils, including the
remaining waste filter clay material. This OU3 also
modifies the OU2 floating product remedial action in that it
selects a remedy of excavation and off-site disposal for the
floating product. This is the last planned operable unit
for the site.
SUMMARY OF SITE CHARACTERISTICS
The purpose of the RI conducted by NJDEP was to accomplish
the following: identify the nature and extent of
contamination at and/or emanating from the site;
characterize the site geology and hydrogeology; and
determine the risk to human health and the environment posed
by the site. The December 1996 RI Report is a comprehensive
report which covers the investigation of numerous
contaminated media including, off-site soils, sediment,
ground water, waste filter clay, floating product and on-.
site soils. The information summarized below is only
information from the RI Report relevant to this Record of
Decision, which addresses on-site soils and floating
product.
Site Geology
Three primary geologic units and two others were identified
at the site. The major geologic units identified were (1)
fill; {2} the Englishtown Formation; and, (3) the Woodbury
Clay Formation. These units are further described below.
Fill Material
With the exception of the area at the northern end of the
site between the berm and Birch Swamp Brook, fill materials
were identified at every test boring and surface-soil
sampling location in the active portion of the site and in
areas investigated adjacent to the site. The -fill unit
consists of sand, silt, and gravel, mixed with varying
amounts of-ash and waste filter clay, wood fragments, coal,
bricks, and concrete rubble. This fill was observed to
range in thickness from two feet near the northwestern and
western fence line to 5.5 feet between the former waste pile
area and the earthen berm.
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A second fill deposit area was observed outside the fenced
portion of the facility, south of the fire pond and west of
the outparking area (see Figure 2). South of the Fixe Fond,
the fill consists of layers of black oil sludge, black ana
orange-stained silt and sand, and wood rubble to a depth of
12 to 15 feet. The sludge-like material was observed as
deep as 14 feet. The fill west of the outparking area was
observed to consist of sands and silts with angular course
fragments, glass, and ash.
Er.crlishtown Formation
The Englishtown Formation outcrops at ground surface just
west of the western boundary fence line. The sand and silty
clay formation ranges in depth across the site from 43 feet
co 67 feet where the top of the Woodbury Clay Formation
exists. Continuous zones from 10 to 15 feet in thickness of
very poorly graded sand with few silty clay layers alternate
with sandy zones where the silty clay is more prevalent.
The western quadrant of the' site exhibits a stiff black clay
interbedded with a thin white quartz laminae ranging in
thickness from 5 feet to 20 feet and found at depths ranging
from 5 feet to 20 feet below ground surface.
Woodburv Clay
The Woocbury Clay is a subscantial confining layer and was
act penetrated by any of the site investigation borings.
Data from well logs in the Mcrganville area indicate chat
th^s formation is greater than 700 feet deep.
Local Hydroqeolocry
Interpretation of local hydrogeologic conditions is based on
water-level measurements, laboratory and in-situ hydraulic
conductivity testing, grain size analysis, and
interpretation of site geology. Two groundwater flow
systems were identified at the site: (1) a local perched
groundwater system, and, (2) the regional water table
system, the Englishtown Aquifer.
Seasonally perched ground water was observed in the fill
areas around the facility parking lot and south of the Fire
?cnd. Ground water was not consistently detected and the
fill areas do not represent a significant groundwater
system. The perched ground water around the former drum-
wash building results from the silty clay layer identified
along the western quadrant of the site. This perched ground
water likely restricts the vertical migration of ground
water to the Englishtown Formation at this location.
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The Englishtown Aquifer is the major groundwater system
underlying the site. The site lies within the recharge zone
for this aquifer. Depth to the water table ranges from 2 to
14 feet across the site. The saturated thickness of the
aquifer beneath the site ranges from 49 to 55 feet. The
Englishtown Aquifer consists-of two flow components: (1) a^
shallow flow component that discharges to the Fire Pond and
Birch Swamp Brook; and (2) a deeper flow component that
comprises the regional flow of the Englishtown Aquifer.
Ground water in the shallow part of the aquifer generally
flows in a northerly direction, with local components to the
east and west as influenced by topographic and geologic
conditions. Ground water flow in the deep zone of the
aquifer beneath the site flows northeast toward Raritan Bay.
RI Soil Investigation
A total of 56 soil borings to varying depths and 111 surface
soil samples were collected from the vicinity of the IOC
facility and from Off-site Areas 1 & 2 as part of the two
phase RI to characterize the soil contamination at the site.
Numerous volatile compounds (VOCsi, semi-volatile compounds
''SVOCs) , inorganic compounds, as well as pesticides and ?C=;3
were detected in site soils. Figures 4 through 14 provide a
summary of the soil findings.
RI sampling indicated that contaminated on-site so s
contain elevated levels of numerous contaminants including,
but"not limited to: PCBs; arsenic; lead; beryllium;
antimony; toluene; xylenes; ethylbenzene; pyrene; TPHs;.
bis .:2-ethylhexyl)phthalate; and butylbenzylphthalate.
Primary areas of contamination include the area below the
former'waste filter clay pile, tank farm soils and fill area
soils. These areas of concern are further described below.
Waste Filter Clav (Former Waste-Pile Area) and Floating
Product
An area containing waste filter clay is identified on Figure
15 as the "Fill/Soil Surrounding Waste Pile". As stated
above, in 1991 EPA excavated the waste filter clay pile down
-o ground level. The remaining waste filter clay and
associated soils contain highly elevated levels of numerous
contaminants including PCBs, TPHs, VOCs, SVOCs, pesticides,
antimony, arsenic-, beryllium, copper, lead, and mercury
Contaminants have migrated from the waste filter clay and
surrounding soil via two transport mechanisms: (1) erosion
of contaminated soil and waste filter clay, and (2) movement
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of floating product along the ground water /soil interface. jat
Much of the migration of contaminants from the former waste- f
pile area via erosion has been curbed by construction of the
containment berm at the northern end of the facility and by
removal of all the waste filter clay that was piled above
grade in 1991. Waste filter clay remaining below grade has
beer, covered with a protective liner since the removal of
above-grade material to limit migration of this contaminated
material. The original liner was replaced with a new liner
in 1997.
The floating product is a continuing source of soil and
groundwater contamination. Migration of contaminants
associated with the waste filter clay continues via the
movement of the petroleum-like floating product layer with
ground water. Floating product identified at the site has
been characterized prior to and during the installation of
the floating product removal system in 1991 and the
operation of that system since that time. As stated above,
to date, this system has extracted 15,000 gallons of this .
highly contaminated petroleum-like material which lies in
the interface of site soils and the shallow ground water .
Sampling reveals that the floating product contains elevated
levels of contaminants including: toluene (1,460 parts per
million ''porn) ; ; ethylbenzene (48.4 ppm) ; xylenes (up to 133
ppT./ ; napthalene (147 ppm) ; fluorene (14.8 ppm) ; and ?C5s
409 ppm.. Table 1 presents a summary of data results for
the floating product from a 1996 sampling event. Migraticr.
cf this product layer appears partly responsible for
subsurface-soil contamination north and northeast cf the
waste filter clay. Most subsurface soil beneath the waste
filter clay contains elevated concentrations of VOCs, SVOCs,
T?H, and PCBs. Based on floating product thickness
measurements obtained in March and April 1996, as part of
the ground water remedial design and in July 1997, as part
of the /round water plume recharacterization, it has been
determined that the floating product has migrated north cf
the active portion of the site (i.e., beyond the' berm) (see
Figure 16}. This indicates that the currently operating
floating product extraction system, while limiting some
migration, is not completely preventing the migration of
this material.
Tank Farms
There are four tank farms located on the site. The tank
farms are discreet areas housing over 50 tanks. Some of the
tanks are used to store oil before blending and others are
used to store blended oil. The tanks are constructed
directly over site soils. During past site inspections,
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visible staining and oil puddles have been observed in the
gravel and soils surrounding and underlying the.tanks.
The RI data shows the widespread detection of a number of
contaminants, particularly arsenic, in soils underlying and
in the vicinity of the four tank farms (see Figure 15}.
Elevated arsenic levels were detected in subsurface soil
samples collected from Tank Farms Nos. 1-, 2, 3, and 4. The
highest concentration of arsenic detected at the site, 6,120
ppm, was detected in soil within a tank farm. Other
inorganics, including beryllium and antimony, have been
detected in the tank-farm areas.
The large areas .of- soils containing elevated arsenic
concentrations suggests that the arsenic is mobile.
Elevated levels of arsenic detected in groundwater samples
collected from monitoring wells located in the vicinity of
the tank farms further indicates that arsenic is for was at
one time) in a soluble, or mobile form and that site soils,
particularly soils in the vicinity of the tank farms, are a
likely source of groundwater contamination.
Fill Deposits
Contaminated fill was placed .west of the outparking area,
south cf the Fire Pond, and adjacent to the drum-washing
building (see Figure 15). Much of the fill deposited south
cf the Fire Pond is likely to have come from past dredging
cf what is now the Fire Pond. Distinct and apparently
continuous layers of oily sludge were observed in borings
drilled through this fill material, suggesting the sludge
rr.ay have been deposited as layers during Fire Pond dredging
episodes. The primary contaminants detected in this area
are TPKs. Elevated concentrations of inorganics were also
•detected, crimarily in samples collected from the discrete
sludge layers. Waste-oil-related VOCs were also detected,
with the greatest concentrations observed in the sludge.
In the fill west of the outparking area, several samples
contained elevated concentrations of TPHs, PCBs, arsenic,
beryllium, and lead. Waste-oil-related SVOCs also were
detected.
Fill up to four feet deep was observed adjacent to the
former drum-washing building. TPHs, PCBs, arsenic, and lead
were detected at elevated concentrations in surface .and
subsurface-soil samples collected from this area.
Data Gap Investigation.
In November 1996, NJDEP collected soil samples at 40 locations
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on-site and in areas abutting the site to fill data gaps in
the RI contamination assessment. The Data Gap Investigation
was organized into four areas of concern: soils in and around
the tank farms, fill south of the Fire Pond, soil beneath on-
site paved areas, and miscellaneous soil samples in previously
unsampled areas.
CcT.pariscn of analytical results from the Data Gap
Investigation to results of sampling presented in the RI
Report indicates a similar distribution of site -contaminants.
Arsenic and lead concentrations in Tank Farm No. 3 are
approximately an order of magnitude greater than those
detected during the RI and.reinforce the interpretation in the
RI Report that soil associated with the tank farms is a
significant source of contamination. Please see Table 2 for
a summary of the results of the Data Gap Investigation.
Summary of Soil Findings
In summary, soil contamination is prevalent throughout the
on-site areas. The contaminants found in soils include, but
are not limited to: PCBs (up to 1,590 ppm); arsenic (up to
6,120 ppm}; lead (up to 3,720 ppm); beryllium (up to 2.9
ppm; ; antimony (up to 30 ppm) ; toluene (up to 3 ppm) ;
xylenes (up to 3.3 ppm); ethylbenzene (up to 4.2 ppm);
pyrene (up to 5 ppm); bis(2-ethylhexyl)phthalate (up to 12
ppm; ,- and butylbenzylphthalate (up to 47 ppm) . Further,
flcating product, which is highly contaminated with ?C3s as
well as ccher contaminants, continues to migrate at r.he sue
ar.d is a source of further soil and groundwater
centamination.
SUMMARY OF SITE RISKS
Human Health Risks
Eased upon the results of the RI, a baseline human health
risk assessment was conducted to estimate the risks
associated with current and future sice conditions. The
baseline risk assessment estimates the human health risk
which could result from the contamination at the site if no
remedial action were taken. The baseline risk assessment
for the site is presented in the December 1996 RI Report.
In September 1999, EPA made some modifications to the risk
assessment, which are presented in the September 1999 Risk
Assessment Addendum for OU3. The Risk Assessment Addendum
was placed in the Administrative Record for the site. The
results of the Risk Assessment and Addendum are presented
below.
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Human Health Risk Assessment
A four-step process is utilized for assessing site-related
human health risks for a reasonable maximum exposure
scenario: Hazard Identification - identifies the
contaminants of concern at the site based on several factors
such as toxicity, frequency of occurrence, and
concentration. Exposure Assessment - estimates the
magnitude of actual and/or potential human exposures, the
frequency and duration of these exposures, and the pathways
(e.g., ingesting contaminated well-water) by which humans
are potentially exposed. Toxicity Assessment - determines
the cypes of adverse health effects associated with chemical
exposures, and the relationship between magnitude of
exposure (dose) and severity of effect (response). Risk
Characterization - summarizes and combines outputs of the
exposure and toxicity assessments to provide a quantitative
assessmenc of site-related risks.
A baseline risk assessment was conducted to evaluate the
potential risks to human health and the environment
associated with the IOC/CC site in its cui .:ent state. The
risk assessment focused on contaminants in the soil which
are likely tc pcse significant risks to human health. A
summary of the contaminants of concern in soils is provided
in Table 3.
This baseline risk assessment addresses the potential risks
to human health by identifying several potential exposure
oathways by which the public may be exposed to contaminant
releases at the site under current and future land-use
conditions. Based on the use of the site, the risk
assessment focused on six areas, and identified potentially
exposed populations for each area. Current exposure
scenarios include facility maintenance workers exposed to
soils in the tank farm area, utility workers exposed in the
fenced portion of the' site, construction/excavation workers
exposed to soils under the old warehouse,
industrial/facility workers in direct contact with soils in
the waste pile, and child and youth trespassers exposed to
surface soils outside the IOC/CC facility. Future exposure
scenarios include child and adult residents exposed to
cnsite soils. Risk was estimated for both incidental
ingest ion and dermal contact. A total of 14 exposure
pathways were evaluated under possible on-site current and
future'land-use conditions. The exposure pathways considered
under future'uses are listed in Table 4. The reasonable
maximum exposure was evaluated.
Under current EPA guidelines, the likelihood of carcinogenic
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(cancer-causing) and noncarcinogenic effects due to exposure
to site chemicals are considered separately. It was assumed
that the toxic effects of the site-related chemicals wou_Ld
be additive. Thus, carcinogenic and noncarcincgenic risks
associated with exposures to individual compounds of concern
were summed to indicate the potential risks associated with
mixtures of potential carcinogens and noncarcinogens,
respectively.
Noncarcinogenic risks were assessed using a hazard index
:HI) approach, based on a comparison of expected contaminant
intakes and safe levels of intake (Reference Doses).
Reference doses (RfDs) have been developed by EPA for
indicating the potential for adverse health effects. RfDs,
which are expressed in units of milligrams per kilogram per
day (mg/kg-day), are estimates of daily exposure levels for
humans which are thought to be safe over a lifetime
•including sensitive individuals). Estimated intakes of
chemicals from environmental media (e.g., the amount of a
chemical ingested from contaminated drinking water) are
compared to the RfD to derive the hazard quotient for the
contaminant in the particular medium. The HI is obtained by
adding the hazard quotients for all compounds within a
particular medium that' impacts a particular receptor
population.
An KI greater than 1.3 indicates that the potential exists
for noncarcincgenic health effects to occur as a result z~
sice-related exposures. The HI provides a useful reference
ccint for gauging the potential significance of'multiple
ccnraminant exposures within a single medium or across
media. The tcxicity values, including reference doses, for
the compounds of concern at the site are presented in Table
5. A summary of the noncarcincgenic risks associated with
zhese chemicals for each exposure pathway is contained in
Table 6 .
It car. be seen from Table 6 that the KI for noncarcinogenic
effects from incidental ingestion of soil is 2.4 for
construction/excavation workers exposed to soil under the
eld warehouse, 3.2 for industrial/facility workers exposed
to soil in the waste pile, 2.6 for future adult residents
exposed to onsite soils, and 24 for future child residents
exposed to onsite soils. The HI for noncarcinogenic effects
from dermal contact with soil is 2.1 for construction/
excavation workers exposed to soil under the old warehouse,
51 for industrial/facility workers exposed to soil in the
waste pile, 3.8 for future adult residents exposed to onsite
soils, "and 14 for future child residents exposed to onsite
soils. Therefore, noncarcinogenic risks may occur from the
exposure routes evaluated in the Risk Assessment. The
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noncarcinogenic risk was attributable to several compounds
including arsenic and PCBs (Aroclor 1242, Aroclor 1248. and
Aroclor 1260) .
Potential carcinogenic risks were evaluated using the cancer
slope factors developed by EPA for the contaminants of
concern. Cancer slope factors (SFs) have been developed for
estimating excess lifetime cancer risks associated with
exposure to potentially carcinogenic chemicals. SFs, which
are expressed in units of (mg/kg-day) "•, are multiplied by
the estimated intake of a potential carcinogen, in mg/kg-
day, to generate an upper-bound estimate of the excess
lifetime cancer risk associated with exposure to the
compound at.that intake level. The term "upper bound"
reflects the conservative estimate of the risks calculated
from the SF. Use of this approach makes the underestimation
of the risk highly unlikely. The SFs for the compounds of
concern are presented in Table 7.
For known or suspected carcinogens, EPA considers excess
upper-bound individual lifetime cancer"risks of between E-04
to E-06 to be acceptable. This level indicates that an
individual has not greater than approximately a one in. ten
thousand to.one in a million chance of developing cancer as
a result .of . site-related expc'sure to a carcinogen over a 70-
year period under specific exposure conditions at a site.
Excess lifetime cancer risks estimated at the ICC/CC site
were 3.5E-04 for the industrial/facility workers exposed to
soils-in the former waste pile area through dermal contact,
2.5 E-C4 and 5.GE-04 for future adult residents exposed to
cnsite soils through incidental ingestion and dermal
contact, respectively, and 5.8E-04 and 2.1E-04 for future
child residents exposed to onsite soils through incidental
ingesticn and dermal contact, respectively. Excess Lifetime
car.cer risks for other populations and pathways evaluated in
this assessment were within EPA's acceptable r_sk range.
The cumulative upper-bound cancer risk at the site for
future adult and child residents is 1.5E-03, while the risk
to the industrial/facility workers is 9.1E-04. These
cumulative risks take into account exposure through both
incidental ingestion and dermal contact. Hence, the risks
for carcinogens at the site exceed the high end of the
acceptable risk range of E-04 to E-06 (see Table 8). The
estimated total risks are primarily due to arsenic^and PCBs.
The risk calculations were based on reasonable maximum
exposure scenarios. These estimates were developed by
taking into account various conservative assumptions about
the likelihood of a person being exposed to soil.
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Uncertainties
The procedures and inputs used to assess risks in this
evaluation, as in all such assessments, are subject to a
wide variety of uncertainties. In general, the main sources
of uncertainty include:
- environmental chemistry sampling and analysis
- environmental parameter measurement
- fate and transport modeling
- exposure parameter estimation
- toxicolcgical data
Uncertainty in environmental sampling arises in part from
the potentially uneven distribution of chemicals in the
media sampled. Consequently, there is significant
uncertainty as to the actual levels present. Environmental
chemistry-analysis error can stem from several sources,
including the errors inherent in the analytical methods and
characteristics of the matrix being sampled.
Uncertainties in the exposure assessment are related to
estimates of how often 'an individual would actually come in
contact with the chemicals of concern, the period of time
ever which such exposure would occur, and in the models used
to estimate the concentrations of the chemicals of concern
at the point of exposure.
Uncertainties in tcxicological data occur in extrapolating
bcth freer, animals zc humans and from high to low doses of
exposure, as well as from the difficulties in assessing the
tc-xicity of a mixture of chemicals. These uncertainties are
addressed by making conservative assumptions concerning risk
and exposure parameters throughout the assessment. As a
x'esult, the risk assessment provides upper-bound estimates
of the risks to populations near the site, and is highly
unlikely to underestimate actual risks related to the site.
More specific information concerning public health and
environmental risks, including a quantitative evaluation of
the degree of risk associated with various exposure
pathways, is presented in the risk assessment report.
Actual or threatened releases of hazardous substances from
this site, if not addressed by implementing the response
action selected in th ROD, may present an imminent and
substantial endangerment to the public health, welfare, or
the environment.
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Ecological Risks
A qualitative and/or semi-quantitative appraisal of the
actual or potential effects of a hazardous waste site on
plants and animals constitutes an ecological risk
assessment. A four step process is utilized for assessing
site-related ecological risks: Problem Formulation - a
qualitative evaluation of contaminant release, migration,
and fate; identification of contaminants of concern,
receptors, exposure pathways, and known ecological effects
of the contaminants; and selection of" endpoints for further
study. Exposure Assessment - a quantitative evaluation cf
contaminant release, migration, and fate; characterization
of exposure pathways and receptors; and measurement or
estimation of exposure point concentrations. Ecological
Effects Assessment - literature reviews, field studies, and-
toxicity tests linking contaminant concentrations to effects
on ecological receptors. Risk Characterization -
measurement or estimation of both current and future adverse
effects. Chapter 14 of the RI Report describes in 'detail
the results of the site-wide ecological risk assessment
performed at the IOC/CC site.
The environmental evaluation focused on how the contaminants
would affect the site's natural resources. Natural
resources include existing flora and fauna at the site,
surface water; wetlands, and any sensitive species or
habitats that may exist. The major types of biological
habitats that exist at the site, ana which were addressed in
the Ecological Risk Assessment include: 1) wooded areas
southeast of the Fire Pond and northeast of the facility; 2:
the Fire Fond and an 0.5 acre wetland area downstream of the
railroad culvert; 3} a shrub habitat in the vicinity of .the
power transmission lines which traverses Off-site Areas 1
ana 2; and 4) a large wooded area to the west and north cf
Off-Site Areas 1 and 2". ' ' '
Note that the Ecological Ris.k Assessment performed at the
site covers ecological risks associated with site
contaminants present in the four areas listed above.
However, only area 1, listed above, is relevant to on-site
areas which comprise Operable Unit 3, the subject cf this
document. On-site soils located within the fenced area of
the site were not included in this assessment. However, the
specific contaminants located within the fenced area of the
site and in the areas included in the Ecological Risk
Assessment are the same. Further, levels of the
contaminants of concern detected within the fenced area cf
the site are higher compared to levels detected in the site
areas included in the ecological risk assessment.
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Therefore, the ecological risks for soils addressed by OU3
would be higher than those determined in the Ecological P.i-sk
Assessment. In addition, the Ecological Risk Assessment
evaluated risks to terrestrial and aquatic receptors.
However, Birch Swamp Brook is the surface water source
evaluated to determine risks to aquatic receptors. Since
Birch Swamp Brook will be addressed under another operable
unit, the discussion below summarizes ecological risks posed
to terrestrial receptors only. Also note that although the
selected receptors have been observed, or are expected to be
present in the vicinity of the site, since the IOC/CC
facility is currently fenced and operating, it is believed
that there is limited use by the terrestrial receptors ,
selected.
Lists of the various plant, mammal, bird, and herptile
^'reptiles and amphibians) species observed or presumed to
occur in the vicinity of the IOC/CC site are presented in
Appendix F (Tables F-l through P-4} of the RI Report. No
federally or State listed or proposed threatened or
endangered flora or fauna are known to occur in the
immediate vicinity of the site.
A total cf five receptor species were chosen to best
represent the ecosystem of the site for purposes of
evaluati-.g ecological risk to terrestrial receptors as
fellows: :. 1} white-footed mouse (small mammal, omnivore; ;
>2! wood thrush 'small bird, omnivcre); (3) eastern garter
sr.ake reptile, carnivore); (4) red fox (predatory mammal,
carnivore.' ,- and !5j red-tailed hawk (predatory bird,
carnivore:' .
Sources of exposures to ecological receptors considered for
this ecological assessment include surface soil (generally
collected from 0 to 2 feet below ground surface) and surface
water. Data from subsurface soils were not evaluated
because these greater depths are not considered likely for
potential contact with burrowing animals or roots of
vegetation. Similarly, ground'water data were not used in
this ecological assessment because it is unlikely the
ecological receptors can contact contaminants associated
v;ith ground water.
Exposure to contaminated constituents in surface soil and
surface water may occur via several pathways. These include
direct contact with (including ingestion of) surface water
and surface soils and ingestion of biota which have
bioccncentrated chemicals in their tissues.
The contaminants of concern selected for the ecological risk
assessment were: PCBs; antimony.; arsenic; beryllium; lead;
and bis-2(ethylhexyl)phthalate.
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To provide estimates of chronic (long term) and acute
exposure to terrestrial organisms, food web modeling was
performed for lead and FCBs present in surface water and
surface soil. Modeling of the other contaminants was not
performed because of the lack of ingestion toxicity data
available for these .chemicals. The results of the food web
modeling indicate that the potential for adverse ecological
effects exists and the greatest exposures occur to organisms
with the smallest home range (white footed mouse, wood
thrush, and garter snake). Organisms with smaller hone
ranges would be expected to receive greater exposures
because they would spend a greater proportion of their lives
feeding in contaminated areas than would organisms with
larger home ranges such as the fox and hawk.
In summary, the Ecological Risk Assessment concluded that
exposure to the IOC/CC site soil and surface water by the
various plant, mammal, bird, and herptile species in the
vicinity of the site, if not addressed by the preferred
alternative, or one of the other remedial alternatives
considered, presents a current or potential future threat to
the environment.
More specific information concerning public health risks and
ecological risks, including a quantitative evaluation of .the
degree cf risk associated with various exposure pathways, is
presented in Chapters 13 and 14 of the RI Report.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect hunar.
health and the environment. These objectives are based on
available information and standards such as applicable cr
relevant and appropriate requirements (ARARs) and risk-based
levels'established in the Risk Assessment.
The following, remedial action objectives were established to
address en-site soils and floating product for the ICC/CC
site: • .
1) restoring the1soil to levels which would allow for future
residential/recreational use without restrictions;
2} preventing human exposure to the on-site contaminated
soils and waste filter clay material;
3) preventing ecological exposure to contaminated surface
soils; and
4) eliminating continuing sources of contamination from on-
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site areas to ground water, Birch Swamp Brook, the Fire
Pond, and associated wetlands.
Soil clean-up numbers for the site were developed by EPA in
accordance with the EPA's December 1991 A Risk Assessment
Guidance for Superfund: Development of Risk-based
Remediation Goals, and other guidance documents. Table 9
provides a complete summary of the selected remediation
goals for each, contaminant of concern identified at the
site. For each contaminant, the selected remediation goal
is the lesser of the risk-based soil criteria for
residential use or the EPA calculated "Impact to Ground
Water Soil Cleanup Criteria".
Soil cleanup levels for PCBs at the site are based on the
toxicity reassessment developed by EPA since the original
1990 EPA "Guidance on Remedial Actions for Superfund Sites
with PCB Contamination". For residential land use, an
action level of 1 ppm- is specified for PCBs. The 20 ppm
cleanup level for arsenic is consistent with the New Jersey
statewide background concentration. Although PCBs and
arsenic are the most prevalent contaminants at the site,
there are a number of other contaminants present. Soil
cleanup standards were developed for these contaminants
which are protective of human health and the environment.
The State of New Jersey has developed a State-wide soil
cleanup criteria for PCBs of 0.49 ppm. EPA's cleanup level
for PCBs is 1 ppm. The state's assessment of the data
indicates implementation of the remedy utilizing EPA's
remediation goals will also achieve NJDEP's remediation
goals for unrestricted use. However, if applicable, the
State agrees to fund all additional costs incurred during
remedial action due to the application of NJDEP's mere
stringent cleanup criteria for any contaminant.
The areal and vertical extent of contaminated soil exceeding
remediation goals was estimated based on a comparison of
analytical results to the remediation goals developed by
EPA. Areas exceeding remediation goals are shown in .Figure
17. The total volume of soils exceeding remediation goals
is estimated at 83,000 cubic yards <,cy) . The volume
calculations were based on the commercial, rather than the
residential remediation goals. However, EPA and NJDEP do
not believe that changing the remediation goals to meet
residential standards will add a significant volume to the
soils that must be excavated. In addition, approximately
5,000 gallons of floating product, a continuing source of
grcundwater contamination, are estimated to be present at
the site.
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DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES
CERCLA §121(b)(l), [42 U.S.C.§9621(b)(1}] mandates that each
selected site remedy be protective of human health and the
environment, be cost effective, comply with other statutory
laws, and utilize permanent solutions and alternative
treatment technologies and resource recovery alternatives to
the maximum extent practicable. In addition, the statute
includes a preference for the use of treatment as a
principal element for the reduction of toxicity, mobility,
or volume of the hazardous substances. CERCLA §121(d), [42
U.S.C. §9621(D)], further specifies that a remedial action
must attain a level or standard of control of the hazardous
substances, pollutants, and contaminants, which at least
attains ARARs under federal and state laws, unless a waiver
can be justified pursuant to CERCLA §121(d)(4), [42 U.S.C.
§9621 (d)(4)].
Based on the remedial action objectives, NJDEP performed an
initial screening process of potential alternatives that
would address the contaminated soils and floating product at
the site. The initial screening of the alternatives is
described in greater detail in the August 199.8 Final Source
Control Feasibility Study (FS) Report..and the January 1999
Addendum. •
Several remedial technologies that could potentially mee~
remedial action objectives for the site were identified, .
formulated into remedial alternatives, and then evaluated
for effectiveness, implementability, and cost. Following
this evaluation, four remedial alternatives were retained
for detailed analysis.
The four alternatives that received detailed analysis are-.
.Alternative 1: NO ACTION
Alternative 2: ON-SITE CONTAINMENT (w/Options A, B, C)
Alternative 3: EXCAVATION/OFF-SITE DISPOSAL/REUSE
Alternative 4: EXCAVATION/TREATMENT
The estimated capital cost, net present worth cost, and
implementation time to successfully complete the cleanup
under each alternative is presented below for comparison
(and summarized in Table 7). The time to implement a
remedial alternative reflects the estimated time required co
construct the remedy, but does not include the time to
prepare design documents or procure.contracts. Actual costs
and implementation times may differ.
25,
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Alternative 1: NO ACTION
Estimated Capital Cost: $ 0
Est. O&M Present Worth Cost (30 years): $ 295,000
Estimated Net Present Worth Cost: $ 295,000
Estimated Implementation Time: None
The National Contingency Plan (NCP) and CERCLA require the
evaluation of a No Action alternative to be considered as a
baseline for comparison with other remedial action
alternatives. The No Action alternative does not include any
remedial action activities to reduce the toxicity, mobility
or volume of contamination or prevent or control, .exposure to
contaminated soil at the site. This alternative includes a
30-year environmental monitoring program. The objective -of
the environmental monitoring program would be to monitor the
impact of the existing sources of contamination on ground
water and Birch Swamp Brook in the future. Because this
alternative would result in contaminants remaining on site,
institutional controls (e.g., a deed restriction) would be
placed on the property that would restrict future use of the
site. Because this alternative would result in contaminants
remaining on-site above health based levels, a review of the
site conditions would be conducted every five years to
ensure that the remedy continues to provide adequate
protection of human health and the environment.
Alternative 2A: RESTRICTED CONTAINMENT WITH PRINCIPAL THREAT
(HOT SPOTS) REMOVAL
Estimated Capital Cost: $14,942,000
Est. O&M Present Worth Cost (30 years): $483,000
Estimated Net Present Worth Cost: $15,425,000
Estimated Implementation Time: 24 months
Alternative 2A involves the dismantling of the tank farms
and other structures at the IOC facility to facilitate- the
excavation of the contaminated soil; .dismantling the
floating product removal system to facilitate the excavation
of waste filter clay material and the floating product; and
excavation and off-site disposal of 27,000 cy of soils which
pose the principal threat (hot-spots). The hot-spot
material includes an estimated 19,000 cy of soil to be
transported to a TSCA-permitted landfill; an estimated 8,000
cy of soil to be transported to a RCRA-permitted landfill,
where it will receive appropriate treatment prior to
disposal (in conformance with RCRA requirements); and an
estimated 5,000 gallons of floating product to be collected
26
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during the course of excavation which will be transported to
a TSCA-permitted incinerator. In addition, this alternative
includes the excavation and stockpiling of an estimated
56,000 cy of contaminated soil exceeding remediation goals
prior to placement in an approximate three-acre containment
system cell on-site. The containment cell would be
constructed on the northern portion of the IOC/CC property
and would have a bottom liner and leachate collection
system. The soil would be dewatered before off-site
disposal and on-site placement. The liner system would be
constructed above the water table and would occupy the upper
portion of the site's five-foot unsaturated zone. Leachate
collected from the containment system cell would be removed
by pumping directly into tanker trucks for appropriate off-
site disposal. The approximate height of the Alternative 2A
containment cell is 30 feet. The wetland areas affected by
this alternative, estimated to be 0.5 acres, will be
restored following the excavation and disposal activities.
This alternative would require a deed restriction to ensure
that no intrusive activities would be performed on the
capped area in the future since such activities would affect
the cap's integrity. Because this alternative would result
in contaminants remaining on-site above health-based levels,
a review would .be conducted every five years from the .
initiation of the remedial action to ensure that the remedy
continues to provide adequate protection of human health and
the environment. - .
Alternative 2B: EXPANDED CONTAINMENT WITH PRINCIPAL THREAT
(HOT SPOTS) REMOVAL
Estimated Capital Cost: $15,514,000
Est. O&M Present Worth Cost (30 years): $ 563,000
Estimated Net Present Worth Cost: $16,077,000
Estimated Implementation Time: 24 months
The components of Alternative 2B are the same as Alternative
2A excepc for the dimension of the containment system cell.
This alternative involves the dismantling of the tank farms
and other structures on the IOC facility to facilitate the
excavation of the contaminated soil; dismantling the
floating product removal system; and excavation and
appropriate off-site disposal of the same estimated 27,0.00
cy of soils and 5,000 gallons of floating product which pose
the principal threat (hot-spots). Similarly, this
alternative includes the excavation and stockpiling of an
estimated 56,000 cy of contaminated soil exceeding
remediation goals prior to placement in an approximate 5.5-
acre containment system cell (covering the entire fenced
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area of the IOC/CC site) complete with a bottom liner and
leachate collection system. The approximate height of the
Alternative 2B containment cell would be 16 feet. The
wetland areas affected by this alternative, estimated to be
0.5 acres, will be restored following the excavation and
disposal activities.
This alternative would require a deed restriction to ensure
that no intrusive activities would be performed on the
capped area in the future since such activities would affecc
the cap's integrity. Because this alternative would result
in contaminants remaining on-site above health-based levels,
a review would be conducted every five years from the
initiation of the remedial action to ensure that the remedy
continues to provide adequate protection of human health and
the environment.
Alternative 2C: PRINCIPAL THREAT (HOT SPOTS) REMOVAL WITH IN
PLACE CONTAINMENT FOR ALL OTHER CONTAMINATION
Estimated Capital Cost: $13,111,000
Est. O&M Present Worth Cost (30 years): $ 387,000
Estimated Net Present Worth Cost: $13,498,000
Estimated Implementation Time: 18 months
Under Alternative 2C, following the removal and appropriate
off-site disposal of an estimated 27,000 cy of soils and
5,000 gallons of floating product which pose the principal
threat (hoc-spots), the remaining 56,000 cy of contaminated
soil on the IOC property would be capped in place on the
site. A limited amount of contaminated soil located west of
the northwest fence boundary would be excavated and
consolidated on-site prior to capping. The estimated size
of the cap under this alternative is four acres and, unlike
Alternatives 2A and 2B, this alternative would not include a
bottom liner and leachate collection system. The estimated
height of the cap would be three feet. The wetland areas
affected by this alternative, estimated to be 0.5 acres,
will be restored following the excavation and disposal
activities.
This alternative would require a deed restriction to ensure
that no intrusive activities would be performed on the
capped area in the future since such activities would affect
the cap's integrity. Because this alternative would result
in contaminants remaining on-site above health-based levels,
a review would be conducted every five years from the
initiation of the remedial action to ensure that the remedy
continues to provide adequate protection of human health and
the environment.
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Alternative 3: EXCAVATION/OFF-SITE DISPOSAL/REUSE
Estimated Capital Cost: $17,201,000
Est. O&M Present Worth Cost: $9,000
Estimated Net Present Worth Cost: $17,210,000
Estimated Implementation Time: 11 months
Alternative 3 involves the dismantling of the tank farms and
other structures on the IOC facility to facilitate the
excavation of the contaminated soil; dismantling the
floating product removal system; excavation of all
contaminated soil * (which includes 27,000 cy of soil which
poses the principal threat (hot-spots) and 56,000 cy of soil
exceeding remediation goals); and the disposal of this
estimated 83, 000 cy 'of contaminated material and the 5,000
gallons of floating product in an appropriate off-site
permitted facility. For the 27,000 cy of soil posing the
principal threat, an estimated,19,000 cy of soil will be
transported to a TSCA-permitted landfill and the other 8,000
cy to a RCRA-permitted landfill for disposal, where it will
receive appropriate treatment prior 'to disposal in
conformance with RCRA requirements. The 5,000 gallons of
floating product (which is also principal threat material)
will be disposed of in TSCA-permitted incinerator. The
56,000 cy of soil exceeding remediation goals will be
transported to an appropriate 'landfill for disposal. Some
of the soil may be.eligible for soil recycling in a Class 3
permitted asphalt-batch plant. The excavated areas would be'
backfilled with clean soil. The affected wetlands would be
restored. Under .this alternative, soil which poses the
principal threat (hot-spots) would be excavated similar to
Alternative 2, except that, after dewatering (as necessary),
all excavated material would be hauled off-site for disposal
after it has been sampled and analyzed for its chemical
characteristics. Accordingly, stockpile requirements are
much lower chan those required for Alternative 2 and
stockpiling could occur within the area of excavation.
Excavations would be backfilled with clean, soil and the site
returned to its existing grade. The wetland areas affected
by this alternative, estimated to be 0.5 acres, will be
restored following the excavation and disposal activities.
Operation and maintenance activities would be performed on
the wetlands after completion of the wetlands restoration.
Since the excavation and off-site disposal of all
contar:nated material under this alternative would result in
the r-_ oval of all contaminants above EPA's cleanup levels
and no contaminants would "remain above health-based levels,
the five-year remedy review would not be necessary. This
alternative would allow for unrestricted future use of the
29
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site without any institutional controls. •
Alternative 4: EXCAVATION/TREATMENT
Estimated Capital Cost: $38,131,000
Est. O&M Present Worth Cost: $9,000
Estimated Net Present Worth Cost: $38,140,000
Estimated Implementation Time: 18 months
Alternative 4 provides for the dismantling of the tank farms
and other structures on the IOC facility to facilitate the
excavation of the contaminated soil; dismantling the
floating product removal system; excavation of the estimated
83,000 cy of contaminated material and 5,000 gallons of
floating product; off-site disposal at a TSCA-permitted
landfill of an estimated 5,000 cy of the 83,000 cy of
material not amenable to treatment; and treatment of the
remaining material in an on-site hydro-metallurgical
extraction treatment system. The hydro-metallurgical
extraction process consists of two steps: (1) a soil
washing pretreatment step that cleans sand-sized particles
and (2) an extraction step that cleans fines. For this
treatment process, the remaining 78,000 cy of material would
be stockpiled and screened for removal of large debris. The
debris would be staged for transport to an off-site
landfill. After screening, the fine soil and sediment would
be then be treated in the hydro-metallurgical treatment
unit. Following treatment, the treated soil would be
supplemented with clean borrow soil and used to backfill the
excavated areas. The. sludge from the treatment system would
be disposed of off-site. The wetland areas affected by this
alternative, estimated to be 0.5 acres, will be restored
following the excavation and disposal activities. Operacicn
and maintenance activities would be performed on the
wetlands after completion of the wetlands restoration.
Since the excavation and disposal of the materials posing
the principal threat (hot spots) and treatment of the
remaining contaminated soil under this alternative would
result in the removal of all contaminants above EPA's
cleanup levels and no contaminants would remain above
health-based levels, the five-year remedy review would not - - .
be necessary. This alternative will allow for unrestricted
future use of the site without any institutional controls.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy, EPA considered the factors set out in - -
CERCLA §12l" [42 U.S.C. §9621], by conducting a detailed
analysis of the viable remedial alternatives pursuant to the ___
30
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NCP, 40 CFR §300.430 (e)(9) and OSWER Directive 9355.3-01.
The'detailed analysis consisted of an assessment of the
individual alternatives against each of the nine evaluation
criteria and a comparative analysis focusing upon the
relative performance of each alternative against those
criteria.
The following "threshold" criteria are the most important
and must be satisfied by any alternative in order to be
eligible for selection:
1. Overall protection of human health and the environment.
addresses whether or not a remedy provides adequate
protection of human health and the environment and
describes how risks .posed through each exposure pathway
are eliminated, reduced or controlled through
treatment, engineering controls, or institutional
controls.
2. Compliance with ARARs (Applicable or Relevant &
Appropriate Requirements) addresses whether a remedy
would'meet all of the applicable (legally enforceable),
or relevant .and appropriate (pertaining to situations
sufficiently similar to those encountered at a
Superfund site such that their use is well suited to
the site) requirements of federal and state
environmental statutes and requirements or provide
grounds for invoking a waiver.
The following "primary balancing" criteria are used to make
comparisons and to identify the major trade-offs between
alternatives:
3. Long-term effectiveness and permanence .refers to the
ability of a remedy to maintain reliable protection of
human health and the environment over time, once
cleanup goals have been met. It also addresses the
magnitude and effectiveness of the measures that may be
required to manage the risk posed by treatment
residuals and/or untreated wastes.
4. Reduction of toxicity, mobility or volume through
treatment refers to a remedial technology's expected
ability to reduce the toxicity, mobility, or volume of
hazardous substances, pollutants or contaminants at the
site.
5. Short-term effectiveness addresses the period of time
needed to achieve protection and any adverse impacts on
human health and the environment that may be posed
31
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during the construction and implementation period,
until cleanup goals are achieved.
6. Implementability refers to the technical and
administrative feasibility of a remedy, including the
availability of materials and services needed.
7. Cost includes estimated capital costs, operation and
maintenance costs, and the present worth costs.
The following "modifying" criteria are considered fully
after the formal public comment period on the Proposed Plan
is complete.
8. State acceptance indicates whether, based on review of
the RI/SGFS reports and the Proposed Plan, the State
concurs with, opposes, and/or has identified any
reservations with the selected alternative.
B. Community acceptance refers to the public's general
response to the alternatives described in the Proposed
Plan and the RI/FS-reports. Factors of community
acceptance to be discussed include support,
reservation, and opposition by the community.
A comparative analysis of the six remedial alternatives
(including Options A, B, and C for Alternative 2) relative
to the evaluation criteria noted above follows:
Overall Protection of Human Health and the Environment
Alternative 1, No Action, was developed as a baseline with
which to compare other alternatives. Because natural
attenuation is the only mechanism that could potentially
reduce concentrations of COCs in soil, implementation of
this alternative would result in continued risk to human
health and the environment for an undetermined period into
the future. Accordingly, this alternative has been
eliminated from consideration and will not be discussed
further.
Alternatives 2A, 2B and to a lesser extent 2C, would be
protective of human health and the environment. Each of the
alternatives includes removal of principal threat (hot-spot)
areas of contamination that could not be reliably contained
on-site, and containment of the remaining contaminated soil
exceeding remediation goals within an engineered cell (2A
and 2B) and/or containment in-place beneath an impermeable
cap (2C). Although contaminated soil exceeding remediation
goals would remain on-site under each of the options of
Alternative 2, placement within a cell and/or beneath an
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impermeable cap provides isolation from the environment, and
offers protection of both human health and environmental
receptors. Continued protection of human health and the
environment would be dependent on effective execution of a
maintenance program to maintain cap integrity and adherence
to a strict deed restriction to ensure the cap is not
breached in the future.
While 'Alternative 2C would be protective of human health
from the exposure pathways related to the contaminated soil
(incidental soil ingestion, dermal absorption and
inhalation), it is not fully protective of the ground water.
In Alternative 2C, contaminated soil exceeding remediation
goals would be in direct contact with the ground water,
which could contribute to the ground water contamination.
Alternative 3, Excavation/Off-site Disposal/Reuse, would be
protective of human health and the environment. All areas
of contamination exceeding remediation goals, not just the
principal threat (hot-spot) areas of contamination, would be
excavated and properly disposed of off-site. Therefore, all
exposure pathways to the site contamination would be
eliminated.
Alternative 4, Excavation/Treatment, would be protective of
human health and the .environment. All areas of
contamination exceeding -remediation goals would be excavated
and treated on-site to reduce the contaminant levels to meet
remediation goals before placement back on-site. The
principal threat (hot-spot) contamination would be properly
disposed of off-site." This would eliminate all exposure
pathways to the contamination similar to Alternative 3.
Compliance with ARARs
All of the alternatives could be designed to comply with
federal and state location-specific ARARs that regulate
excavation, filling, and discharge into wetlands and
floodplains. These alternatives could also be designed to
comply with action-specific ARARs associated with the
discharge of treated water, from soil dewatering, to Birch
Swamp Brook; employ engineering controls to comply with
federal and state air-quality standards for fugitive dust
from remedial activities; and comply with RCRA, TSCA, U.S.
Department of Transportation (DOT), and New Jersey hazardous
and solid waste regulations that apply to the transport and
disposal of waste material.
There are no chemical-specific ARARs for soil. However, EPA
has developed soil cleanup criteria, referred to as
remediation goals, that while not legally applicable, were.
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selected by EPA for the cleanup of on-site soils for the
site. In addition, because a portion of the site is
classified as wetlands, all alternatives would need to
comply with Section 404 of the Clean Water Act and federal
Executive Order 11990 which requires federal agencies to
take actions to minimize the destruction, loss, or
degradation of wetlands and to preserve and enhance the
natural and beneficial values of wetlands. A wetland
restoration and monitoring plan will be prepared as part of
the remedial design plan to address potential impacts to
wetlands under all alternatives.
Long-Term Effectiveness and Permanence
Alternative 4 provides the greatest long-term effectiveness
and permanence since the contaminated soils are excavated
and treated to meet remediation goals prior to backfilling
on-site. Treatment of soils exceeding remediation goals
would eliminate the need .for engineering and/or
institutional controls and long-term monitoring. For
Alternative 3, the excavation and off-site disposal/reuse of
che contaminated soil also provides long-term effectiveness
in eliminating future residual risk from the soil and also
would eliminate the need for engineering and/or
institutional controls at the site. However, it does not
provide zhe permanence that the Alternative 4 treatment
option provides because the contaminated soil is disposed of
ac off-site RCRA, TSCA, or special waste licensed landfills.
These licensed facilities effectively isolate the waste
materials such that future residual risks are negligible,
however long term maintenance at these facilities would be
required to assure protectiveness. Alternatives 2A, 2B, and
2C provide lesser long-term effectiveness and permanence
than Alternatives 3 and 4, but they- can effectively minimize
residual risk to publ .. z health and the environment as long
as the containment systems are properly maintained in the
fucure and institutional controls are enforced.
Reduction of Toxicity, Mobility or Volume Through Treatment
For Alternatives' 2 and 3, no treatment is proposed to reduce
tcxicity, mobility or volume except "for (1) the estimated
5,000 gallons of floating product expected to be recovered
during soil excavation, which would be destroyed by ,,
incineration at an appropriate TSCA-licensed incinerator,
and (2) the 8,000 cy of tank farm soil that is estimated to
exceed TCLP (Toxic Contaminant Leaching Procedure) threshold
criteria for RCRA-characteristic hazardous waste which would
be stabilized to reduce mobility of contaminants prior to ^
disposal in a secure landfill (either on-site under
Alternative 2 or off-site under Alternative 3). While no ^^
34
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treatment is proposed beyond thisV each of the alternatives,
provides a reduction in contaminant mobility for all other
contaminated material by containing the material in either
an off-site properly licensed landfill or an on-site
containment cell where contaminants are isolated from
environmental transport mechanisms. Under Alternative 4,
all soil exceeding -remediation goals (except an estimated
5,000 cy which would not be amenable to treatment) would be
treated using hydro-metallurgical extraction. Assuming an
estimated 78,000 cy of soil is treated, a volume reduction
of approximately 10% will leave an estimated 70,200 cy of
cleaned soil to be backfilled on-site and approximately .
7,800 cy of treatment sludge that would require off-sice
disposal as a hazardous waste at a properly licensed
landfill. -
Short-Term Effectiveness
Alternative 3 provides the greatest overall short-term
effectiveness primarily because the work can be completed in
the shortest period of time, an estimated 11 months from
site preparation to wetlands restoration. Alternatives 2C
and 4 are estimated to take 18 months to complete while
Alternatives 2A and 2B are estimated to require the longest
period of time to complete at 24 months.
Under each option of Alternative 2 and under Alternative 3,
(a) residences near the site would be affected by noise and
dust from remedial activities on the site and trucks hauling
material on and off-site, (b) short-term risks to site
workers would result primarily from dermal contact with
contaminated materials and inhalation of contaminated dust
during remediation, and (c) adjacent wetlands and Birch
Swamp Brook are at risk of impact by soil runoff during
excavation activities associated with the remediation. The
negative impacts to nearby residences can be mitigated by-
implementing engineering controls to reduce fugitive dust
and. limiting work to normal working hours. The short-term.
risks posed to site workers can be addressed by implementing
a site-specific Health & Safety Plan to minimize^exposure to
site contaminants.. The short-term impacts to adjacent
weclands and Birch Swamp Brook can be mitigated by
implementing proper controls in accordance with a site
specific Erosion and Sedimentation Plan to be developed
during the design of the remedy. In addition, any wetlands
that are disturbed during implementation of the remedy can
be restored after completion of the remediation.
Alternative 4 provides the least short 'term effectiveness
because, in addition, to the impacts posed by Alternatives 2
and 3, the soil Treatment plant would be operational 24
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hours per day and may cause a significant noise nuisance to
nearby residences. In addition, a large area of wetlands
would likely be adversely impacted during the implementation
of this alternative because of the limited space at the site
to construct the hydro-metallurgical treatment system,
including a temporary wastewater treatment plant rated for
300 gallons per minute and the associated waner storage
basin required for the water recirculation needs of the
treatment system.
Implamentability
Alternative 3 is considered the easiest alternative to
implement, because there are no significant technical or
administrative implementability concerns. Excavation and
disposal can be implemented with readily available equipment
and construction methods utilizing well-demonstrated
technologies. There exists sufficient capacity at off-site
landfills for disposal of the estimated quantities of RCRA
and TSCA regulated wastes. There are available soil
recycling facilities in the area and several construction
contractors in the region available to undertake the work.
Alternative 3 is considered a final remedy and no additional
remedial actions will be necessary once the remedial
alternative is implemented. Some implementability issues
for Alternative 3 are the same issues which are common to
all of the alternatives, namely, (a) the western edge of the
floating product is interpreted to be close to one of the
transmission towers which raises concerns regarding the
feasibility of using heavy equipment to.excavate under
electrical transmission lines and stability issues
associated with excavating near the foundation of the
transmission tower, ib) site access agreements would need to
be obtained to disturb, remediate, and restore this area as
well as the railroad embankment along the western boundary
of the site where contamination exists, and- (c) tank farms,
and other structures would need to be dismantled. These
issues could be resolved during the design of the remedy.
Alternatives 2A, 2B, and 2C are similar to Alternative 3
with regard to the manageable technical implementability
concerns because containment technology equipment and
methods are well-demonstrated and readily available.
However, in addition to the common administrative
implementability concerns described above, all of the
options of Alternative 2 require substantial restrictions to
the future use of the site in order to protect the waste
containment systems that would be constructed. Also, a
continual maintenance program to insure the integrity of the
cap, continual future monitoring of the effectiveness of the
i-emedy, and continual operation and maintenance of the
36
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leachate collection systems (under Alternatives 2A & 2B) are
implementability issues unique to Alternative 2.
There are numerous logistical concerns related to the
implementation of Alternative 4. In order to create
adequate space for all of the components of the treatment
system plant building and stockpiled/soil handling areas,
contaminated soil in the way of the treatment plant
construction would have to be excavated and stockpiled
elsewhere on the site. The only available space on the
IOC./CC property for these facilities would likely be in
uncontaminated areas south or east of the Fire Pond which
lie within the 100-year floodplain and would result in
adverse impact to additional wetland areas. Special design
features would need to be incorporated into the treatment
plant design to mitigate the potential for inundation of the
plant by flood waters and the associated release of
hazardous substances into the environment.
Although treat-ability studies on petroleum-contaminated soil
have indicated that hydro-metallurgical extraction may be
effective for removing organic contaminants from soil, it
has not been demonstrated beyond bench-scale testing. To
demonstrate the effectiveness of the hydro-metallurgical
extraction technology to treat soil with both inorganic and
organic contamination, additional treatability studies would
be required. ' "~-
Cost
The capical, annual operation and maintenance (O.&M) , and
present worth costs are presented in Table 10. Present
worth costs for all the alternatives were calculated
assuming a 5% interest rate and a 30-year O&M (where
applicable). .
For Alternative 1, No Action, there is no capital cost
associated wich the alternative. The O&M costs calculated
for this alternative provide for periodic sampling, of ground
water and sediment adjacent to the site to monitor off-site
contaminant migration. The assumed monitoring program
includes quarterly sampling in year 1, bi-annual sampling
during years 2-5, and annual sampling during years 6-30.
The present worth cost of this sampling program is $295,000.
The capital cost for Alternative 2A is $14,942,000,
including the construction of a three acre containment ceil
with bottom liner and mitigation of an estimated 0.5 acres
of wetlands. The present worth costs for 30 years of O&M
associated wich monitoring and maintaining the containment
system, including the installation of three ground water
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monitoring wells, is $483,000.
The capital cost for Alternative 2B is $15,514,000,
including the construction of a 5.5-acre containment cell
with a bottom liner and mitigation of an estimated 0.5 acres
of wetlands. The present worth costs for 30 years of O&M •
associated with monitoring and maintaining the containment
system, including the installation of three ground water
monitoring wells, is $563,000.
The capital ccst for Alternative 2C is $13,111,000,
including the construction of a four-acre containment cell
with no bottom liner and mitigation of an estimated 0.5
acres of wetlands. The present worth costs for 30 years of
O&M associated with monitoring and maintaining the
containment system, including the installation of three
ground water monitoring wells, is $387,000.
The capital cost for Alternative 3 is $17,210,000. This
includes all excavation and off-site disposal costs
associated with this alternative, as well as mitigation of
an estimated 0.5 acres of wetlands. Since all soils will be
remediated to meet residential use standards, and all
floating product will be removed, there are no G&M .costs
planned.
The capital cost for Alternative 4 is $38,140,000. This
includes the cost of all excavation and treatment of the
contaminated soil on-site (except for the estimated 5,000 cy
of soil/waste pile material not amenable to treatment and
5,000 gallons of floating product requiring off-site
disposal) and backfilling the excavated areas with treated
soil. This alternative also includes the mitigation of an
estimated 0.5 acres of wetlands. Since all soils will be
remediated to meet residential use standards, and all
floating product will be removed, there are no O&M costs
planned.
On a comparative basis, the total costs for Alternative
4($38,140,000) are significantly greater than the total
costs for Alternatives 2A ($15,425,000), 2B ($16,077,000),
2C ($13,498,000) and 3 ($17,210,000). When comparing the
Alternative 2 options to Alternative 3, Alternative 2A costs
90% as much as Alternative 3, Alternative 2B costs 93% as
much as Alternative 3, and Alternative 2C costs 78% as much
as Alternative 3.
State Acceptance
NJDEP concurs with EPA's selection of Alternative 3
(Excavation/Off-site Disposal/Reuse) as the preferred
0
-------
remedy. It is noted that the remediation goals for the
contaminants found at this site were developed by EPA to
meet EPA's unrestricted use criterion. while NJDEP's
unrestricted use criterion for the contaminants found at the
site are in some cases more stringent than EPA's (i.e.,
NJDEP's criterion for PCBs is 0.49 ppm compared to EPA's 1.0
ppm), the state's assessment of the data indicates
implementation of the remedy utilizing EPA's remediation
goals will also achieve NJDEP's remediation goals for
unrestricted use. However, if applicable, the. State agrees
to fund all additional costs incurred during remedial action
due to the application of NJDEP's more stringent cleanup
criteria for any contaminant.
Community Acceptance
Community acceptance was evaluated after the close of the
public comment period. Written comments received during the
public comment period, as well as verbal comments during the
public meeting were evaluated.
The majority of comments received during the public comment
period reflected the community's request that the site be
remediated to allow for unrestricted future use of the
property. The.community was otherwise supportive of the
selected remedy.
The current owner of the IOC/CC property and che current
operator of che IOC/CC facility are opposed to the decision
to excavate the majority of the contamination. They
recommend a remedy that includes an evaluation of vacuum
enhanced product removal to address the floating product and
installation of a modified cap over the soil.
The attached Responsiveness Summary (Appendix C) addresses
each of the comments received during the public comment
period.
PRINCIPAL THREAT WASTES
For OU3, the principal threat wastes are highly toxic and/or
mobile materials at the site. They include:
- waste filter clay materials;
- TSCA-regulated materials;
- Floating product; and
- contaminated soils underlying Tank Farms 1, 2, 3,
and 4 .
39
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SELECTED REMEDY
Based upon consideration of the results of the RI/SCFS, the
requirements of CERCLA, the detailed analysis of the
alternatives, and public comments, EPA and NJDEP have
determined that Alternative 3 - Excavation/Off-site
Disposal/Reuse is the appropriate alternative for
remediating contaminated soil and floating product.
Alternative 3 best satisfies the requirements of CERCLA
§121 and the NCP's nine criteria for evaluating remedial
alternatives, 40 CFR §300.430 (e)(9).
Alternative 3 is comprised of the following components:
4 Excavation of an estimated 83,000 cubic yards of soils
containing contaminants above the selected remediation
goals and disposal of this material at appropriate off-
site facilities.
t Transportation cf an estimated 27,000 cubic yards of
the soils which pose the principal threat (hot spots)
to a RCRA/TSCA hazardous waste disposal facilities. An
estimated 19,000 cubic yards of this soil will'be
transported to a TSCA-permitted landfill and the other
8,000 cubic yards to a RCRA-permitted landfill for
disposal, where it will receive appropriate treatment
in accordance with RCRA requirements.
* Transportation of an estimated 56,000 cubic yards cf
soils containing contaminants above the selected
remediation goals to an appropriate landfill. A
portion of this material may be recycled as asphalt
base material.
4 Removal of an estimated 5,000 gallons of floating
product via vacuum truck and transportation of this
material to a TSCA licensed incinerator.
4 Dismantling of site buildings and tank farms, as
necessary to complete the selected soil excavation and
floating product removal.~
* Backfilling of all excavated areas with clean fill.
* Restoration of the wetlands affected by cleanup
activities.
The selection of Alternative 3 is based upon the comparative
analysis of alternatives described above and provides the
best balance of tradeoffs with respect to the nine
evaluation criteria.
40
-------
Alternative 3 is protective of human health and the
environment, and can be performed in compliance with the
chemical-specific cleanup criteria selected by EPA along
with all other Federal or State requirements that are
applicable or relevant and appropriate to this action.
These include those ARARs that regulate: (a) excavation,
filling, and discharge into wetlands and floodplains,- (b)
discharge of treated water to Birch Swamp Brook resulting
from any dewatering necessary during excavation; (c) air-
quality standards for fugitive dust during excavation; and
(d) transportation and disposal of solid and hazardous
waste.
Alternative 3 provides better short-term effectiveness than
Alternative 4 and provides the best long-term effectiveness
along with-Alternative 4 (at less than one-half the cost of
Alternative 4) because there is no long-term maintenance or
monitoring of the integrity of the capping systems as
required under the Alternative 2 options. While the
Alternative 2 options rank highest in short-term
effectiveness compared to Alternative 3 because of the
increased volume of material transported off-site over
public roads and the potential increased risk posed by this
transportation, this increased risk, is not considered
substantial and all precautions required under Federal .and
State transportation laws will be complied with.
While Alternative 4 ranks highest in the Reduction of
Toxicity, Mobility or Volume criteria and is a more
permanent remedy than Alternative 3, the cost differential
is too substantial to justify the incremental benefit under
these criteria. Alternative 3 ranks equal to the
containment options of Alternative 2 with regard to the
Reduction of Toxicity, Mobility or Volume criteria and ranks
higher than any of the Alternative 2 options under the
permanence criteria when considering the site itself.
Alternative 3 is cost effective as compared with the other
alternatives, especially the Alternative 2 options.
Alternative 3 is also considered the most implementable of
all of the alternatives. Excavation and disposal can be
implemented with readily available equipment and
construction.methods utilizing well-demonstrated
technologies. There exists sufficient capacity at off-site
disposal facilities for all of the various waste mixtures
involved, both hazardous and non-hazardous. Tank farms and
other structures will need to be dismantled prior to
excavation. In particular, the Masonry Building, as
mentioned above, is abandoned and is in danger of collapse.
This building is likely to be dismantled as an early action,
during .remedial design activities.. Alternative 3 is
considered a final remedy and no additional remedial actions
41
-------
will be necessary once the remedial alternative is
implemented. The affected wetland areas will be restored
following the excavation and disposal activities.
STATUTORY DETERMINATIONS
As was previously'noted, CERCLA §121(b)(l) mandates that a
remedial action must be (a) protective of human health and
the environment, (b) cost-effective, and (c) utilize
permanent solutions and alternative treatment technologies
or resource recovery technologies to the maximum extent
practicable. Section 121(b)(l) also establishes a
preference for remedial actions which employ treatment to
permanently and significantly reduce the volume, toxicity,
and mobility of the hazardous substances, pollutants, or
contaminants at a site. CERCLA §121(d) further specifies
that a remedial action must attain a degree of cleanup that
satisfies ARARs under federal and state laws, unless a
waiver can be justified pursuant to CERCLA § 121(d)(4).
For the reasons discussed below, EPA and NJDEP have
determined that the selected remedy meets the requirements
of CERCLA §121.
Protection of Human Health and the Environment
The selected alternative (Alternative 3 - Excavation/Off-
site Disposal/Reuse) is protective of human health and the
environment and deals effectively with the threats to human
health and the environment posed by the contaminants that
exist at this site. All areas of contamination exceeding
EPA's remediation goals for unrestricted use will be
excavated and properly disposed of off-site.
Compliance with ARARs
The selected remedy will achieve compliance with all
chemical-specific, action-specific, and location-specific
ARARs that regulate excavation, filling, and discharge into
wetlands and floodplains. There are no chemical-specific
ARARs for soil. EPA has developed guidances, that while not
legally enforceable, were considered by EPA in establishing
cleanup levels (remediation goals) for the site.
The selected remedy will comply with action-specific ARARs
associated with the discharge of treated water to Birch
Swamp Brook; employ engineering controls to comply with
federal and state air-quality standards for fugitive dust
from remedial activities; and comply with RCRA, TSCA, U.S.
Department of Transportation (DOT), and New Jersey hazardous
and solid waste regulations that apply to the transport and
42
-------
disposal of waste material.
Location-specific ARARs for the selected remedy include:
Executive Order 11990 (Wetlands Protection); the Wetlands
Construction and Management Procedures (40 CFR, Appendix A);
and Executive Order 11988 (Floodplain Management). Since a
portion of the site is classified as wetlands, the soil
remedy needs to comply with Section 404 of the Clean Water
Act and federal Executive Order 11990 which requires federal
agencies to take actions to minimize the destruction, loss,
or degradation of wetlands and to preserve and enhance the
natural and beneficial values of wetlands. Any actions
which disturb or impact wetlands would additionally require
development of a wetland mitigation plan.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
The selected remedy utilizes permanent solutions and
alternative treatment (or resource recovery) technologies to
the maximum extent to which permanent solutions and
alternative treatment technologies can be utilized in a cost
effective manner at the IOC/CC site. Some of the material to
be addressed through the selected remedy will be addressed
by permanent solutions and/or resource recovery solutions.
Specifically, the estimated 5,000 gallons of floating
product will be permanently destroyed by incineration at a
TSCA-licensed incinerator. In addition, some of the soil
may be eligible for soil recycling in a permitted asphalt -
batch plant. Further, an estimated 8,000 cubic yards of the
site's most contaminated soils will receive stabilization.
treatment to reduce the mobility of contaminants prior to
disposal in a secure landfill. While the remaining material
will not receive any treatment, a reduction in contaminant
mobility will be achieved by containing the material off-
site in a properly licensed secure landfill.
Preference for Treatment as a Principal Element
The selected remedy utilizes treatment as a principal
element to the maximum extent practicable. As previously
indicated, the complex nature of the.waste material at the
site with elevated levels of both organics and inorganic
contaminants, and the limited space on site to construct a
treatment plant limit the cost effectiveness and
implementability of the on-site treatment technologies
available that would treat all the waste. However, part of
the principal threat waste, that is the floating product,
will be incinerated at a TSCA-licensed incinerator. In
addition, an estimated 8,000 cubic yards of the principal
threat soils will receive stabilization treatment to reduce
the mobility of contaminants prior to disposal in a secure
43
-------
landfill. Although the selected remedy will treat a portion
of the principal threat materials, most of the contaminated
soils will be disposed of in a landfill. Therefore, the
selected remedy does not satisfy the statutory preference
for remedies that employ treatment as a principal element.
Cost-Effectiveness
Alternative 3, the selected remedy, affords the highest
level of overall effectiveness proportional to its cost.
The treatment alternative, Alternative 4, at a cost of
$38,131,000 is over twice as expensive as the selected
alternative ($17,201,000) and compares more favorably than
the selected alternative in only one of the nine criteria
(Reduction of Toxicity, Mobility, or Volume). While the
various containment alternatives (Alternatives 2A, 2B and
2C) are slightly less costly (ranging from 78% to 93% of the
cost of Alternative 3), they do not rank more favorably than
the selected alternative in any of the nine evaluation
criteria.
DOCUMENTATION OF SIGNIFICANT CHANGES
During the public comment period for the Proposed Plan
(February 19, 1999 through April 6, 1999), extensive comment
requesting that EPA and NJDEP reconsider the soil cleanup
objectives for this operable unit were received.
Specifically, a number of commentors recommended that the
proposed cleanup criteria for PCBs, which was the EPA-
developed industrial use standard of 13 ppm, be revised to
allow for unrestricted future use of the site. These
comments were made both verbally at the public meeting and
in writing. The commentors included local elected
officials, local health officials, community members, a
community environmental group and technical experts
representing the community.
Despite the fact that the land use of the site property
currently is industrial, residential properties and
ecologically sensitive resources border the site. As some
of the commentors pointed out, a review of the remedial
investigation data indicates that the selected remedy may
achieve unrestricted (residential) future use cleanup
criteria for PCBs by default, based on the spacial
distribution of contaminants. Accordingly, the agencies
have agreed to modify the proposed remediation goals which
were derived based on future industrial use of the property
to remediation goals that will be protective, if the property
were used in the future for residential purposes. This
change does not affect the cleanup standard for every
contaminant (see Table 9 for the list of selected
44
-------
remediation goals). Note that this modification changes the
proposed remediation goal for PCBs from 13 ppm to a selected
remediation goal of 1 ppm.
This modification of certain remediation goals to meet
residential use criteria is not expected to significantly
increase the costs to implement this remedy. Since meeting
residential use standards will allow for unrestricted future
use of the site, only a minor amount of O&M related to the
restored wetlands will be required. A five year review of
the selected remedy will not be required.
While NJDEP's unrestricted use criterion for the
contaminants found at the site are in some cases more
stringent than EPA's (i.e., NJDEP's criterion for PCBs is
0.49 ppm compared to EPA's 1.0 ppm), the state's assessment
of the data indicates implementation of the remedy utilizing
EPA's remediation goals will also achieve NJDEP's
remediation goals for unrestricted use. However, if
applicable, the State agrees to fund all additional costs
incurred during remedial action due to the application^of
NJDEP's more stringent cleanup criteria for any contaminant.
45
-------
-------
FIGURES
-------
-------
FIGURE I
Site Location Map
IOC/CC
SUPERFUND SITE
Marlboro
Airport
Morganville
NodoScato
-------
/ j#5n~~
PRIVATE HOMES
o
LEGEND
•>" » EXTEHT OF PAVED AREA
SCALE
Figure 2
SCHEMATIC LAYOUT OF
IMPERIAL OIL CO. FACILITY
IMPERIAL OIL/CHAMPION CHEMICALS SITE
I200 r«T WORGANVILLE, NEW JERSEY
._ ECJORDANCQ'
-------
FIGURE 3
OU -I OFF-SITE SOILS LOCATION MAP
Off-site Areds 1 & 2
Approximate
ScatonFoel
D
Imperial Oil
Company Facility
Legend
|~"1 IOC Building
• Tank Farm
[7771 OU-1 Off-site Soil
Contamination
-------
•Wf MX Mt. UWU
.ttC.JMMK.IMII
DISTRIBUTION OF VOC« IN
ON-SITE SURFACE SOIL SAMPLES
TE
Figure 4
-------
DISTRIBUTION OF VOC* IN
ON-iilTE SUBSURFACE SOIL SAMPLES
ERIAL (ML/CHAMPION CHEMCALS SITE
MORGANVK.LE, NEW JERSEY
ECJORDANOQ
Figure 5
-------
o
3
"i •Sr=is &!i:"?
CMxfV^Sx P
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i
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Figure 7
-• f P-J . .niB-'iTH ^ i ) A A^ // /jli.lS*-': '--."'
L W PaUOMWa CONCtNltMIXM
MKtttMOO
EX. JOMDAH tM*|
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Figure 8
K. ,» .v frfrsTSUNI v /^ U_•• r ^-" -S7'// " XI^
^s^^W<^<^Ww^ |//i( rfni
^^h^HHSfVV / 7^1i-- w>»••'"-"a! '' // C
ffiBqSTOffiyff -g^te|
' »J**!?'1*11 "I"*—~"LS - "L*i N / 'l**oi>P TJIB.I33 I ~ frf>«lj2tW~Ml™"hO
y !!2 IlILJ ' J yV-'^IJ«W HI) L. — >^"«rrx
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Figure 9
^ygs-'^t^"1. ir'/^^vT^*5) ^/x
^fep3;T^^^^9/^ £
^^r^L \""t\W^ M7/ ^ ^T
LEGEND
,„„ "• BS5BU«—«»
_y Jf JIB iru miiofwo
X' V ICOMPtETEO •* t C JO«*A". I
* ^ V is
ML CONCCNIfUUIOM « •
DISTRIBUTION OF TPH
IN ON-SITE SUBSURFACE SOU. SAMPLES
IMPERIAL OIL/CHAMPION CHEMICALS SITE
MORGANVtLLE, NEW JERSEY
. ECJORDANCQ-
-------
Figure 10
IN ON-SI1E SURPACE SOU -5AMPI £S
IMPERIAL OIL/CMAMPIOC CHEMICALS ?tl£
MOriGANVlLLE, NEW JERStv
•—• — ECJOKLWNOJ -
.*'
-------
Figure 11
?^t^^\>j;.?,122 pcfefxN-
\^ m-m is-.ir iff ir / ?•? f* -A' w .
» IK- ( JIB 112,* 4IIIH i« UK
i / ^- - <«s i«s \ . «r — —
f fc >• ti v ___^ p'»L *• ?« tj /
t e»ICBn«10««Of
HDKUMCt WIM FU SOUtH W
M m K»» «• ncifiireo H
DISTRIBUTION OF INORGANICS
IN ON-'ilTE SUBSURFACE SOH. SAMPLES
MIPERIAl OIL/CHAMPION CHEMICALS SITE
MORQANVLLE, NEW JERSEY
ECJORaWCQ-
-------
Figure 12
WSTRffiUTION OF PESTICIDES
IN ON-SITE 3CML SAMPLES
IMPERIAt OM./CHAMPION CHEMICALS SITE
MOHGAHVILLE, NEW JERSEY
-------
/^"~-O> • nil iii// Jin |4« /\/ iu—•'"
—-. MO HO b JTH-ljl/^ ( JTO-lJf f TJ\
^L_—. "° •fc^j.unnimi •• 4 /TXisV^
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.-^^ii..« .^<^,t£:^Wj 4"z» %™%&
*^"»- i^^j^TTvf^^"" ^^
OM-SITE SUBSURFACE SOIL SAMPLES
IMPERIAL OL/CHAMFIOM CHEMKALS SITE
IwtHIAL U^'MOROAHVILE> mv JERSEY
-------
Figure 14
U-CU4MI
Cr-CMtOUUH
te-ccmM
r».uuo
.
I IWOUUFCRVItUCDFOII
PHUCI JO DO*OH OOMCtNTAA I
(cavuno •« tc. jncuw. IHO
DISTRIBUTION OF IMORGAMCS
IN SUBSURFACE SOH. SAMPLES
FILL SOUTH OF THE FIRE POND
IMPERIAL OIL/CHAMPION CHEMICALS SITE
MORGANVttXE, NEW JERSEY
E.CJORDANCQ
-------
Figure 15
" > Y ' ' / V-' ->AA r=
••V" / ' -OfJ-SITE / -Vlf '• V\\> /
/ . Afl-M -\°- •, > / i v j£*as. /.
••i^[v^^Vi4^»iB&a^^?c
-s "/'it -•V'^X / L StMtS 0** THe »ANK W \ %'n ' X
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AREAS OF SOIL INVESTIGATION
IMPERIAI. OIL/CHAMPION CHCMKAI.S
MORGANVILLE, NEW JERSEY
-------
FIGURE 16
OU-3 DISTRIBUTION OF FLOATING PRODUCT
D
Imperial Oil
Company Facility
Approximate
Orchard Place
IOC Building
Tank Farm
Floating
Product
-------
< LS\. .//?
t\ y/
II I. Si1-1
ii »! ^\ v Ui '
IiJ\^! ll HJ;j\\\ 1
/f c^ \"^
y * °<-A*^
<^>+. -\v
125
««8
fill
I "Si
h-5-
tiiii
1:111
111}'
11
1 i j '
w
-------
-------
TABLES
-------
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Table 1
Summary of Results of Floating Product Analysis
December 1996
Parameter Concentration (ppb)
Benzene 3,840
1,2-Dichlorobenzene 21,900
Ethylbenzene 48,400
Tetrachloroethylene 46,100
Toluene 1,460,000
Trichloroethylene 8,730
Total Xylenes 188,000
Butyl Benzyl phthalate 672,000
Di-n-butyl phthalate 88,300
Fluorene 14,800
Napthalene 147,000
Phenanthrene 48,300
1,2,4 Trichlorobenzene 78,700
Arsenic . 3,600
Lead 15,300
PCBs 409,000
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Table 2
Data Gap Investigation Results
Chemical Detected in the
Soils in Tank Farm No. 1
Chemicals
Volatile Organics
Acetone
Semi-Volatile Organics
Di-n-Butylphthalate
Bis(2-Ethylhexyl)phthalate
Pesticide/PCBs
Alpha-BHC
Heptachlor
Aldrin
Heptachlor epoxide
Endosulfan I
4,4-DDE
Edrin
Endosulfan II
4,4-ODD
Endosulfan Sulfate
4,4-DDT
Edrin ketone
Edrin aldehyde
Alpha-Chlordane
Gamma-Chlordane
Arochlor-.1248
Arochlor-1260
Inorganics/TPHC
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Copper
Iron
Lead
Concentration Range
(ppm)
51
610
330
2.5-95
2.4-19
1.8-45
17
7.2-7.5
2.8-23
7.2
2.4-15
4-6.1
17
21
2.2-2.8
12-25
1.6-12
3.2
1100
120-900
810
2.7-486
4.7
0.1-8.8
67.8
2.8
2 .5
1900
2.5-353
Page 1 of 18
-------
Chemicals
Table 2
Data Gap Investigation Results
Chemical Detected in the
Soils in Tank Farm No. 1 (con't)
Inorganics/TPHC (con't-)
Magnesium
Manganese
Nickel
Potassium
Vanadium
Zinc
Total Petroleum Hydrocarbon (TPHC)
Concentration
(ppm)
Range
65 . 6
4.1
0.87
134
2.8
8.9
130-37000
Page 2 of 18
-------
Table 2
Data Gap Investigation Results
Chemical Detected in the
Soils in Tank Farm No. 2
Chemicals
Volatile Qrqanics
Acetone
Tetrachloroetbene
Toluene
Ethylbenzene
Xylene (total)
Pesticide/PCBs
Alpha-BHC
Beta-BHC
Delta-BHC
Gamma-BHC (Lindane)
Heptachlor
Aldrin
Heptachlor epoxide
Dieldrin
4,4-DDE
Edrin
Endosulfan II
4,4-DDD
4,4-DDT
Edrin ketone .
Edrin aldehyde
Alpha-Chlordane
Gamma-Chlordane
Arochlor-1242
Arochlor-1260
Inoraanics/TPHC
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Concentration Rang**
(ppm)
210
40
45
31
140
37-310
26-240
1.9-15.
10-82
8.2-26
8.8-31
1.6-22
11-28
2.6-71
14-70
6.4-300
14
2.4-140
60
10-170
1.9
1.1
3000-5800
1600-8000
3660
1.1
7.8-216
301
1.3-6
0.45
2230
Page 3 of 18
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Table 2
Data Gap Investigation Results
Chemical Detected in the
Soils in Tank Farm No. 2 (con't)
Chemicals
Inoraanics/TPHC (con't)
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Vanadium
Zinc
Total Petroleum Hydrocarbon (TPHC)
Concentration Range
(ppm)
48.4
21
286
11900
328-500
752
98
0.08
88.8
284
1.3
0.35
425
8.9
1120
16000-55000
Page 4 of 18
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Table 2
Data Gap Investigation Results
Chemical Detected in the
Soils in Tank Farm No. 3 & 4
Chemicals
Volatile Oraanics
Acetone
Trichloroethene
Tetrachloroethene
Toluene
Ethylbenzene
Xylene (total)
Semi-Organics
Napthalene
2-Methylnaphtalene
Bis(2-Ethylhexyl)phthalate
Pesticide/PCBs
Alpha-BHC
Beta-BHC
Delta-BHC
Gamma-BHC (Lindane)
Heptachlor
Aldrin
Heptachlor epoxide
Endosulfan I
Dieldrin
4,4-DDE
Endrin
Endosulfan II
4, 4-ODD
Endosulfan Sulfate
4,4-DDT
Edrin ketone
Edrin aldehyde
Alpha-Chlordane
Gamma-Chlordane
Arochlor-1242
Arochlor-1260
Concentration Range
(ppm)
22
6
17
42
96
2400
5000
1200
2.0-2.5
3 .0
1.4-33
11-15
1. 9-17
5.9-8.4
3.1-17
2.1-37
4.9-86
4 . 1 - 5.4
2.1-19
5.7-120
3.3-40
8.6-150
2.1-27
4.5-27
190-2500
120-2800
Page 5 of 18
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Table 2
Data Gap Investigation Results
Chemical Detected in the
Soils in Tank Farm No. 3 & 4 (con't)
Chemicals
Inorganics/TPHC (con't_
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Total Petroleum Hydrocarbon (TPHC)
Concentration Rang**
(ppm)
4410
7.4-6120
38.8
0.19-0.47
0.26
1470
22.8
2.3
36.8
18400
2-3720
923
34.5
0.04
22.3
645
93.3
0.59
24.6
45
73-72000
Page 6 of 18
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Table 2
Data Gap Investigation Results
Chemical Detected in the
Soils Beneath On-site Paved Areas
Chemicals
Volatile Organics
Acetone
Carbon Bisulfide
1,2 Dichloroethane
Chloroform
2-Butanone
Trichloroethene
4-Methyl-2 -Pentanone
Tetrachloroethene
Toluene
Ethylbenzene
Xylene (total)
Semi-Organics
Napthalene
2-Methylnaphtalene
Di-n-Butylphthalate
Bis(2-Ethylhexyl)phthalate
Pesticide/PCBs
Alpha-BHC
Beta-BHC
Delta-BHC
Gamma-BHC (Lindane)
Heptachlor
Aldrin
Heptachlor epoxide
Endosulfan I
Dieldrin
4,4-DDE
Endrin
Endosulfan II
4,4-DDD
Endosulfan Sulfate
4,4-DDT
Concentration Range
(ppm)
64-660
6-9
4
2
53-110
680-1200
56-58
35-40
19
130
320-520
380
6.0-72
1.1-5.5
3 .4-11
1.8
1.8-7.7
2-3.1
1.1-17
1.8-6.2
5.6-8.2
3.5-14
4.2-50
2.4-7
4.4
2.5-48
Page 7 of 18
-------
Table 2
Data Gap Investigation Results
Chemical Detected in the
Soils Beneath On-site Paved Areas (con't)
Chemicals
Concentration Range
(ppm)
Pesticide/PCBs
Edrin ketone
Edrin aldehyde
Alpha-Chlordane
Gamma-Chlordane
Arochlor-1242
Arochlor-1260
Inorganics/TPHC
Aluminum
Ant imony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium ,
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Total Petroleum Hydrocarbon (TPHC)
3.6-9.3
6.6-35
1.2-7.2
1.4-1.9
190-2500
85-1500
1290-8250
1.6-619
9.2-162
0.06-0.95
0.12-0.40
188-1570
5.5-22.6
0.91-10.8
3.7-25.8
10100-21900
1.3-253
69.9-679
4.6-26.9
0.04-734
1.2-14.1
264-2320
0.75-1.7
121
1.2
12.2-54.9
12-36
43-19000
Page 8 of 18
-------
Table 2
Data Gap lixvestigatibn Results
Chemical Detected in the
Fill Soils South of the Fire Pond
and
Tank Disposal Area
Chemicals Concentration Range
(ppm)
Volatile Oraanics
Acetone 27
Carbon Disulfide
1,2 Dichloroethane ~
Chloroform
2-Butanone
Trichloroethene
4-Methyl- 2 -Pentanone
Tetrachloroethene " • -
Toluene
Ethylbenzene
Xylene (total) -
Semi-Organics
Napthalene ~
2-Methylnaphtalene ~
Di-n-Butylphthalate
Bis(2-Ethylhexyl)phthalate
Pesticide/PCBs
Alpha-BHC
Beta-BHC ~ .
Delta-BHC . • ' - .
Gamma-BHC (Lindane) ~ ••
Heptachlor
Aldrin
Heptachlor epoxide • !-4
Endosulfan I 1.4-2.6
Dieldrin . ~
4,4-DDE 4-7
Page 9 of 18
-------
Table 2
Data Gap Investigation Results
Chemical Detected in the
Fill Soils South of the Fire Pond
and
Tank Disposal Area (con't)
Chemicals Concentration Range
(ppm)
Pesticide/PCBs (con't)
Endrin 2.9
Endosulfan II 7.0
4,4-DDD 1.9-13
Endosulfan Sulfate
4,4-DDT 36
Edrin ketone
Edrin aldehyde 4.2-18
Alpha-Chlordane
Gamma-Chlordane
Arochlor-1242
Arochlor-1260 26-260
Inorganics/TPHC
Aluminum 9990
Antimony - .
Arsenic 3.4-24.7
Barium 56
Beryllium 0.6-1.2
Cadmium 0.16
Calcium 2550
Chromium 21.5
Cobalt .17.5
Copper 16.5
Iron 19400
Lead 5.2-50.2
Magnesium 2930'
Manganese , 503
Mercury
Nickel 26
Potassium 3360
Page 10 of 18
-------
Table 2
Data Gap Inveatigation Results
Chemical Detected in the
Pill Soils South of the Fire Pond
and
Tank Disposal Area (con't)
Chemicals
Inorcranics/TPHC (con't)
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Total Petroleum Hydrocarbon (TPHC)
Concentration Range
(ppm)
118
38.3
100
49-98
Page 11 of IS
-------
Table 2
Data Gap Investigation Results
Chemical Detected in the
Near Old Warehouse
Chemicals
Volatile Oraanics
Acetone
Carbon Disulfide
1,2 Dichloroethane
Chloroform
2-Butanone
Trichloroethene
4-Methyl-2 -Pentanone
Tetrachloroethene
Toluene
Ethylbenzene
Xylene (total)
Semi-Organics
Nap"halene
2-Methylnaphtalene
Di-n-Butylphthalate
Pyrene
Bis(2-Ethylhexyl)phthalate
Pesticide/PCBs
Alpha-BHC
Beta-BHC
Delta-BHC
Gamma-BHC (Lindane)
Heptachlor
Aldrin
Heptachlor epoxide
Endosulfan I
Dieldrin
4,4-DDE
Endrin
Endosulfan II
Concentration Range
(ppm)
160
2400
5000
28-140
130
21-71
6.1-25
12-47
28-120
32-66
Page 12 of 18
-------
Table 2
Data Gap Investigation Results
Chemical Detected in the
Near Old Warehouse (con't)
Chemicals
Pesticide/PCBs (con't)
Concentration Range
(ppm)
4,4-ODD
Endosulfan Sulfate
4,4-DDT
Endrin Ketone
Endrin Aldehyde
Alpha-Chlordane
Gamma-Chlordane
Arochlor-1242
Arochlor-1248
Arochlor-1254
Arochlor-1260
Inorganics/TPHC
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
4.4-7.6
33-110
15-22
20-36
11-72
2.6-98
1300-9900
3000
940-1900
4360
115-368
17
0.21-0.44
0.19
946
29.6
8.5
17.2
13200
10.8^44.7
290
16 .6
8 .7
839
Page 13 of 18
-------
Table 2
Data Gap Investigation Results
Chemical Detected in the
Near Old Warehouse (con't)
Chemicals
Inorganics/TPHC (con't)
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Total Petroleum Hydrocarbon (TPHC)
Concentration Range
(ppm).
80.9
35.2
17.3
6500-40000
Page 14 of 18
-------
Table 2
Data Gap Investigation Results
Chemical Detected in the
Southwest of Parking Area
Concentration Range
Chemicals (ppm)
Volatile Qraanics
Acetone
Carbon Disulfide
1,2 Dichloroethane
Chloroform
2-Butanone
Trichloroethene ~
4-Methyl-2-Pentanone ,
Tecrachloroethene
Toluene
Ethylbenzene
Xylene (total)
Semi-Organics
Napthalene
2-Methylnaph.talene
Di-n-Butylphthalate
Bis(2-Ethylhexyl)phthalate
Pesticide/PCBs
Alpha-BHC . ' "
Beta-BHC
Delta-BHC
Gamma-BHC (Lindane)
Heptachlor
Aldrin -^ s '
Heptachlor epoxide
Endosulfan I
Dieldrin
4,4-DDE
Page 15 of 18
.
-------
Table 2
Data Gap Investigation Results
Chemical Detected in the
Southwest of Parking Area (con't)
Chemicals
Pesticide/PCBs (con't)
Endrin
Endosulfan II
4,4-DDD
Endosulfan Sulfate
4,4-DDT
Edrin ketone
Edrin aldehyde
Alpha-Chlordane
Gamma-Chlordane
Arochlor-1242
Arochlor-1260
Inorganics/TPHC
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium '
Zinc
Total Petroleum Hydrocarbon (TPHC)
Page 16 of 18
Concentration Range
(ppm)
12200
0.89
9-17.6
32.1
0.39-1.1
0.14
649
19.8
1.2
14.3
22200
1-25.2
616
18.5
1.9
1320
50
20
44-120
-------
Table 2
Data Gap Investigation Results
Chemical Detected in the
Outside Northwest Fenceline
Chemicals
Concentration Range
(ppm)
Volatile Oraanics
Acetone
Carbon Bisulfide
1,2 Dichloroethane
Chloroform
2-Butanone
Trichloroethene
4-Methyl-2 -Pentanone
Tetrachloroethene
Toluene
Ethylbenzene
Xylene (total)
Semi-Organics
Napthalene
2-Methylnaphtalene
Di-n-Butylphthalate
Pyrene
Bis(2-Ethylhexyl)phthalate
Pesticide/PCBs
Alpha-BHC
Beta-BHC
Delta-BHC
Gamma-BHC (Lindane)
Heptachlor
Aldrin
Heptachlor epoxide
Endosulfan I
Dieldrin
4,4-DDE
Endrin
Endosulfan II
68
14
18
170
1100
1.2
13
1.6-48
41
2.0-25
9-250
5.2-290
5.3-240
3.1-41
4 .9-140
2.7-250
14-270
Page 17 of 18
-------
Table 2
Data Gap Investigation Results
Chemical Detected in the
Outside Northwest Fenceline (con't)
Chemicals
Pesticide/PCBs (con'tl
Concentration Range
(ppm)
4,4-ODD
Endosulfan Sulfate
4,4-DDT
Endrin Ketone
Endrin Aldehyde
Alpha-Chlordane
Gamma-Chlordane
Arochlor-1242
Arochlor-124 8
Arochlor-1260
Inorganics /TPHC
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Total Petroleum Hydrocarbon (TPHC)
Page 18 of 18
4.4-26
3 .9
12-230
6.1-91
13-250
6.2-110
3.0-14
460-14000
1500-10000
300-7500
4470
8.5-202
11.8
0.08-1.3
493
13
.75
9.3
10700
6.5-183
678
19.8
1.7
1610
16.8
15.5
520-49000
-------
Table 3.1: Summary of COPCs and Exposure Point Concentrations
.'mperial Oi! - Tank Farm
Scenario Timofranw: Current/Future
Medium: So*
Exposure Medium: Sat
Exposure Point: Soil/Tank Farm
Exposure
Point
Soils m the
Tank Farm Area
Chemical of
Chemical
Aluminum
Arsenic
Beryllium
Cadmium
Chromium
Copper
Iron
Manganese
Mercury
Vanadium
Minimum
Concentration
<10
<2
<1
<1
12.3
7
<10
11.5
<0.02
15.6
Maximum
Concentration
9.800
231
1.7
1.1
28
116
20800
302
0.22
34.5
Units
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
Detection
Frequency
2/4
3/4
2/4
1/4
4/4
4/4
2/4
4/4
"1/4
3/3
Exposure
Point
Concentration
9.800
231
! 1.7
1.1
28
116
; 20800
302
0.22
34 5
Statistical
Measure
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
ug/kg: micrograms per kilogram: parts per billion
.•ng/kg: milligrams per likogram: parts per milliion
MAX Maximum Detected Concentration
95°'. UCL. 95% Upper Confidence Umit of the Mean
-------
Table 3.2: Summary of COPCs and Exposure Point Concentrations
Impenal Oil • Fenced Portion of the Site
Scenario Tinwframe: Cuirsm/Futum ,
Medium: Sot
Exposure Medium: So* ;
Exposure Point: Soil/Fenced Portion of m« Ste
Exposure Chemical of
Point Concern Minimum
Concentration
Maximum
Concentration
Units
Detection
Frequency
Exposure Statistical
Point Measure'
Concentration
Soils in the
Fenced Antimony
Portion of Arsenic
She Site Banum
Beryllium
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
<6
1.3
6.7
<0.5
<0.5
4,6
0.81
<10
<0.5
3.5
<0.02
13
283
668
1.3
2.1
463
1020
29800
1350
189
0.26
mg/kQ
mo/kg
rng/kg
mg/Vg
mg/kg
mg/kQ
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
1/19
19/19
19/19
10/19
3/19
19/19
19/19
4/19
15/19
19/19
4/19
4
278
280
0.48
0.65
65
335
29800
1350
55
0.12
95% UCL
95% UCL
95% UCL
95% UCL
95% UCL
95% UCU
95% UCL
Max
Max
95% UCL
95% UCL 4
Benzene
Total Xylenes
<5
<5
140
1900
ug/kg
ug/kg
7/19
10/19
23
1900
95% UCL
Max
8enzo[ajanthracene
8enzo(a|pyrene
3enzc[b]fluorantnene
cis< 2-Ett-yihexyOpmnaiate
lndeno[ 1 23-ca]pyrene
Naphthalene
N-nitrosodimethylamine
Pentacnlorophenol
<330
<330
<330
«330
<330
<330
<330
<330
530
270
510
17500
84
13000
40
38000
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
3/19
2/19
2/19
4/19
1/19
9/19
1/19
2/19
209
180
203
2341
84
13000
40
2491
95% UCL
95% UCL
95% UCL
95% UCL
Max
Max
Max
95% UCL
*
Aroclor 1242
Arocior 1260
<80
<-30
11000
13000
ug/kg
ug/kg
16/19
16/19
11000
13000
Max
Max
.;C.kg. -nicrcgrarri ser kilogram: parts per oilfion
irg;kg T.ilhgrams per «c
-------
Table 3.3: Summary of COPCs and Exposure Point Concentrations
i-pcrisi Ci! - Soils Under the Old Warehouse
Scenario Ttmefnirm: Curmnt/Futuf*
Medium: Soil
Exposure Medium: So8
Exposure Point Soil/Under th« Old Wanahouaa
•
Exposure Chemical of
Point Concern
Soils Under the Aluminum
Old Warehouse Antimony
Arsenic
Banum
Beryllium
Chromium
Copper
Manganese
Mercury
Vanadium
Total Xylenes
Arocior 1016
Aroclor 1 260
Minimum
Concentration
4820
<12
201
<40
<1
10.2
<5
23
0.13
19
<5
<80
1900
Maximum
Concentration
6.420
31
464
129
3.3
57.4
206
111
1.1
36.7
3300
9000
Units
mg/kg
mg/kg
•ng/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
ug/kg
ug/kg
Detection
Frequency
3/3
2/3
3/3
2/3
2/3
3/3
1/3 '
3/3
3/3
3/3
1/3
2/3
3/3
Exposure
Point
Concentration
5.420
31
464
129
3.3
57.4
206
111
1.1
36.7
3300
9000
7000
Statistical
Measure
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
.g.Kg: micrograms per kilogram: parts per billion
—g.kg1 -riiitgrarrs per 'ikcgram: parts per milliion
MAX Maximum Detected Concentration
i5°j UCL. 95s's Upper Confidence Limit of the Mean
-------
Table 3.4: Summary of COPCs and Exposure Point Concentrations
imperial Oil - Soils in the Waste Pile
Scenario Timafram*: Current/Future
Medium: Soil
Exposure Medium: Soil
Exposure Point: Soil/Waste Pile
Exposure Chemical
Point
Soils in (he Arsenic
Waste Pile Banum
Beryllium
Chromium
Copper
Iron
Manganese
Benzo[a]anthracene
Benzo(a]pyrene
Benzo(b]fluoranlhene
Benzo(k]fluoranthene
Naphthalene
Aroclor 1242
Aroclor 1248
Aroclor 1260
Minimum
Concentration
6.1
248
<0.5
9.3
42
5510
33
<330
<330
<330
<330
<330
<80
<80
9600
Maximum
Concentration
7
676
0.83
32
45
7050
'"2
4700
5600
4700
4700
1400
43000
5200
80000
Units
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg^
Detection
Frequency
3/3
3/3
2/3
3/3
3/3
3/3
3/3
2/3
1/3
1/3
1/3
1/3
2/3
1/3
• 3/3
Exposure
Point
Concentration
7
676
0.83
32
45
7050
172
4700
5600
4700
4700
1400
43000
5200
80000
Statistical
Measure
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
jg;kg mcrograms per kilogram: parts per billion
•rg.kg; milligrams per hkogram: parts per milliion
MAX Maximum Delected Concentration
55% UCL 55'ft Upper Confidence Limit of the Mean
-------
Table 3.5: Summary of COPCs and Exposure Point Concentrations
Scenario Timaframa: Current/Future
Medium: Soil
Exposure Medium: Sod
Exposure Point: Soil/Surface Soils Outside the Imperial Oil Facility
Exposure Chemical of
Point Concern
Surface Soils Aluminum
Outside Antimony
the Impenal Arsenic
Oil Facility Banum
Beryllium
Cadmium
Chromum
Copper
Iron
Lead
Manganese
Mercury .
Vanadium
Benzo[alanthracene
Benzo[b]fluorantnene
Benzo(k]fluoranthene
<3-8HC
Aroclor 1 242
Aroclor 1 260
Minimum
Concentration
<20
<6
<2
<40
<0.5
<0.5
12.4
<5
<20
<0.5
<3
<0.02
2
<330
<330
<330
<8
<80
<160
Maximum
Concentration
3.380
26
73.5
229
1.7
1.5
428
236
31200
534
87.9
0.43
26.3
110
110
110
200
2500
2600
Units
mg/kg .
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
Detection
Frequency
1/8
1/7
6/8
5/8
8/8
1/8
8/B
6/8
4/8
6/8
7/8
3/8
5/6
1/3
1/3
1/3
1/6
1/8
5/8
Exposure
Point
Concentration
8.380
26
73.5
229
t.7
1.5
4CS
236
31200
534
0.43
1.2
26.3
110
110
110
200
2500
2600
Statistical
Measure
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
MAX
ugAg Ticrograms per kilogram: parts per billion
."^g/Kg: milligrams per likogram: parts per millfion
MAX Maximum Detected Concentration
95"» UCL. 55"> Upper Confidence Limit of the Mean
-------
Table 3.6: Summary of COPCs and Exposure Point Concentrations
Impenal Oil - Onsite Residential Us«
Scenano Timeframa: Currant/Futum
Medium: Sod
Exposure Medium; Sol
Exposure Point: Sori/Onsrte Residential Use
Exposure Chemical Minimum
Point Concentration
i
Maximum Units
Concentration
Detection Exposure
Frequency Port
Concentration
Statistical
Method*
Onsiio Aluminum
Residential Antimony
Use Arsenic
Banum
Beryllium
Cadmium
Chromium
Iron
Lead
Manganese
Mercury
Silver
Vanadium
<20
<8
<20
<40
-------
Scenario
Tnnoframo
Cuiiuiil/
future
Medium
Soil
Exposure
Medium
Suil
Table 4
Selection of Exposure Pathways
Exposure
Point
Tank faun
Fenced Portion
of the Sile
Soils Under the
Old Warehouse
Soils in llio
Waste Pile
Suifacu Seils
Outside lh«
IOC/CC Facility
Onsile Soils
•
Onsile Soils
Receptor
Maintenance
Woikuis
Facility
Maintenance
Woikeis
Utility Workers
Utility Woikers
Construction/
Excavation
Woikms
Construction/
Excavation
Woikeis
Facility Workers
Industrial/
Chikl
Trespassers/
Recrealois
Child
Trespassers/
Ftecrealois
Future
Residents
Future
Residents
Residents
future
Receptor
Ago
Adult
Adull
Adull
AUull
Adult
Adult
Adull
Adult
Child
Child
Adull
Adull
Child
Child
Exposure
Route
Ingostiun
Dermal
Contact
Inyeslion
Deimal
Contact
Ingeslion
Dermal
Contact
lng«stion
Dermal
Contact
Ingeslion
Dermal
Contact
Ingeslion
Dermal
Contact
Ingcsiion
Dermal
Contact
Onsile/
Olfsile
Oiisile
Onsile
Onsile
Onsile
Onsila
Onsile
OnsiU
Onule
• Onsile
Onsila
Onsito
Qnsile
Onsile
Onsile
Ralioiulo lor Seloclion/Exclusluii ol
Exposure Palhway
Aiea ol IOC/CC sile whH.li is lieiiuoiiiud
Ly I'acilily MamlciuLe Woikuis
Aiea ol Ihe IOC/CC site which is
liequenled by Facility Maintenance
Woikers
Restricted area ol Ihe IOC/CC sile whn.li
IS lieqiiunled by Ulilily Workers
Reslncted aiea ol live IOC/CC site which
is liet|uenlod by Utility Workers
Area ol the IOC/CC sue which is
accessible only lo
ConslructionVExcavalion Wnikers
Area ol Ihe IOC/CC sile which is
accessible only lo
Consliuclion/Excavalion Wiirkui s
IndustiiuirFacility Maintenance Wuikers
have access lo this arua ol Ihe sile
1 d 1 1 M
have access lo this area ol H"t site
Areas outside the IOC/CC Facility uie
accessible loiecrealnii and itespassers
Aieas outsido Hie IOC/CC Faciliiy JIH
accessible lorecreatois and hr-'passors
Potential fuluie residenliiil use
Potential (uluie residential use
Polcnliai (tilulu lesidunhal use
Pelenlul lultuti lesiduulul use
Summary of Selection of Exposure Pathways
1 IK: i.iulu presents all eposuru modi.i v»uo
pi.inti .mil diaiuctuiibtif.i ol lecuploi pupiiuuons .uu ini.liiilud
•
ifft
-------
Table 5
Non-Cancer Toxlcity Data Summary
•IngnsUon, Dermal Contact
Crwnci! of
Concern
Artimwum
Antimony
Auoc.iC.
Bantim
8aryi?.un
Cacnxim
Chromum
Ccpc«r
Iran
Manganese
Marcuty
&!v«
Vanactum
Btrzere
TclalXy*rte»
flflnzo'aj-
arwaee.10
0«nzo|al-
went
Benzole).
Ijcramnane
Qenzc!M|*
Oocrareirtene
0'Si2'Einyt'
reiy JphWB'ate
ii-oenofiJJ-
:c.oyrer:o
Nasr.iRaiene
N-N,!/=so
StrreBiyiamne
Pecucwoto-
phenol
3-BHC
Arocor 10!6
Arocor 1242
Atoc'or !H8
chronic;
Subchnnlc
Chfcnic
Chmntc
Chmmc
SuDCnronic
Cnrcrtic
:wonic
Chronic
Chronic
Chronic
Chronic
Succnromc
Chronic
CMonic
Chronic
Crtrontc
Cnrcivc
SuCcnromc
Chronic
Suocftronic
SubcMonc
Subchronic
SLbclrranic
Onl
RIO
VUu.
1E»00
4E-04
3E-04
7EJJ2
2E-03
1E-03
3E-03
-------
I Key to Table 5
NA. No information available.
IRIS, integrated RisX Information Syjwn, U.S. EPA
H6AST. Health Erfscs Assestment Summary Tablet, us. EPA
NCSA: National Center (or Environmental Assessment U.S. EPA
Summary of Toxicity Assesimcnt
OUIIIIIIBI J VI *V*IVIIJ n»Va91Udl»
TCiis table provides non-carcinogenic risk information wfttcti is rei*5vant to tft£ contaminants of concern in soil Constant with draft EPA Guiflanc*
ior Dermal Risk Assessment oral toxioty data were not adjusted for those cnemicais for which tfi« oral atiso^pbon fraction exceeds 50%.
-------
Table 6.1
Risk Characterization Summary - Noncarcinogens
Scenario Timalrame: Current
Receptor Population: Facility Maintenance Worker
Receptor Age: Adtill
Medium
Soil
Exposure
Medium
Soil
Exposure Point
Tank Farm
Chemical of Concern
Aluminum
Atsenic
Beryllium
Cadmium
Chromium
Copper
Iron
Manganese
Mercury
Vanadium
Primary Target
Organ
CNS
Skin
Small Intestine
Kidney
NOAEL
-
Liver
CNS
CNS
NOAEL
Noncarclnogenic Hazard Quotient
IngeMion
I 2E-03
9 OE-02
1 OE-W
1 3E-04
1 1E-03
34E-04
B IE-03
1 8E-03
26E-04
5 8l-:-04
Dermal
1 6E-01
30E-04
TOTAL RISK:
Exposure Routes Total
I 2E-03
2 6E-01
10E-04
43E-04
1 IE-03
3 4E-04
8 IE-03
1 BE-03
26E-M
58E-04
2.6E-01
-------
Table 6.2
Risk Characterization Summary - Noncarcinogens
Scenario Timeframa: Current
Receptor Population: Utility WotKer
Receptor Age: Adult
Mudium
Soil
Exposure
Medium
Soil
Exposure Point
Fenced Portion ol (tie Site
Chemical ol Concern
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Iron
Manganese
Mercury
Benzene
Total Xylenes
Benzojalanthiacena
Benzo[a]pyis(2-Ethylhexyl|phlhalate
hiusno|123-cd]pyrene
Naphthalene
N-Nilrosodimethylamme
Pentachlorophenul
Aiocloi 1242
Aioclor 1260
Primary Target
Blood
Skin
NOAEL
Small Intestine
Kidney
NOAEL
-
Liver
CNS
CNS
Liver
CNS
Liver
-
Body Weight
l.ivef/Kidney
Immunologies!
linmunological
Noncarcinogenic Hazard Quotient
Ingestion
4.7E-04
4 4E-02
1.9E-04
1.1E-05
3 1E-05
1 OE-03
39E-04
4 9E-Q1
1 3E-04
5.6E-06
1 1E-06
A 5E-08
5.5E-06
31E-OS
39E-06
2 6E-02
1 11-112
Dermal
7.5E-02
70E-05
5 6E-05
2 1E-OI
25E-0!
TOTAL RISK:
Exposure Routes Total
47EO4
t 2E-01
1 9E-04
1 IE-OS
1 OE:04
1 OE-03
3 9E-04
49E-03
1 3E-04
56E-05
1 1E-06
4 SE-OB
5 5E-06
3 IE-OS
6 OE-05
2-4E-OI
2BE-OI
6.4E-01
-------
Table 6.3
Risk Characterization Summary - Noncarclnogens
Scenario Tlmeframo:
RuLCplor Population:
Receptor AQO:
Medium
Soil
Exposure
MU ilium
Soil
Current
Conslruction/Excavalioii WoiXeis
Adull
Exposure Point
Soils Under (he Old
Warehouse
Chemical ol Concern
Alumtnum
Antimony
Arsenic
Danum
Beryllium
Chromium
Copper
Munganeso
Mercury
Vanadium
Total Xylenos
Aroclor 10t6
Aiocloi 1260
Primary Target
Organ
CHS
Blood
Skin
NOAEL
Small Intestine
NOACL
-
CNS
CNS
NOAEL
CNS
Developmental
Immunological
Nonearclnogenlc llaiard Quotient
Ingosllon
77E-03
8 7E-02
1.7C«00
2.IE-03
V9E-03
2.2E-02
S 6E-03
6.3E-03
1 2E-02
5 9E-03
I9E-06
1 4E-01
39E-QI
Oarmal
63E-QI
8 5E-01
6 6E-01
TOTAL RISKS:
Exposure Routes Total
72E03
87.02
2 31--03
2 IC-03
1 9E-03
22E02
S8E03
63E-03
1 2E-02
5 9E-03
1 9E-06
99E-OI
1 IE-01
4.5E<-00
-------
Table 6.4
Risk Characterization Summary - Noncarcinogens
SCL-IUIIO Tmielrjmo: Ctirivni
Receptor Population: InuuitiiiitKiicilily
Receptor Aiju: Adult
Medium
Soil
Exposure
MU ilium
Soil
Exposure Point
Soils in the Wasle Pile
Chemical ol Concern
Arsenic
Djuum
Ueryllium
Chromium
Copper
lion
Manganese
Qenjo|a]anlhiac8ne
Bonzo|a]pyiena
Ben/olb|lluoianlhene
Benzo|k|(luoianlhene
Naplilhalune
Aioclot 1242
Arocloi 1248
Aroclur 1260
Primary Target
Skin
Small tfltu&lirve
NOAEL
Livur
CNS
-
Body Weight
Imniunologicil
Immunological
Imniunotogical
Noncarcinofjenlc H32jiJ Quotienl
Ingeslion
1.1E-02
4 7E-03
20E-04
' S.2E-03
S5E-04
1 1E-02
4 2E-03
3 4E-OS
1 1'E«00
1 3E-01
20EiOO
Dermal
3 9E-02
1 6E*01
19E«00
29E»01
TOTAL RISKS:
Exposure Routei Tout
5 OE-02
4 7fc.Q3
20L-04
52E-03
5 bt-04
1 IE 02
42E-03
346 05
1 76*01
20E.OO
31EIQI
6.0E>01
-------
Table 6.S
Risk Charactorization Summary - Noncarcinogens
Scenario Timclraius: Cuiiunl
llui.u|itni Population: RecrejloiblTiespassi: i
Reco|ilui A(ju: Child
Mudium
Soil
:xposuri*
Medium
Suit
Exposure Point
Surface Soils Outside
Hi* IOC/CC Facility
Chemical ol Concern
Aluminum
Anlmiony
Arsenic
Qarium
Beryllium
Cadmium
Chiomium
Copper
Iron
Manganese
Morcury
Vanadium
Beii2o|a)anlhracene
BunlolD]lluoianlhene
Benzo|fcjfluoranlhene
dBHC
Aroclor 1242
Aioclor 1260
Primary Target
Organ
CMS
Uluod
Skin
NOAEL
Small Inlusliuo
Kidney
NOAEL
Liver
CMS
CNS
NOAEL
Liver
lininunolo^ical
Immunotogical
Honcarcinogonlc Harard Quoliont
Ingasllon
3.3E-03
2 5E-02
9 6E.Q2
1.3E-03
3 3E-04
5 9E-04
S 6E-02
23E-03
41E-02
1,76-03
1 7E-03
1.5E-D3
266-M
49E-02
6 1E-02
Dermal
1 2E-Q1
2QE-02
2.aE-OI
2 9E-01
TOTAL RISKS
Exposure Roulut Total
3 3E-03
2 SE-02
22E01
1 3E-03
3 3E-Q4
3 OE 02
S6E-02
23E03
4 IE 02
1 7t' 03
1.7E-03
t 5E 03
26E-04
33EOI
34E-01
1.0E.QO
J ~
-------
Table 6.6.1
Risk Characterization Summary - Noncarcinogens
Scenario TuneJMnie: Fuluie Receptor Population: Residiml Receptor Afjo: Adull
Medium
Soil
Liposure
Medium
Soil
'
'
Exposure Point
Onsile Soils
Churntc.il ol Concern
Aluminum
Antimony
Arsenic
Uarium
Qerylfoum
Cadmium
Chfomitim
lion
Manganese
Mercury
Silver
Vanadium
Tool Xylenei
Ben*o(a]anlhiacene
Benzo|»|pyrene
Benzo|b)(luoranlhane
Benzo[k]lluoijnlliena
bis|2-Ethylhexyllphthalate
Indeno|l23-cd]pyrene
Naphthalene
. • N Nilrosodirnelhylamine
Penlachlompttenot
d BUG
Aroclor 1242
Aiocloi 1260
"
Primary Tarcjot
Oryan
CNS
Blood
Skin
NOAEL
Small Inleslme
Kidney
NOAEL
liver
CNS
CNS
Skm
NOAEL
CNS .
-
Liver
Body WeKjIit
LiveWKidney
I ivur
tnimunuluyical
Inintuiiuluij^3'
Noncarcinoijenjc Mnrard Quotionl
Ingestion
1 IE 02
2 7E-02
ISEtOO
2 3E-03
6 2E.04
9 5E-04
4 7E-02
1 4E-01
9 5E-03
66-03
4.9E-04
7 66-03
1 8E-07
2.0E-M
S8E-04
1.3E-04
91E-04
26E-01
4 6E-01
Dermal
26C«00
2 2E 03
1 9E-03
23L>00
39b«l)0
TOTAL RISK
Exposure Routes Total
1 lt-02
27t 02
4 IE>00
2 3E-03
B 2U-04
3 ^E-03
4 7E-02
1 4E-01
9 51: -03
6E-03
4 9E-04
7 6E-03
1 5E-07
2 OE-04
i8E04
20E03
9 1E-04
2 6E*00
44E<00
V1E«01
-------
Table 6.6.2
Risk Characterization Summary - Noncarcinogons
Scenario Tiinelrame; Future
Receptor population: Hesiilont
Ruiuulor Age: ChikJ
Medium
Soil'
xposure
Xeilium
Suil
--
i
-. .11
Exposure Point
Onsite Soils
_
— . —
— —
,
,.,. " —
Chemical ol Concern
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
lion
Manganese
Mercury
Silver
Vanadium
Total/ .ones
Benzo[a)anlhiacene
Benzo[a]pyrene
Benzo[b|(luoranlhene
_ _ i —
Benzolkjfluoianlnene
bisl2-£lliylhexyl)phlhalale
lndeno[123-cd]pyrene
— —
Naphthalene
— . — • —
N-Niliosodimetliylamme
*~—~ — •— — ^ —~ ^ ~"^~^~^
PeiitaclUoiopfienol
J . .-. — — — — '
Primary Targol
Organ
CNS
Blood
Skin
NOAEL
Small Intestine
Kidney
NOAEL
Liver
CNS
CNS
Skin
NOAEL
CNS
-
-
liver
— — — — — — ^-^
Body Weigiu
Liverfhidiuty
Noncarcinogenic Hazard Quollint
InQOSlion
1.1E-01
2 6E-01
1.4E«01
22E»02
7.7E-03
88E-03
4.4E-01
1.3E*00
8E-02
S6E-02
4.6E-03
7 1E-02
t 4E-06
1 BE-03
S 4E-03
1 3E-03
Oormal
44E<00
3 6E-03
3.2E-D3
_^ ^f^—
Exposure Routes Total
1 IE-01
26E-01
1 8£t01
2 2E*02
7 7E-03
1 2E-02
44E-01
1 3E»00
8E-02
56E-02
46E-03
7.1E-02
1.4E-06
1 BE-03
5 4E-03
4 5E-03
-------
Table 6.6.2 (continued)
(iOIIC
Aroclor 1242
Aiocloi 1260
Liver
Iwmunological
Imimmological
8 5E-03
26E»00
4 5E*00
37E»00
6 4E+00
TOTAL RISK:
8 5E-03
63£«00
1 1E*OJ
3 8E»01
Risk Characterization
Table D provides hazard quotients (HQs) for each route of exposure and the hazard index (sum of hazard quotients) for all routes of exposure. The Risk Assessment Guidance for
Supeifund (RAGS) stales that, generally, a hazard index (HI) greater than 1 indicates the potential for adverse noricancer effects The estimated His of 4.5 (Table 0 3). 50 (Table O.4),
11 (Ttiblo 061), and 38 (Table 0.6.2) indicate that the potential for adverse nonconcur effects could occur from exposure to contaminated soil containing arsenic and PCDs
-------
Table 7
Cancer Toxicity Data Summary
-Ingestion, Dermal Contact
Chemical of Concern
Arsenic
Benzene
Benzo[a]anihracene
Benzo(a]pyr«ne
Benzo[b]fluoranthene
Benzo[k]fluoranthene
lndeno(1 23-cd]py rene
bis[2-
Ethylhexyljphthalata
N-Nitrosodimethylamme
Pentachlorophenol
d-BHC
Aroclor 1016
Aroclor 1242
Aroclor 1248
Aroclor 1260
Oral
Cancer
Slope
Factor
1 .5E+00
2.9E-02
7.3E-01
73E+00
7.3E-01
73E-02
7 3E-01
1 4E-02
5.1E+01
1 2E-01
13E+00
2E+00
2E+00
2E+00
2E+00
Absorption
Efficiency
(for Dermal)
0.95
0.89
0.89
0.89
089
0.89
•
0.76
080-0.96
080-0.96
0.80-0.96
0 80-0 96
Adjusted
Cancer Slop*
Factor
(for Dermal)
1.5E+00
2.9E-02
7.3E-01
73E+00
7.3E-01
7 3E-02
7 3E-01
1 .4E-02
5.1E+01
12E-01
1.3E+00
2E+00
2E+00
2E+00
2E+00
Slope Factor
Units
(mg/kg-day)"'
(mg/kg-day)"1
(mg/kg-day)''
(mg/kg-day)''
(mg/kg-day)''
(mg/kg-day)''
(mg/kg-day)''
(mg/kg-day)'1
(mg/kg-day)'1
(mg/kg-day)''
(mg/kg-day)'1
(mg/kg-day)''
(mg/kg-day)''
(mg/kg-day)'
(mg/kg-day)''
Weight of
Evidence/
Cancer
Guideline
Description
A
A
B2
B2
B2
B2
B2
B2
B2
B2
B2
B2
B2
B2
Source
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
Date
08/25/99
08/25/99
08/25/99
08/25/99
08/25/99
08/25/99
08/25/99
08/25/99
08/25/99
08/25/99
08/25/99
08/25/99
08/25/99
08/25/99
08/25/99
Key EPA Group:
— No information available A - Human carcinogen
IRIS, Integrated Risk Information System, U.S. EPA B1 - Probable Human Carcinogen - Indicates that limited human
data are available
B2 - Probable Human Carcinogen - Indicates sufficient evidence in
animals associated with the site and inadequate or no
e vidence in humans
C - Possible human carcinogen
D - Not classifiable as a human carcinogen
E - Evidence of noncarcinogenicity
Summary of Toxicity Assessment
This table provides carcinogenic risk information which is relevant to the contaminants of concern in soil. Consistent with draft
EPA Guidance for Dermal Risk Assessment, oral toxicity data were not adjusted for those chemicals for which the oral
absorption fraction exceeds 50%.
-------
Table 8.1
Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current
Receptor Population: Facility Maintenance Worker
iluceptor Age: Adult
Medium
Soil
Exposure
Medium
Soil
Exposure Point
Tank Farm
Chemical of Concern
Arsenic
Carcinogenic Risk
Ingestion
1 5E-05
Dermal
2.5E-05
TOTAL RISK:
Exposure Routes Total
4 OE-05
4.0E-OS
-------
Table 8.2
Risk Characterization Summary - Carcinogens
Scenario "I imeframe: Current
Receptor Population: Utility Worker
Receptor Age: Adult
Medium
Soil
Exposure
Medium
Soil
Exposure Point
Fenced Portion of the Site
Chemical of Concern
Arsenic
Benzene
Benzo(a)anthracene
Benzo[a]pyrene
Benzolb]fluoranthene
bis|2 -Ethylhexyllphlhalale
lndeno( 1 23-cd]pyrene
N-Nitrosodimelhylamme
Pentachlorophenol
Aroclor1242
Aroclur 1260
Carcinogenic Risk
Ingestion
7.0E-06
1 1E-11
2 6E-09
22E-08
2 5E-09
55E-09
1 OE-09
8 6E-08
t 3E-08
9 2E-07
1.1E-06
Dermal
1 2E-05
19E-08
1 6E-07
1 9E-08
4 1E-09
77E-09
7 2E-08
30E-06
JbE-06
TOTAL RISK:
Exposure Routes Total
1 9E-05
1 1E-11
2.2E-08
1.7E-07
2 2E-08
96E-09
8.7E-09
8 6E-08
B.5E-08
3.9E-06
46E-06
2.8E-05
-------
Table 8.3
Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current
Receptor Population: Construction/Excavation Workers
Receptor Age: Adult
Medium
Soil
Exposure
Medium
Soil
Exposure Point
Soils Under the Old
Warehouse
Chemical of Concern
Arsenic
Aroclor 1016
Aroclor 1260
Carcinogenic Risk
Ingestion
1.1 £-05
2 9E-07
23E-07
Dermal
4.0E-06
4.9E-07
3.8E-07
TOTAL RISKS:
Exposure Routes Total
1.5E-05
7BE-07
61E-07
1.7E-05
Table 8.4
Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current
Receptor Population: Industrial/Facility
Receptor Ape: Adult
Medium
Soil
Exposure
Medium
Soil
i • i "• ••
. ' -
•
Exposure Point
Soils in (he Waste Pila
Chemical of Concern
Arsenic
Benzo|a)anthracene
Benzo|a]pyrene
8enzo[b]fluoranthene
Benzo[k]fluoranlhene
Aroclor 1242
Aroclor 1246
Aroclor 1260
Carcinogenic Risk
Ingestion
1 8E-06
60E-07
7.1E-06
60E-07
6 OE-08
1 5E-05
1 8E-06
2 8E OS
Dermal
6.3E-06
9.0E-06
1.1E-04
90E-06
9.0E-07
2.4E-04
2.9E-05
45E-04
TOTAL RISKS:
Exposure Routes Total
8.1E-06
9.6E-06
1.2E-04
9.6E-06
9 6E-07
2 6E-04
31E-05
48E-04
9.1E-04
-------
Table 8.5
Risk Characterization Summary - Carcinogens
Scenario Timelrame: Current
Receptor Population: Reueators/Trespassers
Receptor Age: Child
Medium
Soil
Exposure
Medium
Soil
Exposure Point
Surface Soils Outside
(he IOC/CC Facility
Chemical of Concern
Arsenic
Benzo[a|anthracene
8enzo[b)lluoranlhene
Benzo(K|fluofanlhene
d-BHC
Aroclor 1242
Aroclor 1260
Carcinogenic Risk
Ingestion
74E-06
5.4E-09
54E-09
54E-10
1 7E-08
3 4E-07
3.5E-07
Dermal
9 OE-06
2 9E-08
2 9E-08
2 9E-09
19E-06
2 OE-06
TOTAL RISKS:
Exposure Routes Total
1 6E-05
3 4E-08
3.4E-08
34E-09
17E-08
22E-06
2.4E-06
2.1E-OS
-------
Table 8.6.1
Risk Characterization Summary - Carcinogens
Scenario Timulrame: I uluie
Receptor Population: Resident
Receptor Age: Adult
Medium
Soil
Exposure
Medium
Soil
Exposure Point
Onsite Soils
Chemical of Concern
Arsenic
Benzo(alanlhracene
Benzo[a]pyrene
Benzo[b)(luoranthene
Benzo(k)(luoranthene
bis[2-Ethylhexyllphlhalale
lndeno[123-cd|pyrene
N-Nilrosodimethylamme
Pentachlorophenol
d-BHC
Aroclor 1242
Aroclor 1260
Carcinogenic Risk
Ingestion
24E-04
79E-08
62E-07
7 OE-08
7 OE-09
1 9E-08
2 9E-08
96E-07
1 7E-07
1 2P-07
39E-06
6 6E-06
Dermal
4 1E-04
59E-07
46E-06
53E-07
5.3E-08 '
2.2E-07
2.4E-06
31E-05
5.3E-05
TOTAL RISK:
Exposure Routes Total
6.5E-04
67E-07
52E-06
60E-07
6 OE-08
19E-08
2.5E-07
96E-07
26E-06
1 2E-07
3 5E-05
6 OE-05
7.SE-04
-------
Table 8.6.2
Risk Characterization Summary - Carcinogens
Scenario Timelrame: future
Receptor Population: Resident
Heceptor Age: Child
Medium
Soil
Lxposure
Medium
Soil
Lxposure Point
Onsite Soils
Chemical of Concern
Arsenic
Benzo[a]anthracene
Benzo|a]pyrene
Benzo[t>]fluoranthene
Benzo[k]fluoranlhene
bis[2-Ethylhexyl]phthalate
Indenol123-cd)pyrene
N-Nitrosodimethylamine
Pentachlorophenol
d-BHC
Aroclor 1242
Aroclor 1260
Carcinogenic Risk
Ingestion
55E-04
18E-07
1.4E-06
1 6E-07
16E-08
44E-08
6.7E-08
2.2E-06
3.9E-07
2.8E-07
90E-06
1.5E-05
Dermal
17E-04
2 4E-07
1 9E-06
2 2E-07
2 2E-08
8 9E-08
9 8E-07
1 3E-05
22E-05
TOTAL RISK:
Exposure Routes Total
7.2E-04
4 2E-07
33E-06
3 8E-07
38E-OB
4 4E-08
1.6E-07
2.2E-06
1.4E-06
2 8E-07
2 2E-05
3 7E-05
7.9E-04
Risk Characterization
T . i» F n,™,^ carcinooenic risk estimates for the significant routes of exposure These risk estimates are bdbeu on a reasonable maximum exposure and were developed
I! UkinnoS2SSS^c^nserlrve assumptions about the frequency and duration of exposure for each population, as we« as the toxicity of each chem.ca. The
CoSconSuSmost s^nificantly the cumulative risks are arsemc and PCBs. See Tables F.4. F.6.1. and F 6 2 for these «sk est«na«es.
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Table 9
Soil/Waste Pile Contaminants & Remediation Goals
Imperial Oil Company/Champion Chemicals Site
Chemical
Maximum Detected
Concentration*
(mg/kg)
Soil
USEPA Soil
Cleanup Criteria
(mg/kg)
Residential
Impact to
Groundwater Soil
Cleanup Criteria
Remediation
Goal
(mg/kg)
Soil
VOCs
Benzene
Chloroform
1 ,2-Dichloroethane
1.2-DichIorethene (total)
Ethylbenzene
Styrene
Tetrachloroethene
Toluene
Trichloroethene
Total Xylenes
0.023
0.0058
0.0023
0.96
0.81
0.12
0.3
2.3
0.79
3.3
0.62
0.24
0.34
42
1400
4100
4.7
580
2.7
1300
0.03
0.6
0.02
0.02
13
4
0.06
12
0.06
200
0.03
0.24
0.02
0.02
13
4
0.06
12
0.06
200
SVOCs
Acenaphthene
Anthracene
Benzo[a]anthracene
Benzo[a]pyrene
Benzo[b]fluoranthene
Benzo[k] fluoranthene
bis[2-Ethylhexyl]phthalate
B uty Ibenzy Iphthalate
Chrysene
0.49
l.l
4.7
5.6
4.7
4.7
2.853
47
4.7
2600
14000
0.56 -
0.056
0.56
5.6
32
11 000
56
100
100
2
8
5
49
100
100
160
100
100
0.56
0.056
0.56
5.6
32
100
56
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Table 9 (continued)
Di-N-Butylphthalate
Fluoranthene
Fluorene
!ndeno[123-cd]pyrene
2-Methylnaphthalene
Naphthalene
N-Nitrosodimethylamine
Pentachloropheno I
Phenanthrene
Pyrene
Total PCBs
Aroclor 1016
Aroclor 1242
Aroclor 1248
Aroclor 1260
1 .2.4-Trichlorobenzene
TOC
1.7
1.5
1.2
0.084
19
13
0.04
2.95
14
5
NA
9
43.
5.2
80
3.2
540000
5500
2000
1800
0.56
NA
55
0.0087
2.5
NA
1500
1
1000
100
100
14
84
84
NA
0.03
NA
4200
50
1000
100
100
0.56
84
55
0.0087
0.03
NA
1500
1
See Total PCBs
See Total PCBs
See Total PCBs
See Total PCBs
480
NA
5
NA
Pesticides
d-BHC
0.2
0.42
NA
Metals
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Iron
9800
31
464
676
3.3
1.5
428
335
31200
75000
30
0.38
5200
150
37
210
600
22000
NA
5
29
1600
63
8
NR
NA
NA
5
NA
0.2
75000
5
20
1600
63
8
210
2800
22000
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Table 9 (continued)
Lead
Manganese
Mercury
Silver
Vanadium
1350
302
1.1
1.8
39
400
3100
22
370
520
NA
NA
2
34
6000
400
3100
2
34
520
Remediation Goals based the Protection of Human Health Under a Residential Scenario are from
the following sources:
1.
2.
3.
4.
Risk Assessment Guidance for Superfund, Volume I - Human Health Evaluation Manual
(Part B, Development of Risk-Based Preliminary Remediation Goals) Interim
(EPA/540/R-92/003) Office of Research and Development. December 1991.
US EPA Region IX Preliminary Remediation Goals; Residential Soil - Integrated Pathway;
August 4, 1999
Remediation Goal for Arsenic is based on New Jersey Statewide Background
Concentration (hup:/'\v\vw.state.nj.us/dep/ srp-regs/scc)
Remediation Goal for Lead is based on the IEUBK model and the protection of children.
5. Remediation Goal for PCBs is consistent with EPA policy.
Remediation Goals based on Impact to Groundwater are from the following sources:
1. EPA Soil Screening Guidance: Technical Background Document (EPA540/R-95/128)
Office of Solid Waste and Emergency Response. May 1996.
2. New Jersey Department of Environmental Protection. Soil Cleanup Criteria: Impact to
Groundwater Soil Cleanup Criteria, (http://www.state.nj.us/dep/srp/regs/scc)
Footnotes:
• * Maximum Detected Concentrations present in this table, were those used for purposes of
risk assessment. Note that for some contaminants, higher levels were detected during the
Data Gap Investigation (see Table 2 for the Data Gap Investigation results).
• mg/kg: milligrams per kilogram, or parts per million
• NA: Value for this chemical is not available.
• NR: Negligible risk via this exposure route.
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Table 10
Summary of Cost Estimates for OU-3
Remedial Alternatives
for the
Imperial Oil Company/Champion Chemical Superfund Site
Alternatives
Alternative 1:
No Action
Alternative 2A:
Containment Alternative A
Alternative 2B:
Containment Alternative B
Alternative 2C:
Containment Alternative C
Alternative 3 :
Excavation/Off-site Disposal
Alternative 4:
Excavation/Treatment
Total
Capital Coat
$0
$14,942,000
$15,514,000
$13,111,000
$17,201,000
$38,131,000
O&M Cost
(Present Worth)
$295,000
$483,000
$563,000
$387,000
$9,000
$9,000
Net Present
Worth Cost
$295,000
$15,425,000
$16,077,000
$13,498,000
$17,210,000
$38,140,000
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APPENDIX A
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nf
* Christine Todd Whitman Department of Environmental Protection Robert e Shinn, jr.
Governor
SEP 2^ 1999
ivfs. Jeanne M. Fox
Regional Administialor
U.S. Environmental Protection Agency
Region II
290 Broadway
New York, N.Y. 10007-1866
Dear Ms. Fox:
The Department of Environmental piotection has evaluated and concurs with the selected remedy for tlic
Imperial Oil Company/Champitm Chemicals Superfund site as described below. This is llic third of three
planned operable units! for the Imperial Oil Company/Cliampion Chemicals site. The selected remedy
addresses the remediation of conlaminated soil and other conlamiralcd material (including waste filter clay
and free/residual oil product) located on the main site,
The major components of the selected remedy include the following;
• Dismantle site buildings and lank farms, as necessary
• Excavation of an estimated 83,000 cubic yards of soils containing contarmnaiits above the selected
wancdiatiou goals ;md disposal of this material at appropriate oU-site disposal facilities
• Transportation of an estimated 27.000 cubic yards oi the soil and other material which pose the
principal threat ("hot spots') to appropriate RCRA/TSCA hazardous waste disposal facilities
• Transportation of an estimated 56,000 cubic yards of soils containing contaminants above the selected
remediation goals to appropriate off-site disposal fiiciliiics. A portion of this material may be recycled
as asphalt base material.
• Removal of an estimated 5,000 gallons oJ' In* product via vacuum track and transportation of this
material to aTSCA licensed incinerator.
• Backfilling of all excavated areas with clean fill.
• Restoration of the wedands aflbcted by the cleanup activities,
The State of New Jersey appreciates the opportjjnjlyjsjjajticipate in Ihis decision making process and
looks forward to future cooperation with.the USEPA.
New Jimvy if »a Equal Opportunity Employer
Rtcyded Paper
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APPENDIX B
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IMPERIAL OIL CO./CHAMPION CHEMICALS SUPERFUND SITE
ADMINISTRATIVE RECORD- OPERABLE UNIT 3
INDEX OF DOCUMENTS
Pre-Remedial Investigation/Feasibility Study Documents
1. Remedial Action Master Plan, prepared by Fred C. Hart
Associates, 9/83
Remedial Investigation Documents
1• Health and Safety Plan, Imperial Oil Co., Inc/Champion
Chemicals Site, Monmouth County, New Jersey, prepared by
E.G. Jordan Co., 1/87
2. Quality Assurance Project Management Plan, Imperial Oil Co.,
Inc./Champion Chemicals Site, Monmouth County, New Jersey,
prepared by B.C. Jordan Co., 1/87
3. Remedial Investigation of Imperial Oil Co./Champion
Chemicals Site, Morganville, New Jersey - Final Report,
Volumes I & II, prepared by ABB Environmental, December 1996
4. NJDEP Data Gap Investigation Sampling, performed by NJDEP in
November 1996
5. NJDEP Waste Characterization Sampling, performed by NJDEP in
April 1998
Health Assessment Documents
1. Health Assessment for Imperial Oil Co.,Inc/Champion
Chemicals, CERCLIS No. NJD980654099, Marlboro Township,
Monmouth County, authored by ATSDR July 1990
2. Site Review and Update: Imperial Oil Company Site by
ATSDR,August 1992 and revised April 1993
3. ATSDR Exposure Investigation. Imperial Oil Co. Site,
June 1995
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4. ATSDR Public Health Consultation, Imperial Oil Co. Site,
April 1995
5. Addendum to the Risk Assessment for Imperial Oil, OU3i,
September 1999, USEPA
Floating Product Recovery Documents
1. Work Plan: Free-Phase Floating Product Recovery System,
Imperial Oil Co./Champion Chemical Co. Site, prepared by
EPA Removal Action Branch, April 1992
2. Summary of Work Conducted at the Imperial Oil Site by Handex
of New Jersey - November 1996 to June 1997
Feasibility Study Documents
6. Imperial Oil Treatability Study Report, prepared by USEPA
Office of Research and Development - Risk Reduction
Engineering Laboratory, August 1994
7. Final Source Control Feasibility Study, Imperial Oil
Company/Champion Chemicals Site, Morganville, New Jersey,
August 1998
8. Addendum to Source Control Feasibility Study by NJDEP,
January 1999
Proposed Plan Documents
1. Proposed Plan - Imperial Oil Company Superfund Site,
prepared by NJDEP March 1999
Record of Decision
1. Decision Summary for the Record of Decision - Imperial Oil
Company/Champion Chemicals Site, Marlboro Township,
Monmouth County, New Jersey - Operable Unit III, prepared by
USEPA, September 1999.
1. This document was prepared and issued concurrent with the
Record of Decision for OU3.
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APPENDIX C
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Responsiveness Summary
Imperial Oil/Champion Chemical Superfund Site
Morganville, New Jersey
As part of their public participation responsibilities, the
U.S. Environmental Protection Agency (EPA) and the New
Jersey Department of Environmental Protection (NJDEP) held a
public comment period from February 19 through April 6,
1999, for interested parties to comment on the Proposed Plan
for Operable Unit 3 (OU3) of the Imperial Oil Company
Inc./Champion Chemical Superfund Site (the site), located in
Morganville, New Jersey. The Proposed Plan described the
alternatives that EPA and NJDEP considered for remediating
contaminated soils and floating product at the site.
NJDEP held a public meeting at the Marlboro Municipal
Building on March 18, 1999 to discuss results of the
Remedial Investigation and Source Control Feasibility Study
(RI/SCFS) Reports and to present the NJDEP/EPA preferred
alternative for remediation of the site. During the public
meeting, representatives from NJDEP discussed the preferred
remedy, answered questions, and received oral comments on
the alternatives under consideration.
In addition to comments received during the public meeting,
NJDEP received written comments throughout the public
comment period. EPA's and NJDEP's responses to significant
comments, both oral and written, received.during the public
meeting'and public comment period, are summarized in this
Responsiveness Summary. All comments summarized in this
document were factored into EPA's and NJDEP's final
determination of a remedy for cleaning up the third operable
unit for the site. .The selected remedy for OU3 is described
in the Decision Summary of the Record of Decision for the
site.
This Responsiveness Summary is divided into the following
sections:
I. Overview: This section discusses EPA's and NJDEP's
preferred alternative for remedial action.
II. Background of Community Involvement: This section
briefly describes community relations activities for the
site.
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III. Public Meeting Comments and NJDEP's Responses: This
section provides a summary of major issues and concerns, and
expressly acknowledges and responds to all significant
comments raised at the March 18, 1999 public meeting.
IV. Response to Written Comments: This section provides a
summary of, and responses to, all written comments received
during the public comment period.
Appendix A: Transcript of the March 18, 1999 public meeting.
Appendix B: Written comments received by NJDEP during the
public comment period.
Appendix C: Proposed Plan.
Appendix D: Public Notice printed in the February 18, 1999
Asburv Park Press.
I. OVERVIEW
This is a summary of the comments and questions from the
public regarding the Proposed Plan, dated March 1999, for
remediation of the Imperial Oil Company/Champion Chemical
(IOC/CC) Superfund Site, and NJDEP's and EPA's responses to
those comments and questions.
At the initiation of the public comment period on February
19, 1999, NJDEP and EPA presented their preferred remedial
alternative to address on-site soils and floating product.
The preferred remedy to address these media includes: 1) the
excavation and appropriate off-site disposal of an estimated
83,000 cubic yards of contaminated soil and 5,000 gallons of
floating product; 2) soil recycling of a portion of the
83,000 cubic yards of soils in a permitted asphalt-batch
plant, where eligible; and 3) restoration of impacted
wetlands.
The preferred remedy differs from the remedy selected for
the site only with respect to some soil cleanup goals
applied to the cleanup. Modifications of the cleanup goals
presented in the Proposed Plan were made in the Record of
Decision in order to address concerns expressed during the
public comment period. The public expressed concerns that -
the proposed cleanup standards, which were developed to be
protective of human health and the environment for an
industrial use scenario, would not be sufficiently
protective, and cleanup standards which are protective for a
residential use scenario should be selected, allowing for
unrestricted future land use at the site. EPA and NJDEP
have agreed to address this concern in the selected remedy,
which selects cleanup standards for soils which would be
protective under a residential use scenario. Therefore, no
institutional controls relating to future land use will be
required.
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II. BACKGROUND OP COMMUNITY INVOLVEMENT
The RI/SCFS Reports and the Proposed Plan for the site were
made available to the public at the information repositories
for the site located at: Monmouth County Library, 1 Library
Court, Marlboro, New Jersey 07746: NJDEP, Bureau of
Community relations, 401 E. State Street, 6th Floor,
Trenton, NJ; and EPA, Superfund Records Center, 290
Broadway, 18th floor, New York, NY. The notice of the
availability of these documents was published in the Asbury
Park Press on February 18, 1999. The public was given the
opportunity to comment on the preferred alternative during
the public comment period which began on February 19, 1999
and concluded on April 6, 1999. In addition, a public
meeting was held on March 18, 1999 at the Marlboro Municipal
Building to answer questions concerning the site and the
remedial alternatives under consideration.
The IOC/CC site has consistently received attention from
area residents, municipal, state, county and federal
officials as well as the media. In 1981, concerned
residents organized the Burnt Fly Bog/Imperial Oil Company
Citizens Advisory Committee (CAC). The CAC includes citizen
representatives from Marlboro and Old Bridge Townships as
well as officials from Monmouth and Middlesex Counties.
NJDEP representatives have met regularly with this group
since 1981 and continue to do so. In 1998, the Monmouth
County Environmental Coalition (MCEC) received a Technical
Assistance Grant from the EPA to hire advisors to review
technical documents and to assist the group in understanding
the remedial activities at the site.
Issues voiced over the years by the CAC, the MCEC, and other
members of the community include the operating status of the
Imperial Oil Company, the potential for the IOC/CC site to
impact Lake Lefferts (located approximately 1.25 miles
downstream of the IOC/CC property) ,- the contamination of
off-site properties by the IOC/CC site; and the length of
time it has taken to investigate and remediate the site.
III. PUBLIC MEETING COMMENTS AND NJDEP'S RESPONSES
Questions or comments are summarized in bold, followed by
NJDEP's response.
Restricted vs. Unrestricted Use Standards
1. Numerous community members, including State Senator
John Bennett, Marlboro Township Mayor Matthew
Scannapieco, Monmouth County Health Officer Lester
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Jargowsky, representatives of the CAC and the MCEC,
stated strong opposition to the NJDEP/EPA proposal to
remediate site soils only to a "restricted use"
industrial cleanup criteria. Reasons for their
opposition included:
a) Zoning -the property is currently zoned
"commercial", which could result in future use of the
property being accessible to children;
b) PCB data - according to the RI data, PCBs are
generally found as a co-contaminant in waste oils, oil
saturated soils and with arsenic. The data also shows
that arsenic contamination in soils is more widespread
than other contaminants of concerns. Therefore, in
excavating the arsenic to the unrestricted cleanup
level of 20 ppm (as called for in the Proposed Plan),
it doesn't make sense to excavate PCBs to a less
stringent level than "unrestricted use" criteria; and
c) Proximity to residents - the site is surrounded by
residential areas and contaminated soil has the
potential to become airborne. Accordingly, any cleanup
level chosen other than the most stringent
"unrestricted use" criteria would be unacceptable.
NJDEP's Response: EPA policy is to select remedial
actions and associated cleanup criteria that are
consistent with current land use and most likely future
land use. The IOC/CC property has been an active
industrial facility since 1912 and continues today as
an industrial operation. The property is currently
zoned for industrial/commercial activities. No
information exists to indicate that the future use of
this property will change. Accordingly, cleanup
standards were proposed that reflected the current and
projected future land use of the site.
However, at the public meeting, NJDEP acknowledged that
all aspects of this comment, including the zoning
issues, the distribution of arsenic and PCB
contamination and the proximity of the site to a
residential area, would be fully considered by EPA and
NJDEP prior to a final remedial decision, and
acknowledged that this same comment had been repeated,
with much vigor, by numerous members of the community.
NJDEP also acknowledged that based on the spacial
distribution of contaminants which are largely driving
the cleanup at the site, namely arsenic and PCBs, it
appears that by remediating the arsenic contaminated
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soils to the proposed level of 20 parts per million
(ppm) and the PCBs to the proposed level of 13 ppm, it
was likely that all detected PCB contamination (soil
containing PCBs at levels greater than 1 ppm) was
likely to be addressed. The community agreed with this
determination, however, further requested that the
Record of Decision((ROD) guarantee that residential
standards be met for PCBs. Again, NJDEP indicated that
this would be further considered prior to selection of
.the final remedy.
NJDEP and EPA have evaluated this comment and those
submitted in writing which support this comment, and
have agreed to revise the PRGs to meet residential
standards. Please see the response to written comment-
2, of this document for a more detailed response.
2. Please explain the statement made to the Asbury Park
Press stating that if the township owns the (IOC/CC)
property in the future and wants to convert it to
unrestricted use, they (the township) can go and clean
it up further if necessary.
NJDEP's Response: The policy for both EPA and NJDEP is
to remediate sites to their "current" land use, or
reasonablely expected future land use. This statement
was made to explain that any future owner of any
contaminated site in New Jersey which has been cleaned
up to_restricted use conditions is entitled to perform
additional cleanup work to meet the "unrestricted use"
criteria which would render the site suitable for
unrestricted,future use.
3. What is the difference in cost between a residential
and industrial cleanup for PCBs?
NJDEP's Response: All available data for this site
indicates that remediating the arsenic to the cleanup
standard of 20 ppm (this standard for arsenic is the
same for both the residential and industrial use
scenario) and PCBs to the industrial standard derived
for this site of 13 ppm, is likely to result in the
remediation of PCBs to the federal unrestricted
standard for PCBs of 1 ppm as well. Based.oh available
data, wherever levels of PCBs are present above'
unrestricted use criteria (1 ppm), but less than
restricted use criteria (13 ppm), arsenic and/or other
site-related contaminants are also present in elevated
levels requiring remediation. Accordingly, cleanup of
these areas to achieve those contaminant criteria will
remediate the low level PCB contaminated areas by
default. Therefore, NJDEP does not anticipate that
-------
there will be any significant difference in the cost to
achieve residential (unrestricted) use standards verses
the cost to achieve industrial/commercial use standards
for the site. NJDEP indicated that the request by the
public to have the site remediated to meet residential
standards would be further considered prior to
selection of the final remedy.
NJDEP and EPA have evaluated this comment and those
submitted in writing which support this comment, and
have agreed to revise the PRGs to meet residential
standards. Please see the response to written comment
2 of this document for a more detailed response.
4. If there is no difference in cost to remediate PCBs to
an unrestricted use, the property is surrounded by
residential land, and there is the potential for water
to flow off the site, why would you not clean up to
residential standards?
NJDEP's Response: As stated in response #1,above, the
industrial standards were proposed based on the current
and expected future land use at the site. As stated in
response #3, above, it is expected that the PCB
contamination would be remediated to the unrestricted
use criteria of 1 ppm, even if the cleanup goal is the
industrial use criteria of 13 ppm, based on the known
spacial distribution of PCBs and other contaminants at
the site. However, that expectation is based on all
the sampling data obtained to date. During the actual
cleanup, additional samples will be obtained at the
bottom of the excavated area. These samples, referred
to as post-excavation samples, are obtained to insure
that no soil contamination exceeding the prescribed
cleanup goals remains. It is possible that one or more
of these post-excavation samples could exceed the
unrestricted use soil cleanup criteria for PCBs.
However, even if this were the case, the minimum depth
of the excavation will be three feet, meaning a minimum
of three feet of clean fill would cover the entire area
of contamination, which eliminates any direct contact
exposure scenario, regardless of the future use of the
site.
NJDEP and EPA have evaluated this comment and those
submitted in writing which support this comment, and
have agreed to revise the PRGs to meet residential
standards. Please see the response to written comment
2 of this document for a more detailed response.
5. Based on the discussions at this evening's public
meeting, will NJDEP recommend that the EPA use the
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state standards for remediation rather than the federal
standards and will NJDEP also recommend that the site
be cleaned up to unrestricted use standards? We do not
agree that the federal industrial standard of 13 ppm
for PCBs should be applied here rather than the state
industrial standard of 2 ppm.
NJDEP's Response: NJDEP's staff at this meeting will
emphasize to their management how emphatically everyone
at this meeting expressed their desire to see that this
cleanup result in the unrestricted use of the property.
Those comments and preferences for cleaning the site to
unrestricted use were considered prior to a final
remedial decision. For clarification purposes, with
respect to the use of a state versus a federal
unrestricted use standard, the federal unrestricted use
standard for PCBs is 1 ppm and the state standard is
0.49 ppm.
NJDEP and EPA have evaluated this comment and those
submitted in writing which support this comment, and
have agreed to revise the PRGs to meet residential
standards. Please see the response to written comment
2 of this document for a more detailed response.
If any contamination remains at the site at levels
higher that the state unrestricted use standard of 0.49
ppm for PCBs, but below the federal standard of 1 ppm
PCBs, the state of New Jersey will expend state funds
to remediate such soils. Therefore, the ROD guarantees
that unrestricted use of the property will be achieved.
6. How long until we (the community) hear feedback on
whether the decision to guarantee the cleanup of PCBs
to residential standards has been made?
NJDEP's Response: The official response will be made in
the Responsiveness Summary, which summarizes all
written and oral comments received during the comment
period. The Responsiveness Summary is part of the
Record of Decision which will be made public after .it
has been approved by the Commissioner of NJDEP and the
Regional Administrator of EPA, Region 2.
7. We (the MCEC) would like to be a part of the decision-
making process.
NJDEP's Response: MCEC is involved in the decision
making process. The MCEC's participation in reviewing
and commenting on the Proposed Plan and providing
verbal comments at the public meeting held on March 18,
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1999 is direct participation in the decision making
process, consistent with the NCP. In addition, the
MCEC has been involved in several previous meetings and
discussions with the agencies, involving a number of
site issues prior to issuance of the Proposed Plan.
Traffic and Safety Issues
8. Where will access roads for the construction phase be
built?
NJDEP's Response: For each of the traffic and safety
issues voiced at the public meeting, the NJDEP will be
seeking input from the appropriate local community
officials as well as impacted residents represented by
the MCEC and CAC throughout the design phase of the
selected remedy. In addition, the local officials will
be involved in the review and approval of pertinent
sections of the construction operations plans prepared
by the construction contractor, including the location
of any necessary access roads.
9. What are the plans to address fugitive dust on the
property during the construction phase?
NJDEP'8 Response: During a construction project, the
goal is to have no dust leaving the property. Dust
suppression measures, such as keeping the area wetted
down during excavation, can be used to achieve this.
Real-time aerosol monitors at the property boundary can
also be set up during certain periods of excavation, if
the site safety and health officer determines this is
needed. As indicated in Response #8, above, the NJDEP
will be seeking input from the appropriate local
community officials, as well as impacted residents
represented by the MCEC and the CAC throughout the
design phase of the selected remedy.
10. How will traffic safety issues, work hours, noise
control, etc. be addressed?
NJDEP's Response: As indicated in Response #8, above,
the NJDEP will be seeking input from the appropriate
local community officials (including Township public
safety officials) as well as impacted area residents,
and representatives of the MCEC and CAC throughput the
design phase of the selected remedy. Each of the
issues will be further addressed in the bid documents
for the construction contract. The construction
contractor selected, after open and competitive
bidding, will be required to submit the final traffic
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plan. In general, we expect that hours of operation
can be suitably restricted and other measures
implemented to satisfy community concerns with traffic
related safety, congestion, and noise.
11. What controls will be in place in the event of heavy
rains after the soil is excavated and prior to the area
being backfilled?
NJDEP's Response: An Erosion and Sediment Control Plan
which is acceptable to the County Soil Conservation
Service will be required as part of the design
documents and will be available for review by the
public.
Other Issues
12. Will the free product in excess of the 5,000 gallons
that is included in this alternative be left at the
site in the area of the hot spots?
NJDEP's -Response: Free and residual product
contamination will be removed in its entirety. It is
estimated that 5,000 gallons of free product will be
available for extraction via a vacuum truck during the
course of the excavation. All residual product
remaining "trapped" in the soil will be excavated and
properly disposed of as part of the planned soil
excavation. No threat to ground water will remain.
13. What standard, state or federal, was used at Burnt Fly
Bog and why?
NJDEP's Response: In general, the selected cleanup
criteria at the Burnt Fly Bog (BFB) site were driven by
the goals of (1) to remove the majority of visibly
contaminated soils and tars, and (2) to remove enough
material such that new wetland restoration can be
effectively implemented. Based on the nature and extent
of the contamination at the Burnt Fly Bog site, the
site was divided into 3 specific areas for purposes of
remedy selection: The Westerly Wetlands; the Northerly
Wetlands; and the Tar Patch Area. Because exposure to
the contaminants of concern, PCBs and lead, were
different in these three different areas, different
sets of cleanup standards were selected for the three
areas. The Westerly Wetlands will be remediated to a
level of 5 ppm PCBs and 8,950 for lead. These values
were developed based on a site-specific ecological risk
assessment. This area will be further addressed by the
installation of a fence and the anticipated sediment
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buildup from vegetative humification processes. For
the Northerly Wetlands, residential cleanup standards
of 1 ppm for PCBs and 400 ppm for lead were selected
because the Northerly Wetlands are more easily
accessible to trespassers. In addition, it will allow
most of the contamination to be excavated, thus
preventing the further spreading of PCBs and lead into
the Tar Patch Area and the Westerly Wetlands. For the
Tar Patch Area, the cleanup goal was based on visual
contamination instead of numerical cleanup levels.
However, excavation of this area is expected to meet
the residential soil cleanup goals of 1 ppm for PCBs
and 400 ppm for lead.
14. Is it possible that any part of this cleanup could be
delayed for long periods of time subject to
negotiations with the existing company that is on the
property?
NJDEP's Response: The necessity to cease the current
operations at the site during remediation will be
addressed during the remedial design phase. It is
anticipated that the property owner (Champion Chemical
Co.) will cooperate with the regulatory agencies in
achieving an effective remediation of the site in an
expeditious manner. This would include the property
owner's accommodation of the present tenant, Imperial
Oil Co., during the disruption of their operations
resulting from the unavailability of the site during
the remediation phase.
15. Was there any input from Imperial Oil Company in
developing the remediation options? Were their
business plans, in terms of vacating or moving the
operation, tied to the cleanup decisions being made?
NJDEP's Response: Imperial Oil was given a courtesy
copy of the Draft Source Control Feasibility Study
concurrent with the copies provided the local community
officials. Any comments received were considered in
the drafting of the Proposed Plan. The comments made by
Imperial Oil related to their ongoing operations or
inabilities to operate as a result of the proposed
cleanup will be addressed with the property owner
during the remedial design phase.
IV: RESPONSE TO WRITTEN COMMENTS
1. At the public hearing the NJDEP proposed to remove PCBs
to the "industrial level" of 15 ppm and stated that
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this would effectively produce a clean-up to the
residential level of 0.5 ppm. Has the NJDEP considered
the slope of the gradient of PCB contamination vs.
distance from the center of the PCB "hot spots" and the
quantity of PCB contamination left behind in the
annulus in the distance between the radius of a
concentration of 15 ppm and 0.5 ppm? If the slope of
the gradient is shallow at this point and the radius of
the "hot spot" is large, a substantial quantity of PCBs
may remain on the site. How can the NJDEP claim that
PCB removal to 15 ppm will effectively produce a clean-
up to 0.5 ppm? (from Old Bridge Environmental
Commission)
Response: A clear gradient of PCB contamination does
not exist at the site. Additionally, the RI data
indicates the "footprint" or areal extent of arsenic
soil contamination above the 20 ppm arsenic cleanup
criteria generally extends beyond the known areas of
PCB contamination that exceeds the EPA's unrestricted-
use criterion of 1 ppm for PCBs (NJDEP's unrestricted-
use criteria for PCBs is 0.49 ppm). Accordingly,
excavation of the arsenic-contaminated soil to meet the
cleanup goal of 20 ppm of arsenic is likely to
remediate the PCB-contaminated soils to meet both the
EPA's and NJDEP's unrestricted-use criterion. Based on
this determination, as well, as other considerations, as
discussed in the response to written comment 2, below/
EPA has agreed to select 1 ppm as.the cleanup goal for
PCBs in soils in the OU3 Record of Decision. If any
contamination remains at the site at levels higher that
the state unrestricted use standard of 0.49 ppm for
PCBs, but below the federal standard of 1 ppm PCBs, the
state of New Jersey will expend state funds to
remediate such soils. Therefore, the ROD guarantees
that unrestricted use of the property will be achieved.
Further, as a point of clarification, the federal
restricted (industrial) use standard for this site is
13 ppm for PCBs, the federal unrestricted (residential)
use standard is 1 ppm for PCBs. The State of New
Jersey's restricted use standard is 2 ppm for PCBs and
the state's unrestricted use standard for PCBs is 0.49
ppm.
Numerous letters were written in support of the
preferred alternative with the provision that the on-
site remediation result in the unrestricted
(residential) use of the property. Letters were written
by the following:
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Mayor Matthew Scannapieco, Marlboro Township
Lizabeth Poulson, Chairperson BFB/IO Citizens' Advisory
Committee
Tina Freedman, President, Monmouth County Environmental
Coalition
James Nicolard, Marlboro Township
Rachel Lulio, Marlboro Township
Editorials in support of cleaning up the site to
unrestricted levels were also written by the Asbury
Park Press and the News Transcript.
The community strongly feels that although the site
exists as an industrial area that lies in a C-2
commercial zone, the area surrounding the contamination
is residential. Therefore, residents should be
protected from any future adverse impacts that could be
caused by contamination remaining at the Imperial Oil
site.
Response: NJDEP's and EPA's proposal (as presented in
the Proposed Plan) to remediate the site to meet
industrial use, rather than residential use, standards
was based on the fact that the current and expected
future land use at the IOC/CC site is commercial-
industrial. Based on the concerns raised by numerous
members of the community, NJDEP and EPA have
reconsidered this proposal. Accordingly, the agencies
have selected a final remedy for the site which will
provide for the cleanup of this property to meet
federal residential standards. This decision is
supported by the fact that the site is located adjacent
to residential properties, as well ecologically
sensitive resources, including wetlands. EPA recognizes
that under current zoning, the. future use of the
property could include a variety of commercial uses
which could lead to a variety of different exposure
scenarios. Further, a review of the patterns of
contamination present in soils based on the data
collected at the site indicates that modifying the
remediation goals from the industrial use standards to
federal residential use standards is not expected to
significantly increase the amount of soil to be
excavated or the cleanup costs.
Comments submitted by Cody Ehlers Group on behalf of the
Imperial Oil Company, Inc. and the Champion Chemical
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Company.
1. The Source Control Feasibility Study (SCFS) does not
reflect the extent, scope and location of the
contamination in order to justify the extensive
excavation and the potential effects on existing
facility operations called for in the remedy selected.
Response: The goal of the SCFS is to identify and
evaluate remedial alternatives for consideration in the
remediation of the site. Therefore, the SCFS provides
only a limited summary of the investigative efforts
carried out by NJDEP and EPA to characterize the nature
and extent of contamination at the site. As indicated
in the Proposed Plan, all readers/reviewers of the SCFS
and the Proposed Plan must refer to the complete
Administrative Record, which includes the Remedial
Investigation Report and all other historical reports
and data upon which this remedial decision is based.
The documents comprising the Administrative Record
fully support the selected remedy. The locations of the
Administrative Record for the site were provided in the
Proposed Plan for this Operable Unit.
2. The SCFS does not present any chemical data for the
product at the Site. This data should be collected so
that appropriate methods of product removal can be
identified and evaluated.
Response: The overall purpose of the SCFS is to
evaluate and screen various alternatives for addressing
the contaminated soil found on the Imperial Oil site.
It also summarizes chemical and other data that are
contained in the Remedial Investigation (RI) Report for
the site. Chemical data and other information
regarding the floating product have been collected and
are summarized in the December 1996 Remedial
Investigation Report for the site. Further, chemical
data and other information regarding the floating
product is presented in a report dated June 22, 1997,
which was prepared by a NJDEP contractor, entitled
"Summary of Work Conducted at the Imperial Oil Site by
Handex of New Jersey - November 1996 to June 1997"
(Handex Report). The RI Report and the Handex Report
are included in the Administrative Record for the site.
EPA and NJDEP have extracted, stored, sampled and
disposed of approximately 15,000 gallons of floating
product at the site since 1991. The chemical data and
physical properties of the product were fully evaluated
before an appropriate method for addressing the product
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was identified. Based on this information, EPA and
NJDEP believe that the excavation and disposal of the
product are the appropriate methods for addressing this
major source of soil and groundwater contamination.
During the remedial design phase, details regarding the
implementation of this portion of the remedy will be
developed.
3. The Preliminary Remediation Goals (PRGs) used should be
revised to conform with NJDEP and EPA guidelines and
practice regarding the remediation of industrial sites
and with the National Contingency Plan.
Response: The PRGs that were developed for this site
are consistent with the NCP and EPA policies. The PRGs
were developed in accordance with the EPA's December
1991 - A Risk Assessment Guidance for Superfund:
Development of Risk-based Preliminary Remediation
Goals, and other guidances. The PRGs are protective of
the groundwater underlying the site and will meet
• federal residential use standards. As stated earlier
in the Responsiveness Summary, EPA and NJDEP have
modified the PRGs presented in the Proposed Plan ,
which were developed to meet industrial use standards,
in order to meet residential use standards. This
decision is supported by the fact that the site is
located adjacent to residential properties. Further, a
review of the patterns of contamination present in site
soils based on the data collected at the site indicates
that remediation of this site to meet residential
standards is not expected to significantly increase the
amount of soil to be excavated or the cleanup costs
compared to a remediation to meet industrial standards.
Please see the response to Comment 2, above, for more
information.
4. In order to not be inconsistent with the NCP and with
EPA guidelines on land use assumptions, the SCFS and
Proposed Plan should be revised to include an
evaluation of remedial action alternatives that use
institutional controls based on an industrial use
exposure scenario.
Response: The No Action alternative presented in the
SCFS was developed, as required by the NCP, to be
considered as a baseline for comparison with other
remedial action alternatives. This alternative would
include institutional controls to restrict the future
use of the site. However, based on the results of the
risk assessment performed for the site, this
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alternative was determined to be not adequately
protective of human health and the environment.
The SCFS also included an evaluation of a "Minimal
Action" alternative, which was screened out prior to
detailed analysis because it did not achieve the
minimal threshold criteria of "Overall Protection of
Human Health and the Environment". The Minimal Action
alternative included fencing to prevent the public from
coming into contact with contaminated soil and sediment
on-site. However, contamination originating from
sources on-site would continue to migrate into off-site
areas by means of soil and sediment erosion and ground
water transport. Allowing contamination to migrate
unimpeded into off-site areas would result in the
accumulation of contamination in depositional areas and
the spreading of contamination into presently
unaffected areas. Consequently, human and ecological
receptors in off-site areas would be subjected to
increasing risk as the contamination spread into areas
of un-impacted habitat and/or that experience greater
public use. Therefore, retaining the Minimal Action
alternative for detailed analysis could not be
justified.
The SCFS should be revised to reflect an acceptable
carcinogenic risk range of 10"4 to 1(T6; not NJDEP's
target carcinogenic risk of 10'6. Spending additional
funds to remediate this site to cleanup levels that are
more stringent than those used to remediate other
CERCLA sites is not justified.
Response: The Risk Assessment performed for the IOC/CC
site is presented in the December 1996 RI Report. A
portion of the Risk Assessment was revised and
presented in the September 1999 Risk Assessment
Addendum (OU3). The Risk Assessment and Addendum were
developed in accordance with EPA's guideline for
conducting risk assessments and, thus evaluate
carcinogenic risks relevant to EPA's acceptable
carcinogenic risk range of 1Q~4 to 10~6. Non-
carcinogenic risks were evaluated as well in the Risk
Assessment. For a number of exposure scenarios
evaluating in the Risk Assessment and Addendum,
carcinogenic risks related to on-site soils at the
IOC/CC site were higher than 10~4, the high end of
EPA's acceptable risk range. Therefore, it is clear
that remediation of the soil is warranted.
If it is determined, based on the results of a risk
assessment, that remediation is warranted at a site,
cleanup levels are generally developed which are
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protective of human health based on the 10"6
carcinogenic risk criteria. The PRGs for the IOC/CC
site were developed in accordance with EPA's
guidelines. The PRGs were derived to assure protection
of groundwater underlying the site as well as
protection from unacceptable risks posed by direct
contact with contaminants in the soil. Further,
residential land use was considered in developing the
PRGs, as explained above in this Responsiveness
Summary. The PRGs selected are consistent with CERCLA,
and appropriately reflect assumptions that are relevant
to the IOC/CC site.
6. NJDEP needs to explain the specific changes made to the
1990 risk assessment that led to the substantial
changes and the unacceptable risks reported in the 1996
risk assessment.
Response: The 1996 version of the risk assessment was
updated to include the on-site residential future use
scenario and to eliminate the exposure route of
inhalation of dust from the on-site waste pile. In
addition, the "Most Probable Case" and the "Realistic
Worst Case" were changed to the "Average Exposure" and
the "Reasonable Maximum Exposure." Updates to EPA risk
assessment guidance between 1990 and 1996 were
accounted for and incorporated into the risk
assessments for the site. The risk assessment for the
site is presented in the December 1996 Remedial
Investigation Report. EPA and NJDEP believe that the
changes made to the risk assessment calculations did
not alter the fact that the contaminants found in the
soils of the Imperial Oil facility pose an unacceptable
risk to human health and the environment.
Further, in August 1999, it was determined that some
errors were made in developing the carcinogenic and
noncarcinogenic quantitative risks. These errors were
corrected in the September 1999 Addendum to the Risk
Assessment (OU3), which has been included in the
Administrative Record for this site. Note that the
errors resulted in modified risk numbers, but did not
effect the summary of site risks which indicates that
contaminated site soils present an unacceptable risk to
human health and the environment. The quantified risk
was still outside of EPA's and NJDEP's acceptable risk
criteria.
7. The December 1997 draft SCFS refers to EPA site-
specific criteria in Table 4-1 as "Site-Specific
Criteria transmitted to NJDEP on January 23, 1997".
The supporting documentation should be included as an
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appendix and the methods and assumptions used to
develop these criteria should be presented in the SCFS.
Response: A number of guidance documents, including the
document entitled "A Risk Assessment Guidance for
Superfund: Development of Risk-based Preliminary
Remediation Goals" (RAGS), were used to develop the
site-specific cleanup criteria for the site. RAGS
contains methods and assumptions-used to develop the
"Site-Specific Clean up Criteria" for the site. The
document was described in the March 18, 1999 Proposed
Plan and August 31, 1998 Final Source Control
Feasibility Study Report. Therefore, EPA and NJDEP do
not believe that it is necessary to include the
document as an addendum to the SCFS.
In September 1999, EPA prepared an Addendum to the Risk
Assessment (OU3). In this addendum, EPA modified the
risk numbers for a number of contaminants and also
developed some modified cleanup numbers based on an
assumed residential use of the property. In doing this
EPA employed the following guidances:
a) Risk Assessment Guidance for Superfund, Volume I -
Human Health Evaluation Manual (Part B, Development of
Risk-Based Preliminary Remediation Goals) Interim
(EPA/540/R-92/003) Office of Research and Development.
December 1991.
b) US EPA Region IX Preliminary Remediation Goals;
Residential Soil - Integrated Pathway; August 4, 1999
c) Remediation Goal for Arsenic is based on New Jersey
Statewide Background Concentration
(http://www.state.nj.us/dep/srp/reas/scc)
d) Remediation Goal for Lead is based on the IEUBK
model and the protection of children.
e) Remediation Goal for PCBs is consistent with EPA
policy.
f) EPA Soil Screening Guidance: Technical Background
Document (EPA540/R-95/128) Office of Solid Waste and
Emergency Response. May 1996.
g) New Jersey Department of Environmental Protection.
Soil Cleanup Criteria: Impact to Groundwater Soil
Cleanup Criteria.
(http://www.state.nj.us/dep/srp/regs/scc)
8. The draft SCFS assumed the site would be used for
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residential purposes in the future and therefore some
of the most cost-effective methods, such as deed
restrictions, to address potential risks at the site
were not adequately evaluated.
Response: All cleanup criteria and alternatives
considered for the site in the final SCFS were based on
the future use of the site remaining industrial.
However, based on EPA's and NJDEP's evaluation of all
comments received during the public comment period, the
preferred alternative for addressing the soil
contamination will meet PRGs that are protective of
residential, as well as industrial use of the site.
Therefore, institutional controls will not be required
to regulate future land use. A deed restriction alone
was evaluated in the SCFS, as part of the No Action
alternative, and was determined not to be protective of
human health and the environment. Deed restrictions
would not be effective in addressing site-related risks
resulting from the continued migration of uncontrolled
contamination from soils and floating product.
Therefore, EPA and NJDEP believe that the preferred
alternative for remediating the site is most cost-
effective method for addressing the risks associated
with the site contaminants.
9. The SCFS states that technologies that specifically
address the recovery and/or the removal of free and
residual product are not identified in the document
because of the high viscosity of the free product and
the low soil permeability. As a result, the only
approach evaluated in the SCFS to address free and
residual product was excavation. The Proposed Plan
should be revised to evaluate: 1) vacuum enhanced
product removal as a component of an industrial use
alternative to address the presence of free and
residual product; and, 2) installation of a modified
cap over soil in the product and other site areas to
address direct contact exposure risks that remain.
Response: (1) Vacuum enhanced removal of the free
product was evaluated by the NJDEP and USEPA, prior to
the SCFS, when the agencies were conducting an
engineering evaluation of the existing Floating Product
Recovery system. This evaluation was completed by
Handex Inc. under contract to the NJDEP. During this
evaluation, Handex evaluated several technologies for
enhancing product removal, including vacuum enhanced
extraction. Handex concluded that vacuum enhanced
extraction could not improve the effectiveness or
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efficiency of wellpoint extraction of this product due
to the extremely high viscosity of the product and the
unusually low permeability of the "filter cake"
material. The agencies did replace the extraction
pumps in the recovery system which did improve system
operation. The results of Handex's efforts were
conveyed to the Department's contractor who was hired
to conduct the SCFS. Accordingly, vacuum enhanced
product removal was quickly screened out of the
alternatives evaluation. Overall, the agencies
determined that the most cost effective solution, over
the long-term was excavation of the product area to
provide direct access to both free and residual product
and saturated filter cake material.
2) With respect to the second part of this comment
related to capping, the three containment options
evaluated in the SCFS did include various capping
options. The agencies are confident that the 'three
sets of containment options evaluated in the report
adequately provide a reasonable analysis of the
containment technology.
10. Since arsenic and other inorganic constituents are not
present in site ground water in concentrations that
require remediation, the sole reason for remediating
the arsenic-containing soil in the tank farm area is to
prevent direct contact. This can best be achieved by
maintaining the site for industrial use and by
installation of a modified cap.
Response: Extensive arsenic contamination of the .
groundwater underlying the site is well documented in
the RI Report. Data presented in the 1996 RI Report and
summarized in Table 13-25 of the RI Report, clearly
show impacts to on-site ground water by arsenic
contaminated soils at the site (with on-site soil
levels of arsenic as high as 6,120 ppm. The arithmetic
mean concentration of arsenic in on-site groundwater
samples is 14,082 ppb, with a maximum concentration of
71,200 ppb. For wells on the IOC/CC property,
carcinogenic risk from ingestion of ground water was
estimated at 8xlO~01 and greater than unity for the most
probable and realistic worst case scenarios,
respectively. These risk greatly exceed EPA's and
NJDEP's acceptable risk criteria. Therefore, EPA and
NJDEP have determined that it will be necessary to
remediate arsenic-contaminated soils, as well as site
soils impacted by other contaminants, not only to
address direct contact risks, but also.to mitigate
impacts to ground water through source removal.
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11. The risks to human health and the environment posed by
the preferred remedial action should be accounted for
and defined in the SCFS and in the Proposed Plan to
properly evaluate these alternatives.
Response: Risks to human health and the environment
posed by all remedial alternatives are evaluated in the
SCFS process under "short-term effectiveness", one of
the five primary balancing criteria. Short-term
effectiveness addresses the period of time needed to
achieve the selected cleanup and any adverse impacts on
human health and the environment that may be posed
during the construction and implementation period,
until cleanup goals are achieved. As stated in the
Proposed Plan, the selected alternative, Alternative 3
provides the greatest overall short-term effectiveness
compared to the other alternatives, primarily because
the work can be completed in the shortest amount of
time. Risks to human health and the environment posed
by all alternatives are outlined and accounted for in
the Proposed Plan, as well as mitigative measures
necessary to address any risks. Short-term risks posed
by the selected remedy can easily be managed through
the implementation of a site-specific Heath and Safety
Plan to be developed during the remedial design phase.
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Appendix A
Transcript of Public Meeting
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IN THE MATTER OF:
IMPERIAL OIL SUPERFUND
SITE
TRANSCRIPT
OF
PUBLIC MEETING
PLACE: Marlboro Township Municipal
Complex
Marlboro Township, New Jersey
DATE: March 18, 1999
PRESENT:
EDWARD PUTNAM, ASSISTANT DIRECTOR, NJDEP
JOSEPH MAHER, SITE MANAGER, NJDEP
MARK STEIMACK, PROJECT MANAGER, HARDING LAWSON ASSOCIATES
ALSO PRESENT:
TREVOR ANDERSON, USEPA
KIM O'CONNELL, USEPA
STEVEN BYRNES, NJDEP
MINDY MUMFORD, NJDEP
DAVID VAN ECK, NJDEP
Transcriber Beatrice A. Creamer
J & J COORT TRAHSCRIBERS, IHC.
268 Ev«rgr««n Avanu*
Hamilton, M«w J«r»«y 08619
(609) 586-2311
FAX MO. (609) 587-3599
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MR. PUTNAM: Good evening. We appreciate the
interest. Tonight we're specifically here to talk about
Operable Unit 3 for the Imperial Oil Champion Chemical site.
We've placed a couple of poster boards up here to try to
indicate the different operable units because obviously we're
up to three now. But we do specifically have to just talk
about three tonight. We will all still be available after the
formal meetings end and the stenographer is turned off and we
can answer any and all questions related to the other aspects
of the case. But I need to get the Operable Unit 3 discussion
*
finished and settled before we move on to anything else.
There were two handouts in the back and a sign-in
sheet. The first is the agenda and it has with it attached a
summary of the alternatives for a quick reference summary. The
full proposed plan is also back there and you can read at your
leisure. The comment period right now extends to April 6.
We're taking oral comments here tonight and they'll be recordec
and put into the formal responsiveness summary, and we will be
taking written comments up until April 6th also.
I'm going to try to get through the up-front stuff as
quick as possible and get through the presentation. Please
hold all your questions until the end and then we're here the
rest of the night to answer questions.
A quick reminder, there is a technical assistance
grant awarded on this site to the Monmouth Environmental
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Coalition. That grant is.approximately $50,000 from the
Environmental Protection Agency to enhance the citizen
participation in the program. So if you are interested in
joining that group, Tina Freedman is present. She's here.
Just to let you know, as you can see we've got a whole crew up
here of DEP people and we have some EPA people in the audience.
And with that, let me get right to turning it over to Joe Maherj
to start off the presentation. Joe.
MR. MAKER: Okay. Mark, I think you can just —
let's just flip through these three slides on the operable
units and let'.s just go the site location map to orient-
everybody with regard to where Imperial Oil is. Can everybody
see that slide? Okay. That's better. Can you hear me new?
As you can see, the site is bordered by Greenwood
Road, Texas Road, Tennant Road and Route 79. The entrance to
the site is just off of Tennant Road onto a little spur of the
street there known as Orchard Place, sometimes known as Orchard
Street. Go the next slide there. Let's just take a look at
the actual site itself. As you can see here to the left,
Tennant Road, there's the entrance onto Orchard Place. The
outlined area that you see there, the entire site is about 15
acres, but the active portion of the site is about 4.2 acres.
ThiS — yOU can see a number of buildings. There's
approximately seven buildings there. Those are for the
administrative offices and the operations of Imperial Oil, the
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current tenant of the facility. The site itself is actually
owned by Champion Chemical Company. The shaded areas that you
see there are a number of tank farms. Those are above ground
storage tanks. Imperial's operation is — they don't really
manufacture anything. It's one of oil blending and they bring
in basically clean oils, store them in those above ground
storage tanks and basically blend that to meet a particular
customer's specifications.
The 4.2 acres is fenced. At the top of the slide
there, you can see that the site is bordered by an abandoned
railroad there. I.don't know if you can distinguish, but "up in
the right-hand corner, would be the northwest corner, you see
three yellow blocks there designated as oil* water separators.
That's the low area of the site. There is a berm between the
fenced in area there and what you see is the blue-shaded area.
That berm wasn't always there and that's, you know, caused a
problem early on where contamination has run off the site into
the water body and has traveled downstream. But the oil water
separators are there to — in heavy rainfall events there's the
potential for residual contamination to picked up there and
they go through that oil water separator. The oil is separatee
out. It's properly disposed of. The water that's collected
goes through a little treatment system that Imperial Oil
operates under a permanent discharge and intermittently as need
discharged into that stream.
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With regard to the site history, this place nas r-n
home to a number of manufacturing facilities since about ^T
3 || From 1912 to about 1950, some of the manufacturing thing, cone
4 there were tomato paste and ketchup. The brunt of that period
5 IIof time there were two different chemical companies that dealt
6|in arsenical based products, arsenic based products
7 manufacturing there. And for a short period of time, flavors
8 and fragrances were manufactured there.
9 II Champion Chemical bought the site in 1950 for the
lOJIpurposes of doing oil waste recycling and oil waste recycling
11 was done there from 1950 to approximately 1965. They brought
12 in waste oil and through a filter medium known as filter clay
13 I or diatomaceous earth and a caustic solution in various tanks,
they took out the impurities of the waste oil, recovered the
15 Jj oil.and unfortunately the waste products from that a let of it
16 was disposed of at the site. In 1969 Imperial Oil, the present
17 operator of the facility, leased this property from Champion
13 Chemical and they're the current operator there.
19 With regard to how the State of New Jersey got
involved in this site, many, many years ago it was alleged that
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Imperial Oil was a potential responsible party, if you will
Materials were alleged to have left the Imperial Oil site and
deposited on another Superfund site not too far away. Some
people are familiar with the Burnt Fly Bog site which is about
three miles away. Based on that, the State did some initial
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investigations. We did in fact determine that there were heavy
metal contamination and PCS contamination. It's typical of the
way we discovery many of our sites. And normally the first
course of action when we — when we identify a site like this
as contaminated, we would normally attempt to negotiate with
the potential responsible parties to get them to take an
action, to investigate the site and ultimately to remediate the
site. Many times, including this particular case, it's rather
complicated. There were various owners/operators of the site.
And rather than go through protracted legal negotiations to try
to reach a settlement up front, luckily for the public we"have
a program called the Superfund Program where federal dollars
are available to states to go in there, investigate the sites,
clean them up and worry about cost recovery later. And that's
in fact what we dia at this particular site.
We applied to get on the national priorities list of
Superfund sites. We successfully did that. That entitled the
state to get money and with that money we performed what we
term a remedial investigation and feasibility study. And with
that, I'd like to turn it over to our contractor. With the
money we got from EPA we contract out that work to an
engineering firm. In this particular case, it was a company
called E. C. Jordan from Portland, Maine. They're now known as
Harding Lawson Associates. And I'd like to turn it over to
Mark Stelmack who's the project manager for the Imperial Oil
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site with Harding Lawson Associates.
2 MR. STELMACK: As Joe mentioned, my company performed
3 remedial investigation feasibility study for the site ^and I'll
4 just briefly run through the steps of the RI process, some of
which are shown on the slide. I don't know if you can read the
words from there.
But first of all, it says conduct field
investigation. We went out and collected samples from the
site, soil samples, literally hundreds of soil samples
collected across the site, sent these samples out to a lab for
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analysis of their -chemical content. We sampled the soil at
various depths across the site ranging from ground surface to
13 as deep as 25 feet below the ground surface. Once the lab
reports came back, we were able to find the nature and extent
of contamination. We knew the types of chemicals that were
there. We knew the levels and we knew the depth, vertical
extent and the horizontal extent in the area.
13 At the same time, we also researched and identified
19 the different regulations, both federal and state, that would
20 — we would need to adhere to when we began the cleanup,
21 compiled those and published those in both the RI report and
the feasibility study report. For example, wetlands
regulations, they play an important part here because there are
wetlands on the site. We had to identify which wetlands
regulations we would need to conform to given he various
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cleanup activities that would occur. Also during review of the
federal regulations during the feasibility study phase we
compared the contaminant levels to the site cleanup criteria
that was developed by the EPA for the site and that -- used to
determine the extent of the cleanup, and those numbers are
published in the proposed plan before — also during the
remedial investigation conducted a baseline risk assessment to
determine the impacts or risks to both human health and
ecological receptors or — habitat that inhabits the site. Anc
the general conclusion was that there are risks to both human
health and the environment that would need to be addressed.
Next slide — results of the remedial investigation
allowed us to -define the principal areas — contamination which
is identified in the tan colored area on this slide. In
includes the lighter of the gray area. The gray areas —
facility, which are the four tank farms, also includes on the.
northern — or actually the western part of the site — the
former waste pile, arid several isolated locations where fill
was brought in during activities on the site, non-native
material scattered about — different locations across the
site. There are a host of different contaminants or chemicals
in the soil — Imperial Oil. The three primary contaminants
found in the larger extent than others, and the three that
would drive the cleanup, are PCBs, arsenic and waste oil
related organics, otherwise known as TPH, or total petroleum
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hydrocarbons.
Next slide, please. We then moved into the
feasibility study portion of the - of the process, which is
basically the preliminary engineering phase where we look at
the different cleanup options. We start by identifying
remedial action objectives, which were basically our goals,
what did we want to accomplish when we — when we clean up the
site. Our next slide, which we won't show just yet, but has a
synopsis of what those remedial action objectives are. We the
identified potential technologies for containment, treatment
and disposal of the waste, containment being one technology
-rhere we would take the waste, this contaminated soil, and
basically encapsulate it, put it in a cell, or a box if you
will, and it has a cover -- sides and the bottom on it, and
store it on site. Treatment of the soil was another technclog-
we looked at, basically cleaning up the soil such that it wcul:
be rendered clean and would be able to be returned to the site
We also looked at off-site disposal of the waste, basically
putting the waste into trucks and then trucking it off to a
licensed off-site disposal facility.
After identified those technologies we screen them
based on their ability to perform the task, and the criteria w
used were effectiveness, implementability and cost. And the
ones that best met those criteria we retained for further use
and then the ones that didn't quite meet those criteria were
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limited effectiveness, basically means how well — to meet our
remedial objectives. Implementability is another word for the
ease that ~ which you could institute these alternatives. Do
you need a lot of equipment? Do you need a lot of labor? Do
you r.eed a lot of room on the site? That kind of thing. And
also we looked at the cost. Obviously the ones that were very,
very costly would be most apt to be screened out.
We then — we then took the technologies that were --
remained after the screening and formulated them into what are
called alternatives, or options. And having developed those
alternatives we performed a detailed analysis of those
alternatives based on certain criteria developed by the NPA
would be — I'm showing those on the slide coming up. And then
from the detailed-analysis of the alternatives we were able to
select — alternative which we would be presenting later in
this presentation.
Next slide — remedial action objectives or the goals
for the cleanup at Imperial Oil were basically to prevent human
and ecological exposure to site contaminants, prevent human
contact to the site contaminants and contact by wildlife that
inhabit the site, and also to prevent further migration or
spreading of the site contaminants. Some of the spreading may
be caused by wind or water erosion or leaching of the
contaminants down into the ground — table. Next slide.
The soil remediation alternatives that we developed
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can* be grouped into four different categories, first one ceing
no act-ion. Under Superfund law we have to look at the no
action site. We kind of look at that to basically not
addressing the problem directly but monitoring the site —
keeping a watch on it, kind of a baseline alternative that we
could use to compare the other ones. Second category was on-
site containment options, as I — as I mentioned before,
basically encapsulating this contamination site.
Third category is off-site disposal — use, trucking
the waste off site to license disposal facilities and if
possible using the soils to be reused in other ways. One of
the ways we can possibly use the soil under a reuse alternative!
— Imperial Oil soil is to send it to an asphalt batching off
site where it can be used in an asphalt batching process to
make asphalt and build roads with it. Fourth category is
treatment, and basically using the state-of-the-art, latest:
technologies for cleaning up chemicals in the soil, rendering
them clean and being able to put the,soil back on the site.
The different alternatives that we developed and
evaluated, again, no action is alternative number one. There
are no actions in this alternative that would directly address
the soils themselves — there's no treatment, there's no
covering, there's no capping. Basically we would be monitorinc
- and the sediment over a 30-year period. ~ possible that
alternative, in today's dollars, is $295,000. Next slide.
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The next thres slides are the three different
containment options that we developed and evaluated. First one
is alternative 2a — probably be stricken, containment. You
would excavate the soil on the site and encapsulate it in a
cell which would isolate it from the environment without a lot
of moisture to get into the contamination, nor would it allow
the contamination to get out. It would prevent contact with
the — with the chemicals in the soil. We would be building
that in approximately three-acre size in this alternative. And
as I — as I may have mentioned, the cover would be made out of
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clay, a combination of clay and synthetic material such as a
plastic, and it would have sides and a bottom liner to it in
this alternative.
Second action in this alternative is to take —
determining the hot spot soil, which is the most heavily
contaminated soil, which reps about a third of the total soil
mass in volume. And we would not encapsulate that in a cell on
site, we would take that hot spot soil and dispose of it off
site, transport it and dispose of it off site — licensed off
site — facility. Cost of that alternative is about 50.4
million dollars.
The second containment alternative, alternative 2b,
is termed expanded containment, very similar to 2a, the main j
difference being that the on-site containment cell is the
largest cell, it would be spread over five and a half acre area
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rather than a three-acre area, resulting in a lower profile of
the finished cell. The approximate height of the sale in this
alternative is about 15 feet above the ground, whereas the
height of the cell — 2a is approximately 30 feet, so it's
twice as high when completed. And, we would be taking one --
approximately one third of the soil, which is the hot-spot soi
in this alternative in transporting and disposing of it on
site. Cost of this alternative, approximately the same as 2a,
16 — just -- 16 — the third containment alternative is
alternative 2c, called- in place containment. Unlike 2a and 2b
this one only has .a cover over the top. There is no bottom
lining to this alternative, therefore it's not quite as
protective — would prevent moisture from seeping in from the
top — the wastes in the soil on the site is still being—
come in contact — ground level. And also similar to 2a and 21
we 'would — we would be excavating the hot-spot soil, disposing
it off site. This one's a little bit cheaper because it
doesn't have the bottom liner, approximately 13 and a half
million dollars.
Alternative three, moving away from the containment
alternatives and getting into the off-site disposal for use,
you would estimate the contaminated soil and remove it from th
site in it s entirety. The hot spot soil would be removed to
licensed — site landfill facility. The remaining two thirds
of the more likely candidates would be shipped off to what's
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term a special waste camp going. And a portion of that
industrial waste, landfill waste, if possible as I mentioned
before we would try to reuse that — send it most likely reuse
candidate at this time would be an asphalt — point, given the
preliminary data that had, at this point chemical data,
chemical data, we think approximately one quarter of the
lightly contaminated soil my be available for use in an asphalt
batching firm. Cost of that alternative, not much more than
the containment alternative, 17.2 million dollars.
Last alternative that we looked at in detail is the
treatment alternative. We would basically build a soil
treatment facility in a building on site, treat the soil,
excavate the soil, treat it in the — in the facility and
return it back to the ground at the site. The treatment that
we identified that would be most likely to be able to handle
the wide range of chemicals on the site is termed metallurgical
extraction. It's a two-phase treatment process, the first
phase being soil washing operation where the larger soil
particles are cleaned, and the second phase being extraction
phase where the smaller particles are cleaned.
The treatment alternative has several serious
implications, one of which is — requires a lot of — quite a
lot of space on the site to build treatment equipment. It
would also be fairly noisy and would have to run approximately
— approximate — it would have to run 24 hours a day,
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something to be considered as far as impact to residents in tha
area,-not to mention the cost of this treatment alternative,
approximately twice that of alternatives two and three.
They're around 38 million dollars. And again, these costs are
ery — they're preliminary in nature. They're — we're in a
preliminary,engineering phase of the evaluations, and these
costs could vary when it comes time to build or actually put
the alternative into place. But relatively speaking they give
you a fair idea of the — of' the cost for treatment versus
containment. Next slide.
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The criteria that we used to evaluate these
alternatives and help us select a preferred alternative are
ths4e nine that are listed here. And these are suggested or
ublished as guides — guidelines by the USEPA and they're used
nationwide in Superfund sites to evaluate alternatives. And
I'll go over them very quickly, the first one being overall
protection of human health and the environment, how well dees
the alternative protect human health and ecological receptors
or wildlife at the site. Second criteria is how well does it
comply with the federal and state regulations and guidelines.
Third criteria is- its long-terms effectiveness and permanence,
in other words, how well does it meet your cleanup objectives
or response objectives, and is it — is it a permanent solutior
or are you leaving some of the waste on site that has to be
monitored over a period of time.
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Fourth criteria is does it — does the alternative
reduce the toxicity, mobility or volume of the contaminants
through treatment? Some of the containment alternatives don't
include treatment. The filth criteria is the short-term
effectiveness. That's another term for how much impact does it
have on the community during its implementation/ is it going to
be noisy, is it going to — are there going to be a lot of —
truck traffic generated, dust, oiling, that kind of thing.
Also protection of workers during the clean up is — is a
factor in short-term — implementability is another criteria.
Are the materials.available to perform the cleanup? If it's a
technology that needs special equipment is it available? How
much spice is needed on the site, how much labor is needed, is
the labor available — costs comes into play. And the last two
are support agency acceptance, and the very last one, cor-jnunit>
acceptance, how well is the alternative received by the
community, and it's part of — tonight is to solicit brief
comments on the — preferred alternative — on the other ones
that we've looked at.
I believe the next slide gets into the preferred
alternative, which Joe will describe in a little bit more
detail.
MR. MAKER: Okay. The proposed plan that everybody
picked up in the back, as you can see/ the State and EPA's
oreferred alternative is alternative three. Unlike many sites
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tha*t we end up evaluating th seems to be the obvious choice.
When you evaluate all the available info with -- it definitely
provides the best balance of all the criteria that were just
explained. It provides the best short-term effectiveness. It
can be implemented in the quickest amount of time compared to
the other alternatives. We estimate probably once we had
approval to go forward, after the thing is designed and we're
ready to actually start construction, the implementation time
would probably be about 11 to 12 months compared to twice that
amount, of time for the other alternatives.
It also provides, we feel, the best long-term
effectiveness. Although the treatment alternative would be th
best when you look at that category, the cost is so prohibit!-/
that,, you know, although'we're digging it up and carting this
material off to another facility and therefore we're not
reducing, you know, the toxicity or the mobility of the
contaminants, it's taken to a facility that's pre-engineered t
be protective, where a number of hazardous waste sites ends up
taking their material. And so it is safe for the environment
because all their — all the engineering controls are built in
up front. It — it's certainly cost effective. When you
compare it to the capping alternatives, for about seven to 10
percent more, you are ending up with a site that has a much
more flexible long-term use with regard to the site. If we
were to choose the capping as Mark described, the cells end up
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having to be above ground substantially, for one of tnem 16
feet in elevation above ground, the other one about 30 feet
above ground. The reason for that is the groundwater table is
so shallow and in order to put this liner system underneath, we
can't go any further than about five feet into the ground which
causes the cell to be above ground. So it certainly restricts
the flexibility for any future use of the site.
By selecting alternative number three, there's no
future monitoring that will be required. We are going to take
all of the contamination and therefore unlike a cap system
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where certainly you're containing the contamination, there
would have to be long-term monitoring, infinite monitoring to
make sure the integrity of that cap is maintained and that, you
know, there's no future migration of that contamination.
So let's — again, we'll just go through the
components of the preferred alternative. This is consistent
with ea.cn of the alternatives. We estimate — there's much
more what we refer to as product at the site, but we feel when
we excavate the site, we can probably get about 5,000 gallons
of free product. That material is very concentrated,
contaminated and that's part of the category that we are
referring to as hot spot material. The hot spot material
consists of the 5,000 gallons of free and residual product and
the 27,000 cubic yards that you see at the bottom bullet of
this slide. That particular material consists of what we call
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TSCA regulated material. That's soils with PCS concentrations
greater than or equal to 50 parts per million. And we also
believe that in the tank farm areas, there's some very elevated
arsenic levels. And one of the disposal criteria under the
RCRA, the Resource Conservation and Recovery Act, that material
would fill the discharge requirements for that and that would
have to be disposed of as what we term as a hazardous waste
which needs to go to a more sophisticated disposal facility, i
you will.
The next slide. And so. from the previous slide,
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there 30,000 -- 83,000 cubic yards of contaminated material,
that's for each of the alternatives, and 27,000 of those cubic
yards we'll refer to it as hot spot. The remaining 56,0CO
cubic yards would be disposed of to an off-site special waste
landfill, as Mark described. We estimated in the feasibility
study that approximately 14,000 cubic yards of that 56,COO
could possibly be a candidate for recycling in this asphalt
batch plan.
Once we excavate the site, we will bring in clean
soil and back fill the entire area, regrade it and restore all
the wetlands that we may impact as a result of building the
entrance roads to get the contamination in and out, any
disturbances that we have to make to actually implement the
remedy.
And this final slide is a site layout. Again, the
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orange area is an irr.print of where the contamination is. And I
think that's it. At this point I'll just turn it over to Ed —
MR. PUTNAM: You want to give me some lights.
MR. MAKER: — to entertain any questions here.
MR. PUTNAM: Okay. The — there's a representative
from Senator Bennett's office who has a statement to read. I'c
like to do that first.
AUDIENCE: Unfortunately the Senator can't be here
tonight, but he has prepared a statement. "I have been
involved in the prodding of clean-up efforts on the Imperial
Oil property since the Health Department first found evidence
of widespread pollution on this property nearly 20 years ago.
It is pitiful that while this site was declared a Superfund
site 17 years ago, Imperial Oil was still able to receive
federal Department of Defense contracts and is still able to
operate an 'active business while taxpayers are asked to pay for
the cleanup. It is shameful that the federal government has
taken so long to take real action on this site and it is a
disgrace that this site is only going to be cleaned to
industrial level standards.
It is common knowledge that an industrial cleanup
does not remove as much contamination as a residential cleanup,
and it is common knowledge that there are residential
communities nearby. I am thoroughly disgusted at this decision
and plan on voicing my opposition to this industrial level
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cleanup until the decision is changed and encourage residents
of the* area to do the same."
I guess what the Senator basically wants to know is
why it's only being cleaned up on industrial level standards?
MR. PUTNAM: Yeah. Basically if you recall the brief
history we've presented, the site 'has been an industrial use
since the early 1900s. And because of .that long history of
historic use, the most probable future use was gc-.ng to remain
industrial and that's what was chosen as the land use to clean
up to.
Now a couple of things I want to point out in
relation to that. . The data we have indicates that the three
primary cleanup goals that are going to drive the cleanup are
the arsenic level, total petroleum hydrocarbons and the ?C3
level. When you compare the industrial number to the
unrestricted,use number, you're really only.looking at ?C3s as
having any significant difference as far as what's industrial
and what's unrestricted use. The numbers come out to 13 parts
per million versus essentially a half a part per million. Our
data that we have doesn't really indicate that we have anywhere
where there is that difference. Now we don't have every piece
of data^we could get, but the PCBs from what we've seen are
either there or they're not in their entirety.
So we would hope that even though we're shooting for
an industrial number of 13 on the PCBs, that we're not going tc
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encounter that spot where it's going to be less than 13 but
above a half. We think that, you know, it's either going to b<
there or not and the cleanup to go after that PCBs in general
is going to achieve the unrestricted use number.
In addition, arsenic really overshadows almost all oj
the contaminated areas. So the arsenic level of 20, which is
not affected, that's an unrestricted use number and it's also
the number that you would use for the industrial number, that
is going to be the main driver. When we achieve that, we
achieve an unrestricted use for the property. And there is a
huge overshadowing, of arsenic. So we do expect the cleanup to
actually achieve unrestricted use. It's just that this
particular decision proposed here doesn't guarantee it.
Now the other part of the equation is community
acceptance of the proposed remedy and that's what we're here
for and this is your place to voice your opinion on this
subject. Mayor, you want to —
AUDIENCE: Thank you. The questions that I have deal
with that unrestricted cleanup —
MR. PUTNAM: Right.
AUDIENCE: — associated with the industrial versus
the residential. The alternative that's preferred, when I was
hearing your presentation, removal of the liquids, removal of
the soil to me takes the problem away. However, how does the
alternative nuinber three that is preferred, which seems to
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address the problem, how does that differ in a residential
versus an industrial scenario?
MR. PUTNAM: With the information we have, we see no
difference in the quantity of soil that would have to be
removed to achieve essentially both. But we don't have a data
point for every place on the site. So theoretically, there
could be a place on the site where arsenic is below 20, total
petroleum hydrocarbons is below the 10,000 number, and PCBs are
below 13 but above the half. We don't see that happening at
this point, but it could happen.
AUDIENCE: Well let me ask the question this way.
Are you removing all of the liquids, the 5,000 gallons?
MR. PUTNAM: Yes. .
AUDIENCE: Is that all of it?
MR. PUTNAM: That's all — 5,000 gallons 'is what we
think is going to leak out.
AUDIENCE: Are you removing all of the contaminated
soil and are you removing all of the hot spot soil?
MR. PUTNAM: We expect to do that, yes.
AUDIENCE: So if you're-removing all of the problem,
why is there a difference between an industrial level and a
residential level? I don't understand.
MR. PUTNAM: Procedurally there's a difference in
that you have to pick a land use end point as far as the
cleanup goal. In this particular circumstance, because of its
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hi-storic use/ industrial was picked. That sets a list of
cleanup goals because of that. Also in this circumstance,
which is unique, at this time with the data we don't see a
difference between achieving the unrestricted use and the
industrial number. It's just that the way you go through the
procedure of choosing a remedy, you have to pick one. We
picked it, but it really didn't result in a change in quantity
or a change in cost.
AUDIENCE: Well I'm still a little bit confused, but
you talk about the land use and this property is currently
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zoned C-2. It's not zoned industrial. It has an industrial
use —
MR. PUTNAM: Right.
AUDIENCE: — but the zoning is C-2. I'll tell you
what those permitted uses are. In addition, it butts up to a
residential zone and in addition, as you've already cleaned up
Orchard Parkway where there are homes, you did clean that to a
residential cleanup, did you not?
MR. PUTNAM: Well that was — they had just arsenic
and we cleaned up to 20 and 20 achieves both residential and —
AUDIENCE: These are the permitted uses and I must
say that no one can predict what the future will be of Imperial
Oil and what the use of that property is, but the current
zoning does allow for general merchandise, food stores, appare.:
and accessories, eating and drinking establishments, variety
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stores, drug stores, liquor stores, florists, finance and
insurance, personal services, business services, repair
services, professional services, government buildings and
grounds, and then there are some other conditional uses such as
public utilities, motor vehicle and amusement arcades. Now
some of those uses have significant impact on human
consumption, such as restaurants, okay, arcades where children
can be. And why should we be cleaning up something that we
didn't cause, that you've identified as a problem, a Superfund
problem, tremendous magnitude, why not clean it up to the^
residential standard? And since essentially you're taking
everything away, both liquid and soil, if there's a little bit
more that needs to be done to get that insurance, that
assurance that it is to that total restricted residential
standard, why don't we do it?
MR. PUTNAM: I can certainly take your comments back
and —
AUDIENCE: Well that's the position of the
administration. We'd like to go the full extent.
MR. PUTNAM: Yes.
AUDIENCE: And I still don't understand why it isn't
Once again, if everything's being taken away, that's what the
standard should be then, the residential standard. Thank you.
MR. PUTNAM: Thank you. For any other questions, if
you could come up and stand in front of the mike, state your
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name for the record.
AUDIENCE: Hi, Tina Freedman, Monmouth County
Environmental Coalition, and Dr. Stephen Penangroth who is the
technical advisor. I just want a — I prepared a statement,
but then I also want to engage in some questions, okay.
The preferred alternative should result in the
cleanup to residential standards. All the contaminated soil is
going to be removed. In the proposed plan, DEP is committing
only to an industrial cleanup level. DEP should commit to a
complete cleanup to residential levels. That way the site' can
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be used without restrictions in the future.
The data in the RI/FS show that all the contaminated
soil that poses a risk to human health will be removed
including PCBs. That being the case, DEP should commit to —
and EPA should commit to making sure that this site is -- has
unrestricted use.
Also you're committing to that all the arsenic is
guaranteed off the site. It's just the PCBs that we're talking
about, is that correct?
MR. PUTNAM: From what we can tell, although taole
one in the handout lists a whole lot of chemicals, the three
that seem to be controlling the quantities to be excavated are
the arsenic, total petroleum hydrocarbons and the PCBs. So the
arsenic is unaffected by the 20 is a average state-wide
background number, it is not based as unrestricted use.
It's a
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background cutoff. The T?H is not — is not really in question
either. And the PCBs is really boiling down to the one that
might make a difference.
AUDIENCE: I — I know — we'd like to see you
guarantee the PCBs. I mean I know that it's —
MR. PUTNAM: I — yeah.
AUDIENCE: — it's unknown for you when you start
cleaning up on what, you know, where you'll hit it and what the
levels will be. But I don't know how it affects it financiall
and maybe that's what part of the problem is. I don't know if
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you're — this cleanup, the PCBs are that much of an unknown
that it's going to drive up the cost. Is that what you're
considering?
MR. PUTNAM: It's not really a cost consideration.
It's basically an observed land use decision to go with the
industrial numbers. But, you know, I mean it was -- we're
certainly, I think, going to hear a lot of that tonight and
that's really the kind of comment we need to hear.
AUDIENCE: I know that Penangroth had some comments
and questions.
MR. PUTNAM: Okay.
AUDIENCE: Thanks. No, I'd just like to follow up or
what Tina said. It seems that the PCBs are going to come out,
you know, the way you've laid out the soil remediation, the
soil removal in the FS and in the proposed plan. So I guess
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"^ MR. PUTNAM: I think it bcila down the point of are
we guaranteeing it or are we just going to hope it happens.
AUDIENCE: Right. Eut can't you — yeah, but can't
yOU — i mean based on the data that you have, I mean that we
all — that we've all shared, you know, that you've shared with
me —
MR. PUTNAM: Right.
AUDIENCE: — just looking at the data, you're going
to do it.
MR. PUTNAM: Right. It's going to happen.
AUDIENCE: It's going to happen. So why not — I
mean I guess I don't understand — from a technical standpoint,
I guess I don't quite understand the reluctance, you know,
because you're going to do it, so why not say you're going to
do it.
MR. PUTNAM: The process —
AUDIENCE: Is there something I'm missing here?
MR. PUTNAM: The process is ruled by procedures that
on some accounts take into consideration the technical data an
on other accounts are based simply on procedural guidelines
that are set for the program.
AUDIENCE: Land use you mean.
MR. PUTNAM: Land use being one of them.
AUDIENCE: So this is basically a land — just a land
use decision.
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MR. PUTNAM: A land use decision is really made
independent of the data and then you-put the two together and
develop alternatives to meet the land use and the remediation
goals based on the data. So you're making a land use decision
independent of the data.
AUDIENCE: Right. Just to bring everybody sort of up
to speed, there's 34 contaminants of concern that I counted in
the table, and of those — and 25 are going to be cleaned up t
residential standards based on the industrial standards. In
other words, the industrial or impact to groundwater standards
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that are used in the proposed plan are actually more stringent
than the human health criteria. And then there's five where
they're less stringent, but the actual levels on the site are
cleaner than the human health. And that leaves four of these,
one is ?C3s which we're talking about. The other three are
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just are a couple of polynuclear aromatic hydrocarbons that ar
just two found at two locations in a waste clay filter pile.
So they'll get cleaned up without any doubt. So it so
really, you know, you've done the — you've done the job.
MR. PUTNAM: I really — I think I'm —
AUDIENCE: I'm just sort of — I guess I'm kind of
like the — why not go that extra half a step, you know?
MR. PUTNAM: When you see it at the end of the
process and you're looking back, you don't quite see how you
got the difference. But if you start at the beginning and move
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forward, they really go on two different tracks and that's why
you end up where you are. But certainly this is the comments
we want to hear.
AUDIENCE: Thank you.
MR. PUTNAM: Thank you.
AUDIENCE: Ed, regarding the formation layers of the
aquifer which we're talking about now, that's the 5,000 gallon
of oil that's sitting on top of it, isn't that correct?
MR. PUTNAM: The 5,000 gallons of oil that we have in
this alternative is basically what we feel is going to leak out
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of the oil contaminated soil hot spot when we pick it up. When
we excavate that, we think it's naturally going to drain about
5,000 gallons. We have calculated there's probably 10 time
that of actual free product in that soil, but it's not going tc
come out. So the other — the hot spot soil —
AUDIENCE: You're only going to be able to get 5, COO
instead of the 10,000.
MR. PUTNAM: Well we think 5,000 is going to fall
out. We're currently taking out about five or six gallons— I
think about five or six gallons a-day is what we're sucking ou
of it currently with the system we have. And we're — you
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know, if you're looking at 50,000, which we're not going to get
there, which is why we're digging it up. So, you know, we're
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going to make sure we dig up and capture all of the free
flowing product.
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formation.
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AUDIENCE: 3c then you're going to base that 30 year
monitoring on that site, I don't think that's acceptable.
MR. PUTNAM: Well if -- if we leave —
AUDIENCE: Because if you're leaving behind 5>OGO --
MR. PUTNAM: No, we won't be leaving — we won't be
leaving — the only thing potentially we're going to be ieavin
behind is PCS contaminated soil —
AUDIENCE: Within the formation -- within the
MR. PUTNAM: Down - yeah, it'll be at depth and -
AUDIENCE: Within the formation of the aquifer?'
MR. PUTNAM: That - that won't - no, it won't be ij
the groundwater.
AUDIENCE: It's sitting right on top of the
grour. water. What makes you think that it won't get into the
groundwater in 30 years or 40 years or 50 years?
MR. PUTNAM: Well PCBs don't — don't really
soiubilize — in the groundwater and we're ~ we —
AUDIENCE: You're talking about sand soil in that
area. It's very sandy.
MR. PUTNAM: We also — one of the operable units in
a groundwater treatment system and we won't turn that off until
whatever is currently in the — in the water has been taken
out. I'm not — we may or may not have to do some monitoring
just to make sure that 'it doesn't solubilize, but we wouldn't
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it to. I .T.ean when we're totally done, really the only
thing left if you do have any, since where you do have seme
PC3s is going to be a deed restriction.
AUDIENCE: But can you promise the Township and the
community that there will not be any residual left'in that
area?
THE COURT: Well it — there won't — there won't be
anything that we feel is a threat to groundwater, because
that's another criteria.
AUDIENCE: What is the level of PCBs in that
contaminated area that we're talking about, in the liquid?
MR. PUTNAM: Oh, it goes up over 500 in some cases.
AUDIENCE: Okay. So we're dealing with —
MR. PUTNAM: But that's the level actually in the
oil. PCBs really do not have an infinity to groundwater. The
number in soil that we feel is protective of groundwater is 50,
and we're going to get that anyway.
AUDIENCE: So if it's safe to sit there, why not just
let it sit there, Ed? You know, if it's not going to move i"-.
the aquifer and it's sitting right on top of the .aquifer, just
leave it there.
MR. PUTNAM: The product is moving and it still
represents a direct contact hazard because it's also in the
soil.
AUDIENCE: So the product is moving, correct?
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MR. PUTNAM: The product is currently moving. We're
going "to get all that out. The PCB level -- the industrial PCB
level is a PCB level in soil, not in — not in actual oil. All
the free flowing oil is going to be taken off site.
AUDIENCE: You're sure that you can get it all out?
MR. PUTNAM: Yeah. Well we're going to have to dig
it up to get it out --
AUDIENCE: Even though —
MR. PUTNAM: — but we're sure we're going to get it
all out. Yeah. Free flowing liquid also can't remain in the
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ground.
AUDIENCE: Well I still think that the 30 years is
unacceptable at that site. I think we have to renegotiate
those figures.
MR. PUTNAM: And get it — and just get it to walk
away, we don't have to do any more to it eventually.
AUDIENCE: Keep monitoring it.
MR. PUTNAM: Well I think if we leave something
behind, the only thing I can think of that we leave behind is
the PCBs.
AUDIENCE: How are you going to assure the Township
and the community that there isn't something there? That's
what I'm getting at.
MR. PUTNAM: You mean that we missed something?
AUDIENCE: Yeah.
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MR. PUTNAM: We feel we've done a good job
characterizing the site and we do what's called post excavation
sampling to make sure we got all of it going down. You know,
there's an off chance that we can miss something, but I think
we've worked pretty hard. I don't think we're going to.
AUDIENCE: All right. Let's go to the access and
ingress roads. Now you said you were going to be building then
to get into that area. How are you going to do that?
MR. PUTNAM: Well, we have a conceptual model at this
point. But the reality is after we — when we get into what we
call the remedial "design, the actual laying out of the .
facilities we need laying out of the access road, we're going
to have to sit down with the public safety officer here in the
Township and figure out what is best. The current access goes
by houses. That's not the greatest. If you do the math, we're
talking about thousands of trucks going in and out of there.
AUDIENCE: That's right.
MR. PUTNAM: So Imperial Oil does own property I
believe that goes all the way out to 79. So there is the
ability to go in and out through that and actually create our
own
road with a pretty good buffer. But that's currently a
wooded area. So it's really I think going to boil down to a
public safety decision in looking at the couple of options and
we'll work with the town on that.
AUDIENCE: Okay. Well I have to stand with the Mayo
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and with the people of the Township and the community when it
comes _to the difference between cleaning it up to the
industrial level and bringing it up to residential. I mean we
have been at this now, what, 24 years, Ed.' Artd after 24 years,
I think we owe it to the community to bring it up to
residential, okay. So you can take that back to your boss.
MR. PUTNAM: Certainly will.
AUDIENCE: Thank you.
AUDIENCE: Ed, how are you?
MR. PUTNAM: Hi. -
AUDIENCE: Saul Honick, Marlboro Township. We were
around and this has gone through, if we count the terms that
Matt and I have served, almost five, administrations. I'd like
to make a couple of comments. First of all, Liz was very kind
to give me the article. Who is Mr. Petrone?
MR. PETRONE: . Right here.
MR. PUTNAM: Ken Petrone.
AUDIENCE: Could you explain why you made the comment
if the Township owns the property in the future and wants to
convert it to unrestricted use, they can go and'clean it up
further if necessary? And when you address that, I would like
to know the difference between the cost of residential cleanup
as opposed to — are you federal or state, by the way?
MR. PETRONE: State.
MR. PUTNAM: State. ,
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AUDIENCE: State, okay. I have another question for
you after that.
MR. PETRONE: Okay.
AUDIENCE: The difference between the cost and how
you came — because the quote comes off very cavalier.
MR. PUTNAM: Yes. And I think he -- let him explain
the quote.
MR. PETRONE: Okay. It was taken a little bit out of
context. What I was trying to say was that we — we remediate
sites to — the policy for the agency is to remediate the site
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to the current land use. It does not remediate the site to a
restricted use cleanup, does not prevent future residential use
on the site. And that was the point that I was trying to
emphasize. What I said was that any future owner of the site,
if the site is cleaned up to a restricted use condition and
future owner of the site wants to come and develop it for a
residential use, they can do that on a restricted use site as
long as the controls are maintained in place.
AUDIENCE: All right.
MR. PETRONE: And beyond that, what I was saying that
the future owner also has the opportunity to remediate further
if they so choose to do that.
AUDIENCE: What is the cost between residential and
the cost of cleanup for industrial?
MR. PUTNAM: At t .s time we see no difference in
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cost.
AUDIENCE: You see no difference in cost. Then if
there's no difference in cost and we recognize the location of
the property, the fact that it's surrounded by residential,
could you tell me why you wouldn't go to a residential cleanup
based on the fact of potential water going onto the site and
going off the site in a natural flow of discharge or what have
you?
MR. PUTNAM: Well the — we don't see any instances
where you're actually going to get a surface of number of PCBs
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that is going to be substantial. More than likely if it is
found that there's a difference, it's going to be a"depth.
There's going to be back fill placed over it. I think again
the reason why you get to' where you get to, is you determine
land use independent of the data and independent of the costs
and the quantities.
AUDIENCE: Well that raises an issue of a 100 year —
MR. PUTNAM: Obviously it's pretty unanimous here,
the comments are.
• AUDIENCE: All right. It raises — as far as off
water, water going off the site, you have various levels of
storms. In '83 we had a tremendous storm and the whole surfacej
washed off and we were out there where the Imperial Oil
abrogated their responsibility and we had to bring in the
Township to protect the dikes. Now the fact of the matter that
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can happen again. And with the federal standard, which
incidentally is much higher than the state standard -- lower
than the state standard, do you know and you should know what
the industrial cleanup for the state standard is?
MR. PUTNAM: For PCBs?
AUDIENCE: Yeah. All right. It's two parts per
million as I've been informed while the federal is 13 parts per
million. And the residential is two to five parts per million
as opposed to .49 parts per million. I want to ask why the
state is lowering their standards with regard to this federal
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standard. I mean we're supposed to be the most aware state
with regard to cleanups. Why are you as state officials
accepting a federal level of cleanup that is less than your own
standard as a state body that you impose upon us? And then if
we have people who come to tr.e Planning Board for an approval,
we go by state standards, not federal, which represents you
inversely condemning the property right from the get go.
MR. PUTNAM: All right.
AUDIENCE: Now I'd like you to defend that position.
How as a state official —
MR. PUTNAM: To some extent, I've been using the .49
number when I refer to the unrestricted use which is the state
standard.
AUDIENCE: Okay. Residential.
MR. PUTNAM: The EPA residential standard is one,
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okay. So I — when I talk here about going to an unrestricted
use standard, I am taking it all the way down to a standard.
Now let me go —
AUDIENCE: Well —
MR. PUTNAM: Now let me go back to the procedure of
how the Superfund program works. The state standards are soil
cleanup criteria. They are not promulgated regulations.
Therefore they are not recognized by EPA to the extent that we
can overrule one of their numbers. So federal — because it's
a federal project being conducted under the federal law, 13
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becomes the number/ okay. As long as the number is above .5,
whether it's two or 13, we would still look to have the same
institutional control, a deed restriction. So —
AUDIENCE: Then you — then ~
• MR. PUTNAM: — from a remedial standpoint, from out
standpoint, allowing two or allowing 13 results in the same
institutional control that we feel will be protective.
AUDIENCE: You're talking almost 200 percent —
MR. PUTNAM: So there's no reason for us to fight the
two, 13 number.
AUDIENCE: You're talking, if my math is correct,
almost from two to 10 is almost a 200 percent increase or some
ridiculous figure, as to the difference between two and 13, if
we divided and so on.
MR. PUTNAM: But we're talking about —
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AUDIENCE: On percentage basis, as two- is the base
and 13, you're talking hundreds of percent increase you're
allowing. And I —
MR. PUTNAM: Right. We're still talking two part pe
million versus 13.
rarely —
AUDIENCE: It doesn't matter.
MR. PUTNAM: Well it does in the field. You very
AUDIENCE: Why did the state — why did you as a —.
listen. Why did you as a state agency which controls — CEP
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which controls us, controls our regulation, sets rules for our
safety, decided to a level that is so much lower than the
federal level, why did you go to that level?
MR. PUTNAM: Our number does not have the legal
authority to overrule the federal.
AUDIENCE: I'm not asking that. I'm not asking what
the federal does.
MR. PUTNAM: Okay. Why did we accept it?
AUDIENCE: The legal authority stems from the fact
that this came from the Superfund,- it doesn't make it right.
But we're raising an issue of percentage. We're raising an
issue of a hundred year flood, wash off, water system, the fact
it sits in the middle of a residential area, these are all the
issues. And the bottom line is, I'm asking why you're not
defending these levels against the federal express because
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they'll just cut and run and do it as fast as possible.
MR. PUTNAM: From our standpoint —
AUDIENCE: After 18 years.
MR. PUTNAM: — even — even the 13 number, although
when you multiply it out, the reality in the field is that's
not a significant difference when you start looking at field
data because they're both very, very small numbers. All right.
AUDIENCE: Well, you can play in it. I'll take the
two.
MR. PUTNAM: But when we're looking at how you would
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respond to two or 13 and whether we feel that's a threat to
surface water or whether we feel it's — what kind of threat it
is, there's no — there's no real difference to us and hew we
would take remedial action in protecting people from two,
protecting people from 13.
AUDIENCE: You're defending your position. We're
putting you on the spot.
MR. PUTNAM: So we have the same remedy regardless o
those two numbers.
AUDIENCE: It's just incomprehensible to me why you
wouldn't take the safer route, why you wouldn't remove as much
as possible knowing the circumstances of the area, the history
of the area. And to rely on quote, unquote, this was 100 year
industrial area, the Mayor has corrected that with regard to
the proper zoning, I just don't understand why if there's no
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difference in cost you would sit down with the feds and say
this is what we are recommending to you. We want this to be at
the state level. We're not in Mi-ssissippi. We're not in
Arkansas. We're here in New Jersey. Why — have you told their
this is what you want or you just went down the path and
agreed?
MR. PUTNAM: The proposed plan is a joint document
between the agencies.
AUDIENCE: Well, I'll tell you, something's very
wrong. And I agree with Senator Bennett and I hope it carries
it through and we can talk to our Congressman also about, it.
MR. PUTNAM: Thank you.
AUDIENCE: It's reality. The fact is because there
aren't 200 people here won't prevent frbm the Township to
exercise its right in Court. I'm sure the Mayor will pursue
that. Another year in Court won't make a difference based on
che time. And one other thing, what is the OSHA stand on this?
Excuse me. What is the OSHA stand on this? If someone works
in the area, goes across the ground, handles the soil at 13.
MR. PUTNAM: I think it's pretty substantial as far
as OSHA. Thirteen would be a number that OSHA — the OSHA
number for PCPs would be a lot higher than 13.
AUDIENCE: Okay. Just thought I'd ask.
MR. PUTNAM: Thirteen would be —
AUDIENCE: But then it's a federal standard, isn't
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it?
MR. PUTNAM: Thirteen is based on a work day, not
necessarily on OSHA standard working with the material.
AUDIENCE: Sorry.
MR. PUTNAM: You're going to make it unanimous?
AUDIENCE: Of course.
MR. PUTNAM: Okay.
AUDIENCE: Les Jargowski, Monmouth County Health
Department. First of all, I'd like to strongly support the
residential concept, the residential standards. It makes^sense
totally through. But I'd like to emphasize something and get
your response, back relative to the living environment, the
people that are there during this construction. Beside the
arsenic and total petroleum hydrocarbons and the PCBs, I seem
to recall a few. elevated readings of beryllium there on that
property, that's correct, right?
MR. PUTNAM: It's — it's a lot higher than our
standard, but it's not so high that we need to take any
I immediate action with regard to it.
AUDIENCE: Okay. As a health officer in terms of
potential dust, fugitive dust on that property, that would get
my attention and I'm sure it gets your attention as well. And
I'd like to hear more about how you're going to control, you
know, fugitive dust and potential noise on that property? And
how long of a period of time might the people have to endure
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that?
MR. PUTNAM: The — when we do a — when we do a
remediation, our goal in dust is to have zero at the fence
line. We don't want any dust going, off the property. We
basically use dust suppressants to achieve that. We have
often, to the point where you have somebody standing there with
a hose spraying material as it's being excavated if you have
to. But we can set up real time aerosol monitors at the fence
line to insure that we're getting that. And especially in this
case with residential property so close to where we're going to
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excavate, I think we're going to have to really be diligent in
emphasizing that zero tolerance on that.
As far as the noise, it's been my experience that the
backup beepers on the equipment are the worst noise you can be
if you're a resident listening to that eight hours a- day.
de're certainly cognizant of that. We will do our best to
strike compromises. You know, we're certainly aware that we
don't — people sleep until 8:00 in the morning, we're not
going to start work at six. But we want to try to achieve the
greatest work day we can in order to get it done faster, but v
recognize that that starts to really start to infringe on
people's lives in the area. And if you have to, there are
options related to removing the person who can't take it any
more. But that's usually a last resort because that sometimes
can be worse.
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AUDIENCE: Okay. But those mechanisms are available
and you are going to have full-time monitoring for any type of
ciust ccming off there?
MR. PUTNAM: Well what we'll do is — what we'd
prccably do is set up — try a couple of things out, see what
worked the best, set up the monitors to testify that and then
we can probably just do periodic monitoring there because of
we'd be looking at actually just implementing the dust plan.
And as long as we continue to implement we know we're okay.
But if we have to, if it really starts to be a problem, we can
*
do real time aerosol monitoring at the fence line.
AUDIENCE: Okay. When you dig this big hole to go
after the oil, you know, in the back there, what kind of
controls are you going to have in place in case we get a real
heavy downpour? And, you know —
MR. PUTNAM: We're going — we're going to defer to
the Soil Conservation Service. They really advise us on that.
We'll sit down with them during the design and we'll lay out
the — basically as part of the soil erosion —
AUDIENCE: So that's a decision to be made further
down the line with the Soil Conservation Service?
MR. PUTNAM: Yeah. We•in essence defer to them on
what they think is appropriate.
AUDIENCE: Okay. I think it's really important that
you understand, I think I said it before, when the water's
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coming down there, it's really coming through there.
MR. PUTNAM: Yeah.
AUDIENCE: There's a flash flow in there and the
water gets kind of deep there at times. Thank you.
MR. PUTNAM: Yeah. We recognize that. Thanks. Any
other questions?
AUDIENCE: I have one question, Ed. If memory serves
me well, doesn't — didn't 'the standard at Burnt Fly Bog,
wasn't that residential?
MR. PUTNAM: It was ecological based. The one area,
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yeah, was residential.
AUDIENCE: Right.
AUDIENCE: Was that federal or state residential?
MR. PUTNAM: Actually I think officially the federal,
but the same thing occurred there where we saw no real
difference in the data and the reality will probably be that
we'll achieve the state standard.
AUDIENCE: So it was a state standard.
MR. PUTNAM: We believe we'll achieve the state
standard there too.
AUDIENCE: There, that's what it achieved.
MR. PUTNAM: Yeah. And that was for the area up
close to the halfway house. When you get further down in,
you're into the ecological areas. Mayor?
AUDIENCE: Yes. Ed, when it comes to the actual work
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being done, the excavation, the truck movement and so forth,
are you going to be coming to the Township to work that out
with regards to our traffic and safety, certain hours when
movement is less impactful, more safe with regards to our
school buses, et cetera?
MR. PUTNAM: Most definitely.
AUDIENCE: We would like to sit down with you and
make sure that it's minimal 'impact where it can be worked out
and most likely or most appropriately safe.
MR. PUTNAM: Yeah. We .-- we encourage — well we
will definitely sit down with public safety official or,
emergency management official, however it works, to go over th«
truck routes. We'll do it during the design. We'll lock at
what options .are available to the contractor. He will then be
able —.if there is limitations, he'll pick one of them and
then when we actually hire the guy to do it, then we sit down
with the contractor who's going to be telling trucks which way
to go with your police and lay put the final plan. We also
encourage them to hire the police as traffic control officers.
AUDIENCE: I'd just like to make one final comment.
I think you've heard a lot from a number of people including
myself with regards to that issue of industrial versus
residential.
MR. PUTNAM: Yeah.
AUDIENCE: I know how I feel. I believe I know how
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some of the council members feel and you've heard from
environmental people, the former Mayor, Saul Honick. We're
going to push pretty hard on getting that assurance that
resider.-ial level. Now I intend to write a letter. I intend
to have the town council do a resolution.. We're going to have
support from Senator Bennett's office, I'm sure. That's why
the representative was here. Do we send it to you? Do we send
it to your bosses?
MR. PUTNAM: Well make sure —
AUDIENCE: We'll send it wherever we have to.
MR. PUTNAM: — make sure a copy goes to the contact
person and pick you, Mindy or Don?
MS. MUMFORD: My boss, Don.
MR. PUTNAM: Don Kakas is the person. Make sure he
gets a copy of it. You can — you can send it to anyone and
everyone you like. Make sure Don gets a copy of it.
AUDIENCE: And I'm also — and I'm also thinking that
in addition to your agency and other people in the State, I
think we need to send it to the federal people, the EPA, and
I'd like to know those contacts.
MR. PUTNAM: Ultimately the decision is going to be
made by the regional administrator, Gene —
AUDIENCE: All right. All right.
MR. PUTNAM: Or the deputy —
AUDIENCE: Can I just interject? You heard us speak.
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You hear what the Senator says. Will you recommend to trie
federa-1 to lower the standard to your standard?
MR. PUTNAM: I heard -- I heard a unanimous voice
from the community that said they want an unrestricted use and
that's what I'll take back with me.
AUDIENCE: Okay.
AUDIENCE: And you feel you could recommend that?
You'll recommend that to the federal?
MR. PUTNAM: It's not really up to me to recommend it
one way or the other. It's something that I take back with me
•
and certainly we'.ll emphasize the unity and the strength- which
everyone has --
AUDIENCE: You'll take back this expression en part
of the administration and the citizens.
MR. PUTNAM: I will — I will take back —
AUDIENCE: The question is, what is your
recommendation to your superior that this be followed or --
MR. PUTNAM: That's actually really considered
confidential and I wouldn't really discuss it in public.
AUDIENCE: 'It's bizarre.
AUDIENCE: It is bizarre. They should be here
tonight then.
AUDIENCE: It's bizarre.
AUDIENCE: Right.,
MR. PUTNAM: We — there's other reasons for that.
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But internal discussions are considered confidential and what
you se.e coming out is the position of everyone involved.
AUDIENCE: Ed, you clearly heard what we all had to
say.
MR. PUTNAM: Yes, I did.
AUDIENCE: I don't know if anyone else wants to come
and speak, but I implore upon you and the others here to take
that message back clearly and loudly. I also would like to
thank you for coming here and giving us the opportunity, to
hear us, to hear what we had to say. And once again, it's been
a long time in coming to getting to this point. You've heard
people make comments about that. I really do think that we.
need to get it done, get it done to the best of the standards
that are there for the benefit of the people not only here
today, but those people that will be here tomorrow and the
years on in the future. So once again, thank you for giving us
this opportunity and let's make the message clear.
MR. PUTNAM: You're welcome.
AUDIENCE: Steve Gusman is my name. I'm vice
president of the town council. And I concur with the Mayor in
the matter that we would like to make it an unrestricted
residential area as well. And we need to do whatever we can to
make that happen. And if it's more money needs to be spent,
then obviously more money needs to be spent. But to do it in a
half-hearted kind of manner I think is a total waste of time
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for everybody. And we need to clean it up in the best way we
can s© that if in fact, as the Mayor said it's a C-2 zone, we
have supermarkets or restaurants or whatever, it's certainly
going to affect people in that area as well as people if in
fact needs to be as far as a residential community as well. So
we would appreciate you doing whatever is necessary. And as
the Mayor said, town council probably will send a resolution to
whoever and whatever to make it get done. And again, we thank
you.
MR. PUTNAM: I would encourage that you do if that's
*
the way it goes. That's definitely the kind of feedback we're
looking for. Thank you.
AUDIENCE: I .just want to ask again. If you can
guarantee the arsenic, why "can't you guarantee the PCBs? Give
me a direct answer. •
MR. PUTNAM: I'll give it.to you. You choose the
land use before you look at the data, okay. So you pick
industrial land use and then you say okay, with industrial land
use these are the remediation goals that we want to achieve.
Then you take the data and compare it to that goal. With
arsenic, the 20 number is an unrestricted use number that is
already above the "industrial number" because the 20 is based
on background levels, naturally occurring background levels.
So that's a number that I — you stop at. You go to 20 and
that's where you stop and that's background. Nobody's allowed
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co go below background in cleanups. It's the other compounds
where "you start to see a difference between unrestricted use
and industrial use.
AUDIENCE: So the conversation about the future land
use of this property, you can then re-evaluate?
MR. PUTNAM: Well what you have here is, you know,
you have the ninth criteria. EPA calls it a modifying
criteria. Okay. So you have seven criteria that engineers
evaluate and they come up with a recommendation based on the
engineering of it. The softer modifying criteria are the.
support agency acceptance and the community acceptance. So the
reason it's called modifying criteria is that the decision
maker can use what he hears from those two things to modify the
decision. So that's why I'm encouraging you to make those
comments so that they are on the record and they will be
addressed and if they -do result in a modification —
AUDIENCE: And what is the process —
MR. PUTNAM: — then you got what you want. If they
don't, you'll have an additional explanation why they didn't.
AUDIENCE: Okay. We'd like to request that after the
30 day, comment that everyone gets to send you their comment,
that how long a time between we submit our comments do we hear
feedback on whether it's going to be modified or not?
MR. PUTNAM: You actually won't know until the
decision is actually made final.
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AUDIENCE: And when would that be?
MR. PUTNAM: It depends on the volume of the
comments. I would expect — you know, these comments on the
land use are going to be one issue fairly simply to respond to.
We're either going to do it or not and give a reason. If we
get other technical comments, they make take a lot more time to
respond to. The responsiveness summary is reviewed by the
[decision maker before they make the decision. So you don't get
the official response until — it all happens at once. The
answers to the questions and the final decision are made at the
•
same time. And that's when you hear.
AUDIENCE: Okay. And is — we'd like to be a part of
that process. I mean we'd like to kind of know where you're
heading.
MR. PUTNAM: You'll probably get some feedback on
this issue anyway because of the type of issue it is. But
there may be a situation where other comments overshadow some
other things too. So I can't guarantee that you're going to
hear before a final decision is made. But if —
AUDIENCE: Well we'd like to request that we do.
MR. PUTNAM: Yeah. And if it is really the only
issue, you probably will.
AUDIENCE: Bonnie Baldwin, resident. This is the
most densely populated state in the country and to decide that
one little plot of land that is pressured by residences all
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around it is very superficial, I think, in the long run of how
things, work. I'm. not a scientist but I know on a March day
like today there's an awful let of stuff blowing around. It
isn't confined to just a specific area that's been called
industrial or commercial. It's blowing all over town. And
it's the same with water. So you're talking about an area that
is surrounded by people and kids and you're talking about, you
know, a very high water table, land and water that moves
through it, it seems really inadvisable to make a decision
based on zoning or something like that when the reality is it's
»
a process and it all moves and it should — it should work for
people and, you know, not just a business decision, but a
decision for our generations that are coming up. So wisdom, we
need wisdom.
AUDIENCE: One last one, I promise you. Is it
possible that any part of this cleanup could be delayed for
long periods cf time subject to negotiations with the existing
company that's on the property to vacate or move around on the
property?
MR. PUTNAM: We're going to try to handle that
concurrent with the remedial design.
AUDIENCE: Try to handle that? That means we could
be another 20 years or —
MR. PUTNAM: Okay. Well the landowner as landowner
has legal avenues available to them. And if a judge agrees
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with they -- if they don't want us to move and the judge agrees
with them, then a judge is telling us not to move. But I can
tell you this, that the only one who would delay it would have
to be a judge. We would not delay it because of our
discussions with the company. .
AUDIENCE: Was this -- is this plan, when it was
developed, was this -- was there input from Imperial Oil as you
were developing these options?
MR. PUTNAM: No. They got, like some of the people
here, got an advance copy of an earlier version of the
feasibility study. We had a meeting with them. They indicated
to us certain comments. Some of them were incorporated or
addressed in the document, most weren't.
AUDIENCE:, Because I was wondering if this was tied
in with their business plans, you know, in terms of them
vacating or moving or what or something was going on in the
background?
MR. PUTNAM: Actually it isn't. We had our engineer
— our engineer did not consider that at all as_to what was
there already. And if you really — if we went back to the
slide, you would see that the area that we're saying needs to
be investigated encompasses a lot of existing structures that
are going to have to come down. So I mean we just looked at it
as what needed to be done and if it happens, it happens.
Any other questions concerning the on-site proposed
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plan tonight? Okay. I'd like to thank you all for coming and
giving, us your passionate, enthusiastic and unanimous comment
on the land use. We definitely will be taking this back with
us. We'll officially end the meeting, but we'll still be
available if anyone has any other questions for any other
aspect. Thank you again.
(Hearing adjourned)
*******
CERTIFICATE
I certify that the foregoing is a correct transcript
to the best of my ability from the record of proceedings in the
above-entitled matter.
$ & J COURT TRANCRIBERS, INC.
BY: BEATRICE A. CREAMER
DATED: March 22, 1999
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Appendix B
Written Comments
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4979
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To: Donald J. Kakas, Section Chief
Bureau of Community Relations
New Jersey Dept of Environmental Protection
P.O. Box 413
Trenton, N.J. 0^8625-0413
Cc: Office of the Mayor, Marlboro Townshn*
Blanche Hoffhan, chair Old Bridge Environmental Commission
Mayor Cannon, Mayor Old Bridge Township
From: Ernest Schmhz, Old Bridge Environmental commission
Subject: PCB's Concentration Imperial Oil Remediation
At the Public Hearing on March 18,1999 regarding the preferred clean-up method for
Unit 3 of the Imperial Oil Site in Marlboro Township, the NJDEP proposed to remove
PCBs to the industrial level of 15ppm and stated that this would effectively produce a
clean-up to the residential level of O.Sppm. Has the DEP considered the slope of the
gradient of PCB concentration vs distance from the center of the PCB "hot spots" and the
quanthy of PCB contamination left behind in the annulus left in the distance between the
radius of a concentration of ISppm and that of O.Sppm ? If the slope of the gradient is
shallow at this point and the radius of the "hot spot" is large, a substantial quantity of
PCBs may remain on she. How can the NJDEP claim that PCB removal to 15ppm will
effectively produce a clean-up to 0.5 ppm ?
>
Ernest Schmhz, (CSP retired)
33 Cymbeline Drive
Old Bridge, N.J. 08857-2798
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THE MARLBORO BURNT FLY BOG/IMPERIAL OIL CITIZENS ADVISOP"
COMMITTEE
April 4, 1999
Mr. Donald J. Kakas, Section Chief
Bureau of Community Relations
N.J. Department of Environmental Protection
Division of Publicly Funded Site Remediation
P. O. Box 413
Trenton, NJ 08625-0413
Dear Mr. Kakas: Subject: Imperial Oil Super-fund-Public Comment Period
As Chairwoman of the CAC. I fail to understand, after all of the years of work-
ing together to see a closure at this site, how we can possibly justify to our
Community, anything less than a Residential standard cleanup.
I fully support Alternative #3. but with the proviso, that the cleanup be of the
RESIDENTIAL standard.
Support for the RESIDENTIAL STANDARD, will ensure this Community, that
working towards this end for the past 18 years, has not been in vain.
Respectfully,
CC:
Hon. M. Scannapieco, Marlboro Township
Tina Freedman, President-MCEC
i LllCl -^ i CCUAAA»*A» •*• * ^» »*••—•»- X^AM
Stephanie Luftglass, Marlboro Public Information Officer MTnlPT,
Edward Putnam, Assistant Director Remedial Planning & Design, NJDEP
Joseph Maher, Site Manager, NJDEP
Mindy Mumford, DEP Community Relations
Trevor Anderson. Site Manager, USEPA
Kim O'Connell. USEPA
Jeanne Fox, Administrator, RegionH
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The Monmouth County Environmental Coalition; inc.
P.O. Box #1
Morganville, New Jersey 07751
(732) 970-022S
April 4, 1999
Mr. Donald-J. Kakas, Section Chief
Bureau of Community Relations
N.J. Department of Environmental Protection
Division of Publidy Funded Site Remediation
P.O. Box 413
Trenton, NJ 08625-0413
RE: IMPERIAL OIL SUPERFUND SITE - PUBLIC COMMENT PERIOD
Dear Mr. Kakas:
On behalf of the Monmouth County Environmental Coalition, Inc., which
continues it's active participati'on with Marlboro Township, surrounding
communities, D.E.P. and E.P.A.. through an E.P.A. TAG grant, we are
responding to the proposed plan for Operable Unit #3 at the Imperial Oil
Superfund site.
We support Alternative 3, excavation/Off-site Disposal/Reuse. The preferred
alternative should result in a cleanup to residential standards verus the proposed
industrial standard. The data in the RI/FS show that ail of the contaminated soil
that poses a risk to human health will be removed. This should also include
PCB's. A residential standard cleanup will be more protective of human health
and the environment therefore leaving the site without future restrictions and
protective of current and future surrounding residential neighborhoods.
This community has worked diligently over an 18 year period to see a complete
cleanup on this site. So has the DEP and EPA. Supporting the residential
standard cleanup will ensure that future generations will benefit from the
Superfund Program. Hopefully, one day, residents won't think of their back yard
as "the Superfund* area of town, just a wonderful place to live.
Sincerely,
Tina Freedman
President-MCEC
cc: Hon. M. Scannapieco, Mariboro Township
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Lizabetn Pouston, CAC
* Stepflfinie Luftglass, Marlboro Public Information Officer
Edward Putnam, Assistant Director Remedial Planning & Design, NJDEP
Joseph Maher, Site Manager, NJDEP
Mindy Murnford, DEP Community Relations
* Trevor Anderson, Site Manger, USEPA
Kim O'Conneil, USEPA
Jeanne Fox, Administrator, Region II
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COMMENTS ON THE
SUPERFUND PROPOSED PLAN
IMPERIAL OIL COMPANY AND CHAMPION CHEMICAL SITE
MORGANVILLE, NEW JERSEY
April 5,1999
Prepared for:
Imperial Oil Company, Inc.
and
Champion Chemical Company
Prepared by:
The Cody Ehlers Group
60 East 42nd Street, Suite 1641
New York, NY 10165
f/jjc\wPsnoocs\/MP\[Mpa3JA DOC
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COMMENTS ON THE SUPERFUND PROPOSED PLAN
IMPERIAL OIL COMPANY AND CHAMPION CHEMICALS SITE, MORGANVILIE, NEW JERSEY
FlHBLEOFJjJONTENTSJ
1.0 INTRODUCTION 1
2.0 COMMENTS ON DATA PRESENTATION AND EVALUATION 2
2.1 DATA PRESENTATION 2
2.2 DATA EVALUATION (FREE AND RESIDUAL PRODUCT) 4
2.2.1 Use of "Apparent" Product Thickness Measurements 5
2.2.2 Product Migration 6
2.2.3 Product Characterization 7
3.0 COMMENTS ON THE REMEDIAL ACTION OBJECTIVES 18
3.1 USE OF AN INDUSTRIAL EXPOSURE SCENARIO 19
3.1.1 History of Industrial Site Use 19
3.1.2 The NCPe USEPA Guidance and Land Use 10
3.2 USE OF A 1CH EXCESS CANCER RISK GOAL 11
3.3 USEPA GUIDELINES ON LEAD AND ARSENIC IN SOIL 13
3.3.1 Lead in Site Soil 13
3.3.2 Arsenic in Site Soil 15
3.4 DIFFERENCES BETWEEN THE 1990 AND 1996 RISK ASSESSMENT 16
3.5 USE OF USEPA SOIL SCREENING LEVELS 18
4.0 COMMENTS ON THE REMEDIAL ACTION ALTERNATIVES 20
4.1 REMEDIAL ACTION ALTERNATIVE RECOMMENDATIONS 20
4.1.1 Acknowledge Future Industrial Use 20
4.1.2 In-Situ Treatment and Removal of Free and Residual Product 21
4.1.3 Modified Cover Containment System 23
4.1.4 Utility Corridors 24
4.2 POTENTIAL OFF-SITE IMPACTS OF OU-3 ALTERNATIVES 25
5.0 SUMMARY 26
6.0 REFERENCES 28
TABLE 1: Comparison of the Results of the 1990 and the 1996 Risk Assessment for
Non-Carcinogenic Risks
TABLE 2: Comparison of the Results of the 1990 and the 1996 Risk Assessment for
Carcinogenic Risks
The Cody Ehkn Croup "* OTCiwinvoocsxiMFUMPOiif DOC
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1.0 INTRODUCTION
The Cody Ehlers Group (CEG) has reviewed the Superfund proposed rum
for the Imperial Oil Company and Champion Chemicals Site (i.e., the
"Site") in Morganville, Monmouth County, New Jersey. The Proposed Plan
was developed by the U.S. Environmental Protection Agency ("USSEPA)
arrd the New Jersey Department of Environmental Protection ("NJDEP")
and was issued by the NJDEP on March 18,1999. CEG also reviewed the
August 31, 1998 Source Control Feasibility Study ("SCPS") on which the
proposed Plan is based. The SCFS was prepared by Harding Lawson
Associates, Inc. ("Harding") for the NJDEP.
The focus of the Proposed Plan and the SCFS is the remediation of soil,
sediment, waste filter clay and free and residual product that is on, under
and bordering the Imperial Oil Company property. The environmental
media and the remedial actions evaluated in the SCFS are referred to as
Operable Unit 3 (OU-3) for the Site. The Proposed Plan identified one of the
remedial action alternatives (i.e., Alternative 3: Excavation and Off-site
Disposal or Reuse) as the remedial action preferred by the agencies for
OU-3. The first two operable units address soil in two off-site areas (OU-1)
and ground water on and off the Site (OU-2).
This document presents comments prepared by CEG on behalf of Imperial
Oil Company based on its review of the information presented in the
SCFS. The remainder of this document is structured as follows:
Section 2.0: Comments on Data Presentation and Evaluation
Section 3.0: Comments on the Remedial Action Objectives
Section 4.0: Comments on the Remedial Action Alternatives
Section 5.0: Summary
The source and year of the references used in preparing these comments
on the SCFS are presented in the text in parenthesis. The full title, authors
or source and date of the references used are listed in Section 6.0 of this
document.
. ,- ../e/oo 1 (J1JC\DOCS\IMP\IMTO3I DOC
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2.0 COMMENTS ON DATA PRESENTATION AND EVALUATION
The SCFS s does not clearly identify the soil and sediment selected for
^ remediation and it does not adequately justify conclusions regarding free
and residual product. These issues are discussed in Section 2,1 and Section
2.2, respectively.
2.1 DATA PRESENTATION
Section 4.2 of the SCFS, in conjunction with Figure 4-1 and Table 4-2,
identifies approximately 83,000 cubic yards of soil and sediment to be
remediated, the Proposed Plan requires that this material be excavated and
removed off-site. This is an extraordinarily large quantity of material to be
remediated for a single site covering less than 5 acres. As a direct result of
Harding's evaluation of the data, the remedial action alternatives
ientified and evaluated in the SCFS all entail the excavation of an
.'xtensive amount of 5oil, which could significantly affect Imperial Oil
Company operations. The SCFS and the Proposed Plan should link the
presence of specific chemicals in Site soil to the extent scope and location
of the remedial actions called for in the Proposed Plan.
The chemicals that are present in Site soil which Harding concluded
required remediation should have been identified in the SCFS through:
• a summary of the remedial investigation data;
• the evaluation presented in the risk assessment; and
• the manner in which USEPA guidance documents on acceptable
concentrations for chemicals in soil were used.
The data and the data ev luation, s :h as the risk assessment or
comparison to guidelines, tha. was used delineate 83,000 cubic yards of
Site soil to be remediated should have been clearly defined.
Section 4.2 of the SCFS, however, only provides a very brief explanation of
the manner in which soil and sediment selected for remediation was
identified. Harding only states that the analytical results were compared
to the Preliminary Remediation Goals (PRGs) developed in Section 4.1 and
that the "... exceedance of PRGs were influenced by the presence of PCBs
and inorganic constituents (primarily arsenic and beryllium) in samples
analyzed." This comparison was used to identify approximately 62,815
cubic yards of soil and sediment to be remediated. The foundation for
Harding's conclusion is wholly inadequate. {Note: Sechcn 3.0 of this
document contains comments on the manner in which the SCFS se :ted and used
various regulatory guidance on acceptable concentrations ofcherr ids in soil
PRGs for this Site.}
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Harding then explains that based ". . .on the interpreted distribution of
free and residual product shown in Figure 1-11.. " there is subsurface soil
containing chemicals in concentrations above the PRGs in areas for which
„ there is no chemical data (Le., beyond the areas encompassing the initial
soil and sediment quantity of 62315 cubic yards). Therefore, Harding
concludes that an additional 10350 cubic yards of subsurface soil would
need to be remediated from areas for which there is no chemical data. The
total soil and sediment quantity of approximately 83,000 cubic yards was
computed as the sum of:
• the 62,815 cubic yards exceeding PRGs;
• an additional 10,850 cubic yards of soil containing free and residual
product;
• 1,560 cubic yards of sediment basin material; and
• a contingency factor of 10% (i.e., an additional 7,522 cubic yards).
A more thorough analysis and presentation of this data is needed. The
costs for the remedial action alternatives evaluated in this document are
significant, ranging from $12.9 million to $37.7 million. In addition,
implementation of the Proposed Plan could significantly affect Imperial
Oil Company operations. A remedy of mis magnitude (Le., 83,000 cubic
yards) and remedial actions that significantly affect facility operations
require that the data and analysis used in the remedy selection process be
presented in a clear and thorough manner.
At a minimum, the following data presentation requirements contained in
the New Jersey Technical Requirements for Site Remediation (i.e., the
"NJDEP Technical Requirements") should have been used as guidance to
prepare the SCFS:
• NJAC 7:26E-3.13(c)3 requires that a table be presented that summarizes
all sampling results, including sample location, media, sample depth,
field and laboratory identification numbers, analytical results, and
comparison to applicable remediation standards organized by area of
concern, and that all chemical concentrations exceeding the applicable
remediation standards be identified.
• NJAC 7:26E-4.8(d)2 requires that sample locations maps be provided
showing all soil, sediment and other sampling locations, sample
depths, chemical concentrations, map scale and orientation and field
identification numbers for all samples.
Tables and figures required by the NJDEP Technical Requirements are
needed to make an informed decision regarding the need for and extent of
soil and sediment remediation at the Site. The SCFS should have used this
information to describe the specific chemicals that are present above the
PRGs in particular soil and sediment areas (i.e., areas of concern). For
Th« Cody Ehlen Group; 4/5/99 3
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example, some soil areas, such as Tank Farms #1, #Z #3> and #4, may
contain only inorganic constituents that do not pose an unacceptable risk
to ground water and pose only potential direct contact risks. Enguuetiiag
^controls (e.g., covers or caps) and institutional controls may be fully
protective of human health and the environment in these areas. Other
areas may contain only organic compounds present in concentrations
above acceptable levels that can be addressed by a combination of
removal, treatment engineering controls and institutional controls. It is
not possible for the public and the regulated community to judge the
appropriateness of the remedy selected in the Proposed Plan if the specific
chemicals that serve as the basis for the remediation of particular soil and
sediment areas are not identified.
The presentation of the data should also be revised so that average
chemic2' concentrations for specific depths can be calculated in
accordance with the method desc.ibed in the NJDEP Technical
Requirer-ents at 7:26E-4.8(c)3(i). The average concentration of ecific
chemicais in particular soil areas (Le., areas of concern) should t. .an be
compared to acceptable levels. Comments on the PRGs used as acceptable
levels in the SCFS and the Proposed Plan are discussed in Section 3.0. The
NJDEP Technical Requirements accepts this approach to evaluating site
data. This method of evaluating data would provide an adequate
understanding of Site conditions, the soil areas to be addressed by
remediation and the depth at which chemicals are present in soil in
concentrations above acceptable levels.
These methods of presenting soil and sediment data are also needed to
evaluate the removal of "hot spots" of soil, as described in the Proposed
Plan for Alterative 3. These "hot spc 5" include 5,000 gallons of free
product and 27,^00 cubic yards of soil frc i the following areas:
waste filter clay: 5,000 cubic yards
soil containing free and residual product 14,000 cubic yards
soil beneath tank farms #1, #2, #3, and #4: 8.000 cubic yards
Total "hot spot" volume of soil - 27,000 cubic yards
A better understanding of the chemicals present in this material, in
particular the chemicals present in residual product is needed in order to
assess the potential risks posed by this material and to evaluate possible
approaches to remedial actions. The presentation of the existing data
should be improved as described above to dearly identify the basis for the
decision presented in the Proposed Plan to remediate this material.
2.2 DATA EVALUATION (FREE AND RESIDUAL PRODUCT)
The SCFS and die Proposed Plan identified approximately 14,000 cubic
yards of soil that contains free and residual product and that is located
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above and below the water table in the northeast section of the Site. All of
the alternatives evaluated in the SCFS (except the No Action alternative)
called for this material to be excavated and either disposed of off-site (i.e.,
^ Alternatives 2 and 3) or treated on-site (i.e., Alternative 4). The remedial
action objectives for this material are defined in the Proposed Plan and in
Section 10 of the SCFS as preventing exposures to chemicals of concern
that leach from free and residual product to ground water.
The presence of free and residual product at the Site is probably the most
important environmental condition to be addressed at the Site. The
presence of volatile organic compounds (VOCs) in this material, which are
more mobile than the other organic compounds and the inorganic
constituents present in Site media and the presence of product below the
water table requires that the information related to free and residual
product be evaluated thoroughly. As a result, the evaluation of this data
presented in the SCFS and used in the Proposed Plan should have been
revised as follows:
• the "apparent" product thickness measurements should not have been
used to evaluate remedial actions;
• the limitations to the data used to conclude that product is migrating
should have been emphasized; and
• information on the characteristics of the product at the Site should
have been presented and evaluated in the SCFS.
2.2.1 Use of''Apparent" Product Thickness Measurements
The extent of product present at the Site was determined by the
measurement of apparent product thickness in a well at the time the
measurements were recorded. Measurements of apparent product
thickness have little or no relationship to the thickness of product that
may be present in the surrounding soil (i.e., the formation). This is noted
on page 1-10 of the SCFS where Harding acknowledges that [B]ecause
free product tends to accumulate in wefls as a result of water table
fluctuations, Figure 1-11 may not be representative of actual product
thickness in the aquifer." During periods of low rainfall, water table
elevations drop and product in adjacent soil flows into the wells or
piezometers. The resulting product thickness in that well or piezometer,
then, is greater than the actual thickness of product in the formation. As
the water table rises, the product tends to stay within the well or
piezometer. This process is repeated as water table elevations rise and fall.
In addition, product accumulates very slowly in wells or piezometersin
areas where actual product thickness is limited (i.e. 2 to 6 inches). The
result is that the "apparent" product thickness is influenced more by the
rise and fall of the water table than by the thickness of product in the
formation.
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To address this issue, actual product thickness in a formation is
determined by conducting baiidown testa. A baildown test involv
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piezometer P-10, discussed above, and no product accumulation was
observed in 6 of the wells and piezometers in 1989 or in 19%. A fair and
reasonable evaluation of the data supports a different conclusion than the
* conclusion drawn in the SCFS, namely that the overall extent of the
product is diminishing over time.
Finally, the conclusion that the product layer has migrated beyond the
berm is not consistent with the location of piezometer P-10, where the
only potential movement of product was identified. This piezometer is
located beyond the western end of the berm, at the base of the railroad
tracks. It is actually located south of the berm, i.e., closer to the center of
the Site than the berm. As a result, the characterization by Harding that
product has migrated beyond the berm is not substantiated by the data.
2.2.3 Product Characterization
The SCFS does not present any chemical data for the product at the Site.
The only reference to characterization of the product layer is on page 2-2
of the SCFS, which states that the product layer contains over 50
milligrams per kilograms (mg/kg) of PCBs, but does not reference the
specific data used to support this statement A review of the data
indicated that PCBs were detected in only one soil boring (JTB428) at a
concentration greater than 50 mg/kg. However, PCB concentrations in
soil borings located in the product area less than 50 feet away (i.e., JTB-
112) and 100 feet away (i.e., JTB-111) from JTB-128 were less than 50
mg/kg. The data that supports the conclusion that product contains PCBs
in concentrations greater than 50 mg/kg appears to be limited to this one
area (i.e., sample location JTB-128),
The U. S. Environmental Protection Agency (USEPA) has installed and
operated a passive product recovery system in this area. Although the
SCFS characterized the effectiveness of this system as not successful, it
should present the data that has been collected during the operation of
this system and should use it to evaluate the need for and extent of any
future remedial actions. The product should have been characterized for
PCB content, viscosity, specific gravity (to confirm that it is light non-
aqueous phase liquid, or LNAPL) and the level of degradation and
estimated exposure period. Other analytical methods, referred to as
petroleum hydrocarbon fingerprinting tests, should also have been used
during the operation of the USEPA system to characterize the product.
This information is critical to the identification, evaluation and selection of
remedial actions for free and residual product To &***«** ** **
information has already been collected by the USEPA dunng the
operation of the existing passive product recovery system, it should have
been presented and used in the SCFS. This data should be collected so that
ropriate ™thnd« nf product removal can be identified and evaluated.
*" 7 : OTCVDOaviMPWMfOiiDOC
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3.0 COMMENTS ON THE REMEDIAL ACTION OBJECTIVES
The SCFS relied on the risk assessment contained in the Remedial
^Investigation Report (Harding, 19%) and on various guidelines from the
. NJDEP and the USEPA to establish Preliminary Remediation Goals
(PRGs) for soil and sediment. The NCP at 40 CFR 300.430(eX2)(i) states
that preliminary remediation goals should be modified as more
information becomes available during the remedial investigation and
feasibility study and that final remediation goals should be determined
when the remedy is selected. Additional USEPA guidance on this issue
(USEPA, 1991) states that the preliminary remediation goals should be
modified based on the given waste management strategy selected at the
time of remedy selection and on the balancing of the nine criteria defined
in the NCP to evaluate remedial action alternatives. In summary,
-^mediation goals should be modified as additional information, sue. is
e volu ne of soil to be remediated, is obtained.
*
The SCFS and the Proposed Plan state that soil areas containing chemicals
in concentrations above the PRGs are assumed to require remediation.
These documents identified a total of 83,000 cubic yards of soil and
sediment to be remediated. Refer to Figure 4-1 and Table 4-2 of the SCFS
and to Section VIII (Alternative 3) of the Proposed Plan, Section 2.1 of this
document commented that the SCFS does not present a thorough
explanation of this data, including the necessary tables and figures.
Section 2.1 concluded that the presentation of the data contained in the
SCFS does not reflect the extent, scope and location of the contamination,
yet this data was the primary factor in the evaluation and selection of a
remedy. The need to link the extent of the remedy to the data collected
during He remedial investigation is particularly acute in light of the
extensi : excavation and the potential effects on existing facility
operati. ,TS called for in the remedy selected in the Proposed Plan.
In addition, the PRGs used in this analysis should also be revised to
conform with NJDEP and USEPA guidelines and practice regarding the
remediation of industrial sites, and with the National Contingency Plan
(NCP). The PRGs used by Harding were based on a number of overly
conservative and unrealistic assumptions, leading to the conclusion that
soil covering almost the entire area of the site, including the operating
facility, would need to be remediated. These unrealistic assumptions
regarding exposure, risk goals and other factors used to establish the
PRGs should be re-evaluated.
There are five issues related to the remedial action objectives addressed
these comments. The issues, and the sections they are addressed in, are
follows:
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Section 3.1: Use of an Industrial Exposure Scenario
Section 3.2: Use of a 1CH Cancer Risk Goal
Section 3.3: USEPA Guidelines on Lead and Arsenic in Soil
*> Section 3.4: Differences Between the 1990 and 19% Risk Assessment
Section 3.5: Use of USEPA Soil Screening Levels and RBC Table
3.1 USE OF AN INDUSTRIAL EXPOSURE SCENARIO
The Proposed Plan states that the USEPA and the NJDEP assumed that the
most probable future use of the Site would be industrial based on the
current land use of the Site. The factors listed below support the
appropriateness of basing remedial decisions on the assumption that this
Site will continue to be used for industrial purposes in the future:
• the 90 year industrial use of the Site and current operations (see
Section 3.1.1 of this document);
• sections of the National Contingency Plan, or NCP, as amended (NCP,
1990) and USEPA guidance related to land use (see Section 3.1.2 of this
document); and
• with other sections of the SCFS(see Section 3.1.3 of this document);.
Remediation of an industrial site to industrial cleanup standards is also
consistent with NJDEP and USEPA brownfield initiatives. The regulatory
brownfield initiatives seek to return abandoned industrial sites to
productive use as industrial or commercial properties by tailoring the
remedial actions to the limited types of exposures associated with non-
residential use. Clearly, the NJDEP and the USEPA have acknowledged
through these brownfield properties that, in many cases, the industrial use
of a site will not change in the future. These brownfield initiatives would
certainly never seek to demolish an existing industrial facility that wishes
to remain in operation so that the property could be cleaned up to
residential standards.
3.1.1 History of Industrial Site Use
The use of an industrial exposure scenario to develop cleanup levels for
the Site is consistent with the 90 year history of the Site as an industrial
facility and with the current industrial operations. The Proposed Plan
acknowledges that the Site has been used for a variety of industrial
operations since at least 1912. The Proposed Plan also states that some of
the industrial operations that have been performed at the Site at various
times during this period include:
• the production of tomato ketchup and tomato paste;
• the production of calcium arsenide and arsenic acid; and
• the production of flavors and essences, oil reclamation activities and
asphalt production.
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As described in the Proposed Plan, Imperial Oil Company leased the Site
from Champion Chemicals in 1968 and began conducting oil blending
.^operations, including mixing and repackaging unused (dean) oil for
delivery. Currently raw products (refined clean oil) are delivered by truck
and transferred to above-ground tanks.
The Site has been used for industrial operations for a considerable amount
of time. In fact, most of the brownfield sites that the NJDEP and the
USEPA acknowledge will always be industrial sites have not
demonstrated the history of industrial activity that characterizes the
Imperial Oil Company and Champion Chemicals Site. As a result the
assumption used in the Proposed Plan that the Site will continue to be used
for industrial purposes is appropriate.
3.1.2 The NCP, USEPA Guidance and Land Use
The types of activities a Site will be used for determines the types of
exposures, the level of potential risk and the nature and extent of the
remedial actions to be considered. In response, sections of the preamble
and the text of the NCP and specific USEPA guidance address the types of
uses that should be presumed for a site when an appropriate cleanup
strategy is being developed.
The preamble to the NCP (Fed. Reg., Volume 55, No. 46, March 8, 1990; ^*
page 8710) states the following: "The assumption of residential land use is
not a requirement of the program ..." It also acknowledges that
institutional controls can control exposure and that their effectiveness in
controlling risks can be considered in evaluating the effectiveness of a
remedial alternative.
Section 300.430(a)(l)(ui) of the NCP specifically states that the USEPA
expects to use institutional controls such as water use and deed
restrictions to supplement engineering controls as appropriate for short
and long term management to prevent or limit exposure to hazardous
materials and mat institutional controls may be used as a component of
the completed remedy. In fact the NCP (at 40 CFR 300.5) accepts
permanent relocation of a resident at a Superfund site as a remedial action
when "such relocation is more cost-effective man and environmentally
preferable" to off-site disposal.
The USEPA has further clarified the manner in which land use should be
evaluated for Superfund sites in a 1995 guidance document (USEPA,
1995). This guidance references the section of the NCP discussed above
and provides the following information with respect to land use and
assumptions regarding future land use:
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• ("Developing Remedial Action Objectives", page 7) "In cases where the
future land use is relatively certain, the remedial action objective
generally should reflect this land use."
>
• ("Land Use Considerations in Remedy Selection", page 8) "The volume and
-concentration of contaminants left on-site, and thus the degree of
residual risk at a site, will affect future land use. For example, a
remedial alternative may include leaving in place contaminants in soil
at concentrations protective for industrial exposures, but not protective
for residential exposures. In this case, institutional controls should be
used to ensure that industrial use of the land is maintained and to
prevent risks from residential exposures."
• ("Institutional Controls", page 9) "In such cases, institutional controls
will play a key role in ensuring long-term protectiveness and should
be evaluated and implemented with the same degree of care as is given
to other elements of the remedy."
• ("Institutional Controls", page 10) "Suppose, for example, that a selected
remedy will be protective for industrial land use and low levels of
hazardous substances will remain on site. An industry may still be able
to operate its business with the selected remedy in place. Institutional
controls, however, generally will need to be established to ensure the
land is not used for other, less restricted purposes, such as residential
use, or to alert potential buyers of any remaining contamination."
• ("Future Changes in Land Use", page 10) "Where waste is left on-site at
levels that would require limited use and restricted exposure, EPA will
conduct reviews at least every five years to monitor the site for any
changes. Such reviews should analyze the implementation and
effectiveness of institutional controls with the same degree of care as
other parts of the remedy. Should land use change, it will be necessary
to evaluate the implications of that change for the selected remedy,
and whether the remedy remains protective."
In order to not be inconsistent with the NCP and with USEPA guidelines
on land use assumptions, the SCFS and the Proposed Plan should be
revised to include an evaluation of remedial action alternatives that use
institutional controls based on an industrial use exposure scenario.
3.2 USE OF A 1(H EXCESS CANCER RISK GOAL
Section 2.6.4 of the SCFS acknowledges that the NCP (at 40 CFR
300430(e)(2)(i)) defines an acceptable exposure level as concentration
levels that represent an excess upper bound lifetime carcinogenic nsk to
an individual of between 1
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the total potential carcinogenic risk to levels less than 1O*. The 10-* risk
level is presented as the target carcinogenic risk level established by the
NJDEP "because it is more stringent and consistently applied."
The NJDEP target carcinogenic risk of 10* is arbitrary and it is not
consistent with the NCR The fact that the NJDEP target level is more
stringent than the NCP acceptable carcinogenic risk range does not justify
its use. The NCP and CERCLA, which govern remedial decisions at
Superfund sites, have established that it is unlikely that sites containing
chemicals posing risks within the 1O4 to 10* range will require
remediation. This is the standard by which Superfund sites across the
country have been judged. Spending additional funds to remediate this
Site to cleanup levels that are more stringent than those used to remediate
other CERCLA sites is not justified.
It is also doubtful that the 1O* risk level is consistently applied. Many of
the environmental statutes or guidance developed pursuant to the dean
Water Act, the dean Air Act R ~3A and the Safer Drinking Water Act are
based on acceptable carcinogeruc risk levels lower than 10*. As a result,
many of the applicable or relevant and appropriate requirements (i.e., the
" ARARs") identified in the SCFS are based on an acceptable carcinogenic
risk level of less than 10*.
The preamble to the NCP addressed this issue as follows (see Fed. Reg.,
Volume 55, No. 46, March 8,1990, page 8717):
"In the Superfund program, remediation decisions must be made
at hundreds of diverse sites across the country. Therefore, as a
practical matter, the remediation goal for a medi- m typically will
be established by means of a two-step approach. F t, EPA will use
an individual lifetime excess cancer risk of 11 as a point of
departure for establishing remediation goals for the risks from
contaminants at specific sites. While the 10* starting point
expresses EPA's preference for setting cleanup levels at the more
protective end of the risk range, it is not a presumption that the
final Superfund cleanup will attain that risk level."
"The second step involves consideration of a variety of site-specific
or remedy-specific factors. Such factors will enter into the
determination of where within the risk range of 1O* to 1O6 the
cleanup standard for a given contaminant will be established."
The preamble to the NCP also contains the following discussion on the
same page:
"EPA believes that ^.her risk levels may be protective when the
10* risk level will not be attained at a site due to the factors
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described above. Moreover, establishing 10-* as the single cleanup
level, i.e., the only level considered protective, would be
incongruous with CHRCLA's requirement to comply with ARAKs.
> Many ARARs, which Congress specifically intended be used as
cleanup standards at Superfund sites, are set at risk levels less
stringent than 10*."
The USEPA has further clarified its position on an acceptable carcinogenic
risk range of 1CH to 10* in a 1991 guidance document (USEPA, 1991). This
guidance states that remedial actions are generally not warranted at sites
where the cumulative carcinogenic risk to an individual based on
reasonable maximum exposures for both current and future land use is
less than 104. This guidance also states that the records of decision for
remedial actions taken at sites posing risks within the 1CH to 1O* risk
range must explain why remedial action is warranted.
As a result, the SCFS should be revised using the NCP acceptable
carcinogenic risk range of 1O4 to 10* in place of the NJDEP target
carcinogenic risk range of 10*. The sections of the SCFS that define the
remedial action objectives, the PRGs, the volume of soil and sediment to
be remediated and the nature and extent of the remedial action
alternatives that were evaluated should be revised to reflect an acceptable
carcinogenic risk range of 104 to 10*.
3.3 USEPA GUIDANCE ON LEAD AND ARSENIC IN SOIL
As discussed in Section 2.1 of this document, the SCFS is not clear as to
which chemicals present in Site soil and sediment require that this
material be remediated. However, there are several references to the
potential risks posed by lead and arsenic in Site soil that appear to have
been contributing factors in the decision to remediate this material. The
SCFS should be revised to reflect the current and future industrial use of
this property, as discussed earlier in Section 3.1, and to reflect USEPA
guidance on the potential risks posed by lead and arsenic in soil.
Information on USEPA guidance regarding the potential risks posed by
lead and arsenic in soil is discussed below.
3.3.1 Lead in Site Soil
The Proposed Plan establishes a " PRG for lead in soil of 400 parts per
million (ppm). This is based on a potential direct contact exposure for lead
in soil. The table lists "NA" for lead concentrations in soil that are
protective of ground water and define this notation as "Value for this
chemical is not available." This is consistent with the fact that the
remediation of inorganic constituents in Site soil to protect ground water
is probably not needed based on the limited presence of lead in ground
water. .__ . _ - -
_ ^_
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The contamination assessment summary presented in Section 2.0 of the
SCFS contained only incidental references to lead in the description of the
^chemicals for which specific soil areas are being remediated. However, the
only potential risks identified in the risk assessment component of the
1990 draft version of the remedial investigation report (i.e., Section 13.0)
that exceeded the acceptable level of risk defined in the NCP (i.e., 10-* to
106 carcinogenic risk and a health quotient of 1.0 for non-carcinogenic
constituents) were identified in that document as due to the presence of
lead in Site soil. The potential risks for the "Reasonable Worst Case*
exposure scenarios were attributed to lead for the following three areas:
AREA
Areas abutting
IOC property
Off-Site Areas
Off-Site Areas
EXPOSURE AMD POPULATION
children, dermal contact
ana incidental ingestion
children, dermal contact
and incidental ingestion
(dirt biking^
children, inhalation (dirt
biking)
NotKARONoeoac
RISK
(REASONAKEWOKST
CASE)
2.6
6.0
1.4
NOTES
99% attributable
to lend
98% attributable
toleid
95% attributable
to lead
As a result, the only area included in OU-3 that the 1990 risk assessment ••
concluded posed a potentially unacceptable risk was the area abutting the
IOC property. Almost all (99%) of this potential risk was attributed in the
report to the presence of lead in Site soil. However, a recent USEPA
guidance document (USEPA, 1997) explains that the USEPA has nr
reference doses or potency slope for inorganic lead and, as a result, it
not possible to calculate risk-based concentrations. The USEPA finds lea
to be ubiquitous in all media and is in the process of developing a
computer model to predict children's blood lead level concentrations
using lead levels in various media. This 1997 USEPA document directs the
reader to a directive from the USEPA Office of Solid Waste on risk
assessments and cleanups of residential soil lead for guidance on this issue
in the interim.
The USEPA guidance on lead in soil (USEPA, 1994) explains that a lead
concentration of 400 ppm in soil is used as a benchmark for further
evaluation. The guidance notes that this is also the lead concentration
used as a screening level in CERCLA and that the screening level is not a f
"cleanup standard" nor a "cleanup goal". Refer also to Section 3.5 of this
document for additional information on USEPA soil screening levels.
Rather, it is a lead concentration above which there is enough concern
warrant a site-specific study of risks. The guidance also states (page
that within the range of 400 to 5,000 ppm of lead in soil, the degree of risk
reduction activity should be commensurate with the expected risk posed
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by the bare soil/ considering both the concentration of lead in soil and the
likelihood of children's exposure.
* A review of the Site data indicates that with respect to on-site soil,
including the areas abutting the IOC property, lead was present in only
four samples in concentrations above the 400 ppm residential exposure
PRG. None of the samples contained lead in concentrations above 5,000
ppm and most of the samples collected from on-site soil did not contain
lead in concentrations greater than 400 ppm.
The SCFS and the Proposed Plan should be revised to address the presence
of lead in Site soil in a manner that is consistent with current USEPA
guidance on managing the potential risks related to the presence of lead in
soil at Superfund sites. The data on lead (and other chemicals) in Site soil
should be re-formatted as discussed in Section 2.1 and the future exposure
scenarios should be limited to industrial uses of the Site as discussed in
Section 3.1. The re-formatted data, including average lead concentrations
in Site soil in particular areas (Le., areas of concern), should be compared
to the 400 ppm to 5,000 ppm level In addition, the containment methods
discussed in the USEPA guidance document (USEPA, 1994) referenced
above should be evaluated in the SCFS and the Proposed Plan.
3.3.2 Arsenic in Site Soil
The Proposed Plan establishes a PRG for arsenic in soil .of 20 ppm. This
concentration was based on potential direct contact exposures for arsenic
in soil in residential and industrial areas. Section 4.2 of the SCFS identifies
62,850 cubic yards of soil containing chemicals in concentrations
exceeding the PRGs and stated that these exceedances were influenced by
the presence of PCBs, arsenic and beryllium. Section 2.1.2 of the SCFS
identified the soil beneath Tank Farms #1, #2, #3, and #4 as containing
elevated concentrations of arsenic. It appears from Figure 4-1, which the
SCFS uses to identify the soil to be remediated, that the presence of arsenic
in tank farm soil is responsible for a significant portion of the 62,850 cubic
yards of Site soil to be remediated.
The SCFS contains a number of references to the fact that inorganic
constituents in ground water are not likely to be associated with Site soil
but are likely to be a result of high turbidity in ground water, which tends
to accumulate and concentrate naturally occurring inorganic constituents.
In fact, the NJDEP conducted a separate ground water investigation at the
Site in July 1997 using a slow purge technique to reduce the effects of
turbidity in ground water data. The SCFS states in Section 2.2 that as a
result of this work, arsenic was detected in ground water in elevated
concentrations in two discrete locations. As a result, the decision to
remediate Site soil containing arsenic is based on the potential direct
contact risks and not to protect ground water.
•^ . **r
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However, the USEPA is currently evaluating a number of uncertainties
regarding the manner in which the potential risks associated with arsenic
^are being evaluated by the agency. A 1989 document (USEPA, 1989) for
the agency's Science Advisory Board concluded that USEPA's risk
assessments should take into account studies showing the humans can
detoxify low levels of arsenic For this and other reasons, a USEPA
guidance document on acceptable arsenic concentrations in soil (USEPA,
1997) refers to an agency risk management policy for arsenic dating from
1988 that considers risk levels of up to 10° for arsenic to be acceptable. The
acceptable risk-based concentration for arsenic in soil presented in the
USEPA guidance (USEPA, 1997) for a 1O3 risk level and a direct contact
industrial exposure would be 3,800 ppm. The acceptable risk level
concentration for arsenic as a non-carcinogen is 610 ppm for industrial
exposures.
The SCFS and the Proposed Plan should address the presence of arsenic in
Site soil in a manner that is consistent with current USEPA guidance on
managing the potential risks related to the presence of arsenic in soil. The
data on arsenic (and other chemicals) in Site soil should be re-formatted as
discussed in Section 2.1 and the future exposure scenarios should be
limited to industrial uses of the Site as discussed in Section 3.1. The re-
formatted data, including average arsenic concentrations in Site soil in
particular areas (i.e., areas of concern) such as the tank farm area, should
be compared to the 610 ppm non-carcinogenic risk-based concentration
contained in the USEPA guidance (USEPA, 1997) for arsenic in soil. If Site
soil, in particular the soil in the tank farm area, contains arsenic in
concentrations above this level, containment and similar methods to
prevent direct contact should be evaluated in the SCFS.
3.4 DIFFERENCES BETWEEN 1990 AND 1996 RISK ASSESSMENTS
The 1990 risk assessment for the Site (i.e., Section 13.0 of the 1990 version
of the Remedial Investigation Report) found that the only exposure for which
a non-carcinogenic health index exceeding the acceptable value of 1.0 for a
reasonable maximum exposure scenario involved neighborhood children
exposed to soil in Site areas abutting the IOC property. As discussed in
Section 3.3.1, 99% of these risks were attributed to lead. No other exposure
pathways led to a non-carcinogenic health index greater than 1.0 and none
of the exposure scenarios evaluated in the 1990 risk assessment resulted in
a carcinogenic risk that exceeded the acceptable NCP carcinogenic risk
range of 10-* to
Table 1 of this document r resents a ..ummary of the non-carcinogenk^p
health indices reported in t.;e 1990 risk assessment for various exposure
scenarios. A summary of the carcinogenic risks reported in the 1990 risk
assessment for various exposures are listed in Table 2 of this document.
The Cody Bites Group; 4/5/99 16 '' 0«C,\OOCSV/*«.\/M«« DOC
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The methods to be used to assess risks at Superfund sites were defined by
the USEPA in a 1989 guidance document (USEPA, 1989a). There have
been some relatively minor changed in the toxirity factors used by USEPA
but the fundamental approach, default values and assumptions used in
risk assessments for Superfund sites have not changed.
However, the 19% risk assessment for the Site summarized in Section 2.6
of the SCFS concluded that the same data and the same exposure
pathways used in the 1990 risk assessment now resulted in unacceptable
carcinogenic and non-carcinogenic risks. A list of the 19% non-
carcinogenic health indices is presented in Table 1 of this document and a
list of the 19% carcinogenic risks is presented in Table 2. The tables also
list the ratio of the 1990 to the 19% risk levels. The tables demonstrate that
despite the fact that both risk assessments used the same Site data and the
USEPA risk assessment protocols have not changed since 1989, the risks
reported in the 19% risk assessment were from 3 to over 8,000 times
higher than the risks calculated in the 1990 risk assessment for the same
exposure pathways.
Part of this increase may be due to the inappropriate use of a residential
exposure scenario for Site soil in the 19% risk assessment, as discussed in
Section 3.1 of this document. Since the 1990 risk assessment concluded
that the Site does not pose unacceptable risks and, consequently, does not
provide a justification for remedial actions, the difference between the
1990 and 1996 risk assessments needs to be explained. Therefore, the
NJDEP needs to explain the specific changes made to the 1990 risk
assessment (e.g., exposure assumptions, potency factors, reference doses,
etc.) that led to the substantial changes and the unacceptable risks
reported in the 19% risk assessment.
In addition, waste pile chemical data should not be used in the 19% risk
assessment As discussed in Section 2.6.5 of the SCFS, between 87% and
96% of the estimated cardnogenk risk and 100% of the estimated non-
carcinogenic risk to facility maintenance workers and to utility workers
(i.e., the only potential industrial use exposure scenarios) are associated
with potential inhalation exposures to fugitive dust emissions from the
waste pile. A Superfund Removal Action conducted by the USEPA in
November 1991 resulted in the removal of the above ground waste filter
clay material from the Site and its disposal in an off-site landfill. This
material, and the chemicals contained in this material, are no longer
present at the Site and this data should not have been used in the l996^*
assessment The limited statement contained in Section 16.5 of the SCFS
that the removal of waste-pile material above grade reduced the potential
for inhalation exposures does not adequately address this issue.
Th« Cody Ehta. Group; 4/5/99 ~ flijCXOOCSWM«w«i»
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3.5 USE OF USEPA SOIL SCREENING LEVELS
Table 4-1 of the SCFS lists the guidance values used to establish PRGs
* the Site. These guidance values are introduced in Section 3.2.1 of the SCFS
• as "To Be Considered" criteria. "To Be Considered" criteria are not
promulgated standards and do not carry the same weight in evaluating
remedial actions at CERCLA sites as do ARARs. Table 4-1 lists a set of
criteria as "USEPA Site-Specific Criteria" and notes that these are "Site-
specific criteria provided by the USEPA". The December 1997 draft
version of the SCFS refers to these criteria in Table 4-1 as "Site-specific
criteria transmitted to NJDEP on January 23,1997." Section 4.1 of the SCFS
contains the following information regarding these criteria:
• The site-specific criteria were developed by USEPA.
• They are based on future industrial use of the site.
• Include -teria for the protection of ground water.
• They ar health based criteria that consider the effects of human
exposur via incidental ingestion.
No other description or supporting documentation is presented of
described that would explain how these criteria were developed. The
January 23, 1997 correspondence from the USEPA to the NJDEP which
contained the USEPA "site-specific" criteria should be included as
appendix and the methods and assumptions used to develop these criteria1
should be presented in the SCFS.
The USEPA "site-specific" soil criteria presented in Table 4-1 of the SCFS
were compared to:
• the USEPA Region III Risk-Based Cor antration Table (USEPA, 1997);
and
• the USEPA Soil Screening Guidance Technical Background Document
(USEPA, 1996a).
This comparison shows that the majority of these "site-specific" USEPA
criteria were obtained from these USEPA guidance documents. This
comparison demonstrated that the USEPA "site-specific" ground
protection criteria listed for 30 of the 34 chemicals shown on Table 4-1 are
identical to the ground water protection criteria listed in the USEPA
guidance document (USEPA, 1996a) as national soil screening levels. The
comparison also showed that the USEPA "site-specific" industrial use
direct contact criteria for 29 of the 34 chemicals listed in Table 4-1 are
equal to one-half of the industrial direct contact screening level listed i
the USEPA Risk Based Concentration Table.
Clearly, these are not "site-specific" cleanup goals but, instead, are
national soil screening levels developed to assess site conditions early in
The Cody Ehlers Group; 4/5/99 IS (]t)C.\DOCS\tMP\lMP
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the remedial investigation and feasibilityJJudy process. The USEPA Risk-
Based Concentration Table and the USEPA Soil Screening Guidance
explain that the chemical concentrations presented in these documents are
soil screening levels and are not to be used as final cleanup criteria. The
intent of the USEPA in developing these soil screening levels is described
in^Section 1.1 of the USEPA Soil Screening Guidance as follows:
1. "SSLs are not national cleanup standards. SSLs alone do not trigger the need
for response actions or define "unacceptable" levels of contaminants in soil
In this guidance, "screening" refers to the process of identifying and
defining areas, contaminants, and conditions, at a particular site that do not
require further Federal attention. Generally, at sites where contaminant
concentrations fall below SSLs, no further action or study is warranted
under the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA)."
2. "Generally, where contaminant concentrations equal or exceed SSLs, further
study or investigation, but not necessarily cleanup, is warranted."
and
3. "SSLs developed in accordance wife mis guidance are based on future
residential land use assumptions and related exposure scenarios. Using this
guidance for sites where residential land use assumptions do not apply
could result in overly conservative screening levels."
Similarly, the USEPA Region IE Risk-Based Concentration Table contains
this guidance:
"To summarize, the table should generally not be used to (1) set cleanup
or no-action levels at CERCLA sites or RCRA Corrective Action sites, (2)
substitute for EPA guidance for preparing baseline risk assessments, or
(3) determining if a waste is hazardous under RCRA."
Based on this information, the SCPS should be revised to:
• acknowledge that the chemical concentrations referred to on Table 4-1
as "USEPA 'Site-Specific' Criteria" are screening levels and should
only be used to determine which soil and chemicals require further
study; and
• that this would only be one of a number of factors to be considered in
establishing final remediation goals.
In addition, the SCFS and the Proposed Plan need to justify an industrial
exposure remediation goal for 29 of the 34 chemicals listed that is equal to
one-half of the USEPA Region IH Risk-Based Concentration Table
(USEPA, 1997). The soil cleanup criteria presented in the USEPA Region
III Risk-Based Concentration Table already incorporates a number of very
conservative assumptions. Consequently, the use of one-half of the
USEPA Region III RBC Table values as cleanup goals is arbitrary and
unnecessarily conservative.
The Cody Ehl«s Group; 4/5/99
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4.0 COMMENTS ON THE REMEDIAL ACTION ALTERNATIVES
Sections 2.0 and 3.0 of this document presented comments on the manner
+\n which the data is presented and evaluated and on the remedial action
objectives established to determine the nature and extent of remedial
actions at the Site. This section provides comments on the development
and evaluation of the remedial action alternatives. These comments have
been grouped into the following sections:
Section 4.1: Remedial Action Alternative Recommendations
Section 4.2: Potential Off-site Impacts of OU-3 Alternatives
4.1 REMEDIAL ACTION ALTERNATIVE RECOMMENDATIONS
There are a number of alternate approaches to remediating the Site that
are effective in prott ing human health and me env; mment, that pose
fewer short-term e ,-cts, 'and are more cost-effective than the •
alternatives evaluated in the SCFS and the Proposed Plan. The SCFS ar ,
the Proposed Plan should be revised to include remedial action alternatives
that incorporate the following alternative approaches to the Site:
• acknowledge the industrial use of the Site;
• evaluate in-situ treatment and removal of free and residual product;
• evaluate a modified cap containment system that is consistent with the
existing use of the Site;
• consider the use of utility corridors to reduce exposures to
maintenance and other on-site workers.
Additional information on these alternative approaches is presented in
Sections 4.1.1 through 4.1.4.
4.1.2 Acknowledge Industrial Use
The SCFS and the Proposed Plan stated that the remedy was based on the
assumption that the Site would continue to be used for industrial
purposes in the future. However, the remedial action alternatives
presented in the Proposed Plan were first evaluated in the draft versions of
the SCFS (e.g., December 1997) that assumed the Site would be used for
residential purposes in the future. As a result, some of the most cost-
effective methods to address potential risks at industrial sites were not
adequately evaluated.
For example, an industrial use alternative should include deed restrictions
to prevent alternate uses of the Site and to limit the disturbance of Site soul
in the future. Adherence to these restrictions would be monitored as part
of USEPA's five year review of CERCLA sites (USEPA, 1995). This
industrial use alternative should seek to incorporate current operations,
The Cody Ehl«, Group; 4/5/995 " JWCADOCSMMPV.M™. ooc
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including existing buildings, access control and on-site maintenance as
part of the remedial actions designed to minimize or eliminate potential
exposures to the chemicals in Site soil.
This approach, either independently or in conjunction with the other
recommendations presented in this section, would provide a similar level
of protection to human health and the environment as do the alternatives
evaluated in the SGFS. However, an industrial use alternative can be
implemented at a significantly lower cost and would not pose the
potential implementability concerns and short-term effects associated with
the alternatives evaluated in the SCFS.
4.2.2 In-Situ Treatment and Removal of Free and Residual Product
Section 5.0 (page 5-3) of the SCFS states that technologies that specifically
address the recovery and/or the removal of free and residual product are
not identified in the document because of the high viscosity of the free
product and the low soil permeability. As a result the only approach
evaluated in the SCFS to free and residual product was excavation.
•
Product removal methods should have been evaluated in the SCFS. There
are product recovery technologies available that are a significant
improvement on the passive product recovery system installed at the Site
in 1991 and operated by the USEPA. The SCFS characterized the effects of
this system as limited, allegedly due to the high viscosity of the product
and the low hydraulic conductivity of the soil. There are several methods
currently available for removing high viscosity petroleum product from
low permeability soil. Some methods, such as hot air, hot water and steam
injection, are routinely used in the petroleum industry to recover crude
oil. These methods have been modified for use in removing petroleum
product from spill sites.
One technology that has been demonstrated to be a significant
improvement over passive product recovery systems is vacuum enhanced
product removal. These systems use a high pressure vacuum to forcibly
remove both free and residual product from subsurface soil located above
and below the water table. These systems remove contaminated ground
water, free and residual product and volatile organic compounds (as
vapors) from subsurface soil. Vapors are treated above ground and the
resulting product and ground water mixture is separated. The product is
transported to an off-site incinerator for destruction and the ground water
is treated and discharged. Treated ground water can also be heated and
re-injected into the formation to promote product removal.
More important, however, is the fact that these systems enhance the flow
of air through the unsaturated subsurface soil. This promotes the
biodegradation of the petroleum constituents that comprise the majority
Ehler* Group; 4/5/» *T~ OTC\OOCSWMPX/M«II DOC
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of the free and residual product. In addition, the rapid removal of ground
water that occurs when this system is in use causes ground water levels to
decrease below the residual saturation level This action physically
^removes the product attached to soil particles but it also exposes the soil
that was previously below the water table to air, enhancing the *
biodegradation of product and other, dissolved constituents in this soil
zone.
y
Demonstration and full-scale projects using this technology have been
conducted and reported by the U. S. Air Force, the Port Authority of New
York and New Jersey, the Xerox Corporation and others. These studies
were used to determine that vacuum enhanced product removal can
remove almost two to three gallons of product through biodegradation for
every gallon of product that is removed as a liquid.
Overall, vacuum enhanced product removal can be expected to remove
60% to 80% of the constituents that constitute free and residual product
within the first three years of operation. The constituents that remain are
relatively immobile. If these constituents cannot be removed by vacuum
enhanced product removal, it is very unlikely that they would migrate
under natural conditions in the future. Vacuum enhanced, product
removal offers several distinct advantages over the remedial action
alternatives that were evaluated in the SCFS: jg±
• Vacuum enhanced product removal treats and destroys between 60%
to 80% of the constituents present in free and residual product in the
first three years of operation. All but one of the alternatives evaluated
in the SCFS simply relocate these constituents to either an on-site or an
off-site landfill containment cell. As a result vacuum enhanced
product removal satisfies the preference for treatment contained in the
NCP and in the NJDEP Technical Requirements, as described in
Section 6.0 of the SCFS. The NCP states that the evaluation of
alternatives shall also consider the preference for treatment as a
principal element and the bias against off-site land disposal of
untreated waste (40 CFR 300.430(f)(l)(ii)(E)).
• Vacuum enhanced product removal is performed in-situ, and does not
require the excavation of this material. Almost all of the alternatives *
evaluated in the SCFS require this material to be excavated. In-situ
treatment and removal (for off-site incineration) eliminates the
potential short-term fugitive emissions, erosion and vehicle traffic /
impacts associated with an excavation scenario and does riot require
that the existing industrial facility be demolished.
• Vacuum enhanced product removal can be used to remove free anc
residual product at greater depths than can be achieved through
excavation. Vacuum enhanced product removal aerates previously
The Cody Ehlers Group; 4/5/99 22 flHC\DOCS\lMPWM«3i occ
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saturated soil and the physical removal and biodegradation it provides
can be used to enhance the remediation of the ground water aquifer
beneath the product area. This approach would be more effective in
removing the volatile organic compounds and the semi-volatile
organic compounds from Site ground water man would the planned
conventional pump-and-treat ground water remedy.
For these reasons, the Proposed Plan should be revised to evaluate vacuum
enhanced product removal as a component of an industrial use alternative
to address the presence of free and residual product
4.1.3 Modified Cover Containment System
Section 7.4 of the SCFS describes and evaluates an alternative (i.e.,
Alternative 2C) that entails removing approximately 27,000 cubic yards of
"hot spot" soil for off-site disposal and capping the remaining soil in
place. The "hot spot" soil to be removed consists of approximately 5,000
cubic yards of soil beneath the former waste filter clay pile, 14,000 cubic
yards of soil containing free and residual product and 8,000 cubic yards of
arsenic-containing soil beneath the tank farm area. As discussed in Section
4.1.2 of this document, the petroleum constituents and PCBs present in the
soil beneath the former waste pile area and in the free and residual
product area can be removed using an in-situ vacuum enhanced product
removal system. The physical product removal, soil bioremediation and
ground water extraction components of this system would reduce
constituent concentrations to levels that are protective of ground water.
Direct contact exposure risks that remain, if any, can then be addressed by
installing a modified cap over soil in the product and other Site areas.
This approach is consistent with the assumption contained in the Proposed
Plan that future use of the Site will be for industrial purposes. The existing
industrial operation would continue, but residential use of the property in
the future would be prohibited.
The modified cap would also be installed over the arsenic-containing soil
in the tank farm area. Recent ground water sampling conducted by the
NJDEP using low flow sampling techniques that limit turbidity in ground
water samples has demonstrated that arsenic and other inorganic
constituents are not present in Site ground water in concentrations that
require remediation. As a result, the sole reason for remediating the
arsenic-containing soil in the tank farm area is to prevent direct contact.
Direct contact with this soil can best be achieved by maintaining the Site
for industrial use and by the installation of a modified cap. Sediment from
the fire pond and from Birch Swamp Brook can be consolidated onto the
area of the Site where the cap is to be installed.
The Cody Ehlen Group; 4/5/99
fllJC \ DOCS \IMP\1MP031 DOC
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The modified cap can be constructed of a 6 to 12 inch thick layer of asphalt
pavement The existing asphalt cap should be incorporated into the new
modified cap. Much of tile asphalt for this cap can be obtained by using
ASite soil in the product area that contains acceptable concentrations of
PCBs. This material can be used in an on-site or off-site asphalt batch plant
to generate a 5 to 11 inch thick asphalt binder course. A. 1 inch thick
wearing course using commercially produced asphalt would then be
placed to complete the cap. The existing buildings would remain and the
cap would be installed between these structures.
This modified cap would eliminate direct contact with Site soil, prevent
fugitive emissions and eliminate erosion and the potential for off-site
migration of Site-related constituents. Since the vacuum enhanced product
removal system would address the potential impacts to ground water
from organic compounds in soil and arsenic in Site soil does not pose a
risk to ground water, the only exposure pathway for which the modified
cap needs to be designed is direct contact As a result, a permeable •-. -phalt
pavement mix can be used in the modified cap. The permeable asphalt cap
would reduce and possibly eliminate storm water runoff from the Site.
4.1.4 Utility Corridors
One of the potential exposure pathways evaluated in the risk assessment
was the potential for a maintenance worker to occasionally come into'
contact with subsurface soil containing Site-related chemicals during the
repair of underground utility lines. The risk assessment contained in the
1990 version of the Remedial Investigation Report determined that the
potential risks for this exposure pathway were well below the NCP
acceptable risk levels for carcinogenic and for noncarcinogenic
constituents. However, the risk assessment contained in the 19% version
of the Remedial Investigation Report (Harding, 19%) determined otherwise,
i.e., that risks for utility workers would be unacceptable. Section 3.4 of this
document questions the reasons for this change, since the same data were
available and the same risk assessment protocols were in place in 1990 and
in 19%.
Nevertheless, potential risks related to subsurface utility workers can be
addressed by installing utility corridors. Utility corridors are trenches of
uncontaminated soil placed around underground utility lines. In this way,
workers maintaining underground utilities in the future would not be
exposed to Site-related chemicals in soil. The trenches can be installed
around existing utilities or the utility lines can replaced in a trench
containing uncontaminated soil that would be installed for that purpose.
The soil removed from the trench can be consolidated onto the site,
areas to be covered by the modified cap described in Section 4.1.3.
The Cody Ehlen Group; 4/5/99 24 (jifO\DOCSVMPVMffui DOC
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It is unlikely that Site soil poses unacceptable risks to workers maintaining
underground utility lines. However, utility corridors should be evaluated
in the SCFS and in the Proposed Plan as part of an uvsitu treatment and
^ containment remedy that does not require extensive excavation of soil and
* would not impact existing facility operations.
4.2 POTENTIAL OFF-SITE IMPACTS OF OU-3 ALTERNATIVES
The Proposed Plan does not address the potentially significant impacts to
surrounding areas that would be posed by implementation of the
excavation remedy. The Proposed Plan calls for the excavation and off-site
disposal of 83,000 cubic yards of soil. The fugitive emissions, dust, noise and
vehicle traffic associated with this type of remedial action are significant
The risks to human health and the environment posed by this remedial
action should be accounted for and denned in the SCFS and in the Proposed
Plan to properly evaluate these alternatives.
Th« Cody Ehl«« Group; 4/5/99
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5.0 SUMMARY
The issues discussed in this document should be addressed in a revised
»SGFS. The principle issues are summarized as follows:
• The SCFS identified approximately 83,000 cubic yards off soil and
sediment to be remediated. As a direct result of the evaluation of the
data presented by Harding in the SCFS, the remedial action *
alternatives identified and evaluated in that document all entail the
excavation of an extensive amount of soil and the demolition and
removal of the operating Imperial Oil Company facility. The SCFS
needs to clearly depict the data and the data evaluation, such as the
risk assessment or comparison to guidelines, that was used by Harding
to delineate 83,000 cubic yards of Site soil to be remediated. The data
presentation needs to be revised so that the reasons for Hard '.->.-
conclusions regarding the extent scope and location of the reme<
bi tnderstood.
• A residential exposure scenario should not have been used to devek.*.
the final remediation action objectives. The need to revise the remedial
action objectives in the SCFS to reflect current and future industrial use
of the Site is supported by (refer to Section 3.1 of this document.}:
1. The requirements of the NCP and guidance provided by the
USEPA regarding land use.
2. The 90 year industrial use history of the Site.
3. The regulatory support of recent brownfield initiatives.
4. The acknowledgment in the SCFS that institutional controls can be
effective in preventing residential use of the Site in the future.
• A 10-6 target carcinogenic risk level for CERCLA sites in the state >f
New Jersey is inconsistent with the NCP and USEPA guidance, wh ch
specifically define an acceptable carcinogenic risk range of 10-* to 1 j*.
The remedial action objectives presented in the SCFS should be revised
to reflect the NCP definition and USEPA guidance on acceptable
carcinogenic risk levels. (Refer to Section 3.2 of this document.)
• The use of USEPA Soil Screening Levels (SSLs) as remedial goals is
inappropriate. This USEPA guidance specifically states that these
screening levels should not be used as final remediation goals. (Refer to i
Section 3.5 of this document.}
• The potential off-site impacts associated with the excavation and off- f
site disposal alternative evaluated in the SCFS (i.e., Alternative 3), such
as the dust generation, wind-blown soil, erosion and the number oif
vehicles that will need to enter and leave the Site, could be significant^
As a result, the potential risks associated with these activities should^
have been evaluated in the SCFS. (Refer to Section 4.3 of this document.}
The Cody Ehlers Group; 4/5/99
26 (]ltC\DOCS\lMf\IMP03l COC
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In addition, revisions are also needed to theSCFS and the Proposed Plan to
address USEPA guidance on lead and arsenic in soil (refer to Section 3.3}
and the differences between the 1990 and the 1996 risk assessments {refer
to Section 3.4}.
Finally, the SCFS and the Proposed Plan should be revised to evaluate an
alternative that would be effective in protecting human health and the
environment, does not require that the existing facility be demolished, and
poses fewer short-term effects and is more cost-effective than the
alternatives evaluated in the SCFS. Section 4.1 of this document discusses
the following technologies that should be considered in developing such
an alternative:
• an industrial future use exposure scenario;
• in-situ treatment and removal of free and residual product (e.g.,
vacuum enhanced product removal);
• a modified cap containment system; and
• utility corridors.
Such low-cost, low-impact technologies can be used to address the
potential risks posed by the Site without posing significant off-site impacts
and can be implemented at a cost far below that of the remedy selected in
the Proposed Plan.
The Cody Ehl«, Group; 4/5/99 *
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6.0 REFERENCES
Harding Lawson Associates, Inc. (Formerly ABB Environmental Service*)
» 1996. Final Remedial Investigation Report, Imperial OH Company and
Champion Chemicals Site, Morganville, N«P Jersey; Harding '•*
Environmental Services, Inc.; Prepared for the New Jersey Department
* of Environmental Protection; December 19%.
t
Grusczcenski, 1987. Determination of a realistic estimate of the actual formation
product thickness using monitoring wells: a filed bailout test.; Grusczcenski,
Thomas, 1987; Proceedings of NWWA/API Conference on Petroleum
Hydrocarbons and Organic Chemicals in Ground Water - Prevention,
Detection and Restoration; pp. 235-253.
Hughes, 1988. Two techniques for determining the true hydrocarbon thickness
in a sandy aquifer:; John P. Hughes, day R. Sullivan, and Ronald E.
Zimmer, 1988. Proceedings of NWWA/API Conference on Petroleum
Hydrocarbons and Organic Chemicals in Ground Water - Prevention,
Detection and Restoration; pp. 291-314.
NCP, 1990. National Oil and Hazardous Substances Pollution Contingency
Plan; 40 Code of Federal Regulations, Part 300; March 1990 (Amended).
USEFA, 1989. Science Advisory Review Board's review of the arsenic issuesmH
relating to the phase II proposed regulations from the Office of Drinking
Water; EPA-SAB-EHC-89-038; Memorandum to William K. Reilly;
Washington, DC: Environmental Protection Agency; September 28,
1989.
USEPA, 1989a. Risk Assessment Guidance far Superfund, Volume I, Human
Health Evaluation Manual; EPA/540/1-89/02; December 1989.
USEPA, 1991. Rote of the Baseline Risk Assessment in Superfund Remedy
Selection Decisions; Office of Solid Waste and Emergency Response
(OSWER) Directive No. 9355.0-30; Don R. day, USEPA Assistant
Administrator; April 22,1991.
USEPA, 1994. Guidance on Residential Lead-Based Point, Lead-Contaminated f
Dust and Lead-Contaminated Soil; memorandum and guidance
document; L. R. Goldman, M.D., USEPA Assistant Administrator; July
14,1994. f
USEPA, 1995. Land Use in the CERCLA Remedy Selection Process; Office of
Solid Waste and Emergency Response (OSWER) Directive No.
04; Elliot P. Laws, USEPA Assistant Administrator; May 25,1995.
The Cody Ehl« Group; 4/5/99 28 ffflC\OOCS\/*!P\iMW3looc
-------
USEPA, 1996. Sod Screening Guidance: User's. Guide; USEPA Office of Solid
Waste and Emergency Response; EPA/540/R-96/018; April 1996.
(Note: The current appendix A, Generic SSLs, was obtained from the USEFA
internet web site in April 199$.}
USEPA, 1996a. Soil Screening Guidance: Technical Background Document;
' USEPA Office of Solid Waste and Emergency Response; EPA/540/R-
95/128; July 1996;
USEPA, 1997. Risk Based Concentration Table; Jennifer Hubbard,
lexicologist, Superfund Technical Support Section (3HS41); October 1,
1998.
The Cody Ehien Group; 4/5/99
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Appendix C
-rcccsec. .r_an
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-------
Proposed Plan
Imperial Oil Company Superfund Site
Marlboro Township, Monmouth County
March 18,1999
I. PURPOSE OF THE PROPOSED PLAN
This Proposed Plan describes the remedial alterna-
tives considered for the Imperial Oil Company, Inc./
Champion Chemicals (IOC/CC) Superfund Site (the
site") to remediate the contaminated soil found at the
main site and presents the remedial alternative
preferred by NJDEP and USEPA along with the
rationale forthis preference. The actions described in
this document represent the third and final Operable
Unit forthe site. The first Operable Unit (OU1) ad-
dressed off-site soil contamination and the second
(OU2) addressed groundwater contamination. This
Operable Unit addresses soil contamination found on
the property in the vicinity of the operating plant. The
preferred alternative forOperable Unit 3 is Alternative 3
- Excavation/Off-site Disposal/Reuse.
This document was developed bythe U.S. Environ-
mental Protection Agency (EPA) and the New Jersey
Department of Environmental Protection (NJDEP). The
NJDEP is issuing the Proposed Plan as part of its
public participation responsibilities under Section
117 (a) of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of 1980, as
amended, and Section 300.430(f) of the National Oil
and Hazardous Substances Pollution Contingency
Plan(NCP).
The Proposed Plan is being provided to inform the
public of N JDEP's and USEPA's preferred remedy and
to solicit public comments pertaining to all the reme-
dial alternatives evaluated, including the preferred
remedy Changes to the preferred remedy, or a
change from the preferred remedy to another remedy,
may be made, if public comments or additional data
indicate that such a change will result in a more
appropriate remedial action. The final decision
regarding the selected remedy will be made after EPA
and NJDEP have taken into consideration ail public
comments.
The Proposed Plan summarizes the information
presented in the Remedial Investigation (Rl) Report
(December. 1996), Source Control Feasibility Study
(FS) Report (August, 1998). and the Addendum to me
Source Control Feasibility Study (Addendum) Report
(January 1999.) These Reports should oe consulted
for a more detailed description of the nature and exient
of contamination at the site and all the remedial
alternatives evaluated.
•II. COMMUNITY ROLE IN THE
SELECTION PROCESS
USEPA and NJDEP rely on public input to ensure that
the concerns of the community are considered m
selecting an effective remedy for each Superfund site
To this end. the Rl and FS Reports, the Addendum to
the FS Report, the Proposed Plan and supporting
documentation have been made available to tne public
for a public comment period which begins on February
19,1999 and concludes on April 6 1999
A public meeting will be held during the public com-
ment period at the Marlboro Township Municipal
Building on Thursday, March 18, 1999 at 7 00 p m to
present the conclusions of the Rl and FS Reports to
elaborate further on the reasons for recommending the
preferred remedial alternative, and to receive puDiic
comments.
Comments received at the public meeting, as well as
written comments, will be documented m the Respon-
siveness Summary Section of the Record of Decision
Dates to Remember
February I9»1999 through April*, 1999
-' PaMkC«ram«rtP«riod
Thurtday .March t*,«*9 «7 pan.
Public Meeting»t ttieMariboro Township
MunWpaJBaidinf
NewJerseyDepartmentof^
«Bureau of Community Relations
(609)984-3081
Printed on r«cycl«d p*p«r
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IOC Suoerfund Site Proposed Plan
(ROD), the document which formalizes the selection of
the remedy.
All written comments should be addressed to:
Mr, Donald J. Kakas, Section Chief
Bureau of Community Relations
New Jersey Department of Environmental Protection
Division of Publicly Funded Site Remediation
PO. Box413
Trenton. New Jersey 08625-0413
{609)984-3081
Copies of the Final Rl Report, FS Report, Addendum
to the FS Report, Proposed Plan, and supporting
documentation which support the selection of this
response action are available locally at:
Monmouth County Library
1 Library Court
Marlboro, New Jersey 07746
(732)536-9406
Copies of the Final Rl Report, FS Report, Addendum
to the FS Report. Proposed Plan, and supporting
documentation are also available at the following
locations:
New Jersey Department of Environmental
Protection
Bureau of Community Relations
401 East State Street, 6th Floor
Trenton, New Jersey 08625-0413
(609)984-3081
U. S. Environmental Protection Agency
Superfund Records Center, 18" Floor
290 Broadway
New York, New York 10007-1880
(212)637-4308
EPA, in consultation with NJDEP, will select a remedy
for the site only after the public comment period has
ended and the information submitted during that time
has been reviewed and considered.
III. SITE BACKGROUND
The Imperial Oil Company/Champion Chemicals (IOC/
CC) site is located in the Morganville section of
Marlboro Township in northwest Monmouth County.
Champion Chemical Company is the owner of th« real
property located on Lot 29, Block 122. Orchard Place
in Morganville. The premises are leased to the
Imperial Oil Company, Inc., which operates an oil
blending facility.
Imperial Oil Company's operations occupy approxi-
mately 4.2 acres of the entire 15 acres of the site. A
chain-link fence surrounds the active portion of the
site. There are seven buildings on-site used for
production, storage, and maintenance and there are
also numerous above ground oil storage tanks (see
Figures 1 & 2). The western property line abuts the
abandoned Central Railroad of New Jersey's Freehold
and Atlantic Highlands Branch Main Line.
There are approximately 30 scattered residential
properties along the surrounding roads. A small
commercial center (Morganville) is located approxi-
mately 2 mile southeast of the site at the junction of
Route 3 and Route 79. Two automobile scrap yards
are located just to the northeast of the site boundaries.
Lake Lefferts, a swimming and recreational area, is
located approximately one mile north of the site. Lake
Lefferts has been identified as a potential potable
water source for the area.
The site is located within the Matawan watershed of
the Atlantic Coastal Drainage Basin. The topography
of the site ranges from 120 feet above mean sea level
(MSL) in the southwest comer of the site to 97 feet
above MSL at the northern boundary. Surface water
runoff at the site is to the north. During periods of
heavy rainfall, water accumulates in a catchment area
in the northern section of the site. This water and site
runoff is contained by an earthen berm that extends
along the northeastern fence line of the site. Three oil/
water separators and an arsenic treatment unit are
used to treat any runoff that collects in the earthen
berm. To the east of the berm is a man-made pond
known as the Fire Pond which discharges to Birch
Swamp Brook. Birch Swamp Brook, an intermittent
stream at the site, flows through a bog northwest of
the site, through a culvert under the rail line and
through Off-site Areas 1 and 2, and subsequently
drains into Lake Lefferts. Lake Lefferts empties into
RaritanBay. The two areas, known as Off-site Areas
1 and 2. are located approximately 220 feet and 700
feet northwest of the facility, respectively. The soil in
these areas is contaminated with arsenic, lead, and
polychlorinated biphenyls (PCS*). QfMwte Areas 1
and 2 are being addressed as part of the OU1 reme-
diation.
The Englishtown AquWer underlies the site. It is
classified as GW-2(Current and Potential Potable
Water Supply) and is an important source of water
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IOC Superfund Site Proposed Plan
supply for Monmouth and northern Ocean Counties.
Twenty-eight residential wells were identified within a
1 -mile radius onhe site, none of which are used for
potable drinking water. The Marlboro Township
Municipal Utilities Authority supplies the potable water
to the residents in the vicinity of the site and their
supply wells, which draw water from the deeper
Rantan-Magothy Aquifer, are located approximately
two miles south (upgradient) of the site.
Industrial activities have been ongoing at the site since
approximately 1912. Initially, ketchup and tomato
paste was manufactured at the facility until approxi-
mately 1917, at which time it was converted to a
chemical processing plant. The products of the
chemical plant may have included arsenic acid and
calcium arsenate. followed by the manufacturing of
flavors and essences, 'n approximately 1950. the
plant was purchased by Champion Chemical and
became an oil reclamation facility. The oil reclamation
process used diatomaceous earth (filter clay) and
caustic solution to remove heavy metals and polychlo-
rmated biphenyls (PCBs) from waste oil. The waste
products of the oil reclamation process, including the
contaminated filter clay and caustic solution, were
disposed of on the site. This operation continued until
approximately 1965. Imperial Oil Company leased the
site from Champion Chemical in 1968 and began .
conducting oil blending operations, including mixing
and repackaging unused (clean) oil for delivery.
Currently, raw products (refined clean oil) are delivered
by truck and transferred to above-ground tanks.
Imperial Oil mixes and blends the oil for its customers.
The IOC/CC site initially came to the attention of
regulatory authorities in September 1978. The results
of NJDEP's 1981 analyses of soil and waste filter clay
pile samples revealed high concentrations of petroleum
hydrocarbons, lead, arsenic, barium, and PCBs.
In Decemberl 981, the IOC/CC entered into an
Administrative Consent Order (AGO) with the N JDEP
in which the IOC/CC agreed to cease discharging of
hazardous wast* and other pollutants into the waters
of the state and agreed to comply with specified
discharge limits sat forth by tha New Jar»ay Pollutant
Discharge Elimination System (NJPDES). In addition,
the ACO required the IOC/CC to repair the oil/water
separators and disposa of tha oil/water separator
sludge in a manner acceptable to the NJDEP.
The IOC/CC site was proposad for inclusion on tha
EPA'sNationalPrioritiesList(NPL) ofSuperfund
sites on Decambar 1,1982. Tha sita was formally
added to the NPL on September 1,1983.
During the period 1983 through 1556, N'JDEr ,r,anv
tained an on-going inspection and monitoring program
of the site and surrounding areas. In addition. EPA
and the Monmouth County Prosecutor's Office con-
ducted investigations at the site, confirming that heavy
metals. PCBs, and petroleum hydrocarbons were
present in soil and ground water.
A remedial investigation (Rl) of the site was conducted
by NJDEP's contractor, E.G. Jordan Company. The Rl
was divided into two phases. The first phase was
conducted in 1987 and the other phase m 1989/1990.
The purpose of the Rl was to. determine the nature
and extent of contamination resulting from historic site
activities; identify potential contamination migration
routes; identify potential receptors of site contami-
nants; and characterize potential human health risks
and related environmental impacts. The Draft Rl was
completed in 1990 by E.G. Jordan.
In September 1990, EPA issued a Record of Decision
(ROD) for the remediation of Off-site Areas 1 and 2
(Operable Unrt 1 (OU1)). The major components of the
ROD included: the installation of fencing to control
access to the contaminated soil areas; the excavation
and appropriate off-site disposal of contaminated soil
from within the wetlands; and the restoration of
affected wetlands.
In September 1991, EPA installed the fence around
Off-site Areas 1 and 2 to control access to the con-
taminated soil.
In November 1991, as part of a removal action, EPA
excavated the waste filter clay pile down to ground
level. The waste clay pile was contaminated with
PCBs, arsenic, lead, and total petroleum hydrocar-
bons. The excavated material (approximately 660
cubic yards) was disposed of in an approved Resource
Conservation and Recovery Act (RCRA) landfill Also,
in 1991, EPA installed extraction walls to remove a
petroleum-like product layer (floating product) from the
groundwatar banaath tha waste filtar clay pita. Tha
extraction walls and floating product removal systam
ware installed undar a removal action. The extracted
floating product is being stored in an orvsrte storage
tank before disposal. In 1996, NJDEP assumed
responsibility for tha operation and maintenance of the
floating product removal systam. To data, approxi-
mately 10 000 gallons of the floating product have
been extracted and disposed of at a Toxic Substance
Control Act (TSCA) regulated incinerator.
in September 1992, EPA issued a ROD for the
remediation of the contaminated groundwater (Oper-
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IOC Superfund Site Proposed Plan
able Unit 2 (OU2))JThe major components of the ROD
included: the installation of extraction wells to extract
the contaminated groundwater; the treatment of
extracted groundwater via precipitation of inorganic
contaminants and carbon adsorption of organic
contaminants: the discharge of the treated groundwa-
ter to Birch Swamp Brook: the continuation of the
floating product removal action that was initially
undertaken by the EPA, and the appropriate environ-
mental monitoring to ensure the effectiveness of the
remedy.
In November 1996. N JDEP collected and analyzed
additional soil samples at the site to complete the
remedial investigation work. The Rl Report was
finalized in December 1996 and the Source Control
Feasibility Study Report for Operable Unit 3 was
completed in August 1998. The Addendum to the
Source Control Feasibility Study Report was com-
pleted in January 1999.
In September 1997. EPA issued an Explanation of
Significant Differences (ESD) to modify the September
1990 ROD to include the remediation of four residential
properties located adjacent to the Imperial Oil facility
and the implementation of engineering controls in the
vicinity of the Fire Pond and forested wetland areas of
the site In March 1998. EPA initiated the excavation
and disposal of the contaminated soil found on the four
residential properties. EPA excavated and disposed of
approximately 5,700 cubic yards of soil from the
properties. In August 1998, EPA completed the work
and restored the properties.
IV.REMEDIAL INVESTIGATION SUM-
MARY
The IOC/CC Rl Report identified the following contami-
nated media/areas:
1. Off-site contaminated residential and wetland soil
2. On-site and off-site ground water contamination
3. Floating product (also referred to as free and
residual product) which underlies the waste fitter
clay material
4. On-site waste fitter day material
5. On-site soil contamination
6. Birch Swamp Brook sediment contamination
The off-site contaminated residential and wetland soils
are being addressed as part of OU1. The on/off-site
groundwater contamination is being addressed as part
of OU2. The remedial designs for OU1 and OU2 are
underway. EPA and NJDEP plan to include the
remediation of Birch Swamp Brook sediment contami-
nation as part of OU1. Since the floating product is a
continuing source of groundwater and soil contamina-
tion at the site, the floating product will be addressed
as part of Operable Unit 3 (OU3). OU3 will also
address the waste filter clay material and the on-site
soil contamination.
The Rl results related to the contaminated waste filter
clay material, the floating product and the on-site soil
indicate that the waste fitter clay material, the floating
product, and the on-site soil are contaminated with
volatile organic compounds (VOCs), semi-volatile
organic compounds (SVOCs), PCBs, metals, and total
petroleum hydrocarbonsfTPH).
The contaminants found m the waste fitter clay
material, the floating product and the on-site soil
include: PCBs (up to 128.2 part per million (ppm)),
arsenic (upto 6,120 ppm), and lead (up to 3,720 ppm),
benzene (up to 0.42 ppm). toluene (up to 2.3 ppm),
xylene (up to 3.3 ppm), ethylbenzene (up to 0.81
ppm), pyrene (up to 5.0 ppm),
bis(2-«thylhexyl)phthalate (up to 12 ppm), and
butylbenzyl phthalate (up to 47 ppm).
V. SUMMARY OF SITE RISKS
Based upon the results of the Rl, a baseline nsk
assessment was conducted to estimate the risks
associated with current and future site conditions. The
baseline risk assessment estimates the human health
and ecological risk which could result from the con-
tamination at the site if no remedial action were taken.
The baseline risk assessment is presented in Chapter
13 of the Rl Report and addresses all contaminated
media identified at the site. The ecological risk
assessment is presented In Chapter 14 of the Rl. The
discussion of risk presented below addresses only
risks posed by soil contamination found on the IOC
facility, the waste fitter day material, and me floating
product since these are the media addressed in this
Proposed Plan.
BASELINE HUMAN-HEALTH RISK ASSESSMENT
A four-step process is utilized for assessing site-
related human health risks for different exposure
scenarios:
1. Hazard /etofffica(xy>---conterninants of concern at
the site are identified based on several factors such as
toxicrty, frequency of occurrence, and concentration.
o
,.
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JCC Superfund Site Proposed Pfan
2 Exposure Assessment—estimates the magnitude of
actual and/or potential human exposures the fre-
quency and duration of these exposures, and the
pathways (e g . ingesting contaminated well water) by
which humans are potentially exposed.
3 Toxicity Assessment—-determines the types of
adverse health effects associated with chemical
exposures, and the relationship between magnitude of
exposure (dose) and seventy of adverse effects
(response).
4. Risk Characterization—summarizes and combines
outputs of the exposure and toxioty assessments to
provide a quantitative (eg., non-cancer and one-in-one-
million excess cancer risk) assessment of site-related
risks.
The Baseline Risk Assessment began with selecting
contaminants of concern (COC) which have inherent
toxic effects that are likeiy to pose the greatest
concern to human health. The COCs for the contami-
nated soil at the Imperial Oil site are listed below:
Carcinogens: Non-Circinoqens:
Arsenic Antimony
Benzene Butylbenzylphthalate
Beryllium Chromium III
bis(2-Ethylhexyl)phthalate Copper
carcinogenic PAHs Di-N-butyl Phthalate
Chloroform 1.2-Dichloroethene (total)
1.2-Qichloroethane Ethylbenzene
PCEs Lead
Trichtoroethene NoncarcinigenicPAHs
Tetrachloroethene Styrene
Toluene 1,2,4-Trichlorobenzene
Total Xytenes
An important factor to consider in the risk assessment
is the assumed future use of the sit*. Based on the
current land use of the site, which is industrial EPA
and N JDEP assumed that the most probable future
use of the site would be industrial. The current land
use of the site has the potential to impact facility
maintenance workers, utility workers, excavation
workers, and neighborhood children playing in areas
abutting the fenced portion of the site.
Potential exposure pathways include dermal absorp-
tion and incidental ingestion of the contaminated sod
by facility maintenance workers, utility workers.
excavation workers, and neighborhood children playing
in areas abutting the fenced portion of the site.
Exposure assumptions were made for average and
reasonable maximum (RME) exposure scenarios.
Exposure intakes (doses) were calculated fc- each
! receptor for all pathways considered.
' Under current EPA guidelines, the likelihood of
I carcinogenic and non-carcinogenic effects due to
exposure to site-related chemicals are considered
separately. Non-carcinogenic nsks were assessed by
! calculation of a Hazard Index (HI), which is an expres-
! sion of t~e chronic daily intake of a chemical dividea
by its safe or Reference Dose (RfD) Ar *( that
exceeds 1.0 indicates the potential for non-carcino-
genic effects to occur. Carcinogenic nsks were
evaluated using a cancer Slope Factor (SF), wmc~ s a
measure of the cancer-causing potential cf a chemical
Slope Factors are multiplied by daily intake estimates
to generate an upper-bound estimate of excess
lifetime cancer nsk. For known or suspected carcino-
gens. EPA has established an acceptable cancer nsk
range of 10r* to 10* (one-in-ten thousand to one-in-one
million). The State of New Jersey's acceptable nsk
standard is ooe-irv-one mMon( 1Q*)
The estimated cancer risk associated with the soil on
I the IOC facility for facility maintenance and utility
! workers is 5x10-* (five-in-ten thousand). Forexcava-
| tion workers and neighborhood children. the cancer
risks are 2x10-* (two-in-one hundred thousand^ and
' 2x10- (two-in-ten thousand), respectively. His cf 5 are
! estimated for both the facility maintenance and utility
! workers. The His for excavation workers and neighbor-
| hood children are 2 and 7. respectively.
ECOLOGICAL RISK ASSESSMENT
A baseline ecological risk assessment was conducted
for the site. The Ecological Risk Assessment involves
a qualitative and/or semi-quantitative appraisal of the
actual or potential effects of a hazardous waste site on
plants and animals. The primary objectives of this
assessment are to identify the ecosystems, habitats.
and populations likeiy to be found at the site and to
characterize the contaminants, exposure routes and
potential impacts on the identified receptors.
The baseline ecological risk assessment of the area
indicates PCBs, arsenic, and lead in the surface soil
of the main site are a source of further sediment
contamination to Birch Swamp Brook and may pose
risks to wildlife.
Excavation of the contaminated soil will reduce wildlife
exposures to. - contaminants.
VI. REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to
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IOC Superfund Site Proposed Plan
protect human hejjth and the environment. These
objectives are based on available information and
standards such as applicable or relevant and appropri-
ate requirements (ARASs) and risk-based levels
established in the nsk assessment.
Based on the site conditions, nature of contaminants,
migration pathways, and conclusions of the risk
assessment, the following specific remedial action
objectives have been established for this site:
prevent human exposure to the on-site
contaminated soil
prevent human exposure to the contaminated
free and residual product located above the
groundwatertable
- prevent the further migration of soil contami-
nants to groundwater
prevent migration of contaminated surface
water, soil, and sediments from on-site areas
to Birch Swamp Brook, the fire pond, and
associated wetlands, and
prevent ecological exposure to contaminated
surface soil.
Soil clean-up numbers for the site were developed in
accordance with the EPA's December-! 991 ARisk
Assessment Guidance for Superfund: Development of
Risk-based Preliminary Remediation Goals. The
Preliminary Remediation Goals (PRGs) for OU3 were
developed from the soil clean-up numbers that were
obtained from the guidance document, which includes
protection of groundwater from the contaminated soil.
AJso. the PRGs are based on a future industrial land
use scenario. The PRGs for the sit* am presented in
Table 1 of this Proposed Plan.
Actual or threatened releases of hazardous sub-
stances from the site, if not addressed by the preferred
alternative orone of the other appropriate alternative!
considered, may present an imminent and substantial
endangerment to the public health, welfare, or the
environment
VII. SCOPE AND ROLE OF ACTIONS
The problems at the site are complex As a result.
NJDEP and EPA have separated the site remediation
into phases or operable units. OU1 will address soil
contamination in Off-site Areas 1 and 2. In addition.
EPA and NJDEP are planning to incorporate the
remediation of the contaminated sediment in Siren
Swamp Brook and the Fire Pond as part of OU1 OU2
will address contaminated groundwater associated
with the site.
The subject of this Proposed Plan for OU3 is the
remediation of the contaminated soil found on the IOC
facility, the saturated waste filter clay material and the
floating product underlying the waste filter clay mate-
rial. These areas of contamination are considered the
sources of the groundwater contamination and Birch
Swamp Brook sediment contamination.
VIII. SUMMARY OF REMEDIAL ALTER-
NATIVES
CERCLA requires that each selected site remedy be
protective of human health and the environment, be
cost effective, comply with other statutory laws, and
utilize permanent solutions and alternative treatment
technologies and resource recovery alternatives to the
maximum extent practicable. In addition, the
statute includes a preference for the use of treatment
as a pnncipal element for the reduction of toxicity,
! mobility, or volume of the hazardous substances.
| Based on the remedial action objectives, NJDEP
! performed an initial screening process of potential
\ alternatives that would address the contaminated soil
at the site. The initial screening of the alternatives is
described in greater detail in the August 1998 AFmal
Source Control Feasibility Study (FS) Report.
Several remedial technologies that could potentially
meet remedial action objectives for the site were
identified, formulated into remedial alternatives, and
then evaluated for effectiveness, implementability, and
cost. Following this evaluation, four remedial alterna-
tives were retained for detailed analysis.
The four alternatives that received detailed analysis
Alternative 1: NO ACTION
Altemative2:ON-SITECONTAINMENT(w/OptionsA,
B, C)
Alternative 3: EXCAVATION/OFF-SITE DISPOSAL/
REUSE
Alternative* EXCAVATIOWTREATMEENT
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IOC Superfund Site Proposed Plan
The estimated capital cost, net present worth ccst,
and implementation time to successfully complete the
cleanup under«ach alternative is presented belcwfor
comparison.' Actual costs and implementation times
may differ.
For OU3. the principal threat (hot-spot) materials are
defined as.
Waste filter clay materials;
TSCA regulated material (i.e., soils with PCS concen-
trations greater than or equal to 50 ppm);
Floating product (Free and residual product); and
Contaminated soils underlying Tank Farms Nos. 1,2,
3, and 4.
CERCLA requires that a review of the site conditions
be conducted every five (5) years if contamination
remains that does not allow for unrestricted use of the
site. In the event the selected remedial action does
not allow for unrestricted use. five (5) year monitoring
as required under CERCLA will be implemented.
Alternative 1: NO ACTION
Estimated Capital Cost:
Estimated O&M Present Worth Cost:
Estimated Present Worth Cost:
Estimated Implementation Time:
SO
$295,000
$295,000
None
The National Contingency Plan (NCP) and CERCLA
require the evaluation of a No Action alternative to be
considered as a baseline for comparison with other
remedial action alternatives. The no action alternative
involves no remedial actions to reduce the toxicrty.
mobility or volume of contamination or prevent or
control exposure to contaminated toil and sediment at
the site. This alternative does include • 30-year
environmental monitoring program. The objective of
the environmental monitoring program would be to
monitor the impact the existing sources of contamina-
tion would have on ground water and Birch Swamp
Brook in the future. Because this alternative would
result in contaminants remaining on site. CERCLA
requires that a review of the site conditions be con-
ducted every five (5) years and this component is
included in the alternative.
Alternative 2A: RESTRICTED CONTAINMENT WITH
PRINCIPALTHREAT(HOTSPOTS) REMOVAL
Estimated Capita1. Cost: 3'^ =«J2 ::•:•
estimated O&M Present Worth Cost $ 483 000
Estimated Net Present Worth Cost: $15 425.000
Estimated Implementation Time: 24 months
Alternative 2A involves the dismantling of the tank
farms and other structures at the IOC Facility to
facilitate the excavation of the contaminated soil.
dismantling the floating product removal system to
facilitate the excavation of the waste filter clay matenal
and the free product, excavation and off-site disposal
of 27.000 cy of soils which pose the principal threat
(hot-spots), which includes an estimated 19,000 cy of
soil to be transported to a TSCA-permitted landfill, an
estimated 8,000 cy of soil to be transported to a
RCRA-permrtted landfill, where it will receive appropri-
ate treatment prior to disposal in conformance with
RCRA requirements; and 5,000 gallons of free product
to be transported to a TSCA-permitted incinerator. In
addition, this Alternative includes the excavation and
stockpiling of an estimated 56,000 cy of contaminated
soil exceeding PRGs prior to placement in an approxi-
mate 3-acre containment system cell on-site. The
containment cell would be constructed on the northern
portion of the 1OC/CC site and would have a bottom
liner and leachate collection system. The soil would
be dewatered before off-site disposal and on-site
placement. The liner system would be constructed
above the water table and would occupy the upper
portion of the site's five-foot unsaturated zone.
Leachate collected from the containment system cell
| would be removed by pumping directly into tanker
' trucks for appropriate off-site disposal. The approxi-
' mate height of the Alternative 2A containment cell is
30 feet Institutional controls would be implemented to
restrict access to the containment system. The
affected wetland areas will be restored following the
excavation and disposal activities.
Alternative 2B: EXPANDED CONTAINMENT WITH
PRINCIPAL-THREAT (HOT SPpTS) REMOVAL
Estimated Capital Cost
Estimated O&M Present Worth Cost
Estimated Net Present Worth Cost
Estimated Implementation Time:
$15,514,000
$563,000
$16,077.000
24 months
The components of Alternative 2B are the same as
Alternative 2A except for the dimension of the contain-
ment system ceH. This Alternative involves the
dismantling of the tank farms and other structures on
the IOC Facility to facilitate the excavation of the
contaminated *c4l, dismantling the floating product
removal system, excavation and appropriate off-site
-------
IOC Superfund Site Proposed Plan
disposal of the sargp estimated 27,000 cy of soils
which pose the principal threat (hot-spots) and 5.000
gallons of free product. The excavation and stockpiling
of an estimated 56.000 cy of contaminated soil
exceeding PRGs prior to placement in an approximate
5 5-acre containment system cell covering the entire
fenced area of the IOC/CC site complete with a bottom
liner and leachate collection system. The approximate
height of the Alternative 28 containment cell would be
16 feet. Institutional controls would be implemented to
restrict access to the containment system. The
affected wetland areas will be restored following the
excavation and disposal activities.
Alternative 2C: PRINCIPAL THREAT (HOT SPOTS)
REMOVAL WITH IN PLACE CONTAINMENT FOR
ALL OTHER CONTAMINATION
Estimated Capital Cost: $13,111,000
Estimated O&M Present Worth Cost: $ 387,000
Estimated Net Present Worth Cost: $13.498.000
Estimated Implementation Time: 18 months
Under Alternative 2C. following the removal and
appropriate off-site disposal of an estimated 27,000 cy
of soils which pose the principal threat (hot-spots) and
5.000 gallons of free product, the remaining contami-
nated soil on the IOC property would be capped in
place on the site. A limited amount of contaminated
soil located west of the northwest fence boundary
would be excavated and consolidated on-site prior to
capping The estimated size of the cap under this
alternative is 4 acres and, unlike Alternatives 2A and
2B. this alternative would not include a bottom liner
and leachate collection system. Similar to Alternative
2B. the estimated height of the cap would be 3 feet
Institutional controls would be implemented to restrict
access to the cap. The affected wetland areas will be
restored following the excavation and disposal activi-
ties.
Alternative 3: EXCAVAT1ON/OFF-SIT! DISPOSAL/
REUSE
Estimated Capital Cost $17.201,000
Estimated O&M Present Worth Cost $ 9.000
Estimated Net Present Worth Cost $17.210,000
Estimated Implementation Time: 11 month*
Alternative 3 involves the dismantling of the tank farm
and other structures on the IOC Facility to facilitate
the excavation of the contaminated soil, dismantling
the floating product removal system, excavation of all
contaminated soil, which includes 27,000 cy of soil
which poses the principal threat (hot-spots), 56.000 cy
of soi! exceeding PRGs, and the disposal of this
estimated 83,000 cy of contaminated material and the
5,000 gallons of free product in the appropriate off-site
permitted landfill. For the 27,000 cy of soil posing the
principal threat, an estimated 19,000 cy of soil will be
transported to a TSCA-permitted landfill and the other
8.000 cy to a RCRA-permitted landfill for disposal,
where it will receive appropriate treatment pnor to
disposal in conformance with RCRA requirements
The 5,000 gallons of free product will be disposed of in
TSCA-permitted incinerator. The 56.000 cy of soil
exceeding PRGs will be transported to an appropriate
landfill for disposal. Some of the soil may be eligible
for soil recycling in a Class B permitted asphalt-batch
plant. The excavated areas will be backfilled with
clean soil. The affected wetlands would be restored.
Under this alternative, soil which poses the principal
threat (hot-spots) would be excavated similar to
Alternative 2, except that after dewatering (as neces-
sary), all excavated material would be hauled off-site
for disposal after it has been sampled and analyzed for
its chemical characteristics. Accordingly, stockpile
requirements are much lower than those required for
Alternative 2 and stockpiling could occur within the
area of excavation. Excavations would be backfilled
with clean soil and the site returned to its existing
grade. If the implementation of this Alternative does
not result in the allowance of unrestricted future use of
the site, institutional controls will be implemented to
restrict the future use of the site to industrial use only
The affected wetland areas will be restored following
the excavation and disposal activities.
Alternative* EXCAVATON/TREATMEiNT
Estimated Capital Cost $38,131.000
Estimated O&M Present Worth Cost $9,000
Estimated Net Present Worth Cost $38,140,000
Estimated Implementation Time: ' . 18 months
Alternative 4 involves the dismantling of «he tank farm
and other structures on the IOC Faefltty to facilitate
the excavation of the contaminated soil, dismantling ?
the floating product removal system, excavation of the
estimated 83,000 cy of contaminated material and
5 OOOgaltonaof free product off-site disposal at a
TSCA-permitted landfW of an estimated 5.000 cy of the »
83,000 of material not amenable to treatment and
treatment of the remaining material in an on-site hydro-
metallurgical extraction treatment system. The hydrdHp
metallurgical extraction process consist* of two stepSPJr
(1) a soil washing pretreatment step that cleans
sand-sized particles and (2) an extraction step that
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IOC Superfund Site Proposed Plan
cleans fines. For this treatment process, the remain- j
mg 78,000 cy of material would be stockpiled and >
screened for reneval of large debris. The debris would
be staged for transport to an off-site landfill. After
screening, the fine son and sediment would be then be
treated m the hydrometallurgical treatment unit.
Following treatment, the treated soil would be supple-
mented with clean borrow soil and used to backfill the
excavated areas. The sludge from the treatment
system would be disposed of off-site. If the implemen-
tation of this Alternative does not result in the allow-
ance of unrestricted future use of the site, institutional
controls will be implemented to restrict the future use
of the site. The affected wetland areas will be restored
following the excavation and disposal activities.
IX. SUMMARY OF COMPARATIVE
ANALYSIS OF ALTERNATIVES
In accordance with the NCR, a detailed analysis of
each remedial alternative was conducted with respect
to each of the nine (9) criteria for selecting a site
remedy. This section discusses and compares the
performance of the remedial alternatives under consid-
eration against these criteria. The nine criteria are
descnbed below! All selected alternatives must at
feast attain the Threshold Criteria. Alternatives that do
not provide protection of human health and the environ-
ment are eliminated from further consideration. The
selected alternative should provide the best trade-offs
among the Primary Balancing Criteria. The Modifying
Criteria will be evaluated following the public comment
penod.
A. THRESHOLD CRITERIA:
Overall Protection of Human Health and the
Environment addresses whether a remedy provides
adequate protection of human health and the environ-
ment and describes how risks posed through each
exposure pathway are eliminated, reduced or con-
trolled through treatment, engineering controls, or
institutional controls.
Compliance with ARARs (Appiigabto or Relevant &
Appropriate Requirements) addresses whether a
remedy will meet all of the ARARs under Federal and
State environmental statutes, and/or provides grounds
for invoking a waiver.
B. PRIMARY BALANCING CRITERIA:
Long-term Effectivenef**n«J Permanence refers to
expected residua! risk and the aoi'fty o* a remeoy to
maintain reliable protection of human health ana me
environment over time, once cleanup goals have been
met.
Reduction of Toxicitv. Mobility or Volume addresses
the statutory preference for selecting remedial actions
that employ treatment technologies that permanently
and significantly reduce toxicity, mobility or volume of
the hazardous substances as a pnncipal element.
Short-term Effectiveness addresses the penod of time
needed to achieve protection and any adverse impacts
on human health and the environment that may be
posed during the construction and implementation
period, until cleanup goals are achieved
Implementabilitv is the technical and administrative
feasibility of a remedy, including the availability of ma-
terials and services needed to implement a particular
option. --
Cost includes estimated capital costs, operation and
maintenance costs, and net present worth costs.
C. MODIFYING CRITERIA:
State Acceptance indicates whether, based on review
of the RI/FS reports and the Proposed Plan, the State
concurs with, opposes, or has no comment on tne
preferred alternative.
Community Acceptance will be assessed in the
Record of Decision (ROD) following a review of the
public comments received on the RI/FS reports and
the Proposed Plan.
X. COMPARATIVE ANALYSIS
Described below is a comparison of the six remedial
alternatives (including Options A, B. and C for Alterna-
tive 2) relative to the evaluation criteria used during the
detailed analysis of alternatives. The purposes of the
comparative analysis are to identify the advantages
and disadvantages of the alternatives relative to one-
anotner, and to aid in the selection of a remedial
alternative for soil at the IOC/CC site.
A. Comparison of Threshold Criteria
Because the selected remedy must be protective of
human health and th« environment and comply with
ARARs, EPA has designated (1) overall protection of
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IOC Superfund Site Proposed Plan
10
human health and the environment, and (2) compliance
with ARARs. as tflt two threshold criteria. An alterna-
tive must meet both criteria to be eligible for selection
as the preferred site remedy.
Overall Protection of Human Health and the
Environment
Alternative 1. No Action, was developed as a baseline
with which to compare other alternatives. Because
natural attenuation is the only mechanism that could
potentially reduce concentrations of COCs in soil,
implementation of this alternative would result in
continued risk to human health and the environment for
an undetermined period into the future.
Alternatives 2A. 2B and to a lesser extent 2C, would
be protective of human health and the environment
Each of the alternatives includes removal of principal
threat (hot-spot) areas of contamination that could not
be reliably contained on-site, and containment of the
remaining contaminated soil exceeding PRGs within
an engineered cell (2A and 2B) and/or in-place be-
neath an impermeable cap (2C). Although contami-
nated soil exceeding PRGs would remain on-site
under each of the options of Alternative 2. placement
within a cell and/or beneath an impermeable cap
provides isolation from the environment, and offers
protection of both human health and environmental
receptors. Continued protection of human health and
the environment would be dependent on effective
execution of a maintenance program to maintain cap
integrity While Alternative 2C would be protective of
human health, it is not fully protective of the groundwa-
ter. In Alternative 2C, contaminated soil exceeding
PRGs would be in direct contact with the groundwater
and would contnbute to the groundwater contamina-
tion.
Alternative 3. Excavation/Off-Site Disposal/Reuse,
would be protective of human health and the environ-
ment. All contamination exceeding PRGs, not just the
principal threat (hot-spot) areas of contamination,
would be excavated and property disposed of off-site.
Therefore, all exposure pathways to the site contami-
nation would be eliminated.
Alternative 4. Excavation/Treatment, would be protec-
tive of human health and the environment All contami-
nation exceeding PRGs would be excavated and
treated on-stte to reduce the contaminant levels to
meet PRGs before placement back on-site. The
principal threat (hot-spot) contamination would be
property disposed of off-site. This would eliminate all
exposure pathways to the contamination similar to
Alternatives.
Compliance with ARARs
All of the Alternatives (except the No Action Alterna-
tive) could be designed to comply with federal and
state location-specific ARARs that regulate excava-
tion, filling, and discharge into wetlands and flood-
plains. These alternatives would comply with action-
specific ARARs associated with the discharge of
treated water to Birch Swamp Brook, employ engineer-
ing controls to comply with federal and state air-quality
standards for fugitive dust from remedial activities .and
comply with RCRA, TSCA. U.S. Department of
Transportation (DOT), and New Jersey hazardous and
solid waste regulations that apply to the transport and
disposal of waste material.
B. Comparison of Primary Balancing Criteria
Lana-temni Effectiveness and Permanence
Alternative 4 provides the greatest long-term effective-
ness and permanence since the contaminated soil is
excavated and treated to meet PRGs prior to backfill-
ing on-site. Treatment of soils exceeding PRGs would'
eliminate the need for engineering and/or institutional
controls and long term monitoring. For Alternative 3.
the excavation and off-site disposal/reuse of the
contaminated soil also provide the greatest long term
effectiveness in eliminating future residual risk to
contaminated soil on-site and also would eliminate the
need for engineering and/or institutional controls at the
site. However, rt does not provide the permanence
that the Alternative 4, treatment option provides
because the contaminated soil is disposed of at off-
site RCRA, TSCA, or special waste licensed landfills.
These licensed facilities effectively isolate the waste
materials such that future residual risks are negligible
but are not permanent Alternative 2A, 2B, and 2C
provide lesser long-term effectiveness and permanence
than Alternatives 3 and 4, but they can effectively
minimize residual risk to public health and the environ- 4
ment as long as the containment systems are properly
maintained in the future and institutional controls are
enforced. Of all the alternatives, Alternative 1 provides
the least amount of tang-term effectiveness and J
permanence, because the soil and sediment would not
be remediated and engineering and institutional control
would not be implemented to mitigate the risks to "*
human and ecological receptors.
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IOC Superfund Site Proposed Plan
11
Reduction o* Tgatieitv. Mobility or Volume Through
Treatment
For Alternatives 2 and 3, no treatment is proposed to
reduce toxicity, mobility or volume except for (1) the
estimated 5.000 gallon of free product expected to be
recovered during soil excavation which would be
destroyed by incineration at an appropnate TSCA-
licensed incinerator and (2) the estimated 8.000 cy of
Tank Farm soil that exceeds TCLP (Toxic Contami-
nant Leaching procedure) threshold criteria for RCRA-
charactenstic hazardous waste which would be
stabilized to reduce mobility of contaminants prior to
disposal in a secure landfill (either on-site under
Alternative 2 or off-site under Alternative 3). While no
treatment is proposed beyond this, each of the
alternatives, excluding Alternative 1, provides a
reduction in contaminant mobility for all other contami-
nated material by containing the material in either an
off-site properly licensed landfill or an on-site contain-
ment cell where contaminants are isolated from
environmental transport mechanisms. Under Alterna-
tive 4, all soil exceeding PRGs (except 5,000 cy of
waste filter clay) would be treated using hydrometallur-
gical extraction. Assuming an estimated 78.000 cy of
soil is treated, a volume reduction of approximately
10% will leave an estimated 70,200 cy of cleaned soil
to be backfilled on-site and approximately 7,800 cy of
Atreatment sludge that would require off-site disposal
as a hazardous waste at a properly licensed landfill.
Short-Term Effectiveness
Alternative 3 provides the greatest overall short-term
effectiveness primanly because the work can be
completed in the shortest period of time, an estimated
11 months from site preparation to site restoration.
Alternatives 2C and 4 are estimated to take 18 months
to complete while Alternatives 2A and 2B are esti-
mated to require the longest period of time to complete
at 24 months.
Under each option of Alternative 2 and under Alterna-
tive 3, (a) residence* near the srt» would be affected
by noise and dust from remedial activiti** on the site
and trucks hauling material on and off-site; (b) short
term risks to site workers would result primarily from
dermal contact with contaminated materials and
inhalation of contaminated dust during remediation;
and (c) adjacent wetlands and Birch Swamp Brook are
at risk of impact by soil runoff during axcavation
activities associated with the remediation. The
negative impacts to nearby residence* can be miti-
gated by implementing engineering control* to reduce
fugitive dust and limiting work to normal working hours
The short term nsks posed to site workers can be
addressed by implementing a site-specific Health &
1 Safety Plan to minimize exposure to site contami-
| nants. The short term impacts to adjacent wetlands
i and Birch Swamp Brook can be mitigated by imple-
menting proper controls in accordance with a site
specific Erosion and Sedimentation Plan. In addition.
any wetlands that are disturbed during implementation
of the remedy can be restored after completion of the
remediation.
Alternative 4 provides the least short term effective-
ness because, in addition to the impacts posed by
Alternatives 2 and 3, the soil treatment plant would De
operational 24 hours per day and may cause a
significant noise nuisance to nearby residences. In
addition, a large area of wetlands would likely be
adversely impacted to implement this remedial
alternative because of the limited space at the site to
construct the hydrometallurgical treatment system
including a temporary wastewater treatment plant .
rated for 300 gallons per minute and the associated
water storage basin required for the water recircuiation
needs of the treatment system.
Imolementabilitv
Alternative 3 is considered the easiest to implement,
because there are no significant technical or adminis-
trative implementability concerns. Excavation and
disposal can be implemented with readily available
equipment and construction methods utilizing well-
demonstrated technologies. There exists sufficient
capacity at off-site landfills for disposal of the esti-
mated quantities of RCRA and TSCA regulated
wastes. There are available soil recycling facilities in
the area and several construction contractors in the
region available to undertake the work. Alternative 3 is
considered a final remedy and no additional remedial
actions will be necessary once the remedial alternative
is implemented. Th* only adminmtrativ*
.
implementability i**ue* for Alternative 3 are me same
issues which are common to all of the alternatives;
namely, (a) the western edge of the free and residual
product is interpreted to be cto** to on* of the trans-
mission tow*r* which raises concern* regarding the
feasibility of u*ing heavy equipment to excavate under
electrical tran*mi**ion ftn** and stability issues
associated with excavating near the foundation of the
transmission tow«r, (b) site access agreements would
need to b* obtained to disturb, remediate, and restore
this area as well a* th* railroad embankment along the
western boundary of the sit* wh«r* contamination
-------
IOC Superfund Site Proposed Plan
exists.
Alternatives 2A. 2B, and 2C are similar to Alternative
3 with regard to the insignificant technical
implementability concerns because containment
technology equipment and methods are well-
demonstrated and readily available. However, in
addition to the common administrative
impiementabiltty concerns described above, all of the
options of Alternative 2 require substantial restric-
tions to the future use of the site in order to protect
the waste containment systems that would be
constructed. Also, a continual maintenance program
to insure the integrity of the cap, continual future
monitoring of the effectiveness of the remedy, and
continual operation and maintenance of the jeachate
collection systems (under Alternatives 2A & 2B) are
implementability issues unique to Alternative 2.
There are numerous logistical concerns related to
the implementation of Alternative 4. In order to
create adequate space for all of the components of
the treatment system plant building and stockpiled/
soil handling areas, contaminated soil in the way of
the treatment plant construction would have to be
excavated and stockpiled elsewhere on the site. The
only available space on the IOC/CC property for
these facilities would likely be in uncontaminated
areas south or east of the Fire Pond which lie within
the 100-year floodplain and would result in adverse
impact to additional wetland areas. Special design
features would need to be incorporated into the
treatment plant design to mitigate the potential for
inundation of the plant by flood waters and the
associated release of hazardous substances into the
environment The reliability of the hydrometallurgical
extraction technology to treat soil/sediment with both
inorganic and organic contamination will require
treatabilrty studies to demonstrate its effectiveness.
Although treatabilrty studies on patrolaum-contarnj-
nated soil have indicated that hydromatallurgical
extraction may b« effective for removing organic
contaminants from soil and sediment, it has not
been demonstrated beyond banch-scato tasting.
Consequently, treatabilrty studiason representative
samples of IOC/CC soil and sediment would ba
necessary to determine the effectiveness of this
technology for attaining PRGs in IOC/CC sofl.
Cost
Total costs range from $295,000 for Alternative 1 to
$38.140,000 for AJtamatjva 4. Tha total cost for
Altemativa 4 is significantly greater than tha total
costs for Alternatives 2A ($15.425.000), 28
($16.077,000).2C($13.498.000)or3($17,210,000).
When comparing the Alternative 2 options to Alternative
3. Alternative 2A costs 90% as much as Alternative 3.
Alternative 2B costs 93% as much as Alternative 3, and
Alternative 2C costs 78% as much as Alternative 3.
C. Comparison of Modifying Criteria
State Acceptance
The preferred alternative, as discussed in the following
section, is acceptable to NJDEP.
Community Acceptance
Community acceptance of the preferred alternative will
be assessed in the ROD following review of the public
comments received on the Final Source Control Feasi-
bility Study and this Proposed_Plan.
XI. PREFERRED ALTERNATIVE
Based upon an evaluation of the various alternatives,
USEPA and NJDEP recommend Alternative 3 -
Excavatlon/Off-slte Disposal/Reuse as the preferred
alternative for remediating contaminated soil, waste pile
material, free product and the fill areas adjacent to the
Fire Pond at the IOC/CC site. Based on all currently
available information, Alternative 3 is selected as the
preferred alternative because it appears to provide the
best balance of trade-offs among the alternatives with
respect to the criteria used to evaluate them.
Alternative 3 is protective of human health and the
environment and can ba performed in compliance with
tha chemical specific cleanup criteria prescribed by
EPA along with all other Federal or State requirements
that are applicable or relevant and appropriate to this
action including those ARARs that regulate (a) excava-
tion, filling, and discharge into wetlands and floodptains;
(b) discharge of treated water to Birch Swamp Brook
resulting from any dawatering necessary during excava-
tion; (c) air-quality standards for fugitive dust during
excavation; and (d) transportation and disposal of solid
and hazardous waste, and » cost effectiv*.
Alternative 3 provides batter short term effectiveness
than Alternativa4 and providas tha bast Jong-term
effectiveness along with Mternativa 4 (at lass than one-
hatf me cost of Alternative 4) because more is no tong
term maintenanca or monitoring of tha integrity of tha
capping systems as required under Alternative 2. While
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IOC Superfund Site Proposed Plan
13
Alternative 2 ranks highest in short-term effectiveness
compared to Alternative 3 because of the increased
volume of materiartransported off-site over public roads
and the potential increased nsk posed by this trans-
portation, this increased nsk is not considered sub-
stantial and all precautions required under Federal and
State transportation laws will be complied with.
While Alternative 4 ranks highest in the Reduction of
Toxiaty, Mobility or Volume criteria and is a more
permanent remedy than Alternative 3, the cost differen- ;
tial is too substantial to justify the incremental benefit \
under these criteria. Alternative 3 ranks equal to the
containment options of Alternative 2 with regard to the
Reduction of Toxiaty, Mobility or Volume criteria and
ranks higher than any of the Alternative 2 options
under the permanence criteria when considering the
site itself.
Alternative 3 is also considered the most
implementable of all of the Alternatives. Excavation
and disposal can be implemented with readily available
equipment and construction methods utilizing well-
demonstrated technologies. There exists sufficient
capacity at off-site disposal facilities for all of the
various waste mixtures involved, both hazardous and
non-hazardous. Alternative 3 is considered a final
remedy and no additional remedial actions will be
necessary once the remedial alternative is imple-
mented. Institutional controls would be implemented
to restrict access to the site and to prevent residential
use. The affected wetland areas will be restored
following the excavation and disposal activities.
XII. FUTURE ACTIONS
After N JDEP has presented the preferred alternative at
the public meeting and has received any comments
and questions dunng the public comment period, EPA
and NJDEP will summarize the comments and provide
rts responses in a document calted the Responsive-
ness Summary. The Responsiveness Summary will
be appended to th« Record of Decision, which will
describe the final alternative setocted by EPA and
NJDEP and will provid* the EPA and NJDEP rationale
for their selection.
-------
-------
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SOURCE CONTROL FEASIBILITY STUDY
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FIGURE 2.
SCHEMATIC LAYOUT OF IMPERIAL OIL CO. FACILITY
SOURCE CONTROL FEASIBILITY STUDY
IMPERIAL OIL COMPANY/CHAMPION CHEMICALS SITE
MORGANV1LLE, NEW JERSEY
__——_____—————— Hardtop Lavmon
300
-------
TABLE 1
SOIL AND SEDIMENT CLEAN-UP CRITERIA
SOURCE CONTROL FEASIBILITY STUDY
IMPERIAL OIL COMPANY/CHAMPION CHEMICALS SITE
CHEMICAL
MAXIMUM
DETECTED
CONCENTRATION1
(mg/kg)
SOIL
USEPA SOIL CLEAN-UP
CRITERIA2
(mg/kg)
INDUSTRIAL
VOC*
Benzene
Chloroform
1 2-Dichloroethane
1 .2-Dicnloroethene
(Total)
Ethylbenzene
Styrene
Total Xylenes
0.42
00058
0.0023
0.960
0.810
0.120
0.300
2.300
0.790
3.300
99
470
31
63
100,000
410,000
55
200,000
260
100,000
IMP ACT TO
GROUNDWA
TER SOIL
CLEAN-UP
CRITERIA
0.03
06
0.02
0.02
13
4
0.06
12
0.06
200
PRELIMINARY
REMEDIATION
GOAL
(mg/kg)
SOIL
—
003
0.6
0.02
0.02
13
4
0.06
12
0.06
200
17 of 2
W003971ST4J rrroed-doc
17
-------
SVOCs
Acenaphthene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Bis(2-
ethylhexyl)phthalate
Butylbenzyl phthaiate
Chrysene
Di-n-butylphthalate
Fluoranthene
Fluorene
2-Methylnaphthalene
Naphthalene
Phenanthrene
Pyrene
Total PCBs
SVOCs Continued
1 .2.4-Trichloroben2ene
Total Organic
Contaminants
0490
1 100
4700
5600
4 700*
4700*
12.000
47000
4700
1 700
1 500
1 200
19000
13.000
14000
5.000
128.200
61.000
310.000
39
0.39
39
39
200
200.000
390
200.000
41 000
41 000
82.000
41.000
NA
31 000
13
570
12.000
2
8
5
49
3,600
930
160
2.300
4300
560
84
84
NA
4.200
10-25
3.200
540,000
510
NA
5
NA
570
2.000
i
0,39
3.9
39
200
930
160
2.300
4300
560
84
84
NA
4.200
13
5
18 of 2
W0039715T4 1 revised.doc
-.8
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+•
Antimony
Arsenic
Beryllium
Chromium 111
Copper
Lead
31.1
6.120
8.6
463
1.020
3.720
410
20
1
1.000.000
38,000
1.000
5
29
63
NR
NA
NA
5
20
1
1,000.000
600
400
Notes:
mg/kg = milligrams per kilogram
B = Not a contaminant of concern for this medium.
NA = Value for this chemical is not available — - — - -
ND = Not detected.
NR = Negligible risk via this exposure route.
1 = Maximum detected concentration reported dunng the remedial investigation and the data-gap
investigation .
2 = Site-specific criteria provided by the U.S. Environmental Protection Agency.
19of2
W0039715T4 1 revbed.doc
19
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Appendix D
Public Notice
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Public Meeting and Comment Perio
For the Proposed Plan for Re-mediation of Operable Unit 3 at the
imperial Oil Company Superfund Site
Marlboro Township, Monmouth County, New Jersey
Public Meeting:
Comment Period:
Thursday, March 18,1999 at 7:00 p.m.
Marlboro Township Municipal Courtroom
1979 Township Drive
Marlboro, New Jersey
February 19,1999 through April 6,1999
Site Background and Current Status
The Impenal Oil Company Superfund srte is located on Orchard Street in Marlboro Township, Monmouth County.
The four acre facility has been operated by several different industries since the early 1900s. Currently Imperial Oil
. Company operates an oil blending and repackaging business at the site under a lease agreement from Champion
Chemicals.
In 1983 the U S. Environmental Protection Agency placed the site on the National Priorities List of Superfund sites.
The New Jersey Department of Environmental Protection began a Remedial Investigation (Rl) at the srte ml 985 to
determine the nature ana extent of the contamination. The Rl revealed that both on-srte and off-site soils nad ceen
contaminated by past industrial operations at the facility. In addition, the R« concluded that a plume of ground water
contamination was present in the underlying Englishtown Aquifer, and a layer of oil product was floating on the water
table where the waste filter clay pile was located. Contamination was also found in the sediments of Birch Swamp
firook, which originates near the northeastern border o? the site and drams into Lake Lefferts. approximately 1 25
miles away.
Remediation of the site has been divided into several Operable Units. Operable Unit 1 addresses off-site soils
contaminated with heavy metals and PCBs. Operable Unit 2 addresses the remediation of contaminated ground
water. Operable Unit 3 addresses the remediation of on-srte soils and sediment contaminated with volatile organic
compounds, petroleum hydrocarbons, heavy metals and PCBs. Feasibility Studies were performed for each oper-
able unit
Proposed Plan and Preferred Alternative
The Proposed Plan, based on the Remedial Investigation and Feasibility Study reports, describes the remedial
alternatives considered for Operable Unit 3 and identifies the preferred remedial alternative along with the rationale for
this preference. The remedial alternative preferred by the NJDEP is excavation with off-sit* tndnus* disposal
options. This alternative includes the following components: - ^
• Excavation of contaminated soil and sediment
• Transportation of acceptable soil and sediment to off-site reuse facilities
• Transportation of remaining soil and sediment to appropriate off-site disposal facilities
• Backfilling excavation areas with dean borrow soil ___
New Jersey Department of Environmental Protection
Site Remediation Program
Bureau of Community Relations
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Documents Available for Review in Repositories
Copies oftne RemejtfSal Investigation. Source Centre; Feasibility Study. Proposed Plan and other site-related docu-
ments will be available for review beginning February 19.1999 at trie following iocatons:
Marlboro Township Library USEPA. Region II
1 Library Court Superfund Records Center. 18th Floor
Marlboro. NJ 07746 ' 290 Broadway
(732) 536-9406 New York. NY 10007-1866.
(212)637-4308
NJDEP
401 East State Street
Trenton. NJ 08625-0413
{609)777-1976
^ Community Role in the Remediation Process
NJDEP solicits public comments on the Proposed Plan during the public comment '.
period which runs from February 19,1999 through April 6,1999. No decision on reme-
dial action will be made until all public comments are evaluated. The Record of Decision
for the remediation will include a summary of both the oral and written comments re-
ceived and the NJDEP responses to these comments. Written comments on the Pro-
posed Plan should be directed to:
Donald J. Kakas, Section Chief
Bureau of Community Relations
New Jersey Department of Environmental Protection
PO Box 413
Trenton, NJ 08625-0413
•Questions should bs directed to Windy Mumford, the Community Relations Coordinator
for this project, at (609) 777-1976
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ROD FACT SHEET
SITE
Name - :
Location/State :
EPA Region :
MRS Score (date)
Site ID # :
Imperial Oil/Champion Chemical Superfund Site
Monmouth County/New Jersey
02
-.33.87 (12/82)
NJD980654099
ROD
Date Signed: September 30, 19.99
Remedies: Excavation/Off-site Disposal/Reuse)
Operable Unit Number: OU-3
Capital cost: $17,201,000 (in 1999 dollars)
Construction Completion: 11 months
O & M in 1999: $9,000
Present worth: $17,210,000
LEAD
Remdial/Enforcement: Remedial
EPA/State/PRP: State
Primary contact: Trevor Anderson (212)-637-4425
Secondary contact: Joseph Maher (609)-633-0765
Main PRP(s): Imperial Oil & Champion Chemical Company
PRP Contact (phone): N/A
WASTE
Type: metals, PCBs, VOC, SVOC
Medium: soil
Origin: on-site disposal of contaminated material
Est. quantity: 83,000 cu.yd., 5,000 gal.
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ill O w W
Zo.!S.£
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