PB99-963120
EPA541-R99-096
1999
EPA Superfimd
Explanation of Significant Difference
for the Record of Decision:
American Cyanamid Company Site
Bound Brook, NJ
11/30/1998
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0f
Christine Todd Whitman Department of Environmental Protection Robert C. Shinn, Jr.
Governor Commissioner
Site Remediation Program
Floor 6E, PO Box 028, 40 1 East State Street
Trenton, NJ 08625-0028
Phone: (609) 292-1250/Fax: (609) 633-2360/EmaiI: RGIMELLO@DEP.STATE.NJ.US
Mr. Richard Caspe ' ; (fa
USEPA Region 2, Floor 19 r- Z5
290 Broadway . : c§
New York, NY 10007-1866 , - . '• . CT
-7 c-j
Dear Mr. Caspe: ~-: ^
c.
Re: American Cyanamid Site £-~ 5
American Home Products Corporation ~ ~
Bridgewater Township, Somerset County : c co .
Enclosed please find a copy of the final Explanation of Significant Difference (ESD) for Impoundments
15 and 16 (part of Group II Impoundments) for information purposes. The purpose of this Explanation of
Significant Difference (ESD) is to explain a modification to the remedy selected in the Record of
Decision (ROD) dated 12 JUL 1996 for the American Cyanamid site located in Bridgewater Township,
Somerset County, New Jersey. This ESD is required pursuant to § 107(c) of the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) and § 300.435(cX2XI) of the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
The New Jersey Department of Environmental Protection Agency (NJDEP) is the lead agency overseeing
cleanup at this site. The United States Environmental Protection Agency (USEPA) acts as the support
agency.
Recycling of the iron oxide material in Impoundments 15 and 16 was evaluated as a remedial alternative
in the July 1996 ROD. But it could not be selected as a renieJy in the ROD because a recycling vendor
had not been identified at that time. The responsible party, American Home Products Corporation
(AHPC), has now identified a vendor which can recycle this iron oxide material. These circumstances
gave rise to the need for this ESD.
The NCP, § 300.435(c)(2XO, states that an Explanation of Significant Difference (ESD) would be
sufficient when the difference in the remedial action significantly changes but does not alter the remedy
selected in the ROD with respect to scope, performance or cost. Recycling of the material of
Impoundments 15 and 16 was evaluated in detail as a remedial alternative in the Corrective Measure
Study/Feasibility Study (CMS/FS) and was carried through in the proposed plan and the ROD. The July
1996 ROD included the following sentence in the "Rational for Selected Remedy for Group II
Impoundments" section: "The selected alternative would serve two purposes simultaneously; protecting
human health and the environment and leaving the option open for recycling of the iron oxide material if
such a user is found in the future."
New Jersey is art Equtl Opportunity Employer
Recycled Paper
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The community was afforded an opportunity to comment on the recycling alternative together with other
alternatives during the comment period of the original proposed plan. The community, including CRISIS
(the local environmental group) and the Township of Bridgewater, preferred recycling then and still
prefer it now. Copy of correspondence from CRISIS and the Township of Bridgewater, which indicate
their support for the current proposal of recycling is enclosed. This correspondence also indicates that the
community does not prefer another public comment period and public meeting on the current recycling
proposal.
The above information clearly demonstrates that the current proposal of recycling does not fundamentally
differ than the remedial alternatives considered and selected in the ROD. Based on this, NJDEP has
determined that the ESD will be sufficient for the current proposal of recycling of the material of
Impoundments IS and 16.
The referenced site is a non-fund-financed (privately funded by responsible party) state-lead enforcement
site under state law. In accordance with the NCP, §300.515(eX2X"), USEPA's concurrence is not a
prerequisite to a state's selecting a remedy at such sites. Further, the July. 1996 ROD for the Group II
Impoundments was signed by NJDEP. As such, NJDEP is moving forward in issuing the ESD.
'Ricr/ard J. Gimel
Site Remediation
Enclosure
immissioner
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EXPLANATION OF SIGNIFICANT DIFFERENCE
IMPOUNDMENTS 15 AND 16 (PART OF GROUP n IMPOUNDMENTS)
..-.-;, AMERICAN CYANAMID SITE
AMERICAN HOME PRODUCTS CORPORATION
BRIDGEWATER TOWNSHIP, SOMERSET COUNTY
••„-• NEW JERSEY
New Jersey Department of EnvironmentalProtection
Site Remediation Program
Bureau of Federal Case Management
November 1998
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INTRODUCTION
The purpose of this Explanation of Significant Difference (BSD) is to explain modification to the remedy
selected in the Record of Decision (ROD) dated 12 JUL 1996 for the American Cyanamid site located in
Bridgewater Township, Somerset County, New Jersey. This ESD is required pursuant to § 107(c) of the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and §
300.435(c)(2XI) of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
The New Jersey Department of Environmental Protection (NJDEP) is the lead government agency,
overseeing cleanup at this site. The United States Environmental Protection Agency (USEPA) acts as the
support agency.
Recycling of the iron oxide material of Impoundments 15 and 16 was evaluated as a remedial alternative
in the July 1996 ROD. It was not selected as a remedy in the ROD because a recycling vendor had not
been identified at that time. The responsible party, American Home Products Corporation (AHPC), has
now identified a vendor, which can recycle this iron oxide material. These circumstances gave rise to the
need for this ESD.
This ESD will become part of the administrative record file. The ESD and other supporting documents
are available for review as follows:
Bridgewater Town Hall
700 Garrestson Road
Bridgewater, NJ 08807
Phone:(908)725-6300
Hours: Monday - Friday 8:30 AM to 4:00 PM
NJDEP
401 East State Street, CN 413
Trenton, NJ 08625
Phone:(609)984-3081
Hours: Monday - Friday 8:30 AM to 4:00 PM
Somerset County Library
North Bridge Street & Vogt Drive
Bridgewater,NJ 08807
Phone:(908)526-4016 .
Hours: Monday - Thursday 9:00 AM to 9:00 PM
Friday - Saturday 9:00 AM to 5:00 PM
SITE HISTORY AND CONTMINATION PROBLEMS
The site has been used for numerous chemical and pharmaceutical manufacturing operations for over 75
years. Currently, only Pharmaceuticals are being manufactured at the plant. Past manufacturing and
disposal activities at the site had resulted in a number of areas used for waste storage and disposal as well as
areas of soil and ground water contamination. The site is listed on the National Priorities List (NPL). Site
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cleanup activities are being addressed under a May 1988 (Amended May 1994) Administrative Consent
Order (ACO) between Cyanamid and NJDEP. American Home Products Corporation purchased American
Cyanamid Company in 1994 and has assumed full responsibility for environmental remediation at the site.
Requirements of CERCLA, as amended by the Superfund Amendments and Re-authorization Act (SARA)
as well as the Resource Conservation and Recovery Act (RCRA) and Hazardous and Solid Waste
Amendments for corrective actions are included in the ACO and are being addressed for overall site
cleanup. The Hazardous and Solid Waste Amendment (HSWA) permit and numerous Air Pollution
Control permits have also been issued to the site.
A Remedial Investigation of the site-wide soils was completed in 1992. A Feasibility Study addressing
the site-wide soils will be initiated after completion of the remediation of the 16 on-site impoundments.
Site-wide ground water contamination will be addressed after completion of the remediation of site-wide
soils. Potential contamination in surface water, sediment and associated wetlands related to the Cuckolds
Brook and Raritan River is being independently (and simultaneously with this program) addressed under
the Natural Resource Assessment investigation program. Depending upon the outcome of this
investigation additional study and/or restoration work may be required.
Due to practical limitations, all 16 of the Superfund impoundments cannot be remediated concurrently.
Therefore, they have been grouped into three impoundment groups according to waste type, nature of
contaminants, and geographical location on the site. This concept allows this complex site to be
subdivided into discrete, more manageable units. The impoundment groups are as follows:
Group I - Impoundments 11,13, 19, and 24
Group II - Impoundments 15, 16, 17, and 18
Group III - Impoundments 1,2, 3, 4, 5, 14,20, and 26
Completed Programs:
American Home Products Corporation has completed, or is conducting, several remedial programs at the
site. Completed programs include: removal of pumpable tars from impoundments 1, 2, 3 and 4 for off-
site use as a supplemental fuel (1986-1987); a berm stability evaluation program; and a surface soil
removal/remedial program. Each of the ongoing programs is discussed briefly below.
On-going Programs
On-site Impoundment 8 Facility Program
This program involves closure and post-closure of four on-site impoundments (Impoundments 6, 7, 8,
and 9A) and the construction of a waste consolidation facility (Impoundment 8 facility). These
construction, closure, and post-closure activities are being conducted in accordance with the May 1994
ACO. Construction of Cell 1 of the state-of-the-art Impound 8 facility was completed in May 1991. The
design includes a triple liner, leachate detection and collection system and ground water monitoring
system. A cross section of the Impound 8 facility is provided (Figure 2). Sludge from old Impoundment
8 was removed, dewatered, solidified, and consolidated into Cell 1 from August 1991 to November 1994.
Also during this time period, most of the waste from Impoundment 7 was removed, dewatered,
solidified, and consolidated into Cell 1. The solidified sludge from Impoundment 19 was placed in
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Cell 1. Construction of Cell 2 of the Impound 8 facility was completed in August 1996. -The design of
this cell includes a double composite liner system, leechate detection and collection system, and a ground
water monitoring system. Solidified sludge from the remediation of Impoundment 11 was placed in Cell.
2 between September 1996 and April 1997. Waste from Impoundment 6 is currently being solidified and
consolidated into Cell 2. This activity is expected to be completed in the summer of 1999. Cells 3 and 4
of the Impound 8 facility are scheduled for construction following the remediation of Impoundment 6."
The design of these cells will be similar to Cells 1 and 2. After completion of the cell construction,
remediation of the remaining impoundments involving consolidation into the Impound 8 facility will
begin. Impoundment 9A has been closed in-place by installing a double synthetic liner capping system
(60-mil High Density Polyethylene).
Hill Property Remedial Investigation/ROD ...... - - ..'
t . . . .-...' - • • •
The Hill Property is approximately 140 acres in area, bounded to the south by the Central Railroad of
New Jersey (CRNJ) railroad tracks, to the east by Interstate Highway 287, to the north by Route 28
(Union Avenue), and to the west by Foothill Road (Figure 1). The Hill •'Property is bisected by Main
Street and encompasses a small traffic circle where Van Home Avenue and Main Street intersect.
Although physically separated from the main plant of the site the Hill property portion is part of the
overall site, which consisted of a research laboratory and administrative buildings. The March 1991 Hill
Property Remedial Investigation Report and comparison of contaminant levels in soils to NJDEP Soil
Cleanup Criteria have indicated that levels of contaminants in soils at the Hill Property are below the
applicable NJDEP Soil Cleanup Criteria (both residential and non-residential) and/or background and/or
Impact to Ground Water Criteria. The March 1992 Baseline Site-Wide Endangerment Assessment
Report (Hill Property Quantitative Risk Assessment, Appendix VII) established that there is no current
or future unacceptable risks to human health and the environment associated with the Hill Property.
Based on this finding, no remedial actions are required for the Hill Property soils.
In July of 1996, a no further action ROD was issued by the NJDEP for the Hill Property portion of the
site. The ROD includes provisions for a Classification Exception Area (CEA) covering the ground water
beneath the Hill Property. This ground water is monitored at five bedrock wells (former production
wells PW-16, PW-17, PW-18, as well as wells UU and MJ). Low levels of some organic compounds
were observed in these wells at the time of issuing of the ROD/CEA. Monitoring of these wells is
required, in accordance with the ACO Amendment and the ROD/CEA, until it is observed that the
monitoring results are below criteria for two consecutive quarters (NJAC 7:26E-6.3). NJDEP approved a
request to terminate monitoring for wells PW17, PW18, UU and MJ on Februaiy 18, 1998 based on the
information submitted in the January 1998 Hill Property Ground Water Quality Assessment report.
Monitoring of well PW16 will continue until such time that the monitoring data meet the conditions
discussed above in this section.
*
Bedrock Ground Water Pumping/Control System Program
For the past 60 years, Cyanamid has withdrawn water from the on-site bedrock production wells for use as
non-contact cooling water in the production operations. Cyanamid's present average withdrawal of over
650,000 gallons per day results in ground water flow inward from the perimeter of the site towards the
pumping wells. This system effectively contains the majority of the ground water contamination within the
production area and West Yard area on the site. Recovered ground water is used as non-contact cooling
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water on-site before discharge to the adjacent Somerset-Raritan Valley Sewerage Authority (SRVSA)
wastewater facility for subsequent treatment. Any ground, water not captured by the production «/*!!
pumping system flows to the Raritan River. A previous study (Lawler, Matuskey, and Skelley, 1983)
concluded that the Cyanamid facility did not have a significant impact on water quality in the Raritan River.
Further study of the Raritan River/Cuckolds Brook water quality was conducted as part of the Natural
Resource Assessment (NRA). The NRA is currently under evaluation.
Impoundments 11,13.19, and 24 (Group I)
Remediation of the Group I Impoundments, consisting of solidification and consolidation into the
Impoundment 8 facility, has been initiated in accordance with the September 1993 ROD, May 1994
Remedial Design Report as well as the July and September 1994 Impoundment 19 Remedial Action
Plans and the August 1996 Impoundment 11 Remedial Action Plan. To date, remediation of Impound-
ments 19 and 11 has been completed. Remediation of Impoundments 13 and 24 wil! be initiated after
completion of the remediation of the Group II and III Impoundments.
Impoundments 15, 16,17, and 18 (Group II)
Remediation of the Group II Impoundments has been initiated in accordance with the July 1996 ROD,
the March 1997 Remedial Design Report, and the October 1997 Remedial Action Plan (Impoundment
18). The selected remedial alternatives for those impoundments are as follows:
Impoundments 15 and 16: Consolidation of the material from Impoundment 16 into Impoundment 15
followed by covering with a synthetically lined cap. These impoundments are the focus of this ESD.
Impoundment 17: Solidification and consolidation into the Impound 8 facility. Remediation of
Impoundment 17 will be initiated after completion of the remediation of the Group III Impoundments
(because of the high concentrations of detected contaminants in the Group HI Impoundments).
Impoundment 18: Security fencing, berm improvements and maintenance of natural vegetative cover. To
date, the closure of Impoundment 18 has been completed.
Group III Impoundments (I, 2, 3, 4, 5, 14, 20 & 26)
A ROD was signed on 8 October 1998 as follows: -
1. Category A material (High BTU tar of Impoundments 1 and 2): ,
• Low-Temperature Thermal Treatment (LTTT) and placement of treated material in Impoundment 8;
2. Category B (Low BTU tar of Impoundments (4,5 (wet), 14, and 20}:
• Biotreatment and placement of treated material in Impoundment 8
3. Category C (remaining tar material of Impoundment 3):
• LTTT and placement of treated material in Impoundment 8:
Category D (non-hazardous material of Impoundments 5
A remedial design is underway for these impoundments.
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Characterizationof Impoundments 15 and 16
Impoundments IS and 16 were characterized as reported in the January 1990 Impoundment
Characterization Program Final Report (ICPFR). A summary of the analytical results of the contents of Im- -
poundments 15 and 16 is provided in Table 1. The location of the site and the impoundments is indicated
on Figure 1. An overview of the characterization of Impoundments 15 and 16 follows: .: ;
Impoundment 15 :
Impoundment IS has a surface area of approximately 2.8 acres. Its surface is devoid of topsoil and vegeta-
tion, and is sloped from the southwest to the northeast comer. This impoundment contains a homogeneous
material composed of greater than 99 percent iron oxide (or magnetite). The iron oxide ranges from
approximately 6 to 9 feet in depth and occupies a volume of approximately 29,500 cubic yards. Impurities
in the iron oxide include trace organics, metals, stones and dirt. The detected predominant volatile organic
contaminants of concern range in average concentration from 0.002 to 0.069 parts per million (ppm) and are
Acetone, Benzene, Methylene Chloride and total Xylenes. The predominant semivolatile organic contami-
nants of concern range in average concentration from 0.092 to 17 ppm and are 4-Chloroaniline, N-nitroso-
diphenylamine, Anthracene, Naphthalene and Phenanthrene. The predominant inorganic contaminants of
concern range in average concentration from 55 to 4,490 ppm and include Arsenic, Copper, Lead and Zinc.
Polychlorinated Biphenyl (PCB-1254) was. also detected in the range of 0.9 to 3 ppm. The contents of
Impoundment 15 are not classified as RCRA hazardous wastes. : •
Impoundment 16 .,.-.. >
Impoundment 16 has a surface area of approximately 3.0 acres. Its surface is devoid of topsoil and
vegetation and has been graded in the southeast comer to facilitate drainage of precipitation. This
impoundment contains a homogeneous material composed of greater than 99 percent iron oxide. The iron
oxide ranges from approximately 5 to 10 feet in depth and occupies a volume of approximately 38,000
cubic yards. Impurities in the iron oxide include trace organics, metals, stones and dirt. The detected
predominant volatile organic contaminants of concern range in average concentration from 0.002 to 0.073
ppm and are Acetone, Benzene, Methylene Chloride and total Xylenes. The predominant semivolatile
organic contaminants of concern range in average concentration from 0.046 to 6 ppm and are 4-Chloroa-
niline, N-nitrosodiphenylamine, Anthracene, Naphthalene, Phenanthrene and Pyrene. The predominant
inorganic contaminants of concern range in average concentration from 20 to 2,620 ppm and include
Arsenic, Copper, Lead and Zinc. PCB-1254 was also detected in the range of 1.5 to 6 ppm. The contents of
Impoundment 16 are not classified as RCRA hazardous wastes.
SELECTED REMEDY FOR IMPOUNDMENTS 15 AND 16 AS DESCRIBED IN JULY 1996 ROD
Consolidation of the iron oxide from Impoundment 16 into Impoundment 15 with capping (synthetic liner)
of the consolidated material. The selected remedy (involving excavation) includes removal of six (6) inches
of underlying soils and any other obviously contaminated material after removal of the contents of the im-
poundments and post-excavation evaluation/sampling of the underlying soils. If the results are above the
NJDEP Soil Cleanup Criteria, the underlying soils will be removed/remediated. The selected remedy also
includes a ground water monitoring program and an air emission control measure (such as a carbon
absorber), if necessary. - • '•• • •••• - . ... .
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DESCRIPTION OF SIGNIFICANT DIFFERENCES AND THE BASIS FOR THOSE
DIFFERENCES
'>;••,.-.'••''•
Description: The responsibleparty, American Home Products Corporation (AHPC), has identified (16 OCT
1998 letter) a vendor, which can recycle the iron oxide material of Impoundments 15 and 16 and use it in
their product. The recycling vendor uses 8 million pounds of iron oxide per year and Impoundments 15 and
16 contain approximately 160 million pounds of iron oxide. Thus, at the current rate it would take 20 years
to use all of the material in the impoundments. However, this vendor is experiencing 15% growth per year
so the time frame could be less. This arrangement allows for beneficial re-use of the material and the
eventual removal of the material from the site. If at some point, the recycling vendor is not able to continue
to use 8 million pound per year, AHPC would have the right to terminate the contract and would then
proceed to consolidate and cap the remaining material in place.
Basis: Recycling/re-use of iron oxide would eliminate long-term maintenance of the impoundments and is
beneficial to the environment. Consolidating and capping the material in-place as selected originally in the
ROD, while cost-effective and not detrimental to the environment, will still require long-term maintenance
and monitoring and provides no benefit to the environment.
MODIFIED REMEDY
Recycling/Re-useof the iron oxide material of Impoundments 15 and 16 as follows:
• Excavation of iron oxide;
• Transport and reuse of the iron oxide at an off-site recycling facility,
• Backfilling, regrading and natural revegetation of former impoundment areas; and,
• Ground water monitoring.
Total Cost: $8,100,000
Time to Implement: 20 years
EVALUATION OF MODIFIED REMEDY USING CERCLA CRITERIA
Threshold Criteria:
1. Overall protection of human health and the environment: addresses whether or not a remedy pro-
vides adequate protection and describes how risks posed through each pathway are eliminated, reduced
or controlled through treatment, engineering controls or institutional controls.
• The modified remedy would achieve overall protection of human health and the environment by
removal of the iron oxide material from the site.
2. Compliance with applicable or relevant and appropriate requirements (ARARs): addresses
whether or not a remedy will meet all of the applicable or relevant and appropriate requirements of
federal and state environmental statutes and other requirements or provides grounds for invoking a
waiver.
• The modified remedy would not trigger chemical specific ARARs such as RCRA Hazardous Waste
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Regulations or Land Disposal Restrictions (LDRs) since the iron oxide is not a RCRA Hazardous
Waste. The modified remedy would contribute in achieving site-wide ground water ARARs by removal
and recycling of iron oxide material. Ground water monitoring is an ARAR under the State require-
ments and under the RCRA program (40 CFR 264.97). Location-specific ARARs consist of wetlands,
cultural resources and flood plains. Based on the preliminary findings, location-specific ARARs, except
for flood plain requirements, would not be triggered for Impoundments 15 and 16 because the proposed
remedial actions would hot impact those natural resources. Requirements for the flood plain will be
evaluated and satisfied (through permit equivalency) during remedial design phase! Action-specific
ARARs include the 1988 AGO, NJDEP Technical Requirements for Site Remediation, Occupational
Safety and Health Administration (OSHA) regulations, and Department of Transportation (DOT)
transport requirements. These ARARs would be met by specifying and monitoring activities so that
they are in compliance with the substantive requirements of these regulatory programs.
Primary Balancing Criteria: ' •"'•'•• •'
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.
• The modified remedy achieves this criterion by removal of iron oxide material from the site resulting in
no long-term maintenance. The modified remedy also achieves permanence by re-use of the iron oxide
material. • ; •
4. Reduction of toxicity, mobility, or volume: through treatment is the anticipated performance of the
treatment technologies a remedy may employ.
• The modified remedy would result in removal of the iron oxide from the site for reuse, thereby elimi-
nating concerns with reducing toxicity, mobility and volume of contaminants.
5. Short-term effectiveness: addresses the period of time needed to achieve protection from any adverse
impacts on human health and the environment that may be posed during the construction and imple-
mentation period until cleanup goals are achieved
• The modified remedy would not result in short-term impacts because the excavation and transportation
activities would be carried out in accordance with the regulatory standards protective of human health
and the environment. However, it might require that workers use persona: protective equipment to
reduce the potential for inhalation of dust particles generated during excavation.
6. Implementability: is the technical and administrative feasibility of a remedy, including the availability
of materials and services needed to implement a particular option.
• The operations associated with the modified remedy employ well-established, readily available con-
struction methods and are all considered technically and administratively feasible. The modified
remedy is now implementable because a recycling vendor has been identified.
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\ .,
AMERICAN CYANAMID COMPANY
BOUND BROOK, NEW JERSEY
GROUP g IMPOUNDMENTS
N.T.S. "
FILE NO. 5772'.010
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TABtE 1 (Coord)
AMERICAN CYAHAMIO COMPANY
BOUND BROOK, NEW JERSEY
CROUP II IMPOUNDMENTS
DATABASE SUMMARY FOR CONTAMINANT CONCENTRATIONS
tm|xHmdm«fi< fl^~f r
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M.flO 7B.M «s'l3 •<*«
4.70 l.X» $.90 . , lot!,.
14.40 , W3 4131 8 1* 8
Ut 1110 788.17 OeU:
3770 4fl.» 47.07 80(8
1030 4,49000 I.MI.I7 'taff'
104 779 181 8018 .
. 1090 1010 1030 . lo<8
1.79300 1.740.00 I.MOOO 8of8
7»1 1.890.00 1.188.17 «d«
•1 MO 70313 8ofS
1930 1930 • 19.30 1ol»
M90 8«* 744IJ toft
Mln • | M»x 1 Mean 1 Dclecli
104.00 799.00 lit 00 tott
7.00 UM 10.83 «ott
3180 UW 6000 toft
,,.480 ' r.JO 111 . «oft
tOO,. 7.80 740 }of|
. 70 » . 7450 M38 toft
'. 479.00 ! 1.070.00 78750 toll
31.10 • 41,40 37 .4 J ' 8oT8
1,040.00 ?.t70.00 1.7 7l.tr 8<4t
431.00000 4(0.000.00 417.113 U tc4t
./. 18.70 17400 t7.U trft
1.18000 1.930.00 1.598.13 8o(*
707.00 1.13000 89600 6(Xt
U1.00 16100 181 03 lolt
'
SIM 17.80 7J74 Sof8
' 7&40 419.03 157.77 8 of 8
_^ lmBoundm«rt t7 1
Mln 1 Max 1 M«an I Otttcit
41.80000 118.000.00 M.3U31 lldll
».70 4910 1 4193 3 gill
17 «0 188.00 • Jill IJolll
3.8UOO IS.V3000- T.ttlfl 11 of 11
2.10 ' 1.10 : 770 lain
1.60 170 J. 3.M II ol It
17.700.09 88.VOOOO' M.17100 17olll
til 00 11.70000} 3.4lt7S 170(11
»tO 14.10^)- 1580 • ; 11 el 11
1.71000 3.WOOO.J 7.4J7M Hal 11
too mo si i4 oj • tool u
14.400.00 ti. 100.00 .8S1t? l*d«
Mtn I
76.70000
• 10
7730
I.HOOO
Otl
too
S.94000
401 OO
310
•3800
410
73.70000
MS 00
3.7)01X1
It700
3} 70
4180
44100
050
180.00
3370
31TOO
. . _ • •(
"w j wn bMrAt indhartA ITut oonttmtatnlt vw rot tfctadad * 4
tOFl C
MM I MOM 1 Detect*
113.00900 t0.tHOO 70 Of 70
MOD 911 TOalTO
S77 I»8I MolTO
14.10000 7.44150 lOotn
10.00 4U i tOetn
113.000,09 M.70750 70 •T7'
1.00000 t.tU» 70 «l
3180 1407 TO*!*,
1.81000 1.08*40 70*170
4*70 11.11 It «I10
V7.0000) S9.S8000 tOaf]O
3.37000 1.085V) TOalM
117.00000 77.5*030 70 WTO
1.89000 95310 Mol40
74403 I»J! JOalJO
3M03 10198 TOatTO
1.50000 fOtl) ISolTO
On OM tolM
111 00 33400 TOolM
17JOO TOD 700(70
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TABLE 1
AMERICAN CYANAMID COMPANY
BOUND BROOK. NEW JERSEY
GROUP IUMPOUNDMENT3
DATABASE SUMMARY FOR CONTAMINANT CONCENTRATIONS
p
J |t Jt,- § 4| fVirl .
* M VU ^fr£ f HUH UNI
Aotant
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AnnMx-1242
AiKNot-1241
AractaHTM
Impoundment 1ft
MIn \ MIX 1 Mtin 1 Delects
0.009 0.010 0010- Jd«
0.017 0011 004* Bdl
0.002 0.00* 0009 3d*
0.002 0.002 0.002 Idt
0.092 000) 0.00) 2dl
0004 0.003 0.003 3d*
0002 OIXN -OMt 4rf<
000* OOM 0.0)4 3d*
•
.
0.200 0200 0200 Id*
0.2(0 17.000 5.0*7 6d*
0.092 00*2 0.0*2 Id*
0110 2.100 0431 *d«
0.0*2 0420 ail) 4d»
0.110 0.490 0247 3d*
0 170 t SOO 0.470 S d •
0.900 3000 1.7*0' Sd*
Impoundment 10
MIn 1 Mix 1 Mem | Detects
.0004 OOM oroi 2d«
001* . 0140 009) td«
0.09) 0.011 009* 4d«
000* 0022 0.01* 7d<
0.002 0.000 0004 3d*
0.004 0.011 0007 4d*
0.004 0.010 0.007 3dA
0005 0.170 0.07) 3d*
0.04* 0.073 OOM 3d*
0820 1100 3.S70 «dl
0.7)0 O.C30 0407 8d*
0.110 0.200 OlfO 8d*
0060 0200 O.tll 5d*
0.150 0.400 0.313 Sdl
Oil 10 0.190 0.13) 4d*
1.900 8.700 368) *d8.
Impoundment U
MIn 1 Mix 1 Me»n 1 Detect*
jwo . j.eoo 'iva .-14*12
• i
0.047 6.000 1.712 lid 12
0004 1.100 ;•'*• 0.471 '*d!2
* *. *
0.320 ' 0320: :' OJ20 • Id 11
0890 17.000 •!•• 1.712 ' «d!2
0075 0.078 i 007S Id 12
0.330 *,000 • 2.3*7 . «d12
0.03) 3.000 ' 0.71) .•' 5d1l
0004 3.400 1.071 Id 11
0020- 38.000'' 1S.il* ,' 7dl3
4000 180.000 87.411 lid 12
3.MO 9000 4400 2dl2
1300 100000 3).«43 7dl3
4700 25000 11.M* 7d17
12000 110000 87.500 1?d12
3.000 14.000 1.843 Id 12
19090 41.000 2I.KJO Sdl}
«.*00 34000 11.711 17 d 12*
•r
3.200 15000 7. 171 7d13.
3.300 300.009 «3075 12d12
4.900 IS 000 9.13) *d12
I
1.500 11000 11040 10d12
10F2
Impoundment 11
MIn 1 Mix | Meir- 1 Detecu
0,041 OOM COM Id 20
0.014 15000 IM) ttal VI
O.OM O.^M ftllt Sd20
0.010 ' 0.010 aOld !»•**•)
0.170 4 ICO 2.*13. 30^0
0.140 0.800 07*1 ?d20
0.01* OMO 9.1011 4d20
0011 0011 001 1 1d»
0019 1.809 0.4) ' 4djo
2.309 1*.000 7*41 5d20
».<00 11000 103TO 2d»
3.900 3 (CO 399). 1*7>>
3900 450000 1l*7lt 4d7
15000 77 POO 111!) 3d"
*000 710000 77.7«l »•.';»
11.000 30000 79 TO 4d79
il.OOO 6«.OOQ) 3*8'« 11^30
7.500 81.000 Jl.fi l*-'70
34090 34.000 3lO;U 1 ">0
U.OOO 1*.0umdih1«f«doDn»T
Rffm M bUnkWXHl* IM cartimtMnlt ««t
-------
DEC 32 1998 -16:11
P^ HftZ SUB CTRL OP? i £39 £33 1439 70 912156374455 P.B5>/fiS
THE OWNSHIP OF BRIDGEWATE0
,«u GAflRETSQN ROAD ' BRlOGEWATER NJ. OSWT
908/725-6300.' FAX 1 908/70W23S
. 4AI.MG ADDRESS
P5.80XJ5CO
1998 . BRBGEWATER.NJO.,07
Mr. Haiyesh Shah .
New Jersey Department of Environmental Protection
Bureau of Federal Case Management r—
Division of Responsible Party Site Remediation •".""- •-.....
401 East State Street. Fifth Floor West "
CN 028
Trenton, New Jersey 08525-0028 i,^, „ _
'"•' 3:938
RE: American Cyanamid Site —
Proposed Recycling Option ^.
Impoundments 15 and 16
Dear Haiyseh: "*
Please be advised the Health Department has reviewed the
proposal to recycle approximately ISO million pounds of iron
oxide material currently located in Impoundments 15 and 16 at
the American Cyanamid site. As a result the Health Department
has no objections to the proposed plan. Furthermore, the .
Department recommends actions be taken to expedite all
approvals necessary co -implement the beneficial reuse of
these materials.
It is suggested a work plan be constructed and provided for
review prior to the initiation of all on-site activities.
This plan should include information on the aspects of dust
control, transportation of materials, and necessary
environmental monitoring during reclamation procedures.
Thank you for the opportunity to comment on this matter.
Sincerely,
Chris 0. Poulsen
Environmental Health Specialist
-------
JJtC A3 193B lo;li m rmtL. SUB cirri, urr 1 bids oj-> j.*O3 iu
' I " ff
>: T t f
CRISIS
Fax Memo
TO: Hatyesh Shah
FAX NO. 609/633-1454
FROM: \VaUSodie ***...* ,,A<
Phone: 609/799-1553; Fax No. 609/716-1705
Number of pages, including this one -1
RE: American Home Products (AHP) (American Cyanamid) Superfund Site
Rccjxling of iron oxide in Impoundments 15 and 16
Reference AHP letter to you of 10/16/98
Per discussions yo;> have had iritfa our Technical Advisor. Tom Germinc, CRISIS has no
objccuon to the timetable for recycling this matcriaJ, as outlined m the above-caphoned AI If
letter.
Further, CRISIS sees no need for holding a public hearing on this issue.
1 f you require any further action from CRISIS, please contact m«.
Walter M.SoUic
Executive D;rccior
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