United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-86/033
September 1986
3 EPA
Superfund
Record of Decision
Syncon Resins, NJ
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TECHNICAL REPORT DATA
iPleate read Instructions on the revene btfore completing
1. R6PORT NO.
EPA/ROD/R02-86/033
3. RECIPIENT'S ACCESSION NO.
4. TITLE ANO SUWTLE
SUPERFUND RECORD OP DECISION
Syncon Resins, NJ
5. REPORT DATE
_September 29, 1986
8. P6RPORMING ORGANIZATION CODE
7. AUTHOR(S)
I. PERPORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME ANO ADDRESS
10. PROGRAM ELEMENT NO.
pi. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME ANO AOORESS
U.S. Environmental Protection Agency
401 M Street, S.w.
Washington, D.C. 20460
13. TVPE Of REPORT ANO PERIOD COv£«e;
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Syncon Resins site encompasses approximately 15 acres and is located in a heavily
industrialized area 'of northern New Jersey. The Syncon Resin facility'produced alkyd
resin carriers for pigments, paints, and varnish products. In the production process-
excess xylene or toluene was separated from the wastewater and reused in subsequent
reactions. The remaining wastewater was subsequently pumped to an unlined leaching pon
(lagoon) to evaporate or percolate into the soil. The sampling performed during the
remedial investigation indicated extensive onsite contamination in the soil, ground
water, building dirt/dust, and stainless vessels and tanks. Four general classes of
chemical contaminants were found onsite: organic compounds, pesticides, PC3s and met.a Is
The cost-effective remedial action selected for this site includes: removing the
contents of the storage tanks and vessels for offsite disposal; decontaminating
buildings and tank structures as necessary; excavation of lagoon liquids, sediments -and
grossly contaminated surface soils and dispose offsite; install a cover over the site
that allows natural flushing; pump and treat ground water; and conduct supplemental
studies to evaluate methods which enhance the effectiveness of flushing and/or treat~
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-2-
The ROD has been reviewed by the appropriate program offices
within Region II and the State of New Jersey and their input
and comments are reflected in this document. In addition, a
letter from the State confirming its verbal concurrence of the
selected remedy is forthcoming.
Attachment
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site Syncon Resins, Kearny, New Jersey
Documents Reviewed
I am basing my decision on the following documents, which
describe the analysis of remedial alternatives considered for
the Syncon Resins site. .
- Remedial Investigation Report, prepared by Ebasco Services,
May 1986 (revised August 1986)
- Risk Assessment Report, prepared by Ebasco Services,
June 1986 (revised August 1986)
- Identification and Screening of Remedial Alternatives, prepared
by Ebasco Services, June 1986 (revised August 1986)
- Feasibility Study Report, prepared by Ebasco Services,
July 1986 (revised August 1986)
- Responsiveness Summaryt September 1986
- Staff summaries and recommendations
Description of Selected Remedy
- Remove the contents of storage tanks and vessels for disposal
in accordance with applicable requirements
- Decontaminate buildings and tank structures as necessary
- Remove lagoon liquids and sediments for disposal in accordance
with applicable requirements
- Remove grossly contaminated surface soils for disposal in
accordance with applicable requirements
- Install an appropriate cover over the site to allow natural
flushing of underlying soil and ground water contaminants
- Collect and treat contaminated waters from the shallow aquifer,
with discharge to the Passaic River
- Conduct supplemental studies to evaluate methods to enhance
the effectiveness of flushing and/or treatment and destruction
of the contaminated soils
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-2-
Declarations
Consistent with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980, and the National Oil
and Hazardous Substances Pollution Contingency Plan (40 CFR
Part 300), I have determined that the alternative described
herein is an operable unit involving control of the source of
contamination which is cost-effective and consistent with a
permanent remedy.
I have further determined that this remedy is a cost-effective
alternative that is technologically feasible and reliable, and
which effectively mitigates and minimizes damages to and provides
adequate protection of public health, welfare and the environ-
ment. Implementation of this operable unit is appropriate at
this time, pending a determination of the need for any further
remedial actions. It is also hereby determined that implemen-
tation of the selected remedy is appropriate when balanced
against the availability of Trust Fund monies for use at other
sites.
The State of New Jersey has been consulted and agrees with the
selected remedy.
H.
Date Christ6pher
Regional Administrator
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
SYNCON RESINS SITE, KEARNY, NEW JERSEY
SITE LOCATION AND DESCRIPTION
The Syncon Resins site encompasses approximately 15 acres and
is located in a heavily industrialized area of northern New
Jersey. The site is located in Kearny, Hudson County, at
approximately 40° 44' latitude and 74° 06' longitude. The site
is bounded on its western edge-by the Passaic River (Figure 1).
Adjacent to the northern and southern boundaries of the site
are two licensed hazardous waste haulers. The site is bounded
on the eastern side by Jacobus Avenue and is across the street
from a lacquer manufacturing facility.
The Syncon Resins site is situated on a narrow peninsula of
land bordered by the Passaic and Hackensack Rivers, whose con-
fluence 1.5 miles south of the site forms the upper reaches of
Newark Say. The site is relatively flat with minor topographic
variations. The elevation at the site ranges from five to ten
feet above mean sea level (MSL). Both the Passaic and Hackensack
Rivers are tidal water bodies with a mean spring tidal range-of
approximately six feet.- Newark'-Bay, the Passaic River,, and the
Hackensack River are major components of the Hudson River-New
York Bight estuarine system.
The narrow peninsula on which the Syncon Resins site is located
is heavily industrialized. Various chemical plants, hazardous
waste transporters, manufacturing companies, petroleum facilit-
ies, and storage terminals are situated within the immediate
area. The closest residential areas to the site are located
approximately one mile due west in Newark and one and one-half
miles due southeast in Jersey City. The shallow aquifer in the
area is not utilized for any purpose. Ground water from the
confined or deeper aquifer within the area is utilized solely
for industrial purposes. All potable water for the area's
users is supplied via municipal water purveyors.
The Syncon Resins site and the surrounding area are situated
within the Hudson River drainage basin. The material overlying
the bedrock comprises primarily alluvial sands, silts, clay
and detritus. Immediately beneath the site are four major
stratigraphic units within the alluvial material: 1) a surficial
fine to coarse sand layer approximately 10 feet thick, 2) a
highly plastic clay layer approximately 8-10 feet thick, 3) a
medium sand layer approximately 10 feet thick, and 4) a deep
layer of silty clay and very fine sand approximately 15 feet
thick. All four stratigraphic units are continuous across the
site.
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FIGURE 1
SITE LOCATION MAP, SYNCON RESINS SITE,
HUDSON COUNTY. NEW JERSEY
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-3-
The two sand layers are separated by the clay layer, which acts
as an aquitard, thereby forming two aquifers beneath the Syncon
Resins site: 1) a shallow, water table aquifer above the clay
layer and 2) a deep, confined aquifer beneath the clay layer.
Over most of the site, the water table is one to two feet below
ground level and gently slopes to the west toward the Passaic
River. The - confining layer of clay underlying the site begins
approximately 10 feet below grade. Ground water velocity within
the shallow aquifer was calculated to be 31.2 feet per year. The
deep aquifer has an estimated ground water velocity of 2.1 feet
per year.
SITE HISTORY
The origin of the Syncon Resins site is obscure. The earliest
evidence documenting the existence of the site consists of 1951
aerial photographs of the area. In November 1981, the New Jersey
Department of Environmental Protection (NJDEP) investigated the
site and ordered its owners to control and contain the hazards
at the site. In May 1977, the owners of Syncon Resins filed
for bankruptcy under Chapter 11 of the Bankruptcy Act; in 1982,
.the company ceased all operations. In December 1982, the site
was listed on the National Priorities List.
The Syncon Resins facility produced alkyd-resin carriers- for
pigments, pai'nts*, and varnis.h products. .The processes- that
produced these resins were carried out in closed stainless steel
vessels. Cooling water utilized in the production process was
recycled within the system. In the production process, excess
xylene or toluene was separated from the wastewater and reused
in subsequent reactions. The remaining wastewater was subse-
quently pumped to an unlined leaching pond (lagoon), where it
was allowed to evaporate or percolate into the soil. Apparently,
much of the company's operations consisted of the reprocessing
of off-specification resins purchased from other manufacturers.
The site consisted of at least two reactor buildings containing
stainless steel vessels, various other buildings and structures,
numerous large bulk storage tanks, two unlined lagoons, and an
unknown number of underground tanks and associated piping systems
(Figure 2). A total of 12,824 55-gallon drums of off-specif-
ication resins, raw materials, wastes and solvents stored at
various locations on the site were removed in 1984, under a
Cooperative Agreement between the NJDEP and the U.S. Environmental
Protection Agency (EPA), at a cost of $2.4 million. Still
remaining on-site are numerous laboratory chemicals and batch
samples of resins which are scheduled to be removed in the
near future.
As stated above, the two unlined lagoons at the site were used
for discharging process wastewater. Lagoon 1 is the larger of
the two lagoons, with approximate dimensions of 40 by 135 feet.
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BUILDING AND TANK SAMPLING
LOCATIONS (1985)
FIGURE 2
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-5-
Lagoon 2 is approximately 40 by 15 feet in size. The depth of
each lagoon has been estimated at 4 feet.
Six main buildings and seven ancillary structures exist on the
Syncon Resins site. Building B-l appeared to be primarily
utilized for maintenance and storage, with the western third of
the building being utilized for some production and/or process
work. Building B-7 was the main production/process building
and electrical service facility. Building B-10, near the front
gate, contained administrative offices on the second floor, and
probably utilized the first floor as a storage area. Building
B-ll, near Lagoon 2, may have served as an equipment storage
and/or maintenance area. Building B-RED, with loading docks
adjacent to the railroad tracks and parking areas, most probably
served as a shipping/receiving or short-term storage area. A
laboratory (Building B-8) located near the main entrance and
adjacent to Building B-10 was utilized for in-process formulations
and quality checks of the finished product. The other buildings
on-site were also used in process-related activities.
CURRENT SITE STATUS
A. Previous Investigations
In 1982, a .limited si'te investigation was performed by the
NJDEP and the EPA at'the Syncon Resins site. This investi-
gation focused on' a preliminary assessment of the types and
extent of contaminants at the facility.
The investigation showed widespread contamination. Within
the deep aquifer, six contaminants (benzene, methylene
chloride, tetrachloroethylene, chloroform, carbon tetra-
chloride and PCBs) exceeded adjusted ambient water quality
criteria (AAWQC). Shallow ground water was grossly contami-
nated with 24 organic compounds, of which fourteen exceeded
AAWQC. Thirteen of these contaminants were found at extremely
high concentrations (greater than 760 parts per million
(ppm)), with nine of them present in the ground water at
percent levels (parts per hundred). Seven contaminants
found in the shallow ground water could not be compared to
the water quality criteria since no criteria currently
exist for these compounds.
Gross chemical contamination was found within the Syncon
Resins facility's soils. Ten base/neutral compounds in
excess of 400 ppm and high concentrations of toluene and
methylene chloride were found in test pit soils. PCBs
(greater than 33,000 ppm), DDT (in excess of 1400 ppm) and
high concentrations of arsenic, chromium, lead, mercury,
and zinc were also present. Nearly all of the compounds
found in the test pit soils are suspected carcinogens.
Two localized areas of high concentrations of contaminants
or "hot spots" were identified during this investigation:
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1) the southwest corner of the site adjacent to the Passaic
River, and 2) the northeast corner of the property near the
large 600,000-gallon storage tanks. High concentrations of
toluene and PCBs were found in the southwest corner, whereas
elevated concentrations of naphthalene and petroleum hydro-
carbons occurred in the northeast corner.
A survey of the 12,824 55-gallon drums stored at various-
on-site locations revealed three main classes of materials:
non-PCB containing, PCB containing, and peroxides. Most of
che drummed material did not contain PCBs and could be
separated into five categories: bulk solids (2,441 tons),
flammable solids (1,452 drums), lab packs (10 drums),
flammable liquids (79,100 gallons) and base/neutral liquids
(66,911 gallons).' PCB containing materials were categorized
as bulk solids (1 ton), drummed liquids (29 drums) and
flammable materials (49 drums). Only six drums of peroxide
were found on-site. All of these drummed materials were
removed from the site by licensed waste haulers.
B. Present Site Investigations
The sampling performed during the remedial investigation
indicated extensive on-site contamination in all of the
matrices s-ampled (i.e.., vessels and tanks>'s.oilf. grou,nd water,
and bftilding dirt/dust), except for ambient air. Four
general classes of chemical contaminants were found on-site:
organic compounds (volatiles and base/neutral extractables) ,
pesticides, PCBs, and metals. The organic compounds present
are normal raw materials and/or resin components, and the
metals seen are probably from metallic oxides or organo-
metallics utilized as pigments or catalysts in the production
processes.
A total of 150 tanks and vessels remain on-site including
three which are underground. Approximately half of the
on-site tanks are empty. Of those tanks containing material,
most of the tanks contained either hexaneor water-soluble
peroxides or hexane-soluble liquids and solids. Table 1
summarizes the tanks and vessels, their contents, and
volumes of material.
Four tanks (approximately 7,000 gallons) contained aqueous
liquids; whereas two tanks (approximately 900 gallons)
contained cyanide-positive organics. Two tanks were essen-
tially empty except for a minimal amount of a solid, hexane-
soluble material. Fourteen tanks were categorized as special
cases because it was difficult to assign them to a single
general category. Most of these fourteen tanks contained
flammable liquids or solids, crystalline or polymeric
material, or sludge residues. In addition to their chemical
content, some tanks and associated piping were encased in
an asbestos-base material.
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-7-
TABLE 1
Group Category
1.
2.
3.
4.
5.
6.
7.
8.
9.
Empty
Near Empty
Cyanides
Hexane-Soluble
Peroxides
Water-Soluble
Peroxides
Hexane-Soiuble'
Liquids
Hexane-Soluble
Solids
Aqueous Liquids
Special Cases
TANKS AND VESSELS
Total No. of Comments
Volume Tanks
66 2 tanks*; 2 tanks**
2 Hexane-soluble solids
900 gal 2
43,000 gal 16
54,000 gal 22
20 CY solids
26,000 gal 11 2 tanks**; 1 tank***'
30 CY 6 1 tank**
7,000 gal 4 largely rainwater
14
PCB concentration ranges:
* 10-100 ppm
** 100-500 ppm
***
>500 ppm
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-8-
Contamination from organic compounds exists throughout the Syncon
Resins site (Tables 2 through 7). Volatile organic contaminant
concentrations were greatest in the lagoon sediments, in saturated
and unsaturated soils near the southwest corner of the site ad-
jacent to Lagoon 2, and around Buildings 1 and 7. Primarily,
the volatile contaminants were common solvents: toluene, xylene,
trichloroethylene, ethylbenzene, benzene,. 2-hexanone, methyl
isobutyl ketone, and chlorobenzene. The data suggest that this
contamination may have been caused, in part, by solvent carry-over
into the wastewater and spills.
The shallow aquifer was contaminated primarily with the same
volatile organic solvents as those found in the lagoon sediments
and former process buildings (i.e., toluene, xylene, trichloro-
ethylene). Generally, the greatest concentrations of these
common solvents occurred in the south-central and south-western
portions of the site near the tank farm and in the northeastern
portion of the site near former drum storage areas. This suggests
that tank and drum leakage or spillage may be the primary
source of this contamination.
The confined aquifer beneath the clay layer did not contain any
volatile organic solvents found in other on-site matrices. Thus,
the confining clay layer beneath the site appears to act as a
barrier to vertical migration of chemical contaminants. Two
solvents (1,1-dichloroethane and chlorobenzene) were present in
the deep aquifer, but their absence from on-site. water matrices
suggest an off-site source.
Acid/base/neutral organic compounds present in saturated and
unsaturated soils on-site were principally phthalates, polyaro-
matic hydrocarbons, dichlorobenzene, N-nitrosodiphenylamine/
diphenylamine and 4-methylphenol. Surficial phthalate contami-
nation was found throughout the site, with the greatest concen-
trations occurring in the soils adjacent to the buildings at
the southeast corner of the site near Jacobus Avenue. In con-
trast, none of the other acid/base/neutral compounds exhibited
any vertical distributional pattern in the on-site soils.
These compounds were instead concentrated in saturated and
unsaturated soils in or near former storage, processing, or
laboratory areas. This suggests that drums, tanks, or buildings
may be possible point sources for these contaminants.
Base/neutral organic compounds, principally naphthalene and 2-
methyl naphthalene, were present in the ground water near the
south-central tank farm and the large 600,OOC-gallon storage
tanks at the northeastern corner of the site. These compounds
were found only in the shallow aquifer, above the clay layer.
The close proximity of the base/neutral compounds within the
shallow aquifer to the large storage tanks and tank farm suggests
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Compound
-9-
TABLE 2
SUMMARY TABLE OF CONCENTRATION RANGES
FOR PESTICIDES/PCBs AND METALS DETEL.'1'KL)
IN UNSATURATED. SATURATED AND CLAY SAND LAYER SOILS
SAMPLED DURING THE 1985 SITE INVESTIGATIONS
. Concentration Ranges
Unsaturated Soil Saturated Soil gay Sand Layer Soil
Pesticides/PCBs:
DDT
ODD
DDE
Aldrin
PCB
Metals*!
Lead
Zinc
Vanadium
Chromium
Arsenic
Nickel
Thallium
Cadmium
Silver
Mercury
Cobalt
Phenol*
ND-120
ND-20
ND-9.1
ND-0.168
ND-31
ND-4919
ND-994
ND-851
12-829
8.5-256
ND-83
ND-69
ND-17
ND-8.1
ND-1.5
-
ND-51
ppm
ppm
ppm
ppm
ppm
. .
ppm
ppm
ppm
ppo
ppm
ppm
Ppa
ppa
ppm
ppm
ppm
ND-0.015
-
-
-
.
ND-12 33
25-330
ND-60
9-332
ND-37
ND-315
ND-44
ND-9.3
-
ND-1.8
ND-18
ND-18
ppm
ppm
ppm
ppm
ppn
ppm
ppm
ppm
ppm
ppm
ppm
ppm
-
-
-
.
^
13-21 ppm
-
ND-12 ppm
-
-
ND-13 ppm
-
-
0.21-1.4 ppm
ND-5.5 ppm
ND-5.5 ppm
Note: Clay Sand Layer Soil ia aoil obtained below the clay layer froa the
17-19 foot depth interval.
"* - Qualified data.
42 9 Ob
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-10-
TABLE 3
SUMMARY TABLE OF CONCENTRATION RANGES
FOR VOLATILES. ACID/BASE NEUTRAL ETTRACTAflLES AND
METALS DET.hX.TKD IN UNSATUBftlED
AND SATURATED
SOILS
DURING THE 1986
SITE
INVESTIGATIONS
Concentration Ranges
Compound
Volatile Organ!
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TABLE 3 (Cont'd)
FOR VOLATILES. AC
AHD SATURATEl
Compound
Acid/Baae Neutrala (Cont'd)
Di-n-octylphthalate
Beazo(a)pyrene
Indeno(l,2,3-c,d)pyrene
Benzo(g,h,i)perylene
Acenaphthene
N-nitrosodiphenlyamine
Benzo(b)fluoranthene
Benzo(k)fluoranthene
4-Methyl phenol
Dibenzo(a,h)anthracene
1,2-Dichlorobentene
Metala
Arsenic
Cadmium
Lead
Nickel
Zinc
Silver
Chromium
Mercury
Tn^ASg NEUTRA3
L ETTRACTAfll
MTJPKEED.
LES AND
i cjftTT^ tanLTflfi Tiff 11** SITE
INVESTIGATIONS
Concentration Rantea
tin.mturated Soil
ND - 210 ppm
ND - 9.4 ppm
ND - U
ND - 5.8
ND - 1.5
ND - 3.6
ND - 2.2
ND - 19
ND - 87
ND - 31
89 - 855
ND - 89
44 - 485
15 - 113
ND - !
ppm
ppm
ppm
ppa
ppm
ppm
ppm
ppm
ppa
ppn
ppm
ppm
4 ppm
^
Saturated Soil
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND
3
7.2
ND
29
ND
10
0.1
2*
.3 ppn
87 ppm
A / . .^
84
53
1.7
2.8
76
58
0.67
1.4
- 25
- 4
- 270
- 57
- 274
- 17
- 68
- 0.
PP»
ppm
ppm
ppm
ppm
ppa
ppa
ppa
ppm
ppm
ppm
ppa
ppm
ppa
ppm
6 ppm
- Compound cannot
be diitinpiiahed from diphenylamine,
3964b
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-12-
TABLE 4
SUMMARY TABLE OF CONCENTRATION RANGES
FOR PRIORITY POLLUTANTS DETECTFT)
IN MONITORING WELL WATER SAMPLED
DURING THE 1985 SITE INVESTIGATIONS
Concentration Range
Compound
Toluene
Xylene
Methylene Chloride
Trichloroethylene
Chlorobenzene
1,1-Dichloroethane
2-Methlynaphthalene*
Naphthalene*
Shallov Groundvater
ND-280,000 ppb
ND-12,000 ppm
ND-3,000 ppb
ND-2000 ppb
ND-5
ND-1500
ND-300
ppb
ppb
ppb
Deep Groundwater
(Below Clay Layer)
ND-6 ppb
ND-7 ppb
ND-88 ppb
ND-14 ppb
Arsenic
Barium
Chromium
Lead
Nickel
Vanadiua
Zinc
ND-76
ND-646
ND-18
ND-131
ND-94
ND-156
ppb
ppb
ppb
ppb
ppb
ppb
ND-261 ppb
ND-12 ppb
ND-12 ppb
57-76 ppb
23-45 ppb
* - Qualified data
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TABLE 7
SUMMARY TABLE OF CONCENTRATION RANGES
FOR VOLATILES. PESTICIDES/PCB* AND METALS DETECTED
ABOVE THE
DETECTION LIMIT IN BUILDINGS SAMPLED
DURING THE 1985
Coo pound
Trichloroethylene
Toluene
Xylene
Ethylbentene
Chlordane
DDD
Arochlorl248
Aaochlor 1254
Barium*
Chromium*
Lead*
Nickel*
Vanadium*
Zinc*
Cadmium*
Cobalt*
B-l
1.5
1.2
1.0
-
-
-
17
4650
428
4379
80
99
10500
17
33
ppa
ppa
ppo
ppa
ppa
ppa
ppa
ppa
ppa
ppa
ppa
ppm
B-7
1.5
1.8
15.0
3.8
-
- -.
2.7
6090
162
3360
84
65
7250
96
30
SITE
^^^m
ppa
ppa
ppa
ppa
ppa
ppa
ppa
ppa
ppa
ppa
ppa
PPP
ppm
INVESTIGATIONS
B-10 B-ll
1.6 ppm 2.6 ppa
-
0.6 ppa
- -
-
1.1 ppa
.32 ppa
24 ppm.
3820 ppm 5200 ppm
64 ppa 288 ppm
3540 ppm 1540 ppm
201 ppa
-
3140 ppa 1460 ppa
7.3 ppa 14 ppm
B-RED
1.7
-
-
0.9
80
-
' -.
-
852
313
1780
62
-
6710
146
ppa
ppa
ppa
,
,
ppa
ppa
ppa
ppa
ppm
ppm
B-l -
B-7 -
Building B-l; probable former maintenance/pipe ehop/itorage and
limited production/proceM area.
BuUding B-7; probable former procew/production building and
electrical itortge facility.
B-ll - Building B-ll; prob.ble former .tor.ge/mechanicel m*inten.nce eree,
T Building B-RZD; proUbl. .hippin./rec.iving/.bort term .tor.ge
Qualified d»t«
-------
-16-
.that these vessels may be contaminant sources. The two base/
neutral compounds present in the shallow aquifer would have
been used in the manufacture of some of the facility's products.
Generally, the pesticides present at the Syncon Resins site
were found in soils adjacent to former drum storage areas and
in the building dust and dirt in former .storage and shipping-
receiving buildings. Pesticide contamination in the soil
appeared to be a surficial phenomenon with the highest concen-
trations occurring in unsaturated soils. The distribution of
pesticide contamination in soils simply suggests spillage, but
bears no apparent connection with resin plant operations.
PCB contamination at the Syncon Resins site is restricted to
lagoon sediments, dirt and dust samples from former production/
process buildings, and one soil area. It was also found in
eight tanks (Table 1) and over 75 drums during the 1984 removal
action. Again, there is no apparent connection between this
contaminant (PCBs) and alkyd resin manufacturing.
While metal contamination was present in all non-air sample
matrices, elevated individual metal concentrations exhibited
distinct on-site distributional patterns within certain matrices.
In soils, the highest metal concentrations were, -generally present
within the western one-third of the site near the Passaic River ..
and adjacent to former drum/tank storage areas. Spillage onto
the soil in the drum/tank storage areas is the most probable
cause of this contamination. In contrast, inorganic contamination
of the shallow aquifer showed no specific distributional pattern
except for arsenic, which also tended to be highest in surficial
soils in the northern half of the site.
In general, inorganic constituents within the deep aquifer were
metals not found within the shallow aquifer. Excluding barium
and zinc, no other metals within the deep aquifer were detected
in the shallow ground water above the clay layer, suggesting
that the clay layer serves as an effective barrier to vertical
migration.
The lagoon sediments and the building dirt/dust contain similar
relative proportions of certain metal concentrations that would
have been utilized at the Syncon Resins site during its operation.
Thus, the bulk of the metal contamination at the Syncon Resins
site may stem from improperly handled raw materials or by-
products, especially with regard to catalysts anr" pigments.
The Syncon Resins site exhibits extensive chemical contamination
of organic compounds, pesticides, PCBs and metals. Although some
specific contaminants were concentrated in particular on-site
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areas, all of the apparent site-related contaminants were re-
stricted to matrices located above the clay layer beneath the
site.
Chemical constituents were present in the confined aquifer
beneath the-clay layer. These constituents, however, appears
to stem from an off-site source.
The chemical contamination present at the Syncon Resins site is
apparently restricted from vertical movement due to the clay
layer beneath the site. However, lateral movements of contami-
nants within the shallow aquifer are not restricted. The ground
water flow within the shallow aquifer can transport these con-
taminants to the Passaic River. This ground water movement, in
conjunction with tidal flushing, is one of the principal means
of off-site transport of contaminants.
PUBLIC HEALTH RISKS
Based on the geological, hydrological, and chemical contaminant
characteristics of the Syncon Resins site, eleven potential
exposure pathways have been identified. These pathways include
ingestion, inhalation, and direct contact with various media.
Three on-site matrices (unsaturated soil, lagoon sediment, and
building dirt and dust) exceeded health-based criteria for
organic and metal contaminants and pose a health risk via
direct contact and ingestion.
In addition to the various on-site matrices posing potential health
risks, some of the on-site tanks and vessels contain materials
that could pose potential health risks to exposed populations
if left on-site.
ENFORCEMENT
A claim for cleanup costs incurred at the site has been filed
in the Bankruptcy proceedings of Syncon Resins, Inc. A cost
recovery action for part of these costs has been initiated
against Benjamin A. Farber, former owner of the entire Syncon
Resins site and present owner of a portion of the site.
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-18-
An investigation is in progress to identify additional potentially
responsible parties (PRP's) for purposes of potential cost
recovery and enforcement actions in regard to future costs of
remedial activities. Any such additional parties identified as
PRP's will., be included in all actions for recovery of cleanup
costs and will be sent notice letters offering them the opportunity
to perform the design and construction activities recommended
in this document before EPA and NJDEP make a decision to fund
any future work.
DESCRIPTION OF REMEDIAL ALTERNATIVES
The feasibility study process involves, as a first step,
selecting technologies that are appropriate for remedying the
public health and environmental concerns associated with a
particular site. In the case of the Syncon Resins site, the
remedial objective is to control the potential release of
contaminants from the site.
The following remedial objectives were established as a result
of the risk assessment performed for the site:
° Develop mitigative measures to prevent exposure of humans
to organic and metal contaminants wi'thin the unsaturated..
soil, lagoon' sediments, and building dirt/dust through
direct contact and ingestion exposure routes;
0 Implement mitigative measures to eliminate the potential
hazard to exposed populations caused by the asbestos material
covering the on-site tanks and vessels and the chemical
materials remaining within them.
While the contaminated, on-site shallow ground water poses
little risk of direct contact or ingestion, it eventually flows
into the Passaic River and so constitutes a discharge of a
hazardous substance. Various State statutes require that the
NJDEP implement or require the implementation of corrective
action prc~-ams where the waters of the State have been sign-
ificantly -agraded by hazardous substances.
The following remedial objectives were established as a result
of NJDEP1s policy on maintaining or improving existing ground
water and receiving water conditions:
0 Implement mitigative measures to remediate the contaminated
ground water within the shallow aquifer to levels identified
in the following guidance documents:
-------
- Ground water criteria for Class GW3 aquifers (N.J.A.C.
7:9-6);
- NJPDES effluent limitations for discharge into the
Passaic River (N.J.A.C. 7:9-5); and
- Best Available Technology (BAT) Limitations, Option III
for Organics and Plastics and Synthetic Fibers, 40 CFR
Parts 414 and 416, Proposed Rule.
0 Develop mitigative measures to remediate the contaminated
saturated soils above the continuous clay layer.
Considering available technologies and the site's existing
physical conditions, several remedial alternatives were developed
and are listed in Table 8, along with their capital costs,
operation and maintenance costs, and total present worth costs.
A summary of treatment, storage, and disposal methodologies for
these alternatives is shown in Table 9.
Present worth costs for all alternatives were calculated using
a thirty-year life cycle as a basis for comparison.
ALTERNATIVE .1 .- NO ACTION- ;
The no action alternative involves installation of a security
fence around the perimeter of the site, removal of structurally
unsafe buildings to an off-site landfill under the Resource
Conservation and Recovery Act (RCRA), sealing of other on-site
buildings, and long-term monitoring of the integrity of buildings,
tanks, and air and ground water matrices. This alternative
does not remove or reduce contaminant levels on-site. Hence,
the risk and exposure pathways are not mitigated and the future
reuse of the site would be restricted.
ALTERNATIVE 2 - REMOVE BUILDINGS, TANKS, AND SOIL, AND OFF-SITE
WASTE DISPOSAL
This alternative involves the removal of all buildings, tanks,
tank contents, piping, and other structures, as well as soil and
sediment exceeding the cleanup criteria for off-site treatment
or disposal. Uncontaminated soil would remain on-site. This
remedial alternative would exceed applicable and relevant Federal
public health and environmental standards and would allow for
future reuse of the property.
a. Tanks
The total amount of liquid and solid wastes in the on-site
tanks is estimated to,-, be 167,000 gallons. A total of 69
tanks are currently Considered to be hazardous based on
the following criteria: -
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-20-
TABLE 8
CAPITAL, OPERATION AND MAINTENANCE (OS.M),
AND PRESENT WORTH COSTS
1986 Dollars (millions)
1.
2.
Remedial Alternatives
No Action
Remove Buildings,
Capital
0.4
116.4
Year
1-30
1-5
Annual Present
O&M Worth O&M
0.08 0.8
0.078 0.4
Total Present
Worth Cost
1.2
116.8
Tanks, and Soil, with
Off-Site Waste Dis-
posal
3. Decontaminate Build-
ings and Tanks, On-
Site Incineration,
.and On-Site Soil
Washing
4a. Decontaminate Build-
ings and Tanks, Im-
permeable Cap, and
Leachate and Ground
Water Control
4b. Decontaminate Build-
ings and Tanks, Perm-
eable Cap, and Passive
Flushing with Leachate
and Ground Water
Treatment**
5. Remove Buildings
and Tanks, and Site
Encapsulation
6. Remove Buildings
and Tanks, On-Site
Chemical Fixation
of Soil, and On-Site
RCRA Landfill
6-30 0.017
53.9 1-5 0.08 0.4
6-30 0.019
5.2 1-30 0.213 2.0
5.6 1-30 0.209 2.0
20.5
55.2
1-30 0.103
1-5
6-3J
0.092
0.032
1.0
0.5
54.3
7.2
7.6'
21.5
55.7
* Subsequent additional-factions to enhance the removal of contaminants from soils
may increase the overall cleanup cost for the site by $10-20 million.
** This alternative was not included in the RJ/FS as such, see pages 35-36 for
further details.
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-21-
TABLE 9
SUMMARY OP TREATMENT, STORAGE AND DISPOSAL METHODOLOGIES
ITEM
BUILDINGS
SECURE
DECONTAMINATE
DEMOLISH
TANKS
SECURE
DECONTAMINATE
DEMOLISH
UNSATURATED SOIL!
ENCAPSULATE
OFF-SITE HAZARDOUS
OFF-SITE NON-HA2ARDOUS
ON SITE HAZARDOUS
ON-SITE NON-HAZARDOUS
SATURATED SOILS
ENCAPSULATE
OFF-SITE HAZARDOUS
OFF-SITE NON-HAZAROOUS
ON-SITE HAZARDOUS
ON-SITE NON-HAZARDOUS
GROUND-WATER.
DECONTAMINATION WATER
AND WASTEWATER
ON-SITE
OFF-SITE
DISPOSAL OF TANK CONTENTS/
DECON MATERIAL/BUILDINGS/
TANKS
OFF-SITE HAZARDOUS
OFF-SITE NON-HAZARDOUS
ON-SITE HAZARDOUS
ON-SITE NON-HAZARDOUS
OTHER
''
MONITOR ING-LONG TERM
OROUNDWATER AND AIR
ALTERNATIVE
1
(OIL iLDGI
(OIL ILOG)
9
2
(GROUNDWATER)
DEWATER
SATURATED
SOIL
3
(SOIL
WASHING)
(SOIL
WASHING)
(SOIL
WASHING INCL
GROUNOWATER)
(INCINERATION
SOIL
WASHING)
9
4
(PARTIAL)
(PARTIAL)
(NATURAL
FLUSHING)
(GROUND
WATER
OECON
WATER)
CONCRETE
ARRIER
ALONG
RIVER
a
(CHEMICAL
FIXATION!
(CHEMICAL
FIXATION)
(LIQUIDS)
(TANKS &
BLOGSl
ON-SITE
RCRA
LANDFILL
0
AlTMMATIVt HO. MMMVTOM:
1. HO ACTON
1 ftlMOVI UILDINO*. TAMM AND 10IL WITM OFMfTf WAfTI OtVOIAL
I MCONTAMINATI AND S«MIM lUILPIWt AND TAMM. ONUTI mONtMATtOM AND OtMITI lOILt WACMINO
4. DieOWTAMINATI tUILOINO AND TAMK1. LIACMATI AND WOONOW4T5* OKfTWOl
I. Ml MO VI IUILDINO* AMD TANKI. Off-tltl HCKA CANOf ILL ANO «TI (HCAnuLATION
1 naaovt auiiAHtas AMD TAMM «ITH ON-HTI cNtitiCAL FIXATION Of IDIL AND ON-MTI
-------
-22-
- Flammable contents (flash point below 60°C)
- PCB contamination
- pH 2.0 and below or 12.0 and higher
- Asbestos insulation of the tank
Liquid hazardous wastes would be pumped from the tanks and
transferred for off-site treatment such as incineration.
Non-hazardous waste materials would be transferred off-
site for treatment at an industrial wastewater treatment
plant with the appropriate permits. All tanks would be
demolished. The tanks and rubble which are not contaminated
with hazardous waste would be transferred to a permitted
off-site sanitary landfill. Contaminated tanks and rub-
ble would be removed and transferred to an off-site RCRA
permitted landfill facility.
b. Buildings
Based upon limited analytical data, all thirteen buildings
on the site are considered contaminated. Seven buildings
were not sampled due to extensive visible signs of resin-
like encrustation on interior and exterior walls, floors
and' interior ancillary items. The Oil Building was not.
sampled as it was j.udged structurally uns.ound. The five
buildings sampled were contaminated at levels exceeding
the maximum acceptable soil concentrations for contaminants
as presented iri Table 10. These recommended cleanup
criteria were developed under the Environmental Cleanup
Responsibilities Act (ECRA).
All buildings would be demolished and the resulting rubble
and building contents would be disposed of in an off-site
RCRA landfill.
c. Soils and Sediments
To distinguish between contaminated and non-contaminated
soils, the cleanup criteria identified in Table 10 were
utilized. It was assumed these criteria would apply to
all soils and lagoon sediments on-site. Based on a
preliminary engineering judgment, approximately 50 per-
cent of the saturated soil, 100 percent of the lagoon
sediment, and 85 percent of the unsaturated soil at the
site above the clay layer is contaminated.
After removal of tanks and buildings, excavation activities
would begin. A sampling program would be implemented
concurrent with the excavation to determine the extent
of contamination. Non-contaminated soil would remain
-------
-23-
TABLE 10
CLEANUP CRITERIA FOR SOILS, BUILDING
DIRT/DUST, AND LAGOON SEDIMENTS
Contaminant
Total Volatile Organics
Metals
Chromium
Lead
.Mercury
Nickel
Zinc
Arsenic
Cadmium
Beryllium
PCBs
Benzo-a-pyrene
Base Neutrals (as a class)
Cleanup Criteria Concentration*
1 ppm
15 ppm
317 ppm
1 ppm
18 ppm
196 ppm-
20 ppm
3 ppm
Not Detected
5 ppm
10 ppm
100 ppm
*Criteria based on the State.of New Jersey Environmental Cleanup
Responsibilities Act (ECRA).
-------
-24-
on-site. Contaminated soil would be disposed of off-site
in a RCRA landfill. Contaminated water from saturated
soil dewatering would be collected and treated off-site
at an appropriately permitted facility. The site would
be restored by filling and grading with a storm runoff
drainage system.
d. . Monitoring
A long-term monitoring program for ground water would be
performed quarterly.
ALTERNATIVE 3 - DECONTAMINATE BUILDINGS AND TANKS, ON-SITE
INCINERATION AND ON-SITE SOIL WASHING
This alternative would provide on-site incineration for inciner-
able contaminated waste and on-site soil washing for uninciner-
able contaminated waste. Incineration uses high temperature
oxidation to degrade organic substances into products that gen-
erally include C02> H20, NOX and HC1 vapors, and ash. The un-
desirable products of the thermal destruction (e.g., particulates,
SC>2, NOX, HC1, and products of incomplete combustion) will be
removed by air pollution control equipment to prevent their re-
lease to the atmosphere. Contaminated materials containing high
metal concentrations may. not be suitable for incineration.. If
so, soil washing would be an alternative'on-site treatment method.
Soil washing processes would leach both organic and inorganic
contaminants from soils and the recovered wastewater. would be
treated by such processes as physical-chemical precipitation,
air stripping and activated carbon adsorption. The combination
of incineration and soil washing would provide complete on-site
treatment for the hazardous wastes and contaminated matrices
'identified at the site. This remedial alternative would provide
direct source control and would attain or exceed the applicable
and relevant Federal public health and environmental standards.
Upon completion of this alternative, the property would likely
be suitable for reuse.
a. Tanks
All waste from the tanks would be removed and segregated
into hazardous and non-hazardous groups. The hazardous
waste would be treated by on-site incineration and the
non-hazardous waste would be treated by the on-site waste-
water treatment facility. Tanks containing hazardous
material would be decontaminated, demolished, and disposed
of in an off-site sanitary landfill or as scrap metal.
Tanks containing non-hazardous material would not be
decontaminated but would be disposed of in an off-site
sanitary landfill or sold as scrap.
An estimated seven of the 47 insulated tanks utilize an
asbestos material. The asbestos insula,tion would be
\
-------
-25-
removed and disposed in an off-site RCRA landfill. In-
sulation from the remaining forty tanks will be tested,
removed, and disposed in an off-site sanitary landfill.
It is proposed to decontaminate the tanks through repeated
hydro-blasting and water-washing. The first application
would- involve the application of high pressure water. The
second pass, if required, would involve the application
of a water detergent rinse, while the final pass would
involve the application of a water rinse. Liquid and
solid wastes from the decontamination would be handled in
the wastewater treatment system.
All above-ground pipes, conduit racks, tank dikes, and
revetments would be considered contaminated and be trans-
ferred to an off-site RCRA storage facility.
b. Buildings
Each building, with the exception of the Oil Building,
would be decontaminated, after which all buildings would
be demolished. Decontamination would first involve vacu-
uming and wiping. For those areas requiring additional
decontamination, grit blasting would be utilized. Con-
taminated waste generated during .building decontamination
would be treated on-site using incineration and/or the
wastewater treatment system. Demolition rubble from
the decontaminated buildings would be disposed of in an
off-site sanitary landfill. Oil Building rubble and
building contents would be disposed of separately in an
off-site RCRA landfill.
c. Soils and Sediments
As described in Alternative 2, contaminated soil would be
excavated as indicated by the sampling results. Nearly
all of the contaminated soil would be treated on-site by
soil washing. Highly contaminated soil and sediments
would be dewatered and incinerated on-site. After treat-
ment, the decontaminated soil would be re-deposited on-site
with additional clean soil.
d. Monitoring
A long-term ground water monitoring program would be
performed quarterly.
ALTERNATIVE 4a. - DECONTAMINATE BUILDINGS AND TANKS, IMPERMEABLE
CAP, AND LEACHATE AND GROUND WATER CONTROL
This.alternative would provide for the decontamination of tanks
and buildings, collection and on-site treatment of leachate and
-------
-26-
contaminated ground water, and partial capping of the site. The
leachate/ground water control system is intended to prevent the
discharge of contaminants to the Passaic River. The on-site
ground water treatment system would utilize physical-chemical
precipitation, air stripping and activated carbon adsorption,
and would discharge to the Passaic River. Thirteen of the
fifteen acres affected (excluding structure footprints) would
be provided with a clay/ soil cover to reduce surface runoff
and rainfall infiltration. The cover would consist of one foot
of clay and one foot of topsoil, which would be graded. This
remedial alternative would attain the applicable and relevant
Federal public health and environmental standards. However,
this alternative would not allow future reuse of the property.
a. Tanks
All hazardous waste from the tanks would be removed and
transferred off-site for appropriate disposal, as discussed
in Alternative 2. Non-hazardous tank liquids would be
treated on-site in the ground water treatment system. The
empty tanks would be decontaminated and would be left on-
site. Wastewater from tank decontamination would also be
treated on-site in the leachate/ground water treatment
system. All above-ground.pipes, conduit racks, and insula-
tion would be classified as hazardous or.non-hazardous and
disposed of accordingly.. .
b. Buildings
All buildings, except the Oil Building, would be decontami-
nated as described in Alternative 3. The Oil Building
would be demolished and disposed of in an off-site RCRA
landfill along with the contaminated contents from the
other buildings.
c. Soils and Sediments
A downgradient subsurface drain system (Figure 3) would
be installed along the edge of the Passaic River and along
portions of the northern and southern property line.
This drain system would be approximately 1,000 feet in
length including a subsurface concrete barrier. The
purpose of this drain system would be to collect leachate
and contaminated ground water for treatment. The purpose
of the concrete wall is to prevent tidal intrusion of
river water onto the site. The collected wastewater
would be treated on-site.
d. Monitoring
A long-term ground water monitoring program would be
implemented and would include quarterly sampling.
-------
-27-
ALTERNATIVE %\
SUBSURFACE AND SURFACE DRAINAGE SYSTEMS
AND SURFACE COVER
-1*" TOfSOIL
2%
EXISTING
SOIL
Lv" / J*^\-'.-
y
\t
i't:
1 K*
l<9
III
^
Ul
oc
u
2
8
. IVCLAV ...\r.Wis
lr -^
, 3-
GRAVEL
(OR
CRUSHED
STONE)
h°£
i,ij
^^^
EXISTING
1(T CONTAMINATED
SOIL
f A fur PERFORATE!
^^^^ V ^ w w w » fc nn*ci^ t ^4
-*-"^ PIPE
':. .";»"" "'-\.';>''^'
>.{%: x-::-/-
V..~ . EXISTING CLAY LAYER >;
! *'
FIGURE 3
-------
-28-
ALTERNATIVE 4b. -DECONTAMINATE BUILDINGS AND TANKS, PERMEABLE CAP,
PASSIVE FLUSHING, AND LEACHATE AND GROUNDWATER
TREATMENT
Alternative 4b was developed to evaluate enhanced flushing to
cleanse the-saturated and unsaturated soils, and to remove the
more significant soil contamination from the site. The goal of
Alternative 4b is to result in a site that could be considered
for future reuse and that would attain all applicable and
relevant State requirements for that reuse (i.e. ECRA, ground
water quality). The major differences between Alternative 4a
and Alternative 4b consist of substituting a crushed stone
cover over the open areas of the site instead of the soil/clay
cap, and excavation of approximately 700 cubic yards (cy) of
sediment and soils beneath the two lagoons. To better prepare
the site for future application of in-situ technologies, approxi-
mately 2,000 cy of highly contaminated soils around the site
will be excavated. This alternative is an operable unit.
Future studies will be undertaken to evaluate further enhancement
of the site cleanup to attain this alternative's goal.
0 Tanks, Vessels, and Buildings
The existing above-ground structures, including .buildings,
t-anks, and storage vessels, would be decontaminated as
appropriate. The Oil Building would be demolished and
disposed of in an off-site RCRA landfill. Hazardous wastes
will be removed and transferred off-s.ite for appropriate
disposal, as discussed in Alternative 2. All non-hazardous
aqueous wastes will be treated in an on-site treatment
system. Non-hazardous solids will be disposed of at a
sanitary landfill.
8 Soils and Lagoon Sediments
Lagoon sediments and highly contaminated surface soils will
be removed and transferred off-site for disposal or treatment
at an approved hazardous waste treatment, storage, or
disposal (TSD) facility. The surface of the site will then
be covered with gravel or crushed stone to enhance natural
flushing of underlying contaminants. The contaminated
ground water would be collected and treated on-site.
0 Ground Water
A containment system consisting of a cut-off wall ano a con-
crete retaining wall will be constructed partially around
the site and adjacent to the river. Both walls will be keyed
into the underlying clay layer to prevent river water from
entering the site and contaminants from migrating off-site.
A trench drain system will collect contaminated ground water.
An on-site wastewater treatment system will treatr collected
. surface and.ground water and discharge the treated effluent
' ; to the Passa'ic River. ' ' '' ' :
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-29-
New Technologies
After installation of the on-site systems described above,
a variety of technologies will be investigated to further
enhance the natural flushing action, so as to attain the
goal of" potential future reuse of the site. The technologies
to be evaluated include active flushing with or without
additives, in-situ biological treatment, and in-situ vitri-
fication.
Monitoring
A long-term monitoring program will be implemented after the
completion of remedial action to protect public health and
the environment. The effectiveness of the site remedy will
be evaluated throughout the planned action and potential
future modifications.
ALTERNATIVE 5 - REMOVE BUILDINGS AND TANKS, AND SITE ENCAPSULATION
This alternative would remove all tanks and buildings to appro-
priate off-site hazardous and sanitary waste disposal facilities
and encapsulate the entire site. Encapsulation would separate
the contaminants from the' surrounding hydrogeolog'ic regime and
would prevent further migration of contaminants off-site. The
lateral barrier wall would be keyed into the clay layer beneath
the site to provide an effective bottom barrier. Lateral bar-
rier walls may consist of a slurry wall, grout curtains, or
steel sheet piling. The materials selected for use in barrier
construction should withstand any chemical attack by the contained
contaminants. This remedial alternative would attain the applicable
and relevant Federal public health and environmental standards.
However, the site would be restricted from any potential future
reuse.
a. Tanks
All waste from tanks would be removed and transferred for
appropriate off-site disposal as discussed in Alternative
2. Tanks having hazardous residues would be decontaminated
and demolished as described in Alternative 3. The decon-
taminated, demolished tanks would be disposed of in an
off-site sanitary landfill or sold as scrap. Tanks con-
taining non-hazardous wastes would not be decontaminated
but would be demolished and disposed of in an off-site
sanitary landfill or sold as scrap.
b. Buildings
All thirteen buildings located on the site would be
considered contaminated and would be demolished. Service
-------
-30- i
facilities/ including ductwork, process piping, and unit
heaters, would also be considered contaminated and would
be demolished. The resulting rubble and debris would be
disposed of in an off-site RCRA landfill.
c. Soil and Sediments
To contain the remaining contaminated soils and ground
water, the entire site would be enclosed with an imperme-
able perimeter barrier wall keyed into the underlying
impermeable 'clay layer. A parallel concrete barrier would
be installed adjacent to the impermeable barrier along
the Passaic River to furnish protection from tidal action.
The site would then be covered with a RCRA cap (Figure
4). These measures would effectively encapsulate the
contaminated soil and ground water remaining on the site.
d. Monitoring
A long-term ground water monitoring program would be
performed quarterly.
ALTERNATIVE 6 - REMOVE BUILDING AND TANKS', ON-SITE. CHEMICAL
FIXATION OF SOIL, AND ON-SITE RCRA LANDFILL
This alternative would remove hazardous tanks and contaminated
buildings and transfer them to an on-site RCRA landfill facility.
Liquid hazardous waste from the tanks would be transferred off-
site for treatment. In addition, contaminated soil would be
removed, mixed with chemical additives for waste fixation, and
used as part of the containment system. Since the contaminated
soils on-site contain an average of less than one-tenth of a
percent of organic contaminants, chemical fixation which limits
the mobility of chemical constituents is feasible.
As shown in Figure 5, the on-site RCRA landfill will be isolated
by the solidified soil above and around its perimeter, and by a
double 40 mil synthetic liner and the existing clay layer below.
A leachate collection system and leak detection system will be
installed during construction of the landfill. This remedial
alternative would attain the applicable and relevant Federal
public health and environmental standards. However, future site
use would be restricted.
a. Tanks
The wastes removed from the tanks would be disposed of in
an off-site treatment facility as described in Alternative 2
The empty hazardous tanks would be demolished and disposed
-------
-31-
ALTERNATIVE 5
RCRA CAPPING SYSTEM
.VTOfSOIL
. V SAND DRAINAGE LAYER
40 MIL
SYNTHETIC LINER
T CLAY LAYER
(PERMEABILITY 1
-------
-32-
ALTERNATIVE 6
RCRA LANDFILL PROFILE
SOLIOIflED
SOIL
»
T
r
TOfSOIL
SAND
SOLIDIFIED SOIL
SOLID WASTE
SAND
SAND
40 MIL
SYNTHETIC
LINER
EXISTING CLAY LAYER
W
\ 6"f
PVC LEACNATE COLLECTION PIPE
4* PVC LEAK DETECTION PIPE
FIGURE 5
-------
-33-
of in the on-site RCRA landfill. The empty non-hazardous
tanks would be demolished and disposed of off-site in a
sanitary landfill.
b. Buildings
The buildings would not be decontaminated but demolished
and disposed of in the on-site .RCRA landfill. It is
estimated that approximately two acres would be required
for the disposal of the demolished buildings and tanks.
c. Soil and Sediments
All soil above the clay layer, including the lagoon sed-
iments, would be excavated and treated on-site by chemical
fixation. The soil would be blended with a chemical
binder such as lime or sodium silicate, and Portland
cement. The blended soil would be deposited and cured in
place. Chemical fixation is expected to minimize leachate
generation. The site would then be restored by regrading
to accommodate storm water runoff.
d. Monitoring
A long-term ground water monitoring program would be
performed quarterly.
EVALUATION OF ALTERNATIVES
To ensure that the remedial objectives for the protection of
public health and the environment are fulfilled, the alternatives
developed were evaluated in terms of technical, environmental,
public health, and cost-effectiveness, as well as for their
institutional requirements which include the appropriate and
relevant State and Federal environmental regulations.
The no action alternative does not remove or reduce contaminant
levels, on-site. Therefore, the risks and exposure pathways,
which include direct contact, ingestion, and inhalation, are
not mitigated. In the absence of contaminant removal from the
unsaturated and saturated zones, the potential remains for
further contamination of the shallow aquifer and the Passaic
River. Tank leakage may also contaminate the soil and ground
water. This alternative, while minimizing access, maintains
the negative environmental and public health impacts and so is
unacceptable. In addition, this alternative requires that the
site is restricted from any future use because of its associated
health risk.
-------
-34-
Alternative 2 involves the removal of all above-ground structures
and contents and contaminated soils for off-site disposal. While
eliminating the long-term health risks, the construction activi-
ties may result in a short-term exposure to contamination through
direct contact and airborne particulate dispersion. Construction-
related imp'acts may be minimized by implementing an effective
health and safety plan, a dust control and traffic control plan,
and a soil erosion and sediment control plan. This alternative
eliminates any site-related contaminant contributions to the
shallow aquifer or to the river. Restoration of the site by
replacing the contaminated soil with clean soil increases the
potential for future reuse.
Alternative 3 results in the removal of contaminated materials
from the site via on-site treatment of major waste streams and
off-site disposal of some contaminated materials at a RCRA
landfill. The benefits include eventual elimination of exposure
pathways and reduction of contamination of the ground water and
the Passaic River. The potential negative impacts of this
alternative involve: air emissions from the incineration oper-
ation; direct contact, inhalation, and ingestion of contaminated
materials during handling and treatment; and spillage of contam-
inated soil into the river via erosion or mishandling. Measures
can be -taken to minimize these negative impacts, including .
implementation of an air emissions control plan, an effective
health and safety plan, and an soil erosion and sediment control
plan. Overall, this alternative produces positive environmental
and public health impacts and increases the potential for
future site reuse.
Alternative 4a involves off-site disposal of hazardous materials,
decontamination of tanks and buildings, installation of a clay/
soil surface cover and concrete barrier, natural flushing of
the saturated soils, and ground water/leachate collection and
on-site treatment. The benefits of this alternative include
minimizing the direct contact exposure pathway of the unsaturated
soils via capping, removal of contamination from buildings and
tanks, minimizing construction-related impacts by reducing on-
site activities, and a gradual reduction in ground water contam-
ination over the long term. The negative environmental and
public health impacts of this alternative include an incomplete
sealing of the surface due to the presence of tanks and buildings,
and the long-term operation of the ground water/leachate collection
and treatment system. . Contaminated, unsaturated soils will
remain on-site essentially untreated, minimizing the potential
for reuse of the site.
Alternative 4b includes off-site disposal of hazardous materials,
decontamination of tanks and buildings, removal and off-site
disposal of the contaminated sediments and soils beneath and
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adjacent to the two lagoons and other "hot spots", a containment
system, a permeable cover, passive flushing, and on-site treatment
of the leachate/ground water. The benefits of this alternative
include minimizing the direct contact exposure pathway of the
unsaturated soils, removal of the contamination from buildings and
tanks, and "minimizing construction-related impacts. The major
advantages of this alternative over Alternative 4a is the removal
of the more grossly contaminated soils and the promotion of natural
flushing, which would result in a more significant reduction of
contamination in the ground water and both the saturated and
unsaturated soils. The negative environmental and public health
impacts of this alternative include the long-term operation of the
natural flushing and ground water treatment processes. Future
studies will be undertaken to further enhance and accelerate the
the cleansing of the site. The implementation of the remedial
actions under this alternative and any subsequent remedial action
will increase the potential for future reuse of the site.
Alternative 5 involves total site encapsulation after buildings,
tanks, dikes, revetments, tank contents, conduits, ductwork, etc.
have been disposed of off-site. Under this alternative, the
exposure pathways of ingestion, direct contact and inhalation are
eliminated, along with site-related contamination of the river.
Encapsulation of. the site reduces -the amount of excavation re-
quired, thereby reducing construction-related'exposure. This
alternative, however, only contains the contaminated soil and
ground water and does not treat them. Under this alternative,
the potential for site reuse is minimal. In addition, encapsul-
ating the site will affect the ground water flow pattern, which
would have a positive health impact and a negative environmental
impact.
Alternative 6 involves off-site disposal or treatment of hazardous
tank contents, chemical fixation of the unsaturated and saturated
soil, and disposal of building rubble, tanks, pipes, .ductwork,
conduits, and other related materials in an on-site RCRA landfill.
While this alternative reduces the exposure pathways of direct
contact, ingestion, and inhalation, it does not eliminate them.
Securing contaminated materials in the on-site RCRA landfill
reduces the potential for site reuse. Chemical fixation reduces
the permeability of the soils and hence reduces contaminant
migration and leachate generation. Construction activities
would temporarily increase exposure by direct contact, ingestion,
and inhalation. These impacts, however, can be minimized"by
the implementation of an effective health and safety plan. In
addition, hydrogeologic patterns would change due to the reduced
permeability, thus producing a positive health impact and a
negative environmental impact.
COMMUNITY RELATIONS
A public meeting was held on September 4, 1986 to present the
results ^f the remedial investigation and feasibility study
(RI/FS) and the recommended alternative. Copies of the FS
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report were distributed to the public on August 21 but it did
not include Alternative 4b per se. However, most of the com-
ponents which make up this alternative are discussed in the
description of Alternative 4a. The modifications to Alternative
4a which produced Alternative 4b, as well as Alternative 4b in
toto, were fully explained at the public meeting. In addition, a
handout describing Alternative 4b was distributed at that time.
No objections to it were raised at the meeting. The public
comment period was open until September 11. Responses to all
comments raised at the public meeting and in a subsequent
letter are included in the Responsiveness Summary (Attachment
1).
RECOMMENDED ALTERNATIVE
In the RI/FS, the six alternatives were evaluated in terms of
technical, environmental, and public health effectiveness and
institutional requirements, and a matrix was developed to compare
the environmental advantages against costs (Table 11). Alterna-
tive 4 (or Alternative 4a, as now designated) was determined to
be the most cost-effective. In further evaluating this alternative,
it was felt that the modifications which eventually led to the
development of Alternative 4b may achieve an even more cost-
effective, environment-all^ sound alternative. . .. '
The most important of these modifications is the substitution of
a crushed stone cover over the open areas of the site instead of
the soil/clay cap. This permeable cap would have numerous
benefits. It effectively eliminates the public health risk due
to direct contact or ingestion of surface soils, yet allows
rainwater to flush through the unsaturated and saturated soils
to hasten the remediation of the contaminated soils and ground
water. It also provides flexibility by providing a good working
surface for trucks or heavy equipment, while allowing easy
access to the surface, if needed, for subsequent monitoring or
the application of new technologies.
Another significant modification involves the excavation and
removal of approximately 700 cubic yards of sediment and highly
contaminated soils that lie beneath or adjacent to the two
lagoons. Finally, approximately 2,000 cubic yards of highly
contaminated surface soils will be removed for off-site disposal.
The removal of these soils are cost-effective in that they
reduce the volume of contaminants to be handled under in-situ
treatment methods.
If the design is optimized to its full potential and properly
implemented, the passive flushing technique may in itself
restore the site to the appropriate cleanup levels. However,
innovative technologies will be evaluated to further enhance
the ability of flushing to cleanse the soil of contaminants.
Although the costs of any future remedial actions cannot now be
accurately estimated, it is believed that the added costs
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TABLE 11
OVERALL COST-EFFECTIVENESS RATING OF ALTERNATIVES
COST TOTAL COST- OVERALL COST-
REMEDIAL EFFECTIVENESS TECHNICAL ENVIRONMENTAL fUllIC HEALTH INSTITUTIONAL TOTAL EFFECTIVENESS EFFECTIVENESS
ALTERNATIVE (PRESENT WORTH) EFFECTIVENESS EFFECTIVENESS EFFECTIVENESS REQUIREMENTS EFFECTIVENESS RATING RANKING
1
2
3
4
5
6
(1)
S
1
3
5
4
3
(2)
4
3
2
4
4
3
(3)
1
5
4
3
3
4
(4) (5)
1 1
5 5
3.5
2 3
3 4
4 5
(e> (7)
<2M3h(«MSM« (1) M (i)
7 35 4
18 18 5
14 42 3
12 60 1
14 56 2
14 42 3
REMEDIAL ALTERNATIVES
ALT. 1 -
ALT. 2 -
ALT. 3 -
ALT. 4 -
NO ACTION
REMOVE BUILDINGS. TANKS AND SOIL AND OFF-SITE DISPOSAL
DECONTAMINATE BUILDINGS AND
AND ON-SITE SOIL WASHING
DECONTAMINATE BUILDINGS AND
GROUND WATER CONTROL
TANKS. ON-SITE INCINERATION.
TANKS. AND LEACH ATE AND ~
LEGEND
EFFECTIVENESS RANKING
ALT. 6 - REMOVE BUILDINGS AND TANKS. AND SITE ENCAPSULATION
ALT. 0 - REMOVE BUILDINGS AND TANKS, ON SITE CHEMICAL
FIXATION OF SOIL. AND ON-SITE RCRA LANDFILL.
1 - LOWEST RATING
5 - HIGHEST RATING
1 - HIGHEST RANKING
5 - LOWEST RANKING
OJ
~J
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(see footnote on Table 8) would still make this remedial alter-
native cost-effective in comparison to the others. Should none
of the methods evaluated under Alternative 4b be successful in
attaining the applicable cleanup levels, the site would still
be nearer to these levels than under any other alternative,
except total excavation and removal of contaminated material
which is prohibitively expensive.
Therefore, Alternative 4b was selected as the recommended alterna-
tive and includes the following components:
0 Tanks, Vessels, and Buildings
The existing above-ground structures, including buildings,
tanks, and process vessels, will be decontaminated, as
appropriate. The Oil Building would be demolished and
disposed of in an off-site RCRA landfill. Hazardous wastes
will be removed off-site to an approved hazardous waste
treatment, storage, or disposal (TSD) facility. All non-
hazardous aqueous wastes will be treated in an on-site
wasteater treatment system. Non-hazardous solids will be
disposed of at a sanitary landfill.
0 Soils and Lagoon Sediments . '
Lagoon sediments and highly contaminated soils will be
removed and 'transported to an approved hazardous waste TSD
facility. The surface of the site will then be covered
with gravel or crushed stone to enhance natural flushing of
underlying contaminants in the soil and ground water,
before collection and treatment.
0 Ground Water
A containment system consisting of a cut-off wall and a con-
crete retaining wall will be constructed partially around the
site and adjacent to the river. Both walls will be keyed
into the underlying clay layer to prevent river water from
entering the site and contaminants from migrating off-site.
A down-gradient drain system will collect contaminated
ground water. An on-site wastewater treatment system will
treat collected surface and ground water and discharge the
treated effluent to the Passaic River.
0 New Technologies
After installation of the on-site systems described above,
a variety of technologies will be investigated to further
enhance the natural flushing action. The technologies
which would be evaluated include active flushing with or
without additives, in-situ biological treatment, in-situ
vitrification, etc.
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0 Monitoring
A long-term monitoring program will be implemented after the
completion of remedial action to protect public health and
the environment. The effectiveness of the site remedy will
be evaluated throughout the planned action and any potential
future modifications.
OPERABLE UNITS
The recommended alternative will be the first operable unit for
this site. Depending on the results of the study to enhance
the natural flushing process, a future operable unit may implement
the study findings.
COMPLIANCE WITH OTHER ENVIRONMENTAL LAWS AND REQUIREMENTS
The recommended alternative, as envisioned, would be in full
compliance with all applicable existing environmental statutes,
save the exceptions discussed below.
Resource Conservation and Recovery Act (RCRA) Cap, 40 CFR PART 264
While the implementation of the recommended alternative will
" not meet the -RCRA closure requirements for a RCRA Subtitle C
cap, this alternative is the first operable unit and not the
final remedy.
The recommended alternative includes a permeable layer at the
surface. This permeable layer would be installed to enhance
natural flushing, which will cleanse the site of contaminants.
Meanwhile, this type of protective cover will prevent direct
contact exposure.
Future studies will evaluate technologies to further enhance and
accelerate natural flushing under Alternative 4b. The goal of
Alternative 4b and future actions will be to attain cleanup
criteria so as to result in a site that could be considered for
reuse. Should these criteria not be met, the need to close the
site under RCRA will be re-evaluated.
OPERATION AND MAINTENANCE
All the remedial components of the recommended alternative re-
quire operation and maintenance (O&M) to varying degrees. The
wastewater treatment facility, the surface cover, and the
collection system must be operated and maintained. The buildings
and tanks must be periodically inspected. O&M will also include
long-term monitoring. The monitoring program will include sampl-
ing of ground water, air, and treated effluent prior to discharge
to the Passaic River. The total annual O&M cost for this
program is estimated to be $209,000.
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Responsiveness Summary
for the
Completion of the Remedial Investigation/Feasibility Study
at the
Syncon Resins site
Kearny
Hudson County
New Jersey
This Community Relations Responsiveness Summary, prepared as part of the Record
of Decision (ROD), is divided into the following sections:
I. Background on Community Involvement and Concerns
This is a brief history of community interest concerning the Syncon Resins
site and a summary of community relations activities conducted by the New
Jersey Department of Environmental Protection (NJDEP) and the United States
Environmental Protection Agency (USEPA) prior to and during the Remedial
Investigation/Feasibility Study (RI/FS).
II. Summary of Major Questions and Comments Received During the Public Comment
Period and NJDEP's Responses
This is a summary of major questions and comments directed to NJDEP during
the September 4, .1986 public meeting .regarding the results of the
Feasibility Study and' sent to NJDEP during the public comment period.
NJDEP's responses are included in this section.
III. Remaining Concerns
This is a discussion of remaining community concerns of which NJDEP and
USEFA should be aware in conducting the remedial design and remedial actions
at the Syncon Resins site.
Attachments
Attachment A
Attendance sheet and Information Package distributed at the February 21, 1984
Public Meeting.
Attachment B
Attendance sheet and Information Package distributed at the April 25, 1985 Public
Meeting.
Attachment C
Attendance sheet and Information Package distributed at the September 4, 1986
Public Meeting.
Attachment D
Copy .of the letter received by NJDEP during the public comment period..
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I. Background on Community Involvement and Concerns
Concern focusing on the Syncon Resins site prior to the RI/FS began in 1976
after the NJDEP uncovered violations of the Clean Water Act at this
facility. -Media attention was generated and a group called the Kearny
Environmental Committee of Concerned Citizens was established. At this
time, this group focused attention on the presence and hazards of chemical
wastes in Kearny. They were concerned that their community might serve as a
waste storage center for the entire region. On September 30, 1981 the NJDEP
provided Kearny citizens an opportunity to comment on the development of a
new site for a hazardous waste storage and transportation operation. After
reviewing public comment, the NJDEP did not approve plans for development of
this operation.
On December 20, 1982 the USEPA issued a press release noting that funds had
been allocated for cleanup work at two New Jersey hazardous waste sites.
One of those was the Syncon Resins site and a brief description of the
problems at the site was included. In particular, it was stated that $2
million would be spent to remove approximately 10,000 drums on site.
On September 9, 1983 a Community Relations Plan (CRP) was completed for this
site. In January 1984 the NJDEP attempted to locate additional citizens and
citizen groups interested in the Syncon Resins site. Mayor Henry Hill
responded and completed our Community Relations Response Form, supplying
numerous names to compliment our CRP contact list. .
/
Prior to the initiation of the Initial Remedial Measure (IRM) for the drum
removal at this site, a series of meetings and briefing sessions were held.
On February 10, 1984 a briefing to keep Kearny officials informed as to the
status of the Syncon Resins cleanup was held. The project was outlined and
town officials Inquired and were informed about contingency plans, waste
transportation routes and material handling. All questions were answered
directly or commitments were made by NJDEP to provide answers. A short
discussion followed concerning the upcoming public meeting scheduled for
February 21, 1984.
The public meeting on the removal of waste storage drums from the Syncon
Resins Hazardous Waste site was held on February 21, 1984. Notification of
the meeting was accomplished through press releases and a direct mailing of
notices to municipal, county, state and federal officials, as well as to all
concerned citizens and citizen groups. Approximately 20 people attended the
meeting and agendas and information packages were distributed. (See
Attachment A.) Major issues and concerns raised during the meeting and
responses given included:
Question: Who will remove waste and do the soil tests?
Response: The drum disposal will be handled by three contractors: Applied
Technology, AETC, Inc. and S & W Waste. Soil conditions will be
addressed in a subsequent RI/FS.
Question: Will sites neighboring [Syncon] be regulated?
Response: The Hazardous Site Mitigation Administration does not regulate these
facilities but other units within the NJDEP do. I
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Question: What will happen to the Syncon property after the cleanup?
Response: At this time we cannot answer specifically since the site is in
litigation as to ownership.
On February 24, -1984 the NJDEP held a press briefing at the Syncon site to
explain procedures that will be used during the cleanup project. . The Kearny
Health officer was quoted in a Star Ledger article of February 25, 1984 saying,
"We're pleased with the setup of the safety feature of the whole project."
A press release was issued by the NJDEP on September 12, . 1984 announcing
completion of the IRM. A total of 12,824 drums were removed, at a cost of $2
million dollars with federal Superfund paying 90% and the state Spill Fund paying
10%. (Actual cleanup cost amounted to $2.4 million dollars.)
Throughout the IRM, the NJDEP received numerous requests for information
concerning progress of the clean-up. Responses were given both verbally over the
telephone or in writing by the NJDEP, Bureau of Community Relations. In
addition, the NJDEP sent out an early meeting notice in May 1984 to advise
concerned citizens that we were planning to schedule a public meeting to discuss
the initiation of the RI/FS; the specific date and location to be announced in a
subsequent notice. This correspondence also emphasized stages in the remedial
process in which NJDEP solicits the benefit of public comment before site
decisions.are made. .
' »
On April 25,' 1985 the NJDEP held a public meeting to discuss 'the initiation'of
the RI/FS at this site. Notification of the meeting was accomplished through
press releases and direct mailing of notices to municipal, county, state and
federal officials as well as concerned citizens and citizen groups.
Approximately 11 people attended the meeting and each received an agenda, fact
sheet and an overview of the community relations program. (See Attachment B.)
Issues and concerns raised during the meeting and responses given included:
Question: What do you plan to do with the tanks?
Response: It is premature to say at this time but there are several possible
options. 1) If tanks can be sufficiently decontaminated then they may
remain on-site. 2) If the tanks can't be sufficiently decontaminated
then they may have to be cut up and disposed of as hazardous waste. 3)
As an additional but very expensive alternative, it may be possible to
remove whole tanks.
Question: Do you know the depth of soil contamination?
Response: That will be determined in the RI/FS~.
Comment: It seems like you should dike and put an impervious cover over the
site.
Response: That may be an option. It would be premature to make that decision
before completing the study. There will be another public meeting at
the end of the RI/FS when decisions begin to be made. That is really
the most important meeting in 'this process. Meanwhile, if you have
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questions after this meeting you can contact the Bureau of Community
Relations (NJDEP).
Question: Do you have any idea how far the plume has gone through the aquifer?
Kearny has six square miles of contaminated aquifer (the largest in the
world!)-.
Response: That will be determined in the RI/FS.
Question: Do you see any evidence of low grade toxicity in your workers?
Response: No. We do have a stringent medical surveillance program to monitor our
workers' health.
II. Summary of Major Questions and Comments Received During the Public Comment
Period and NJDEP's Responses
On August 21,1986 the RI/FS was placed in the following repositories for
public review: Kearny Town Hall, Kearny Public Library, Hudson County Law
Library in Jersey City and the NJDEP, Division of Hazardous Site Mitigation
in Trenton. The NJDEP issued a press release and contacted local officials,
as well as interested citizen groups regarding the availability of the RI/FS
at these repositories.
On September 4.,_ 1986 the NJDEP held a public meeting to present, the results
of and to receive comments/questions regarding the RI/FS. Notification of
this meeting was also accomplished through press releases and direct mailing
of notices to municipal, county, state and federal officials, as well as to
concerned citizens and citizen groups. Approximately 25 people attended
this meeting and each received an agenda, fact sheet, an overview of the
community relations program and steps in a major hazardous waste site
cleanup. (See Attachment C.) Responses to questions and comments, for the
most part, were stated at the meeting. The public comment period was held
from August 21, 1986 through September 11, 1986. In addition to the
comments made during the public meeting, one letter was received by the
NJDEP during this period. (See Attachment D.) This written comment is
included in this section.
During the public meeting, Mr. Thomas Granger, Manager of Projects of Ebasco
Services, Inc. presented six remedial alternatives for long-term site
remediation. These are:
0 Minimal action.
0 Removal of buildings, tanks and soil for off-site disposal.
0 Removal of buildings* and tanks, on-site incineration and on-site
soil washing.
0 Decontamination of buildings and tanks and leachate and ground water
control.
0 Removal of buildings* and tanks and site encapsulation.
0 Removal of buildings and tanks, on-site chemical fixation of soil and
construction of an on-site RCRA Landfill.
*Buildings and/or tanks are decontaminated prior to removal as solid
non-hazardous waste to a sanitary landfill.
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Mr. Richard Salkie, P.E., Acting Director of NJDEP's Division of Hazardous Site
Mitigation, then discussed NJDEP's recommended alternative which is primarily a
composite of various components of the alternatives (modified alternative /i*4)
previously mentioned. This includes decontamination of tanks, vessels and
buildings, excavation plus off-site disposal of lagoon sediments, site covering
with crushed stone, installation of a dowrgradient collection trench to collect
water to be treated on-site and discharged to the Passaic River, a continuous
30-year monitoring program, improvement of site access and fence conditions and
additional studies to evaluate a variety of technologies to enhance natural
flushing/treatment/destruction of contaminants. Comments and questions were then
received from the audience. In addition to Director Salkie, and Mr. Granger,
other representatives of NJDEP were present and responded to questions relevant
to areas of their expertise.
In general, the tone of the comments at the public meeting and of those received
during the public nnnent period was very positive. Several individuals,
including Kearny Mayor Henry J. Hill and New Jersey Assemblyman Charles Catrillo,
expressed appreciation for NJDEP's presentation. Margaret Halloway, President of
the Kearny Environmental Committee of Concerned Citizens, expressed support with
some reservation for a remedy to the contamination. There were, however, some
areas of concern. These are summarized by subject as follows:
8 Movement and Extent of Contamination.
0 Costs of Alternatives. . .
0 Siting of an. Incinerator in Kearny for this Site or Other Uses.
0 Site Security-Past, Present, and Future.
0 Future Use of the Site.
0 Other Issues
Movement and Extent of Contamination
Question: What is the amount of contamination (poison) allowed into the water?
Is the contamination still discharging into the Passaic River?
Response: The surface water criteria is set forth in the NJDEP Effluent
Limitations for Discharge into the Passaic River (NJAC 7:9-5) and the
ground water criteria is based on the GW3 class aquifer (NJAC 7:9-6).
Presently, the contaminated ground water is discharging into the
surface water (Passaic River) through normal aquifer movement. NJDEP
proposes to construct a concrete wall to contain the movement of the
contaminated water and control river tide. Then the contaminated water
will be treated on-site to meet the required standards prior to release
into the Passaic River.
Question: What do the measurements in the RI/FS regarding mercury, and other
contaminants mean? What measurement is used to evaluate each
contaminant? What does the measurement ND-1400 mean?
Response: The levels of contaminants indicate the amounts that existed on the
site at the time of the sampling. The measurements of each contaminant
are in parts per billion (ppb) within the saturated soil. The ND-1400
means that levels of the contaminants were found within the range of
not detectable to 1400 ppb.
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Question: I am curious how such highly toxic poisons as mercury, cyanide, lead
and arsenic were used in a paint factory? Are these materials normally
associated with paint production?
Response: It was found that the contamination on site, in fact, did relate very
well with the processes conducted at Syncon Resins. Mercury, cyanide,
lead and araenic are part of the catalysts utilized in the resins
manufacturing process, reprocessing of resins, or varnish
manufacturing. The other contaminants (i.e., pesticides) were probably
brought on site for a specific use (pest control).
Question: To what location were the 12,000-plus drums removed?
drums disposed of in Kearny?
Were any of the
Response: The drums were removed to licensed hazardous waste facilities within
New Jersey and out of state. None of the drums were disposed of in
Kearny.
Question: How many feet below the surface is there evidence of definite
contamination?
Response: The contamination is found mainly in the first ten feet. A clay layer
: is found at that point under the surface, providing a barrier to
prevent further migration of the contaminants. In this area, the
groundwater is found about two feet below the ground's surface.
Question: Can you give an idea of how long it will take to remove the
contaminants found below the surface?
Response: The proposed alternative will take the water that passes through the
site and prevent it from leaving the site. The water will be collected
and treated on-site to meet relevant standards prior to discharge into
the Passaic River. The length of time required, by this method, to
remove the contaminants will be determined by treatability tests and
further identification and evaluation of various technologies.
Question: From the soil data in the report, it appears there are areas of heavy
contamination (hot spots). Do you plan to do additional
characterization of those sites to see if it is necessary to remove
contaminated soil removal?
Response: We will do additional characterization. Then we will make a
determination as to whether there will be some removal in specific hot
spots or whether all the highly contaminated areas will be removed.
That vill be evaluated during the conceptual design in terms of cost
effectiveness. Also, we will consider whether it is most cost
effective in achieving the objectives to run the treatment system with
natural flushing for a long period of time or just to remove the
contaminated soil at the beginning of the project.
Question: Will the characterization of contaminants be done prior to any work on
this site?
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Response: Following the signing of the ROD (Record of Decision) with EPA, we will
begin the development of the conceptual design. At that stage, further
characterization and the full evaluation of that area will be made.
There was a strong feeling among NJDEP staff that part of the
contaminated soil (hot spots) should be removed.
Question: Is the general intent to flush the contaminated soil rather than remove
it?
Response: The expectation is that some contaminated material will be removed.
Prior to full evaluation by the engineers, I cannot tell you how much
soil, what area of soil will be removed, or even guarantee that the
soil will be removed.
Question: A newspaper article mentioned that after the removal of the 12,000-plus
barrels that two barrels remained. We would like to know why you
forgot the two, since they were visible from the street and only ten
feet from the fence?
Response: As far as I can tell from the picture (with the article) and your
description, those barrels are full of the cuttings taken from the
ground during the soil borings. During the drilling
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Question: What will you spend to clean up the contamination caused by negligence?
Response: The expected capital cost of the recommended alternative is $8.3*
million. The total present worth cost, which includes all the
operating and maintenance costs for a 30 year period, will be $10.3*
million.
Question: Is the cost of the soil removal from the hot spots included in the
$8.3* million?
Response: Extensive soil removal costs are not part of the $8.3* million.
Question: Is the $2.6 million spent already on Syncon Resins part of the $8*
million clean up cost? (Actual total is $3.0 million already spent.)
Response: The $8 million is in addition to the $2.6 million already spent.
(Actual total is $3.0 million already spent.)
*Subsequent to the public meeting, cost estimates were recalculated and an error
was discovered. The correct capital cost is $5.6 million and the total present
worth cost including operations and maintenance for the 30-year period is $7.6
million.
Siting of an Incinerator in" Kearny for This Site, or Other Uses
Question: Your report mentions that you prefer to incinerate .some of the
contaminated material. Will the incinerator be located in Kearny?
Response: One of the considered alternatives did include on-site incineration,
but that was not selected. The contaminated materials will be removed
and sent to an existing, licensed incinerator, probably out of state.
There are no plans to construct an incinerator anyvhere for this waste.
The amount of material would not justify constructing an incinerator to
be used only for this site.
Comment: The Town of Kearny is concerned that an incinerator site will be
constructed in South Kearny to burn the contaminated materials from the
Syncon site.
Response: An incinerator field would fall within the jurisdiction of the
Hazardous Waste Siting Commission. A petition would have to be made to
the commission for a permit to site any hazardous waste incinerator or
facility. There are no known plans of such considerations for Kearny.
It is not the NJDEP or the USEPA preferred alternative to construct an
incinerator, and, presumably, it is not Kearny's preferred alternative.
Comment: I think our town should demand, in writing, that the NJDEP or USEPA
(whoever is in charge of the site) provide a legal guarantee that an
incinerator will not be placed in South Kearny under any circumstances.
Response: When the Record of Decision (ROD) is made with the final selected
alternative, it will be in writing. It will serve as a basis for the
, grant that EPA would .provide for the design and construction phases for
mitigation of the Syncon site. There are no plans, at this point in
time, to construct an incinerator to burn the waste materials.
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Site Security - Past. Present, and Future
Comment: Mr. Dewling in a written response to our letter stated that the Syncon
site was secure. Several individuals, including a reporter, went to
the Syrrcon site and were able to go between sections of the fence onto
the site. Children are riding their bicycles and walking around the
site due to a lack of security or proper fencing. You must have a
security guard.
Response: That will be taken back to Trenton and considered.
Comment: The newspaper article (mentioned earlier) about the site indicates the
failure of the fencing to secure the site. Due to the overall
inexpensiveness of new fencing compared to the total project, I would
think at least the fencing problem could be immediately resolved.
Response: We can look into that right away.
Question: Are you going to extend the fence into the water to prevent entry to
the site?
Response: The fence will go across the river bank at the site.
.Future Use of the Site ...'.-'
Comment*: We agree that the proposed alternative is the most feasible, but
strongly recommend alternative #2, which is the removal of buildings,
tanks and soil to an off-site waste disposal unit. Alternative #2,
while more expensive, would provide the most protection for health,
environment and the use of the land as a ratable for the Town of
Kearny.
* This is the only written comment received. (See Attachment D.)
Response: As you indicate, alternative //2 would provide the most complete health
and environmental protection by eliminating exposure pathways through
complete excavation and off-site disposal. This would lead to an
enhanced potential for site re-use in the shortest period of time.
Unfortunately, this option does not represent the most feasible and
cost-effective alternative for remediating conditions at this site.
Alternative #2 accounts for a massive expenditure of over $115,000,000
and the transportation to and from the site of over 300,000 cubic yards
of material. It would be an ideal solution if we had the resources and
off-site facilities to dispose of large amounts of contaminated
material in an environmentally acceptable manner. It is a common
situation at hazardous waste sites statewide that off-site cleanup
costs and the scarcity of off-site disposal facilities prohibit
selection of this type of alternative.
^r
Question: How many years will it take before the site will be usable as a
development area for other companies?
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-10-
Response: Monitoring will continue for 30 years on this site. We will return
after five years to reassess and evaluate the progress of the system in
operation. Following completion of the reassessment and evaluation, a
determination will be made regarding specific actions necessary for a
permanent solution.
Question: What influence will the pollution from the Syr.con Resins site have on
the surrounding area regarding the future development of that area?
Response: The flow of the ground water within the Syncon site is from the NE to
SW towards the Passaic River. The contamination tends to move from
various locations on the site directly towards the river. The
operation included in the recommended alternative would be within the
boundaries of the 15 acres of the site. As part of the alternative, a
barrier wall will be constructed from the ground surface into the clay
layer along part of the southern boundary, the entire river boundary,
and along part of the northern boundary to prevent ground water from
leaving the site or coming in. French drains will be constructed to
collect the water from the site for on-site treatment. Following
treatment of the water to acceptable standards, it will de discharged
into the Passaic River.
Question: How much of the site will be restricted from future development for the
30-year period? .
* . - '
Response: Development will be prohibited for the entire site for 30 years.
Question: What is the purpose of keeping 50 year old buildings? If you want to
develop the land, 1 do not see retaining the buildings as a feasible
alternative. Would it not cost more to decontaminate the buildings
than to destroy them?
Response: It will cost a great deal more to destroy the buildings than it would
to decontaminate them. If they were destroyed, they would have to be
removed and disposed of in a hazardous waste facility. The buildings
that are structurally sound will be left in place. The buildings that
are not structurally sound will be demolished and removed to a
hazardous waste facility. (The study determined that one small
building will be removed.)
Other Issues
Question: During the RI/FS presentation I counted four different Alternative #3's
shown. Each one was different than the one explained in the hand out
(fact sheet). The third alternative on the fact sheet is the only
reasonable one. If I wish to write a letter to the Commissioner of
DEP, how will he know which Alternative //3 I am referring to?
Response: All the Alternative #3's are the same. In the fact sheet the
description is more detailed than the descriptions used QJI the over
head transparencies. The transparencies are for highlighting purposes.
The real purpose of these meetings is to hear from you, the: public. As
, a result, we have directed our consultants , to shorten their
' '' presentations to allow more time for public comments. The original
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-11-
Comment:
presentation was about three times as long as tonight's. The
shortening of the presentation may have led to a little confusion
because every step was not presented in detail. Maybe we are learning
from the experience that the presentation should not be too brief.
The people that owned the Syncon Resins company should be brought
forward and made to pay for the destruction that they caused in South
Kearny.
Response: The company is in bankruptcy. The NJDEP is the same as any other party
seeking restitution. The NJDEP is already pursuing that issue.
Question: How soon will the clean up begin at Syncon Resins?
Response: The process begins with a comment period to receive additional
suggestions in writing regarding NJDEP's recommended alternative. At
the close of the comment period, all suggestions (written and those
made during this meeting) will be evaluated. Then the NJDEP will
develop a Responsiveness Summary to be incorporated in the Record of
Decision (ROD). These comments are submitted to the USEPA and
evaluated by them. If the NJDEP and USEPA agree, the ROD is signed.
This is follow'ed by: NJDEP's request to USEPA for funding; the signing
by. both agencies, of a cooperative agreement; the receipt of the grant
.'for funding by DEP; the procurement process to hire an engineering'
firm; completion of the design by the engineering firm; .reapplication
to EPA for construction funds; the procurement process again to hire a
contractor for construction; and then the construction on site. This
process will probably take a total of two and one-half to three years.
Question: May we have a copy of all the materials from the presentation mailed to
us?
Response: A copy of the summary presentation of the RI/FS will be sent to you.
You are welcome to that.
Comment: We would like members of the NJDEP to take interested parties (local
and state officials and concerned citizens) on a tour of the Syncon
site. We also would like tours of the site at various stages of the
clean up.
Response: The NJDEP does not provide routine tours of hazardous waste sites for
the public. Hazardous waste sites are hazardous and only properly
equipped and trained individuals can enter these locations. If anyone
calls the NJDEP, Bureau of Community Relations (609-984-3081), we would
gladly provide status updates regarding on-site conditions, schedules,
etc.
Question: If I come to the NJDEP in Trenton, can someone sit down with me to
explain the proposed alternative from A to Z? Then I will be able to
provide an explanation of the plan to the citizens of Kearny at
meetings and by flyers.
; ' We > are here tonight, to do just that; to provide explanations of the
plan and to solicit your comments. If you have additional questions,
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-12-
please call the NJDEP, Bureau of Community Relations at (609) 984-3081
and arrangements can then be made to provide answers via the telephone
or by meeting with you directly.
III. Remaining Concerns
Basically, the community seemed pleased with the recommended alternative for
the Syncon Resins site. There are primarily three remaining concerns:
0 The Security of the Site,
NJDEP will immediately look into securing the site with the necessary
fencing.
0 The effect of the site on redevelopment under the Master Plan of South
Kearny.
NJDEP stated that the cleanup of Syncon Resins will be conducted within
the boundaries of that site.
0 The length of time until the Syncon Resins site could again be a
productive ratable.
NJDEP explained that all development will be prohibited for the entire
site for 30 years.
Note: , September 4-, 1986 Public Meeting Fact Sheet corrections: .
p.l Replace "147 bulk storage tanks" with "15C bulk storage tanks and
vessels".
p.l Replace "ranging in capacity from 200 to 1,323,000 gallons" with
"ranging in capacity from 200 to 610,000 gallons".
p.l (For clarification, please note) Although a Cooperative Agreement was
signed for the IRM for $2,000,000., the final cleanup cost for the IRM
was actually $2,400,000.
p.3 Replace "a total of 147 tanks" with "a total of 150 tanks".
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ATTACHMENT A
N.J. Department of Environmental Protection
Division of Waste Management
Hazardous Site Mitigation Administration
Public Meeting to Discuss the Removal of Waste Storage Drums
from the Syncon Resins Superfund Site
Kearny, Hudson County, New Jersey
Tuesday, February 21, 1
7:00 p.m.
Kearny Town Hall
400 Kearny Avenue
Kearny, New Jersey
NAME
AFFILIATION
^
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NAME
AFFILIATION
AZDPESS
.
19.
20.
22.
22.
25.
27.
23.
29.
30.
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N.J. Department of Environmental Protection
Division of Waste Management
Hazardous Sice Mitigation Administration
Removal of Waste Storage Drums
from the
Syncon Resins Hazardous Waste Site
Tuesday, February 2:, i
7:00 p.m.
Xearny Town Hall
Kearny, N.J.
Agenda
i. Opening Remarks on Community input in Superfund
Program and introduction of DEP members
Grace Singer
2. Overview of situation and introduction of contractor,
O.H. Materials Company of Findlay, Ohio
Jorge ierkowitz
3. Presentation: O.H. Materials Company, contractors
Robert Panning/
John Hitchings
Questions and Answers
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FACT SHEET
RBOVAL CF WASTE STCRKZ CRA6 FRCM TH= SV?NO^ RESINS
SUPERRN3 SITE IN KEAHW, NSW JERSEY
SITE CESO11PT1CN
Syncon Resins,. Inc. fs an inactive paint, varnish, and resin rranufacturing
facility located on a 15 acre tract in South Kearny. The company which
formerly operated the plant has filed for bankruptcy.
The site is situated within a coastal wetlands rranagernent area and is bordered
on the west by the Passaic River, a tidal waterway.
There are now approximately 9,000 to 11,000 55-gallon drums on site, most
of which are in poor condition and leaking. Analysis indicated that many
drums contain hazardous substances, sane of which are volatile and flarnnable
posing the threat of fire and air polltion. Several bulk liquid storage
tanks suspected of containing hazardous substances are also on the site.
Two unlined ponds used for subsurface disposal of process waste were sampled
and found to contain hazardous organic chemicals.
Tests have indicated the presence of Priority Pollutants and PCBs in soil
and groundwater samples.
PROJECT DESCRIPTION . ...
Remedial response for this site is divided into four segnents:
Part I Project initiation for Part I is scheduled for early February,
198<» and is expected to take six months to canplete.
Phase 1 includes staging, testing, and removal of the 55-gallon
drums presently on site as well as inspection of the
bulk liquid storage tcnks.
Phase II is disposal of the drums.
Part I I Work on Part II activities is scheduled to begin in the
*th quarter of 198** and is expected to take nine months
to canplete.
This part of the project will include a Remedial Investigation
to assess site contamination and a Feasibility Study
to investigate ranedial action alternatives.
Part 111 Work on the engineering Design is scheduled to begin in
the 1st quarter of 1986 and is expected to take three
months to canplete.
Part IV Scheduling of the implementation of the design is dependent
on the work detailed in that document.
PROJECT FINDING
Two mi 11 ion dollars to canplete Part I of the remedial action project, 90%
of which is provided by the United States Environmental Protection;. Agency
as part of the Superfund Program. The remaining I0%will;be provided by '
the State of New Jersey from its Spill Carpensation Fund.
N.H. Department of Envirorrnental Protection
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MEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
A Community Relations Program at Superfund Hazardous Waste Sites
As part of the federal/state program of cleanup of hazardous waste
sites, a Community Relations Program is conducted to receive local input
and to advise local residents and officials about the planned remedial actions
at the three major stages of the cleanup: 1) feasibility study 2) engineer-
ing design and 3) removal/treatment/construction. Local briefings and public
meetings are conducted with elected officials and residents and generally
take place at:
") The commencement of a feasibility study so that local concerns
can be addressed early in the process.
'2} The completion of a feasibility study to discuss the. alternative
courses of remedial action. There -is a 30-day comment period after
public presentation of the alternatives.
3) The engineering design stage to carry cut the mandates of the selected
remedial alternative.
-) The commencement of the removal/treatment/construction stage to
advise of the expected physical remedial action.
5 ' The cor.rleticn of the remedial acti:n.
In addition to the more formal activities outlined above, there is
generally informal communication with local officials and residents.
Depending upon whether the New Jersey Department of Environmental Protec1
!DE?) or the U.S. Environmental Protection Agency !E?A) has the lead in
remedial action at a site, community relations activity is conducted by
the relevant state or federal agency.
In New Jersey at DEP, the Community Relations Program is conducted
by Grace Singer, Community Relations Program Manager (609) 95*-3C3'. At
Region II, EPA, the contact person is Lillian Johnson ;212; 25*-25l5.'
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9TEPS INVOLVED JN A MAJOR HAZARDOUS WA.STE SITE CLEANUP INVOLVING EPA AND SUPEKFUND MONIES
> i te Ident if Led
ind Referred
(1)
Initial Site Invest i<|..it ion
(2)
5>ecuro Site
Site; Analy'sis Evaluation
and Assessment
(4)
'r ioritization
(5) __
lit ing of Contractor
:or Feasibility Study
(9)
Remedial Action Master Plan
and Determination of Lead
Pi eparat ion of Feasibility
Study
(10)
liring ol Const.i net ion or Cleanup Evaluation
iemoval Conliacloi and
: leanup
(ll)r~ (14)
Community Relations Si
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ATTACHMENT B
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
Public Meeting to Discuss Commencement of
Remedial Investigation/Feasibility Study
at
Syncon Resins Site
Thursday, April 25, 1985
7:00 p.m.
Kearny Town Hall
Kearny, New Jersey
NAME
AFFILIATION
/V /) -
""
£$ol^U^ VAiL
J I
IS Po^i /^jgr^.^
ro
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Jfc
fhite ai Xtw ilersey
DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SiTE MITIGATION ADMINISTRATION
UP.VAN v, SACA- »= CN 020. Trenton. N.J 08625 JCRGE - 5E =
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NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
Public Meeting
on
Commencement of
Remedial Investigation/Feasibility Study
at tt.e
Syncon Resins Site
Thursday, January 31, 1985
7:00 p.m.
Kearny Town Hall
400 Kearny Avenue
Kearny, NJ
AGENDA
1) Opening Remarks; Ms. Grace L. Singer, Chief
Introduction of NJDEP personnel Office of Community Relations
NJDEP
2) Overview of Past History and ' Mr. Russell Trice. Site Manager
Current Situation; Bureau of Site Management
Introduction of Contractor: NJDEP
Ebasco Services, Inc.
3) Presentation: Remedial Mr. Garry Cusack, Project Director
Investigation/Feasibility Study Ebasco Services, Inc.
4) . Questions and Answers
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Site Description:
Background:
STATE or NEW JERSEY
DEPARTMENT or ENVIRONMENTAL PROTECTION
FACT SHEET
Public Meeting
on
Commencement of
Remedial Investigation/Feasibility Study
dt
Syncon. Resins Site
Town of Kearny
Hudson County
April 25, 1985
Syncon Resins is an inactive paint, varnish, and resin
manufacturing facility situated within an industrialized
section of a coastal wetlands management area. This 15-acre
site is bordered on the west by the Passaic River, a tidal
waterway, and on the east by Jacobus Avenue. There were
12,824 55-gallon drums on site, most of which were in poor
condition and leaking. Analyses indicated that many con-
tained hazardous substances including volatile and flammable
materials which .posed an immediate fire and air pollution
threat. Presently remaining on site are: 144 bulk storage
tanks, ranging in capacity from 375 -gallons to 600,000
gallons and containing various hazardous materials; two
unlined lagoons used for subsurface disposal of process
waste which were sampled and found to contain hazardous
organic chemicals; and five suspected underground storage
tanks with their associated piping systems. Among the
diverse contaminants found at this site are: solvents,
waste oils, corrosives, organic liquids, solids, acids,
alkalies, ketones, and inorganic liquids and solids. Soil,
shallow ground water and surface water samples indicate the
presence of various pollutants including toluene, xylene,
PCBs, heavy metals, pesticides and cyanide.
In November 1981, an Administrative Order was issued by the
New Jersey Department of Environmental Protection (NJDEP)
requiring Syncon Resins to control and contain the hazards
at the site. However, the company has since filed for
bankruptcy. A Remedial Action Master Plan (RAMP) was
prepared by the United States Environmental Protection
Agency (USEPA) in November, 1982. A Cooperative Agreement
was signed in December 1982 committing $2,000,000 for the
Initial Remedial Measure (IRM) and $350,000 for a subsequent
Remedial Investigation/Feasibility Study (RI/FS).
Cleanup work in the Initial Remedial Measure began in
February, 1984 and was completed in August, 1984. This
included:
0 the inspection, sampling, and disposal of all 12,824
drums. (Prior to the disposal, the contents were grouped
into categories of compatibility.);
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the completion of a Tank and Vessel Report which de-
termined the capacity and integrity of each tank and
vessel, the quantity and phase (liquid, solid or gas)
of the contained material with a number assigned to
each;
Status:
0 transportation, treatment and/or disposal of the waste.
In November, 1984 NJDEP awarded the contract for a Remedial
Investigation/Feasibility Study to Ebasco Services, Inc. of
New York City. The scope-of-work involves the following
activities:
0 Evaluation of all background information, confirmation
of the level of protective equipment to be provided to
personnel during site investigations and preparation of
a Health and Safety Plan, a Field Sampling Plan and a
Quality Assurance/Quality Control Plan for the Syncon
Resins site.
0 Identification, to the extent possible, of the type,
source, location and quantity of hazardous wastes
present at the site.
0 Determination of the nature, extent and severity of
ground water contanir.z.t::.on beneath the. site and its
impact on the surrounding areas.
0 Determination of the nature, extent and severity of
soil contamination at the site.
0 Determination of the nature, extent and severity of
surface water contamination at the site and its impact
on related surface streams and water bodies.
0 Air monitoring to determine the nature and extent of
gaseous emissions.
0 Selection of remedial response objectives and
identification of alternatives.
0 Evaluation of alternatives and selection of an environ-
mentally sound, cost-effective remedial action.
0 Development of the conceptual design of the selected
remedial action and preparation of the final report.
NJDEP
4/85
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NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
A Community Relations Program at Superfund Hazardous Waste Sites
As part of the federal/state program of cleanup at hazardous waste
sites, a Community Relations Program is conducted to receive local input and
to advise local residents and officials about the planned remedial actions at
the three major stages of the cleanup: 1) remedial investigation/feasibility
study 2) engineering design and 3) removal/treatment/construction. Local
briefings and meetings are conducted with elected officials and residents and
generally take place at:
1) The commencement of a remedial investigation/feasibility study so
that local concerns can be addressed early in the process.
2) The completion of a feasibility, study to discuss the alternative
courses of remedial action.- There is a 30-day comment period after
public presentation of the alternatives during which the feasibility
study is available in local repositories.
3) The engineering design stage to carry out the mandates of the
selected remedial alternative.
4) The commencement of the removal/treatment/constmction stage to
advise of the expected physical remedial action.
5) The completion of the remedial action.
In addition to the activities outlined above, there is generally
ongoing communication with local officials and residents as required.
Depending upon whether the New Jersey Department of Environmental Protection
(DEP) or the United States Environmental Protection Agency (EPA) has the lead
in remedial action at a site, community relations activities are conducted by
the relevant State or Federal agency.
In New Jersey, the DEP Community Relations Program is directed by Grace
Singer, Chief, Office of Community Relations (609) 984-3081. At Region II,
EPA, the contact person is Lillian Johnson, Community Relations Coordinator
(212) 264-2515.
HS45:js.
4/85 '
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STEPS INVOLVED IN A MAJOR HAZARDOUS WASTE SITE CLEANUP
(1)
Site Identified
and Referred
(5)
Prioritization
(9)
Hiring of Contractor
"for Remedial Investi-
gation/Feasibility
Study
(13)
Hiring of Construction/
Removal Cleanup
Contractor
(2)
Initial Site Investigation
(6)
Determination of Lead
(10)
Preparation of
Feasibility
Study
A)
Cleanup Evaluation
(3)
Secure Site
(A)
Site Analysis Evaluation
and Assessment
(7) (8)
Community Relations Signing of Contract or
Plan Activated Cooperative Agreement
(11) (12)
Selection of Remedial Hiring of Contractor
Action Alternative for Engineering Design
(15)
Contractor Audit and
Close out
New Jersey Department of Environmental Protection
5/84
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ATTACHMENT C
NAME
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF HAZARDOUS SITE MITIGATION
Public Meeting to Discuss Completion of the
. Remedial Investigation/Feasibility Study
at
Synccn Resins site
Thursday, September 4, 1986
7:00 P.M.
Kearny Town Hall
400 Kearny Avenue
Kearny, NJ
PLEASE PRINT
AFFILIATION ADDRESS
11.
12.'
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NAME
AFFILIATION
ADDHES3
23.
\
24.
25.
26.
27.
23.
29.
30,
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NEW JERSEY- DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF HAZARDOUS SITE MITIGATION
Public Meeting
on
Completion of
Remedial Investigation/Feasibility Study
at
Syncon Resins Site
Town of Kearny
Hudson County
Thursday, September 4, 1986
7:00 P.M.
Kearny Town Hall
400 Kearny Avenue
Kearny, NJ
1. Opening Remarks and
Introductions
AGENDA
Mr. Richard C. Salkie, P.E., Acting Director
Division of Hazardous Site Mitigation
2. Overview of Past History
and Current Situation
3. Presentation:
Remedial Investigation/
Feasibility Study
4. NJDEP Recommended
Alternative
5. -Comments and Questions
Dr. Adi Aleti, P.E., Site Manager
Division of Hazardous Site Mitigation
Mr. Thomas Granger, Project Manager
Ebasco Services, Inc.
Mr. Richard C. Salkie, P.E.
The floor will be open for comments and
questions at this time.
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FACT SHEET
Results of
Remedial Investigation/Feasibility Study
at
Syncon Resins Site
Town of Kearny
Hudson County
September 4, 1986
Sice Description
Syncon Resins is an inactive paint, varnish, and resin manufacturing facility
situated within an industrialized section of a coastal wetlands management area.
This 15-acre site is bordered on the west by the Passaic River, and on the east
by Jacobus Avenue. There were 12,824 55-gallon drums on site, most of which were
in poor condition and leaking prior to their disposal in 1984. Analyses
indicated that many of these drums contained hazardous substances including
volatile and flammable materials which posed an immediate fire and air pollution
threat.
Presently remaining on site are: thirteen structures and buildings; 147 bulk'
storage tanks (ranging i'n capaci'ty from 200 to 1,323,000 gallons and containing-
various hazardous. materials); two unlined lagoons'(used for subsurface disposal
of process waste) containing hazardous organic chemicals; and five suspected
underground storage tanks with their associated piping systems. Among the
diverse contaminants found at this site are: solvents, waste oils, corrosives,
organic liquids, solids, acids, alkalies, ketones, and inorganic liquids and
solids. Soil, shallow ground water and surface water samples indicate the
presence of. various pollutants including toluene, xylene, polychlorinated
biphenyls (PCBs), heavy metals, pesticides and cyanide.
Background
In November 1981, an Administrative Order was issued by the New Jersey Department
of Environmental Protection Agency (NJDEP) requiring Syncon Resins to control and
contain the hazards at the site. However, the company ceased operation in 1982
and filed for bankruptcy. The Syncon Resins site was included on the National
Priorities List (NPL) in September 1983. Of the 97 New Jersey Sites on NPI, the
Syncon Resins site is ranked 48th. A Remedial Action Master Plan (RAMP) was
prepared by the United States Environmental Protection Agency (USEPA) in November
1982. A Cooperative Agreement was signed by the USEPA and NJDEP in December
1982, committing $2,000,000 in federal funds for the Initial Remedial Measure
(IRM). Cleanup work under the IRM began in February 1984 and was completed in
August 1984. This included: disposal of all 12,824 drums; treatment and/or
removal of the wastes that were contained in the 12,824 drums; and an inventory
and content evaluation ol the tanks and vessels.
In December 1982, the NJDEP and the USEPA signed a Cooperative Agreement for a
Remedial Investigation/Feasibility Study (RI/FS) at this site. In November 1984,
N'JDEP awarded, the contract for the Remedial Investigation/Feasibility Study to
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Ebasco Services-, Inc. of New York City. The cost of this study is approximately
$550,000.
Status
The Draft Remedial Investigation/Feasibility Study was completed in August L986
and has been available since August 21, 1986 at the following repositories:
Kearny Public Library in Kearny, Hudson County Law Library in Jersey City, Kearny
Town Hall in Kearny, and the NJDEP, Division of Hazardous Site Mitigation in
Trenton. The public comment period will extend until September 11, 1986. Any
comments on the study should be submitted to Kevin Kratina at NJDEP, Bureau of
Community Relations, CN028 - 432 East State Street, Trenton, NJ 08625. After
considering all public comments, NJDEP and USEPA will determine the selected
remedial alternative for the site and sign a Record of Decision which will
specify the details of the long-term site cleanup.
Summary of Remedial Investigation/Feasibility Study
The following remedial objectives were established for the site as a result of
the site investigations and risk assessment:
0 Mitigative measures should be developed to prevent human exposure to organic
and metal contaminants found within unsaturated soil, lagoon sediments, and
dirt/dust in on-site buildings.
9 Mitigative measures should be -taken to eliminate the potential hazard to
nearby populations caused by the chemical materials remaining in the on-site
tanks and vessels and their asbestos coverings.
0 Mitigative measures should be taken to remediate the contaminated ground
water within the shallow aquifer and saturated soils above the continuous
clay layer.
Based on the above listed objectives, the Remedial Investigation included the
following activities:
0 Identification of the type, source, location and quantity of hazardous
wastes at the site.
0 Determination of the nature, extent and severity of ground water
contamination beneath the site and its impact on the surrounding areas.
8 Determination of the nature, extent and severity of soil contamination at
the site.
0 Determination of the nature, extent and severity of surface water
contamination at the site and its impact on related surface streams and
water bodies.
0 Air monitoring to Jeterrine the nature and extent of gaseous emissions.
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. 3
Results of th« Remedial Investigation
0 A total of 147 tanks and vessels are present on site. Seventy-three tanks
contain less than three inches of liquid material or contain residual scale
material. " Thirty-eight tanks contain either hexane or water soluble
peroxides. Nineteen tanks contain hexane soluble liquids and solids.
Fourteen tanks contain flammable liquids or solids, crystalline and
polymeric material, or sludg-j residues. Four tanks contain aqueous liquids
and two tanks contain cyanide positive organic liquids. Eight tanks contain
PCBs at concentrations greater than 50 parts per million (ppm).
9 Contamination with organic compounds is widespread throughout the site. The
greatest concentrations of volatile organics were found in lagoon sediments,
soil at the southwest corner of the site, and in two buildings. These
primarily include toluene, xylene, trichloroethylene (TCE) , ethylbenzene,
2-hexanone (MBK), methyl tsobutyl ketone (MIBK), and chlorobenzene. The
shallow ground water beneath the site is also contaminated with primarily
the same volatile organic solvents, but only at certain locations. Two
other organic compound solvents (i.e. 1,1-dichloroethane and chlorobenzene)
are present in the deep aquifer at very low levels.
9 Contamination with acid/base neutral organic compounds is widespread
throughout the site. The on-site soils above the clay layer contain
principally phthalates (diethyl, dibutyl, . dioctyl, .arid bis (2-.ethylhexyl:
phthalate), polyaroma'tic hydrocarbons (17 compounds), dlchlorobenzene, N-
nitrosodiphenylamine, and 4-methylphenol. The shallow water table (above
the clay layer) contains principally naphthalene ar.d 2-methyl naphthalene in
two general " areas. No base neutral compounds were detected in the deep
aquifer beneath the clay layer.
0 Pesticide contamination (aldrin, DDT and its associated breakdown products)
was found in the soils in several areas, including the dust/dirt inside
several buildings.
8 PCB contamination is restricted to lagoon sediments, tank contents, certain
buildings, and soil in specific locations of the sice.
9 Metal contamination is present in the soil, shallow ground water, lagoon
sediment, and buildings. The major contaminants in che shallow ground water
are arsenic, cadmium, chromium, lead and zinc. The Lagoon sediments and the
buildings' dirt/dust contain chromium, cadmium, nickel and barium.
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Summary of Remedial Alternatives for Long-Tera Sice Remediation
* Alternative 1 - Minimal Action
This entails securing the structures and improving fencing conditions around
.the perimeter of the site.
0 Alternative 2 - Removal of Buildings. Tanks, and Soil for Off-Site
Disposal
Removal and off-site disposal of all buildings, tanks, tank contents,
and soils exceeding the established cleanup criteria.
8 Alternative 3 - Removal of Buildings and Tanks. On-Site Incineration
and .On-Site Soil Washing
Removal and on-site incineration of hazardous tank contents and off-site
disposal of non-hazardous tank contents; decontamination and off-site
disposal of all buildings and tanks; on-site soil washing of hazardous
soils.
* Alternative 4 - Decontamination of Buildings and Tanks, and
Leachate and Ground Water Control
Removal and- off-site disposal of tank .contents; decontamination and
securing of buildings and tanks; placement of a hazardous waste cap in open
areas; extraction and on-site treatment of ground w?.cer and leachate.
0 Alternative 5 - Removal of Buildings and Tanks, and Site Encapsulation
Removal and off-site disposal of all buildings, tanks, tank contents and
waste materials; and site encapsulation with a perimeter slurry wall and a
hazardous waste cap.
8 Alternative 6 - Removal of Buildings and Tanks, On-Site Chemical Fixation
Soil, and On-Site RCRA Landfill
Removal and disposal of hazardous buildings, tanks and solid tank contents
to an on-site hazardous waste landfill; off-site disposal of liquid tank
contents and soil dewatered wastewater; and chemical fixation of soils.
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Syncon Resins
September 4, 1986 Public Meeting
NJDE? Recommended Alternative
Based on the results of the RI/FS, the NJDEP recommends the following alternative
for site remediation. This recommendation includes various components of
alternatives described previously in this fact sheet.
' Tanks, Vessels, and Buildings
The existing above-ground structures including all buildings, tanks, and
storage vessels will be decontaminated. Hazardous contents and
decontamination wastes will be removed for either incineration (preferred
option) or landfilling at an approved hazardous waste facility. All
non-hazardous aqueous wastes will be treated in an on-site treatment system.
Non-hazardous solids will be disposed of at a sanitary landfill.
0 Soil (Unsaturated, Saturated, and Lagoon Sediments)
Sediments from the two lagoons will be excavated and disposed of off site by
incineration (preferred) or landfilling at an approved hazardous waste
facility. Soils will be covered with a layer of crushed stone to prevent
contact with the soil and to allow natural flushing of the contaminants by
rain water. A downgradient collection trench will be installed to collect
the contaminated water which will be treated on site and discharged to the
Passaic River.
.
* Monitoring
A continuous 30-year monitoring program will be implemented after the
completion of remedial action to ensure the safety of public health and the
environment.
0 Site Access
The site will be secured by improving fence conditions, including a locked
gate. Access roads will be constructed.
8 Additional Studies
This will include the evaluation of a variety of technologies that will
enhance the natural flushing and/or treatment/destruction of contaminants.
These technologies are meant to achieve a more permanent solution for the
contaminated soil. After these studies are complete, the site will be
reassessed to determine specific actions for a more permanant remedy.
Additional soil samples will be collected/analyzed to ensure public and
environmental safety. If soil analyses indicate a potential environmental
problem, excavation and off-site disposal will be considered.
For . further information contact Kevin Kratina of NJDEP's Bureau of Communiry
Relations at (609) 984-3081.
HS224:fb
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FIGURE M
SITE LOCATION MAP. SYNCON RESINS SITE,
HUDSON COUNTY, NEW JERSEY
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Glossary of Terms
Administrative Consent Order (AGO): A binding legal document between a govern-
ment agency and a responsible party. It is issued by the government in the form
of an order that specifies site mitigation activities to be undertaken by the
responsible party.
Contract; The legal agreement that outlines federal and state government
responsibilities at USEPA-lead sites on the National Priorities List (Superfund
sites) as authorized by the Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA).
Cooperative Agreement: An agreement whereby USEPA transfers funds and other
resources to a state for the accomplishment of certain remedial activities at
sites on the National Priorities List (Superfund sites) as authorized by the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).
Engineering Design (Remedial Design); Following a feasibility study, an
engineering design is executed to translate the selected remedy in accordance
with engineering criteria in a bid package, enabling implementation of the site
remedy.
**
Focused Feasibility Study (FFS): A limited feasibility study which is performed
on a certain aspect of site remediation and/or when more than one ^remedial
measure is considered technically viable for the immediate control of a threat.'
Immediate Removal Actions (IRAs): Actions taken to prevent or mitigate immediate
and significant risk to human life, health or to the environment.
Initial Remedial Measures (IRMs); Actions that can be taken quickly to limit
exposure or threat of exposure to a significant health or environmental hazard at
sites where planning for remedial actions is underway.
Monitoring Well; A well installed under strict design specifications that, when
sampled, will reveal hydrogeologic data at its point, of installation. Monitoring
wells are installed at predetermined locations, usually in groups, to gain
knowledge of site conditions including: extent and type of ground water con-
tamination, soil types, depth to ground water and direction of ground water flow.
National Contingency Plan (NCP): The basic policy directive for federal response
actions under th« Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA). It sets forth the Hazard Rankir.g System and procedures
and standards for responding to releases of hazardous substances, pollutants, and
contaminants. The NCP is a regulation subject to regular revision.
National Priorities List (NPL): A list of the highest priority releases or
potential releases of hazardous substances, based upon State and U.S.
Environmental Protection Agency (USEPA) Regional submissions of candidate sites
and the criteria and methodology contained in the Hazard Ranking System (HRS) ,
for the purpose of allocating funds for remedial response under the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA). Published by
the USEPA, the NPL is updated periodically. Sites on the NPL are cotmonly called
Superfund sites. .
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NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF HAZARDOUS SITE MITIGATION
A Community Relations Program at Superfund Hazardous Waste Sites
As part of the federal/state program of cleanup at hazardous waste sites, a
Community Relations Program is conducted to receive .local input and to advise
local residents and officials about the planned remedial actions at major stages
of the cleanup. Local briefings and meetings are conducted with elected
officials and residents and generally take place at:
1) The commencement of a remedial investigation/feasibility study so that
local concerns can be addressed early in the process.
2) The completion of a feasibility study to discuss the alternative
courses of remedial actj.cn. There is a 21-day comment period on the
alternatives during which the feasibility study is available in- local
repositories.
3) The commencement of the removal/treatment/construction stage to advise
of the expected physical remedial action.
4) The completion of the remedial action.
In addition to the activities outlined above, there is generally ongoing
communication with local officials and residents as required. Depending upon
whether the New Jersey Department of Environmental Protection (DEP) or the0United
States Environmental Protection Agency (EPA) is the lead agency in remedial
action at a site, community relations activities are conducted by the relevant
State or Federal agency.
In New Jersey, the DEP Community Relations Program is directed by Grace Singer,
Chief, Bureau of Community Relations (609) 984-3081. At Region II, EPA, the
Community Relations Coordinator is Lillian Johnson, (212) 264-2515.
7/86
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STEPS INVOLVED IN A MAJOR HAZARDOUS WASTE SITE CLEANUP
(1)
Site Identified
and Referred
(2)
Initial Site Investigation
(3)
Site Secured
Site Analysis Evaluation
and Assessment
(5)
Prioritizatlon
(6)
Determination of Agency Lead
(NJDEP or USEPA)
(7)
Community Relations
Plan Activated
(8)
Signing of Contract or
Cooperative Agreement
(9)
Hiring of Contractor
for Remedial Investi-
gation/Feasibility
Study
(10)
Preparation of
Feasibility
Study
(11)
Selection of Remedial
Action Alternative
(12)
Hiring of Contractor
for Engineering Design
(13)
Hiring of Construction/
Treatment/Removal Cleanup
Contractor
Cleanup Evaluation
(15)
Contractor Audit and
Close out
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ATTACHMENT D
COMMISSIONERS
KEARNY BOARD OF HEALTH
LILLIAN CAROOZA. President
VICTOR RUDOMANSKI, M.D.. Vice President
JO-ANN CARRATURA
PETER CICCHINO
CHESTER KOZLIK
GORDON POWLIE
ROBERT R. KERWIN. SR
Bepartm*nt nf JJublir
and Enoinmmtntal $rot*rtinn
BOARD MEETS
THIRD WEDNESDAY OF EACH MONTH
AT HEALTH CENTER
645 KEARNY AVENUE
KEARNY. N.J. 07032
997-O600
EDWARD GROSVENOR
HEALTH
Septanber 8, 198
Mr. Kevin Kratina
N.J. Dept. of Environmental Protection
Bureau of Carrtunity Relations
CN-203
432 East State Street
Trenton, New Jersey 08625
RE: SYNCON RESINS SITE, KEARNY, NEW JERSEY
Dear Mr. Kratina:
Being present at the Public Hearing on September 4, 1986, we were delighted that the
Remedial Investigation/Feasibility Study was completed and that decisions will be made as tc
what alternative to initiate at the site in the near future.
We agree that the presented alternative is the most feasible, but, strongly recommend alter-
native #2, which is removal of buildings, tanks, and soil to an off-site waste disposal unit
Alternative #2, while more expensive, would provide the most protection against health
environment and the use of the land as a ratable to the Town of Kearny. We can ill afford t
have industrial sites sitting idle while other clean-up studies are conducted. We could
conceivably have hundreds of acres of prime industrial land under long range maintenance
programs providing no tax ratable at all.
Thanking you in advance for your consideration,
I am
Sincerely,
Edward* Grosvenor,
Health Officer
EG: el
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