United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-89/076
April 1989
&EPA
Superfund
Record of Decision
Ciba-Geigy, NJ
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REPORT DOCUMENTATION
PAGE
1. REPORT Na
EPA/ROD/R02-89/076
X Redpienre Accoeaton No.
4. THtocndSUMM*
SUPERFUND RECORD OF DECISION
Ciba-Geigy, NJ
Remedial Action
5. Report Date
4/24/89
I. Performing OrgmizMton Ropt No.
». Performing OrgaJntorton Nemo end Addma
10. ProtectfTaak/Work UnH No.
11. Contrmct
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EPA/ROD/R02-8 9/076
Ciba-Geigy, NJ
First Remedial Action
6. Abstract (Continued)
filtercake disposal area was also closed and covered with soil. Ground water
contamination is migrating from these inactive disposal sites easterly towards the Toms
River. Currently, the company generates both liquid and solid wastes. The liquid
wastes are treated onsite in a wastewater treatment plant before discharge to the
Atlantic Ocean. The solid wastes are disposed of off site, and sludges from the
wastewater treatment plant are disposed of in a permitted, double-lined, onsite
landfill. EPA began investigating the site in 1980. Throughout its operation, the
facility has routinely violated treatment and disposal permits, including accepting
hazardous off site waste beginning in 1981. The landfill reportedly was leaking as
early as 1981, precipitating remedial measures by the State including issuance of a
consent order forcing Ciba-Geigy to close part of the landfill and monitor ground water
and leachate. In 1984, after discovering that Ciba-Geigy was illegally disposing of
drums containing liquids and hazardous waste in the landfill, the State ordered
Ciba-Geigy to remove 14,000 drums. In 1985, leaking equalization basins associated
with the wastewater treatment plant led to Ciba-Geigy closing the basins and beginning
remediation of the ontaminated plume from these basins. Currently, contaminants are
present in leaking drums, waste sludges, soils, and ground water. This Record of
Decision addresses the first operable unit focusing on the remediation of ground water
contamination in the upper aquifer. Remediation of the onsite source areas and deeper
aquifer (if needed) will be addressed in future operable units. The primary
contaminants of concern affecting the ground water are VOCs including benzene, PCE,
TCE, and toluene; and metals including arsenic and chromium.
selected remedial action for this site includes sealing contaminated residential
rrigation wells; on- and offsite ground water pumping with onsite treatment using
filtration, reverse osmosis, and GAC in an upgraded version of the Ciba-Geigy
wastewater treatment plant, followed by temporarily retaining the ground water in
basins for monitoring and subsequent discharge to the Toms River; and implementation of
a river and ground water monitoring program. The estimated present worth cost for this
remedial action is $164,500,000, which includes annual O&M of $12,539,000.
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UNITED STATES
ENVIRONMENTAL PROTECTION
AGENCY
REGION II
RECORD OF DECISION
OPERABLE UNIT ONE
CIBA-GEIGY CHEMICAL CORPORATION SITE
TOMS RIVER, NJ
APRIL 24, 1989
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TABLE OF CONTENTS
Section Page
I DECLARATION STATEMENT
II DECISION SUMMARY
Site Name, Location and Description 1
Municipal and Private Wells 2
Site History and Enforcement Activities 3
Wastewater Treatment Activities 4
On-Site Waste Disposal Activities 5
Site Investigations ' 6
CERCLA Enforcement Activities 8
Community Relations 8
Proposed Remedy; Public Review 8
Scope of the Operable Unit Within Site Strategy 9
Summary of Site Characteristics 10
Remedial Investigation Conclusions 11
Summary of Site Risks 13
Human Exposure Routes 14
Environmental Media Sampling 16
Description of Alternatives 17
Applicable or Relevant and Appropriate
Requirements 17
Components of Remedial Alternatives 19
Component 1 - Groundwater Extraction Alternatives..19
Component 2 - Groundwater Discharge Alternatives..22
Treated Groundwater Holding Basins 22
Alternatives for Discharge to the Toms Piver 24
Alternatives for Discharge to the Upper Sand
Aquifer 25
Deep Aquifer Reinjection 2~
Alternative Placement of Infiltration Basins 29
Component 3 - Groundwater Treatment Alternatives... 29
Existing Wastewater Treatment Plant Operation....30
CIBA-GEIGY Wastewater Treatment Plant
Alternatives 31
Alternatives for a Newly Constructed On-Site
Wastewater Treatment Plant 35
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Section . Pace
Summary of Comparative Analysis of Alternatives 38
Overall Protection of Human Health and the
Environment. 39
Compliance with ARARs 42
Long-Term Effectiveness and Permanence 44
Reduction of Toxicity, Mobility or Volume 46
Short-Term Effectiveness 43
Implement abili ty 50
Cost 52
State Acceptance 53
Community Acceptance 54
Selected Remedy 56
Description of the Selected Remedy 56
Future Work 60
The Statutory Determinations 61
Protection of Human Health and the Environment 61
Attainment of Applicable or Relevant and Appropriate
Requirements 61
Location-Specific 61
Action-Specific 62
Chemical-Specific 62
Cost Effectiveness 62
Utilization of Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable..62
Preference for Treatment as a Principle Element 63
III TABLES
1 Total "No Action" Carcinogenic Risks And Chronic
Hazard Evaluation For Residential Exposure Routes
2 Total "No Action" Carcinogenic Risks And Chronic
Hazard Evaluation For Recreational Exposure Routes
3 Action-Specific ARARs - Discharge Criteria for the
Atlantic Ocean (Mass Units)
3A Action-Specific ARARs - Discharge Criteria for the
Atlantic Ocean (Concentration Units)
4 Proposed Discharge Criteria for the Toms River -
To Be Considered (Mass Units)
4A Proposed Discharge Criteria for the Toms River -
To Be Considered (Concentration Units)
5 Chemical-Specific ARARs for Groundwater Protection -
New Jersey Drinking Water Standards
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Section
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III
TABLES
6 Chemical-Specific ARARs for Groundwater Protection -
General Guidelines for Unregulated VOCs
7 Component 1 - Groundwater Extraction Alternatives
8 Component 2 - Groundwater Discharge Alternatives
9 Component 3 - Groundwater Treatment Alternatives
10A Comparison of Present Worth For Component One
(Groundwater Extraction) Remedial Alternatives
10B Comparison of Present Worth For Component Two
(Treated Groundwater Discharge) Remedial Alternatives
IOC Comparison of Present Worth For Component Three
(Groundwater Treatment) Remedial Alternatives
IV FIGURES
1 Site Location Map
2 CIBA-GEIGY Site Plan
3 Approximate Lateral Extent Total Volatile Priority
Pollutants Contamination 5 ug/1 and Electrcr ignetic
Conductivity Contours 5 millimhos/m
4 Maximum Detected Total Volatile Priority Pollutants
5 Wells With Inorganic Contaminant Concentrations
Above Maximum Contamination Limits (MCL)
6 Component 1 - Remedial Alternative GE-2
Installation of Groundwater Extraction Wells
7 Component 1 - Remedial Alternative GE-3
Installation of Groundwater Extraction System
and Partial Injection of Clean Water
8 Component 2 - Remedial Alternative GD-33
Discharge to Upper Sard Aquifer 100% Reinjection
of Treated Groundwater Through Reinjection Wells
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Section
IV FIGURES
9 Component 2 - Remedial Alternative GD-3C
Discharge to Upper Sand Aquifer 100% Recharge
of Treated Groundwater Through Reinjection
Wells and Infiltration Basins
10 Schematic of Existing CIBA-GEIGY Wastewater
Treatment Plant
11 Component 3 - Remedial Alternative GT-1B
CIBA-GEIGY Wastewater Treatment Plant-Separate
Treatment of Process Wastewater and Groundwater
With Discharge to the Atlantic Ocean
12 Component 3 - Remedial Alternative GT-1C
CIBA-GEIGY Wastewater Treatment Plant -
Treatment of Contaminated Groundwater Only
With Discharge to the Atlantic Ocean
13 Component 3 - Remedial Alternative GT-1D
CIBA-GEIGY Wastewater Treatment Plant - Treatment
of Process Wastewater and Contaminated Groundwater
With Discharge to the Toms River or Upper Sand
Aquifer
14 Component 3 - Remedial Alternative GT-1E
CIBA-GEIGY Wastewater Treatment Plant - Treatment •
of Contaminated Groundwater Only With Discharge to
the Toms River or Upper Sand Aquifer
15 Component 3 - Remedial Alternative GT-1F
CIBA-GEIGY Wastewater Treatment Plant - Separate
Treatment to Non-detectable Levels
16 Component 3 - Remedial Alternative GT-1F
CIBA-GEIGY Wasatewater Treatment Plant - Treacrrer. t
of Contaminated Groundwater Only to Non-detectable
Levels
17 Component 3 - Remedial Alternative GT-2A
New Physical/Chemical Treatment Plant With Discharge
to the Atlantic Ocean
18 Component 3 - Remedial Alternative GT-2B
New Biological Treatment Plant With Discharge co
the Atlantic Ocean
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Section
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V
FIGURES
19
20
21
Component 3 - Remedial Alternative GT-2C New
Biological Treatment Plant With Discharge to
the Toms River or Upper Sand Aquifer
Component 3 - Remedial Alternative GT-2D
New Biological Treatment Plant With Treatment to
Non-detectable Levels
Component 3 - Remedial Alternative GT-4
In Situ Bioreclamation System
APPENDICES
1 Appendix A - Average and Maximum Concentrations of
Priority Pollutants in Various Media
2 Appendix B - Location-Specific ARARs; Action-Specific
ARARs
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DECLARATION STATEMENT
RECORD OF DECISION
CIBA-GEIGY Chemical Corporation - Operable Unit I, Dover Tcvr-.sh ip,
Ocean County, New Jersey
STATEMENT OF PURPOSE
This decision document presents the selected remedial action
for the CIBA-GEIGY Chemical Corporation site - Operable Unit
I in Dover Township, New Jersey, developed in accordance with
the Comprehensive Environmental Response, Compensation and
Liability Act of 1980, as amended, and to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency
Plan, 40 CFR Part 300.
STATEMENT OF BASIS
I am basing my decision primarily on the following documents,
which are contained in the administrative record for this site:
- Remedial Investigation for the CIBA-GEIGY site, prepared by
NUS Corporation, January 22, 1988;
- Final Draft Feasibility Study for the CIBA-GEIGY site,
prepared by NUS Corporation, April 29, 1988;
- Final Report - CIBA-GEIGY Technical Enforcement Support
Document, Groundwater Modeling Report, CIBA-GEIGY, Toms
River, New Jersey, prepared by Camp, Dresser & McKee,
April 1989;
- Final Report - CIBA-GEIGY Plant, Groundwater Treatment
Alternatives, Toms River, New Jersey, prepared by Camp,
Dresser & McKee, April 1989;
- Proposed Remedial Action Plan, CIBA-GEIGY site, June 1983;
- The attached Decision Summary for the CIBA-GEIGY site,
- The attached Responsiveness Summary for the site, which
incorporates public comments received; and
- Staff summaries and recommendations.
The State of New Jersey has concurred on the selected remedy.
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DESCRIPTION OF THE SELECTED REMEDY
This operable unit was developed to protect public health and
the environment by remediating the contaminated groundwater
in the upper aouifer. The groundwater will be extracted until
the federal and state cleanup standards are met to- the maximum
extent practicable. The operable unit is fully consistent
with all planned future site activities. Future site activities
include further evaluation of potential areas of contamination
and development of measures to remediate these areas and
further evaluation of the deeper aauifer and development of
remedial measures for this aquifer, if required.
The major components of the selected remedy for the CIBA-GEIGY
site - Operable Unit I are as follows:
0 Sealing of contaminated residential wells in the Cardinal
Drive area to prevent human exposure to contaminated ground-
water.
0 Installation of an extraction well system on and off site
to stop migration of contaminated groundwater at the property
line and capture the contaminated groundwater in the off-site
areas.
0 After extraction, treatment of the contaminated groundwater
separately from the process wastewater in an upgraded
existing CIBA-GEIGY wastewater treatment plant. The conta-
minated groundwater will be treated to the discharge levels
as specified by the NJDEP for discharge to the Toms River.
0 After treatment, the groundwater will be retained in basins
to allow monitoring of residual contaminant levels prior to
discharge through a pipeline to the Toms River.
0 Monitoring of the Toms River to determine current water
quality upstream, downstream, and adjacent to the' site.
Monitoring will continue during the implementation of the
remedial action to evaluate the effects of the extraction
system and river discharge over time.
DECLARATION
Consistent with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended, and the
National Oil and Hazardous Substances Pollution Contingency
Plan, 40 CFR Part 300, I have determined the selected remedy
is protective of human health and the environment, attains
federal and state requirements that are applicable or relevant
and appropriate for this remedial action and is cost-effective.
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This remedy satisfies the statutory preference for remedies
that employ treatment that reduces toxicity, mobility, or
volume as a principal element and utilizes permanent solutions
and alternative treatment technologies to the maximum extent
pract icable.
Because this remedy will result in hazardous substances remain-
ing on-site above health-based levels, a review will be
conducted within five years after commencement of remedial
action to ensure that the remedy continues to provide adequate
protection of human health and the environment.
v
Date William J./Muszynski, P.E.
Acting Regional Administrator
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DECISION SUMMARY
CIBA-GEIGY CHEMICAL CORPORATION SITE - OPERABLE UNIT I
DOVER TOWNSHIP, NEW JERSEY
SITE NAME, LOCATION AND DESCRIPTION
The CIBA-GEIGY Chemical Corporation site is located on Route
37 in Toms River, Ocean County, New Jersey, about one mile
west of the Garden State Parkway (refer to Figure 1). The
site, presently owned by the CIBA-GEIGY Chemical Corporation,
covers 1400 acres, 320 of which are developed; the remaining
area is largely wooded. The manufacturing facility, which
has been in operation since 1952, is composed of twenty-two
buildings, a wastewater treatment plant which currently has
an average operating capacity of 4.0 million gallons per day
(MGD), and a lined reservoir for emergency storage of treated
and untreated wastewater.
Topographically, the CIBA-GEIGY site is flat but drops off
sharply toward the Toms River in the northeastern sector of
the property. Winding River Park, an outdoor recreational
area situated on the floodplain of the Toms River, adjoins
the site to the east. A residential area borders the site
to the southeast. The site is bounded on the west by an
industrial park, and on the north and southi; by residential
and commercial properties. Major residential developments,
including two retirement communities, are located 1 mile
south of the site. The business district of the town of Toms
River lies 3 miles southeast of the site (refer to Figure 2).
Geologically, the CIBA-GEIGY site is directfy underlain by
the Kirkwood Formation and Cohansey Sand. in general, the
Kirkwood Formation is composed of quartz-bearing very fine-
to medium-grained sand and contains dark-colored micaceous,
diatomaceous clay, known to be regionally extensive ac the
base of the formation. The Cohansey Sand i-s composed of
light-colored, medium- to coarse-grained guSrtz sand with
pebbles, and locally, clay beds. The thickness of the
Kirkwood-Cohansey aguifer system in the vicinity of the
CIBA-GEIGY site is approximately 205 feet. \ Perched water
tables and semi-confined aquifer conditions', occur locally
within the Kirkwood-Cohansey aquifer system.
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The drainage course of the Toms River traverses Ocean County
along a 16-mile pathway from the northwest to the southeast.
The main channel of the Toms River, along with associated
tributaries of the river system, provides drainage to a basin
encompassing 190 square miles. Surface waters from all
tributaries in the northern drainage basin of the Toms River
contribute to the hydraulic flow and water quality at the
CIBA-GEIGY site.
Average stream discharge of the Toms River for the past 57
years at the CIBA-GEIGY site is 215 cubic feet per second
(cf/s). Stream flows in the New Jersey Coastal Plain,
including the surface water discharge in the Toms River
are derived primarily from groundwater baseflow.
Water quality data for the past 20 years show that the waters
of the Toms River are acidic, with a pH range of 3.4 to 7.8
and a median of 5.0. Surface waters are normally oxygen
saturated; however, conditions of oxygen stress occurred during
the summer months of 1966 and 1970. Biological oxygen demand
(BOD) of the surface waters has remained within the expected
concentration range of river water and presently ranges from
0.2 mg/1 to 1.5 mg/1. Total nitrogen content of the river
shows a trend toward decreasing concentrations over time.
Total phosphorous has remained fairly stable, with a range of
0.01 to 0.20 mg/1. The total dissolved solids (TDS) level is
approximately 35 mg/1.
From 1952 to 1966, operators of the site discharged treated
effluent into the Toms River. Sinc.e 1966, the treated effluent
has been sent to the Atlantic Ocean;. Improved water quality
in the Toms River, notably a decrease in nitrogen and BOD
concentrations, may be related to |hese changes at the
CIBA-GEIGY plant. f.
?:
Municipal and Private Wells '-?
The Kirkwood-Cohansey aauifer system in the area surrounding
the CIBA-GEIGY site is tapped by municipal, industrial and
private wells. The nearest public water supply well, owned
by the Toms River Water Company and; designated "TRWC 20," is
located approximately 2200 feet from the site boundary on the
east side of the Toms River. Privately-owned drinking water
wells near the site are concentrated along the southwestern
site boundary and in the southern portion of the Cardinal
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Drive area, located between the eastern site boundary and the
Toms River (refer to Figure 2). Several residents in the
Cardinal Drive area also have irrigation wells. Additional
residential drinking water wells are located along Coulter
Street between well TRWC 20 and the Toms River (refer to
Figure 2) .
The U.S. Environmental Protection Agency (EPA) sampled both
residential drinking water and irrigation wells several times
beginning in the Spring of 1985. Elevated levels of mercury
(which are not believed to be site-related) above EPA's
Maximum Contaminant Level (MCL) of 0.002 mg/1 were found in
three private residential drinking water wells on Coulter
Street. These residences have since been put on municipal
water supplies. In addition, elevated levels of lead
contamination above EPA's MCL of 0.05 mg/1 were found in
three private residential drinking water wells along the
southwestern site boundary. One home has been placed on
municipal water supplies. The contamination found in these
wells is not believed to be site-related.
Elevated levels of volatile organic compounds (VOCs) and
metals were also found in water from private irrigation
wells in the Cardinal Drive area. Some of these contaminated
irrigation wells have been sealed. Presently, all residences
in the Cardinal Drive area which are within the CIBA-GEIGY
plume ^use municipal water as their potable water source.
SITE HISTORY AND ENFORCEMENT ACTIVITIES ,
According to CIBA-GEIGY, the manufacturing facility commenced
operation in 1952 as the Toms River Chemical Corporation (TRC),
jointly owned by Society of Chemical Industry, Basle (Ciba),
J.R. Geigy, S.A., Basle (Geigy) and Chemical Works, the
predecessor of Sandoz Limited (Sandoz). In 1970, the U.S.
subsidiaries of Ciba and Geigy merged to become CIBA-GEIGY
Corporation. From 1970 through 1981, TRC was jointly owned bv
Sandoz and CIBA-GEIGY. In 1981 Sandoz transferred all interest
to CIBA-GEIGY.
From 1952 to 1988, a variety of synthetic organic pigments,
organic dyestuffs and intermediates, and epoxy resins were
manufactured at the site. Principal markets for these products
were the paper and textile industries and the electronics
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industry. In 1988, CIBA-GEIGY phased out the dye manufacturing
processes. According to CIBA-GEIGY, epoxy resin nanufacturing
processes are scheduled to end in late 1991. Dye standardization
will continue indefinitely.
Currently, the company generates both liguid and solid wastes.
The liquid wastes are treated on site in a wastewater treatment
plant before discharging to the Atlantic Ocean. The solid
wastes, consisting of residue from the manufacturing processes,
are disposed off site, and sludges from the wastewater treatment
plant are disposed in permitted double-lined, on-site landfills.
In 1987, the company applied to the New Jersey Department of
Environmental Protection (NJDEP) for permits to convert the
existing facility to a pharmaceutical manufacturing facility.
On October 24, 1988, NJDEP denied these permits. On November
28, 1988, CIBA-GEIGY announced that it would not appeal the
NJDEP permit denials and on December 6, the company announced
that it would significantly reduce manufacturing operations
at this location and close the current ocean outfall by December
31, 1991.
Wastewater Treatment Activities
Since 1952 until 1960, TRC operated an industrial wastewater
treatment plant. According to CIBA-GEIGY, this plant consisted
of an equalization basin, an oxidation lagoon, and a settling
basin, with discharge to the Toms River. Of these units, only
the equalization basin was lined. The liner!, however, began
to leak soon after the. basin became operational. All licuid
wastes were disposed through this treatment plant. Solid wastes
were disposed in bulk on site.
In 1960, the existing treatment plant was closed except for
the equalization basins, which were re-lined. A new treatment
plant was built adjacent to the Toms River in the northeastern
area of the site. A portion of the settling basin frcrr the
original wastewater treatment plant was converted to a solid
waste disposal area for both drummed waste and other wastes
such as iron sludge and biological sludge.
In 1966, the river discharge was closed and the treated
effluent was sent to the Atlantic Ocean through a ten-mile
pipeline.
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The second wastewater treatment plant was closed in 1977 and
a third, more modern treatment plant with lined basins was
constructed. The sludge from the second treatment plant was
sent to an on-site area known as the Filtercake Disposal
Area, after which this area was closed and covered with soil.
On-Site Waste Disposal Activities
The company disposed of chemical wastes on site in several
locations. These locations include:
0 a 5.3-acre Drum Disposal Area (reported by CIBA-GEIGY
to contain approximately 100,000 drums),
0 a 3.9-acre Lime Sludge Disposal Area,
0 a 12-acre Filtercake Disposal Area,
0 five Backfilled Lagoons comprising approximately 8.5
acres, and
0 a Calcium Sulfate Disposal Area.
Aerial photographs indicate that other areas designated as
the Borrow Area, Casual Dumping Area and the suspected East
Overflow Area may have also been used as waste disposal sites
(refer to Figure 2).
The Drum Disposal Area was used from 1960 until 1977. Also
during this time, the Filtercake Disposal Area was used for
the disposal of sludge from the wastewater treatment plant.
In addition, the Lime Sludge Disposal Area was used to dispose
of inorganic wastes (including arsenic wastes) stabilized
with calcium carbonate. Some of this waste was. drummed,
while s£me was disposed in bulk. The Drum Disposal Area and
the LimS Sludge Disposal Area were closed in 1978. Investiga-
tions have shown that groundwater contamination is migrating
from these inactive disposal sites in an easterly direction
towards^, the Toms River. In addition to the closed disposal
areas, an active landfill designed and permitted to acceot
wastewater treatment plant sludge is also located on site.
After 1977, CIBA-GEIGY began disposing of waste in a double-
lined permitted landfill and shipping waste off site for
disposal.
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Site Investigations
During the late 1970s and early 1980s, CIBA-GEIGY performed
various closure activities and geohydrologic investigations
at the site in response to NJDEP directives. These activities
included closing the Drum Disposal Area and the Lime Sludge
Disposal Area with 30-mil PVC caps in 1978, installing drainage
swales and initiating geohydrologic studies to identify the
sources of groundwater contamination and the direction and
extent of contaminated plumes. Also, as early as 1979, there
were reports of leakage of the double-lined Active Landfill
and remedial measures were taken under the direction of the
NJDEP Solid Waste Administration.
EPA completed an Identification and Preliminary Assessment
report of the CIBA-GEIGY site under the Potential Hazardous
Waste Site Program in 1980. The site was proposed for the
National Priorities List in 1982 and was ranked at 166 nation-
ally among 418 listed sites.
An Administrative Consent Order was entered into between the
NJDEP and CIBA-GEIGY in 1981 to close Cell .1 of the Active ,
Landfill, delineate conditions for the use of Cell II, sample '
and analyze leachate from Cells I and II, and monitor ground-
water.
In 1981, CIBA-GEIGY began accepting waste for treatment and
disposal from off site. In 1983, the Division of Water
Resources (DWR) of NJDEP notified CIBA-GEIGY that further
acceptance of hazardous/nonhazardous waste into the on-site
was-tewater treatment plant from off-site sources would be in
violation of its New Jersey Pollution Discharge Elimination
System Permit and would result in prosecution.
In|;i984/ the NJDEP discovered that CIBA-GEIGY was illegally
dis-posing of drums containing liquids and hazardous waste in
Cell II of its Active Landfill. This discovery led the Mew Jersey
Division of Criminal Justice to conduct an investigation into
the waste handling and disposal practices at the site. The
criminal investigation resulted in indictments on two occasions,
of^several CIBA-GEIGY officials who were charged with the
illegal disposal of chemical waste, filing false documents
with the NJDEP, making false and misleading statements to the
NJD.EP, and illegal disposal of hazardous waste.
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In 1985, CI3A-GEIGY notified EPA and NJDE? that the existing
RCRA Equalization Basins may be leaking into the groundwater.
Also in 1985, after discovering the disposal of hazardous
wastes and liguids in the Active Landfill (permitted only
for the disposal of nonhazardous solid wastes), NJDEP ordered
CIBA-GEIGY to remove 14,000 drums from Cell II, pay a $1.65
million fine, and reorganize its Environmental Technology
Department at the Toms River plant.
By 1986, CIBA-GEIGY had committed to close the leaking
Equalization Basins and install purge wells to begin remediat-
ing the contaminated plume from these basins. A RCRA closure
plan for the Equalization Basins was submitted to NJDEP in
1987.
Under the Comprehensive, Environmental, Response, Compensation
and Liability Act of 1980 (CERCLA), EPA began the Remedial
Investigation (RI) in January 1985 and released the RI report
to the public in September 1986. The objectives of the RI
were the following:
0 to characterize the nature and extent of contamination
associated with the site;
0 identify site-related off-site contamination and its
impact on the environment and on public health; and
0 to determine the need for remedial measures to mitigate
the impact of the site on public health and the environ-
ment, i
After further review and analysis of the data, EPA released
a revised RI in February 1988. This report presented a more
conservative interpretation of the hydrogeology and extent of
surficial soil contamination at the site than the earlier -
document. The principal revisions of the study included:
0 a new hydrogeologic interpretation that the layers
between the two aduifers are semi-confining, and
therefore, a potential for contamination of the
deeper aquifer zones exists,
0 the identification of several additional areas of scil
contamination requiring further evaluation, and
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0 discussions of additional potential source areas,
such as the Borrow Area, the Suspected East Overflow
Area and the Casual Dumping Area were expanded to
provide more detail on the histories and locations of
these areas.
After the RI, a Feasibility Study (FS) evaluating remedial
alternatives was performed by EPA and was released to the
public for comment in June 1988.
CERCLA Enforcement Activities
EPA issued general notice to CIBA-GEIGY in March 1984 to inform
the company of its potentially responsible party (PRP) status
and the Agency's intention of beginning the RI/FS process.
In October 1984, because of the numerous violations and criminal
actions related to the company's waste disposal activities, EPA
denied CIBA-GEIGY the opportunity to perform the RI/FS under
CERCLA. CIBA-GEIGY reimbursed EPA $1.08-5 million for RI/FS
expenditures in June 1985.
In May 1988, EPA sent general notice to eighteen PRPs who contri-
buted outside waste streams to the TPC/CIBA-GEIGY wastewater
treatment facilities.
CIBA-GEIGY has formally requested to conduct additional studies
needed to supplement the information obtained during the RI/FS
process and to implement the remedial action for the first operabl?
unit under EPA oversight. The company has publicly stated its
willingness to conduct remedial activities at the site. In additic
in a November 4, 1988 letter from CIBA-GEIGY to EPA, the company
submitted a statement of qualifications in support of its request.
CIBA-GEIGY confirmed its commitment in a March 8, 1989 letter to
EPA.
COMMUNITY RELATIONS
This project has included extensive community relations activities
and has received a significant amount of community input. Several
groups, including the Ocean County Citizens for Clean Water (OCCCv:
the Save Our Ocean Committee (SOOC), and the CIBA-GEIGY Oversight.
and Advisory Committee formed in response to concerns related to
the CIBA-GEIGY Superfund site and the ocean discharge pipeline.
Beginning in December 1984 and continuing throughout the PI/73
process, EPA met with citizens' groups and held several public
meetings to update the public on EPA's progress during the PI'FS.
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In April 1986 and again in 1987, OCCCW requested a Technical
Assistance Grant (TAG) from EPA. Since the regulations for
issuing TAGs had not been developed, EPA suggested that the
OCCCW request funding directly from CIBA-GEIGY. The company
agreed to provide a $50,000 grant to the citizens which
enabled them to hire technical consultants to review EPA's
and CIBA-GEIGY's work. Additional monies were later provided
to OCCCW by CIBA-GEIGY to allow the citizens' group to continue
to obtain the services of technical consultants.
At the request of OCCCW, EPA developed a process to increase
community involvement during the Feasibility Study. A series
of technical meetings with both CIBA-GEIGY and OCCCW and its
consultants was held during 1987 and 1988 to discuss EPA's
development of the FS. As part of this process, an early
draft of the FS was released to this group for input.
Proposed Remedy; Public Review
On June 23, 1988, EPA announced that the preferred alternative
for groundwater remediation was to pump and treat the contaminated
groundwater and discharge it through the existing CIBA-GEIGY
pipeline to the Atlantic Ocean. EPA also stated that discharge
to the Toms River, although producing a somewhat higher
public health risk, was also acceptable. This announcement
began a 60-day public comment period during which time a
public meeting was held on August 2, 1988.
Due to the extensive public opposition to EPA's preferred
remedy, EPA proposed to meet weekly with a group of Federal,
State and local public officials and citizens groups to
discuss potential alternatives to the ocean discharge. This
group included mayors from the nearby .towns and coastal
communities, and representatives of the local water companies,
health department, and several citizens' environmental groups,
NJDEP and CIBA-GEIGY. The weekly meetings began July 21 and
continued un_til October 27, 1988. EPA extended the formal
comment period to November 4, 1988 during which tine the
Agency evaluated additional alternatives proposed by the
group. Through this process, EPA was able to review a ranee
of remedies in an attempt to develop a remedy which was
acceptable to the Agency, NJDE? and much of the community.
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SCOPE OF THE OPERABLE UNIT WITHIN SITE STRATEGY
As is the case with many Superfund sites, the contamination
at the CIBA-GEIGY site is complex and extensive; it consists
of a wide range of chemicals emanating from many source
areas. The contaminants are present in leaking drums, waste
sludges, soils and the groundwater. The complexity of such
a situation necessitates addressing the contamination in
discrete phases, referred to as operable units.
This Record of Decision for the first operable unit focuses
on the remediation of groundwater contamination in the upper
aquifer. Groundwater contamination was selected as the first
operable unit of a multi-phase remedy because its nature
and extent are best understood, the remedy can be implemented
quickly, and it will reduce the most significant risk to
public health while alternatives for source remediation are
being evaluated.
Although EPA has conducted investigations of the waste disposal
areas, further investigatory work is necessary. As a result,
EPA has deferred remedy selection for the source areas until ~
the nature and extent of contamination are more fully under-
stood and treatability studies can be conducted. Remediation
of the on-site source areas and the deeper aquifer (if needed)
will.be addressed in future operable units. In this way, the
most significant public health concerns will be addressed by
preventing further off-site migration of groundwater contamina-
tion. It is possible that remediating the contaminant source
areas could shorten the time required to remediate the contaminated
groundwater.
SUMMARY OF SITE CHARACTERISTICS
EPA accomplished the following major tasks during the RI:
0 Historical geological, geophysical, hydrological, and •
chemical information was reviewed and evaluated.
0 Eight boreholes were drilled to identify waste disposal
areas. The wastes were sampled, analyzed and charac-
terized. Waste volumes were calculated and the impacts
of the waste deposits on groundwater, surface water and
biological systems were assessed.
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0 Fifty-nine monitoring wells were installed and the sub-
surface data generated during the drilling were employed
to determine and define the geology of the site area.
Groundwater was sampled and analyzed in August and October
1985 and February, June and September 1986.
0 Ground penetrating radar and terrain conductivity surveys
were conducted throughout the site.
0 One hundred eighty-nine shallow soil samples were col-
lected and analyzed for Hazardous Substance List (HSL)
parameters, indicator parameters, and dioxin to charac-
terize contamination of on-site soils.
0 Surface water, stream-bottom sediment, and insect popula-
tions were sampled at each of five locations along the
Toms River adjacent to the site to determine the impact
of the site on these systems.
0 A "No Action" public health evaluation was performed to
determine the potential impact of human exposure to
contaminants.
During EPA's performance of the RI, CIBA-GEIGY and its consultants
conducted parallel studies and additional investigations at the
site. The work included the installation and sampling of
additional monitoring wells, additional soil borings in some of
the source areas, and sampling in the marsh area. Information
from these investigations including data from more than 200
existing CIBA-GEIGY wells was used by EPA to supplement the
data gathered for this RI.
Remedial Investigation Conclusions
The major conclusions of the RI are as follows:
0 The two aquifers investigated at the site are separated
by a thirty foot thick semi-confining layer of silt and
clay located at an approximate depth of 100' below r^ear.
sea level.
0 Groundwater in the upper aquifer flows towards and discharges
into the Toms River. Site-related groundwater contamination
appears to be restricted to the upper aquifer. Althouch
most of the groundwater in the shallow aquifer ultimately
discharges into the Tons River, locally some contarination
has migrated a short distant beyond the Tons River. Ficure
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-12-
3 depicts the extent of volatile organic contamination in
the Upper Sand Aquifer. Figures 4 and 5 depict the total
concentration of volatile organic chemicals and inorganic
chemicals, respectively, found in monitoring wells during
the RI.
The semi-confining layer of silt and clay appears to have
prevented groundwater contamination from migrating into-
the lower aquifer. Unlike the shallow aquifer, groundwater
in the lower aquifer does not discharge into the Toms
River.
8 The Backfilled Lagoons and the Filtercake Disposal Area
contain large volumes of sludge; buried drums also appear to
be present. These waste disposal areas are unlined, and the
sludges in them contain significant concentrations of hazardous
substances which are contributing to contamination of the
shallow groundwater.
0 The inactive Drum Disposal Area is releasing hazardous
substances into the groundwater. The contaminants detected
in the groundwater downgradient of the Drum Disposal Area
closely match the chemicals known to have been disposed in
this area.
x
0 The surface soil sampling results reveal several areas
where inorganic chemical contamination exists. The inorganic
chemicals tend to be localized within the source areas.
There is evidence that inorganic contaminants are migrating
from the contaminated areas via surface water runoff.
0 The public health evaluation for human exposure to contaminants
emanating from the CIBA-GEIGY site indicates that, although
. at present no exposure exists, if no action is taken the
population will eventually be exposed to a potentially sig-
nificant risk. This is due to the fact that private drink-
ing water wells are located south and southeast of the site.
There is the potential that groundwater contamination could
migrate to these wells if no remediation were undertaken.
0 Potential routes of exposure include ingestion and dsrnal
exposure of contaminated groundwater from existing irrication
wells, and ingest ion of, dermal exposure to and inhalation of
contaminants in a marshland adjacent to the Toms Fiver.
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0 Approximately 95 chemicals were detected in the groundwater
and soils at the site. Of these 95 chemicals, 17 were
above MCLs. Some of the chemicals and contaminants
identified at the site include: benzene, chlorobenzene,
tetrachloroethene, trichloroethene, toluene, arsenic,
cadmium, chromium, copper and mercury. (NUS Remedial
Investigation, 1988.)
Appendix A lists the average and maximum concentrations of con-
taminants found in each of the media on and off site.
SUMMARY OF SITE RISKS
A public health evaluation (PHE) was performed for the CIBA-GEIGY
site to determine the impact of the site on public health and
the environment under various exposure scenarios and different
contaminant pathways. This evaluation is presented in the
"Quantitative Public Health Evaluation for the No Action
Alternative at the CIBA-GEIGY Site" (NUS, April 1988.)
The PHE identified 11 indicator chemicals in accordance with
the EPA Superfund Public Health Evaluation Manual. The
indicator chemicals selected for the CIBA-GEIGY Site are
compounds that are in the groundwater, have a history of use
and disposal at the site and were found in private wells off
site (refer to Appendix A). These compounds are listed below.
Carcinogens Noncarcinogens
Arsenic Barium
Benzene Cadmium
Chloroform Chlorobenzene
1,2-Dichloroethane Nickel
Tetrachloroethene 1,2,4-Trichlorobenzene
Trichloroethene
The PHE involves four steps. The first step is to identify
indicator chemicals to address the' potential public health
and environmental concerns associated with the site. The
next step is to use the toxicity of each chemical to deternir.e
whether the contaminants present at the site may be associated
with adverse health and/or environmental effects. The third
step identifies likely exposure scenarios and defines the
individuals who may be at risk via these exposure scenarios,
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as well as the most likely indicator compound concentrations
associated with these scenarios. The PHE at CIBA-GEIGY used
the maximum concentration of each indicator chemical detected
in the groundwater or marshland sediment. The.groundwater
concentrations used were not directly in a source area.
Air concentrations for the residential exposure routes were
calculated, while actual air concentrations found at the marsh-
land were used for the recreational exposure scenarios. The
final step in the process is the calculation of potential
risks associated with exposure to indicator chemicals.
In the PHE, individual contaminants were separated into two
categories of chemical toxicity depending on whether they
cause carcinogenic or noncarcinogenic effects. In the case
of chemicals exhibiting carcinogenic effects, exposures and
associated risks are expressed in an exponential nomenclature,
1 x 10-4 (one in ten thousand), 1 x 10-7 (one in ten.million) ,
etc. EPA has used the range of 1 x 10-4 to 1 x 10-7 in evaluat-
ing risk. For chemicals exhibiting noncarcinogenic effects,
exposures and associated risks are expressed as a ratio. This
ratio, called a Hazard Index, is estimated by dividing the
amount of a chemical that an individual might be exposed to
by the amount of the chemical that will not cause any adverse
health effects. A hazard index that is less than 1.0 indicates
that no adverse health impacts would be expected. Summaries
of the quantitations of carcinogenic risks and hazard indices
are presented for residential and recreational exposure routes
in Tables 1 and 2, respectively. The information in these tables
is discussed in subsequent paragraphs.
Human Exposure Routes
The human exposure assessment for the CIBA-GEIGY site included
the areas where the public could be exposed'to contaminants
migrating from the site. The data, which were obtained from
the five media, namely groundwater, surface water, soil,
sediments and air, indicated that human exposure to contaminated
groundwater, marshland sediments and air and contaminated river
water can occur.
The human exposure pathways were divided into two categories:
exposure due to residential uses of contaminated groundwater
and exposure due to recreational uses of a marshland adjacent
to the river and the river itself, all of which are receiving
contaminated groundwater. The residential exposure routes
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included ingestion, dermal absorption and inhalation of
contaminants from residential well water. The"recreational
exposure routes included ingestion, dermal absorption and
inhalation of contaminants from contaminated marshland sediments
and the river through activities such as fishing and swimming
in the river and walking in the marshland. These pathways
are particularly relevant to children who play in this area.
It should be noted, however, that the public health evaluation
used extremely conservative assumptions related to lifetime
exposures to chemicals from drinking, bathing, cooking, etc.
with contaminated water for seventy years.
Wells in the vicinity of the CIBA-GEIGY site are currently used
for residential purposes such as drinking, bathing and other
domestic activities, as well as agricultural purposes such as
watering lawns and gardens and filling swimming pools.
If an individual were to use a contaminated residential well
for domestic purposes, exposure could result from ingestion
of contaminated groundwater, dermal absorption of contaminants
through showering and other domestic activities, and inhalation
of contaminants volatilizing from sprayed water during activities
such as showering.
The RI indicates that the marshland adjacent to the Toms River
contains contaminated sediments. If an individual were to
walk in the marshland area, exposure to contaminants could
result from incidental ingestion of sediments, dermal absorp-
tion of contaminants from direct contact with sediments, and
inhalation of contaminants volatilizing from the marshland area
surface water. Exposure could also occur through fishing and
swimming in the river.
The potential for significant exposure through dermal contact
with, and incidental ingestion of on-site soils or wastes bv
trespassers is considered low due to the fact that much of
the site is fenced and the wastes are buried and covered.
Access to the site by unauthorized persons is restricted and
monitored by CIBA-GEIGY's site security personnel. Off-site
migration of contaminated soils does- not appear to be occurring.
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Summaries of the potential risks posed by each pathway evaluated
in the PHE are given in Tables 1 and 2. Under certain conditions
in which persons could be exposed to the contaminants through
residential uses, the risk of contracting cancer would increase
to 1 x 10-2. While this risk is significant, it is almost
entirely from the residential exposure routes. Carcinogenic
risk from human exposure from recreational uses alone is
estimated at 8 in a million population.
Since the Hazard Index, a measure of noncarcinogenic risks,
is greater than 1, chronic health effects due to exposure to
the noncarcinogenic contaminants at the site can occur. As
with the carcinogenic risk numbers, the Hazard Index is
almost entirely based on the residential exposure scenarios.
If all wells were to be, capped, the Hazard Index would drop
to below 1 and there would not be a chronic health hazard due
to recreational exposure routes alone.
The Agency for Toxic Substances and Disease Registry (ATSDR)
performed a Public Health Evaluation for the site. The Agency
agrees that the human exposure pathways of concern are from
oral, dermal and inhalation exposure to contaminated residential^
well water and contaminated surface water, sediment and air in
the marshland area. Ingestion of contaminated plants from
gardens or lawns irrigated with contaminated well water is
also possible.
Environmental Media Sampling
As has been stated previously, contaminated groundwater is
migrating from the site into the Toms River. A limited
number of water and sediment samples was taken in the river,
some of which indicated that low levels of trichloroethene
were found in the surface water and chlorobenzene and benzene
were found in the sediments.
Aquatic insect populations were surveyed along the Toms River.
No aquatic insects were found at the confluence of the river
and the CIBA-GEIGY cooling water discharge channel. This may
be attributable to either thermal effects from the cooling
water discharge or the trace levels of organics four.d in the
surface water.
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DESCRIPTION OF ALTERNATIVES
The major objectives of this first operable unit ROD are
mitigation of the effects of groundwater contamination on
public health and the environment and restoration of the Upper
Sand Aquifer to drinking water standards. These objectives
will be met by extracting both the contaminated groundwater
on site and the plume of contaminated groundwater which has
migrated off site and treating this contaminated groundwater
for discharge to either surface waters or the aquifer.
Applicable or Relevant and Appropriate Requirements
Section 121(d) of CERCLA, as amended by SARA, requires that
remedial actions comply with all applicable or relevant and
appropriate Federal and more stringent state requirements
(ARARs) for the hazardous substances, pollutants, or con-
taminants that are present and attributable to a site.
Applicable reauirements are defined as those cleanup standards,
standards of control, and other substantive environmental protec-
tion requirements, criteria or limitations promulgated under
Federal or State law that specifically address a hazardous
substance, pollutant, contaminant, remedial action, location
or other circumstance at a CERCLA site.
Relevant and appropriate requirements are those cleanup
standards, standards of control, and other substantive
environmental protection requirements, criteria or limitations
promulgated under Federal or State law that, while not
"applicable" to a hazardous substance, pollutant, contaminant,
remedial action, location or other circumstances at a CERCLA
site, address problems or situations sufficiently similar to
those encountered at the CERCLA site that their use is well
suited to the particular site.
Other information that does not meet the definition of ARAR
but may be useful in developing a CERCLA remedy is to be con-
sidered (TBC). Criteria, advisories, or guidance developed by
EPA, other Federal agencies, or States fall within the T3C
category.
There are three categories of reauirements with which Suoerfund
actions may have to comply, namely, location-specific (refer to
Appendix B), action-specific (refer to Appendix B and Tables 3
and 4) and chemical-specific (refer to Tables 5 and 6).
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Location-specific requirements are restrictions of activities
placed upon the concentrations of hazardous substances
or the conduct of activities depending on the site or its
immediate environs. Location specific requirements with
regard to the CIBA-GEIGY site pertain to the discharge of
treated groundwater to the Toms River or Atlantic Ocean.
ARARs for the remediation of the contaminated groundwater
include the Endangered Species Act of 1973; Executive Order
11990, Protection of Wetlands; Executive Order 11988, Protection
of Floodplains; New Jersey State Coastal Management Program;
and the National Historic Preservation Act.
Action-specific requirements set controls or restrictions on
particular kinds of activities related to management of
hazardous substances, pollutants or contaminants. Action-
specific requirements specify particular performance levels,
actions or technologies, as well as specific levels (or a
methodology for setting specific levels) for discharged or
residual chemicals. ARARs for discharge of treated groundwater
to the Atlantic Ocean include the Federal Register dated
November 5, 1987 Part IV 40 CFR Parts 414 and 416, Organic
Chemicals and Plastics and Synthetic Fibers Category Effluent
Limitations Guidelines, Pretreatment Standards, and New
Source Performance Standards: Final Rule (refer to Appendix
B). The specific standards based on the above regulation are
presented in Table 3 as the discharge criteria for the Atlantic
Ocean. Table 3A presents the concentration equivalents of
these criteria.
ARARs for discharge of treated groundwater to the Toms River
include the New Jersey State Surface Water Quality Standards
(NJSWQS) (refer to Appendix B) . New Jersey has proposed more
stringent and protective NJSWQS which are anticipated to be
promulgated in the near future. Due to their proposed status,
these standards would be classified as TBCs. After consultation
with New Jersey and in anticipation of promulgation, EPA has
chosen to use these proposed standards in developing the Tor.s
River discharge criteria (refer to Table 4). Table 4A presents
the concentration equivalents of these criteria.
Chemical-specific requirements are usually health or risk-
based concentration limits or ranges in various environmental
media for specific hazardous substances, pollutants or
contaminants. These requirements indicate an acceptable level
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of discharge (e.g., air emission or wastewater discharge takino
into account water auality standards) for remedial activity.
The New Jersey Safe Drinking Water Act (MCLs) are the reguired
cleanup standards for the aouifer, a current source of drinking
water, and for any treated groundwater which would be reinjected
into the aquifer. Tables 5 and 6 present the chemical-specific
ARARs for the site.
Components of Remedial Alternatives
The remedial alternatives for the first operable unit ROD are
divided into three components:
Component 1 - Groundwater Extraction,
Component 2 - Treated Groundwater Discharge, and
Component 3 - Groundwater Treatment.
The remedial alternatives which were evaluated for these com-
ponents are described below.
COMPONENT 1 - GROUNDWATER EXTRACTION ALTERNATIVES
The objective of Component 1 is to control the migration of
contaminated groundwater at the CIBA-GEIGY site and in off-site
areas and limit its migration into the Toms River. Five
remedial alternatives were evaluated in the FS ranging from a
No Further Action with Monitoring Alternative to the instal-
lation of extraction wells, reinjection wells and infiltration
basins.
After the release of the FS and during the public comment
period, EPA developed modifications of the original groundwater
extraction/reinjection scenarios evaluated in the FS. These
additional evaluations were performed in response to comments
and questions from the public. This work effort is presented
in the report entitled "Final Report - CIBA-GEIGY Technical
Enforcement Support Document, Groundwater Modeling Report,
CIBA-GEIGY, Toms River, New Jersey" (COM,'April 1939)".
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The extraction alternatives which were evaluated in this
decision document are listed in Table 7. The extraction
systems were designed to achieve three remedial objectives:
1) mitigate the groundwater contamination in the off-site
residential areas, 2) limit the migration of groundwater
contamination from the plant site and the property border,
and 3) limit the downward vertical migration of contaminated
groundwater and thus protect the semi-confined acuifer.
ALTERNATIVE GE-1 NO FURTHER ACTION WITH MONITORING
Implementation of this alternative would not eliminate or
reduce carcinogenic or chronic health risks associated with
exposure to contaminated groundwater. This alternative would
require only regular sampling and analysis of selected ground-
water wells, surface water and sediments to monitor the present
contamination. Groundwater contamination would continue to
move and disperse in an east-southeastward direction under
residential areas and into the Toms River.
The continued leaching of contaminants from source areas
could result in higher levels of contamination before natural
attenuation occurs.
The health risk associated with the No Further Action Alternative
is 1 x 10-2 due mainly to the ingestion of contaminated ground-
water from potable wells.
ALTERNATIVE GE-2 GROUNDWATER EXTRACTION
(GROUNDWATER MONITORING, SEALING OF
RESIDENTIAL WELLS)
This alternative consists of sealing contaminated residential
irrigation wells in the Cardinal Drive Area to prevent potential
human exposure to contaminated groundwater through the use of
these wells. At present, no drinking water wells in this
area have been found to be contaminated from the site. There
are no drinking water wells in the area of the plume and no
contamination has been found in drinking water wells which
exist south of the plume. However, there are contaminated
irrigation wells located within the CI3A-GEIGY croundwater
contamination plume.
It is estimated that twenty-eight extraction wells would be
installed and operated on the CIBA-GEIGY property and along
the Toms River (refer to Figure 6). Computer modeling efforts
have indicated that about 2.7 to 4.0 million gallons per day
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(MGD) of groundwater would need to be extracted to mitigate
groundwater contamination under this scenario. For estimating
purposes in this ROD, it was assumed that approximately 3.3
MGD of contaminated groundwater would be extracted. The
extraction wells would be placed so that they would most
effectively and efficiently capture the plume and produce or
maintain an upward groundwater flow gradient.
Groundwater cuality would be monitored quarterly. The rnon i tor ir.c
wells would aid in verifying the effectiveness of the ground-
water extraction well program.
One potential, constraint in implementing this alternative is
that extraction wells may create a relatively stagnant zone
of groundwater movement in the Cardinal Drive Area. As a
result, the cleanup time within this stagnant area is estimated
to be longer than for cases which include injection of clean
water or reinjection and/or infiltration of treated ground-
water. To address this potential concern, the remedial
design would be developed so as to minimize or eliminate the
stagnation effect by increasing the number of extraction
wells. Additional extraction wells would be added to assure
an upward groundwater flow gradient in this area and other
contaminated areas of the site. Creating an upward flow
gradient would cause contaminants to be drawn upward and
prevent them from migrating deeper into the aquifer system.
ALTERNATIVE GE-3 GROUNDWATER EXTRACTION WITH INJECTION
OF CLEAN WATER (GROUNDWATER MONITORING,
SEALING OF RESIDENTIAL WELLS)
This alternative is similar to Alternative GE-2 above with the
addition of three injection wells installed along the south-
eastern property border of the site. Clean water (from either
a deeper aquifer, a potable source or the Toms River) would
be injected into the Upper Sand Aquifer to promote a flushing
action in the Cardinal Drive area (refer to Figure 7). These
injection wells would accelerate the cleanup of the ccnta-inatec
groundwater and reduce the size of the stagnation zone which
occurs in Alternative GE-2. However, there is concern that
injection could cause some downward vertical migration of
contaminated groundwater. It is estimated that approximately
3.9 MGD would be extracted, treated and discharged with
approximatley 0.38 MGD of clean water injected through the
three injection wells.
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Additional constraints in implementing this alternative
include concerns related to the high maintenance reouired for
injection wells and the potential for clogging of both the
wells and tha aauifer from the precipitation of metals such
as iron in the aquifer.
COMPONENT 2 - GROUNDWATER DISCHARGE ALTERNATIVES
After extraction, the groundwater must be treated and discharged.
The type and level of treatment of the contaminated groundwater
is dependent on the discharge location selected. Table 3 lists
the alternatives for groundwater discharge. These alternatives
are described in subsequent paragraphs.
Treated Groundwater Holding Basins
During the public comment period, representatives of several
citizens' environmental groups requested EPA to evaluate the
use of holding basins for the treated groundwater prior to
discharge. The citizens' representatives stated that holding
basins could afford certain safeguards to public health and the
environment should unexpected problems arise with the groundwater^
treatment plant. As a result of this request, EPA evaluated
the function and benefits of these basins.
The holding basins would serve five beneficial functions:
1) provide retention capacity should a major problem
develop with the groundwater treatment plant;
2) provide equalization of the treated groundwater;
3) provide additional filtration of the treated
groundwater;
4) provide a certain amount of retention time durinc
which analyses could be performed to determine if the
treated groundwater were within discharge permit
limitations; and
5) provide public confidence of the groundwater treatment
and discharge systems.
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The construction and location of the holding basins would be
the same for all groundwater discharge alternatives with the
exception of Alternative GD-4, which would consist of treatment
at the Ocean County Utilities Authority and would therefore
not require retention basins. The basins would be.located in
the northeast quadrant of the site and would consist of
aboveground tanks. It is envisioned that two tanks, each with
a capacity of 4 million gallons, may be reauired. A thick
layer of sand and gravel would cover the bottom of the basins
and would serve to remove additional fines from the treated
effluent. After the treated groundwater filters through the
sand and gravel, it would be collected in an underdrain
system and then piped to the discharge point. The sand and
gravel layer would be periodically reconditioned in order to
maintain a satisfactory rate of infiltration.
Since these basins would be constructed above ground with
bottoms, they would not result in groundwater mounding that
could adversely effect the direction of groundwater flow or
groundwater contaminant migration. Should it be determined
that treated groundwater contained in the basins did not meet
discharge permit requirements, the basin contents would be piped
back to the treatment plant to be retreated.
An alternative to constructing new holding basins would be to
use the existing 75 million gallon emergency reservoir. This
would result in an estimated savings of up to $4 million.
For the ocean discharge option, treated groundwater from the
holding basins would be discharged directly into the existing
CIBA-GEIGY ocean outfall pipeline.
For the Upper Sand Aquifer recharge option, treated groundwater
would be directed from the holding basins to infiltration basins
and/or the reinjection well network.
Two options are possible for river discharge: direct discharge'
and indirect discharge. For the direct river discharge option,
treated groundwater would be fed directly from the holding basins
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-24-
to the Toms River via a pipe. The indirect river discharge option
would employ a network of gravel filled channels located along
the banks of the Toms River which would allow treated groundwater
from the holding basins to flow into the Toms River. Treated
groundwater from the holding basins would be distributed throughout
this seepage network by a system of pipes.
ALTERNATIVE GD-1 OCEAN DISCHARGE THROUGH THE EXISTING
CIBA-GEIGY PIPELINE
CIBA-GEIGY is currently discharging treated process wastewater
through its outfall to the Atlantic Ocean. Alternative GD-1
would continue this process by discharging the treated
groundwater into the ocean.
The company has recently announced that it will end using its
pipeline for ocean discharge of treated process wastewater by
December 31, 1991. By this date, CIBA-GEIGY's process flows,
laboratory wastewater and other miscellaneous flows would
decrease to approximately 600,000 gallons per day. This
volume would then either be sent to the OCUA for treatment or
treated and discharged to the Toms River.
Alternatives for Discharge to the Toms River
As previously discussed, the treated groundwater from the
holding tanks can be discharged to the Toms River either
directly by a pipe or by a network of channels.
ALTERNATIVE GD-2A DISCHARGE TO THE TOMS RIVER BY PIPE
In this alternative, the treated groundwater would be discharged
to the Toms River adjacent to the site by a pipeline from
the holding tanks.
ALTERNATIVE GD-2B DISCHARGE TO THE TOMS RIVER BY SEEPAGE NETWOPK
In this alternative, the treated effluent from the holding
tanks would be piped to a seepage network which consists of
perforated pipes placed in gravel-filled, concrete channels
which discharge to the Toms River.
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-25-
Alternatives for Discharge to the Upper Sand Aquifer
In these alternatives, some or all of the treated groundwater
would be recharged into the Upper Sand Aauifer. This could
be accomplished using reinjection wells and/or infiltration
basins.
ALTERNATIVE GD-3A DISCHARGE TO UPPER SAND AQUIFER
30% REINJECTION OF TREATED GROUNDWATER
As previously mentioned, additional groundwater recharge
scenarios were modeled and evaluated after the release of the
FS in response to comments from the public. One of the primary
objectives of these scenarios was to determine the maximum
volume of treated groundwater which could be recharged on-site
without causing negative impacts to the vertical or horizontal
groundwater flow regime. A primary consideration of the
groundwater remediation scenarios was maintaining the existing
groundwater flow field below the CIBA-GEIGY site. The maximum
amount of groundwater which could be returned to the aquifer
was determined with the stipulations that there would be no
reversal in the vertical groundwater gradient which would result
in pushing contaminants further down into the aquifer and no
change in the horizontal gradient which would affect the plume
of the off-site contamination located north/northwest of the
site. There is currently groundwater contamination in a
residential area adjacent to the northern property border
which groundwater modeling has shown could spread to uncontam-
inated areas as a result of the reinjection of large volumes of
water on the site. For this reason, in most cases, the ground-
water was recharged upgradient of the sources in the western
portion of the site. Specifically, the present groundwater
flow through the Semi-Confining Unit (separating the Upper
Sand Aquifer from the Lower Sand Aquifer) and the horizontal
flow patterns in the adjacent residential areas were used as
a baseline with which to compare changes in the flow regime
produced by each extraction/recharge scenario.
The following scenarios were evaluated as part of this analysis:
0 10%, 30%, 50% and 90% recharge of treated groundwatsr
using infiltration basins;
0 90% recharge of treated groundwater using reinjection wells;
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-26-
8 90% recharge of treated groundwater with 70% reinjectec
into a deep aauifer;
0 90% recharge of treated groundwater with 70% infiltrated in
the northeast portion of the site along the Toms River;
In each case, 10% of the treated groundwater was also returned
through reinjection wells in the Cardinal Drive Area.
These evaluations indicated that approximately 10 to 15% of the
extracted groundwater could be returned to the Upper Sand
Aquifer upgradient of the source areas without significantly
impacting the horizontal or vertical flow regime.
Using these analyses, it was concluded that as much as 30% of
the extracted groundwater could be reinjected or infiltrated
into the Upper Sand Aquifer (10 to 15% in the Cardinal Drive
Area and 10 to 15% upgradient of the source areas) without
negatively impacting the present groundwater flow conditions.
The remaining treated groundwater would need to be discharged
to a surface water or the municipal treatment plant.
ALTERNATIVE GD-3B DISCHARGE TO UPPER SAND AQUIFER
100% REINJECTION OF TREATED GROUNDWATER
In this alternative, the extraction wells would be placed as
in Alternative GE-3, however, all treated groundwater would
be recharged into the Upper Sand Aquifer through three
Cardinal Drive reinjection wells and 15 reinjection wells
installed along the southwestern and northwestern property
borders of the site (refer to Figure 8). The effluent would
be treated to drinking water standards before reinjection.
Approximately 4.0 MGD of contaminated groundwater would be
extracted, treated and reinjected into the Upper Sand Aauifer.
A constraint associated with this alternative is the altering
of the present groundwater flow direction and, consequently,
potentially spreading contamination in adjacent areas. The
groundwater contamination in the residential area to the
north of the site would be expected to spread to uncontam-.
inated areas.
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- 27 -
There is also the consideration that the reinjected groundwater
could force contaminants vertically downward through the
area's semi-confining layer into the deeper aquifer. The
maintenance problems related to reinjection wells (discussed
in Alternative GD-3A) would again be a concern in this alter-
native, and to a greater degree, as there are many more
reinjection wells and there is a much greater volume of water
being reinjected.
Concerns associated with this alternative include the high
maintenance required for the reinjection wells and the potential
of clogging of both the wells and the aauifer from the precipita-
tion of iron in the aquifer.
Finally, the increase in horizontal groundwater flow from the
reinjection of 4.0 MGD would make it more difficult to capture
all of the contamination before it reaches the river. As a
result, an increase in extraction well pumpage rates would be
required to capture the contaminated groundwater, although it
is estimated that groundwater cleanup times would be shorter
than those from previous alternatives.
Deep Aquifer Reinjection
Reinjection into the deeper aquifer was also simulated and
evaluated to determine the impact of deep aquifer reinjection
on the regional groundwater flow regime and the feasibility
of reinjecting treated groundwater into the deeper semi-confined
aquifer.
Evaluation of the deep aquifer reinjection scenarios revealed
the following: 1) reinjection into the Lower Sand Aquifer may
induce upward groundwater flow through the Semi-Confining
Unit to the Upper Sand Aquifer; and 2) treated groundwater
reinjected into the Lower Sand Aquifer could potentially migrate
into the public drinking water supply wells.
Deep aquifer reinjection was not considered further because
of the maintenance problems related to reinjection wells which
have -been previously discussed, the potential impact of the
treated contaminated groundwater on residential and public
supply wells, and the availability of other alternatives.
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-28-
ALTERNATIVE GD-3C DISCHARGE TO UPPER SAND AQUIFER
100% RECHARGE OF TREATED GROUNDWATER USING
REINJECTION WELLS AND INFILTRATION BASINS
In addition to the supplemental groundwater extract ion/reinjection
scenarios which were performed during the public comment period,
the differences between recharging groundwater through reinjection
wells versus infiltration basins were evaluated further. Two
significant differences between these methods were identified.
First, reinjection wells induce a greater horizontal flow component
in the Upper Sand Aquifer than do infiltration basins. This is
due to the fact that the reinjection wells are distributed over a
larger area in the western portion of the site. Thus, the water
tends to spread out more in a horizontal direction. However,
infiltration basins induce a greater vertical flow component
across the Semi-Confining Unit than do the reinjection wells.
This is due to the concentrated application of treated groundwater
in a smaller area. The horizontal component of flow decreases,
but because the water is concentrated in a smaller area, a
greater vertical flow component is produced.
Additional differences between reinjection wells and infil-
tration basins are that reinjection wells are more expensive
to operate and maintain and are more susceptible to fouling
than^are infiltration basins.
Alternative GD-3C is similar to Alternative GD-3B with the
exception that two infiltration basins would be designed to
infiltrate 3.7 MGD of treated groundwater in the western
portion of the site instead of the majority of reinjection
wells to recharge the Upper Sand Aauifer (refer to Figure 9).
The three Cardinal Drive wells would still be used to reinject
0.4 MGD to flush the residential area. The groundwater flow
patterns in this alternative are similar to those in Alternative
GD-3B, that is, significant changes in horizontal groundwater
flow direction are predicted to occur in nearby off-site con-
taminated areas. Additionally, the downward vertical migration
of contaminants is still a concern with this scenario. However,
the maintenance concerns related to well clogging would be
less than in Alternative GD-3B. Aquifer clogging problems
from the introduction of water into the aouifer would still
exist. Maintenance costs related to infiltration basins are
substantially less than those related to injection wells.
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-29-
Alternative Placement of Infiltration Basins
Placing the infiltration basins in other locations on site
(other than upgradient) was also evaluated during the public
comment period. However, in each case, either horizontal
flow was impacted in off-site areas, or downward vertical
gradients were created through the Semi-Confining Unit either
beneath contaminant source areas or where upward gradients
presently exist. Since one of the requirements of the groundwater
modeling effort was to maintain the present groundwater flow
conditions in the area, it was determined that the placement
of basins in the western portion of the site was necessary.
ALTERNATIVE GD-4 DISCHARGE TO OCEAN COUNTY UTILITIES AUTHORITY
For this alternative, after extraction, the groundwater would
be discharged to the OCUA treatment plant. The groundwater
would be pretreated, if necessary, in a CIBA-GEIGY treatment
system before being transported via pipeline to the OCUA
plant. Either the existing municipal sewerage system would
be used or, if the existing system is at hydraulic capacity,
a new pipeline would have to be constructed to transport the
groundwater. At the OCUA plant, the groundwater would receive
secondary treatment prior to discharge to the Atlantic Ocean
via the OCUA pipeline.
COMPONENT 3 - GROUNDWATER TREATMENT ALTERNATIVES
The four treatment options evaluated in the FS for the extracted
groundwater are the' following: the existing CIBA-GEIGY waste-
water treatment plant, a newly constructed on-site treatment
plant, the Ocean County Utilities Authority treatment facility
and an in-situ bioreclamation system.
During the extended public comment period, as part of the
supplemental FS effort, the groundwater treatment alternatives
were evaluated in more detail. This information is described
in a document entitled, "Final Report - CI3A-GEIGY Plant,
Groundwater Treatment Alternatives, Toms River, New Jersey"
(COM, April 1989) and is discussed in the following evaluation
of treatment alternatives.
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-30-
The alternatives involving groundwater treatment are listed
in Table 9. The information in this table indicates that the
groundwater alternatives include treatment in the existing
CIBA-GEIGY treatment facility, in a new on-site facility, at
the OCUA plant and in situ.
The objective of Component 3 is to treat the extracted ground-
water tc the level required in a New Jersey Pollution Discharge
Elimination System (NJPDES) permit for the appropriate discharge
point, namely the ocean, river or aquifer. These options can
be conducted through either an on-site treatment facility or
in situ or off site through the OCUA facility. The criteria
for on-site treatment for discharge to the ocean and river
are listed in Tables 3 and 4, respectively. The criteria for
on-site treatment for discharge to the aquifer are presented
in Tables 5 and 6. For all treatment alternatives, it was
assumed that the groundwater would be treated at a rate of
4 MGD.
Existing Wastewater Treatment Plant Operation
CIBA-GEIGY1s wastewater treatment plant currently maintains
tertiary treatment using biological activated sludge with
powdered activated carbon. The plant treats approximately
1.1 MGD of process wastewater, 0.5 MGD of contaminated ground-
water and 0.5 MGD of other miscellaneous flows such as laboratory
wastes, sanitary wastes, landfill leachate and stormwater
runoff.
A schematic of the existing treatment facilities is presented
in Figure 10. Influent wastewater initially undergoes pH
adjustment in two primary tanks before entering two eaualization
tanks. Chemical precipitation of metals and suspended solids
is then accomplished by adding ferric chloride and lime prior
to clarification. Subsequently, the flow enters the aeration
basin where powdered activated carbon (PACT*) is added for
biodegradation of organic contaminants. Finally, the wastewater
undergoes secondary clarification and is discharged to the
Atlantic Ocean through a ten-mile pipeline. Sludges fron
these processes are eventually disposed in the on-site Active
Landfill.
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-31-
CIBA-GEIGY Wastewater Treatment Plant Alternatives
As shown in Table 9, six alternatives were evaluated using
CIBA-GEIGY's wastewater treatment plant. Two possible influents
to the treatment plant were considered: groundwater combined
with process wastewater, and groundwater only. For each case,
the treatment plant was evaluated for treating the wastewater
to meet ocean discharge criteria. It is noted that an alternative
for treatment of contaminated groundwater combined with process
wastewater to meet river or aquifer discharge criteria was
not evaluated. The discharge of process wastewater is permitted
by the State of New Jersey, Division of Water Resources, and
is not regulated by CERCLA.
The treatment plant was also evaluated assuming the treatment
of groundwater only with discharge to either the Toms River
or the Upper Sand Aquifer (recharge). The choice of the
receiving water for the plant effluent determines what modifi-
cations are required for the existing plant to meet the permit
requirements of such a discharge.
ALTERNATIVE GT-lA CIBA-GEIGY WASTEWATER TREATMENT PLANT
COMBINED TREATMENT OF PROCESS WASTE AND
GROUNDWATER WITH DISCHARGE TO THE
ATLANTIC OCEAN
S.
The existing treatment plant was preliminarily evaluated in
the FS. It is believed that the current treatment plant, with
some modifications, could treat the combined waste streams.
However, pilot studies would be required to confirm this. It
should be noted that the volume and composition of process
wastewater has been decreasing and changing during the past
few years and will continue to exhibit this trend through
1991 as CIBA-GEIGY phases out additional processes.
ALTERNATIVE GT-1B CIBA-GEIGY WASTEWATER TREATMENT PLANT
SEPARATE TREATMENT OF PROCESS WASTE-
WATER AND GROUNDWATER WITH DISCHARGE
TO THE ATLANTIC OCEAN
The feasibility of utilizing the CIBA-GEIGY treatment plant
and hydraulically separating the process wastewater and
contaminated groundwater is dependent upon utilizing some
existing duplicate process units and constructing some new
process units in addition to new pumping and piping facilities.
The determination that the existing treatment facility could
handle the two separate waste streams was based on the assump-
tion that the need for redundant or standby units could be .
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-32-
waived. An existing 75 million gallon emergency reservoir is
available to provide temporary storage for process wastewater.
In addition, the groundwater extraction system could be shut
down for periods of time while system repairs are performed.
In order to divide the existing plant facilities for separate
treatment of the process wastewater and contaminated groundwater,
the following process modifications and additions would be
required:
1) an existing equalization tank would be converted to a
volatile organics stripping reactor;
2) an aeration basin would be modified to allow for the
addition of PACT*. A second aeration basin may also be
needed;
3) a secondary neutralization reactor would be refurbished
for chemical addition and pH control;
4) a flocculation tank would be added for metals removal;
5) a new sludge thickening tank would be installed; and
6) a carbon regeneration system consisting of a 30,000-gallon
holding tank and two wet air oxidation reactors would be
built.
!
Figure 11 shows this process train using the available units
with the proposed modifications and additions required to treat
the groundwater 'flow.
ALTERNATIVE GT-1C CIBA-GEIGY WASTEWATER TREATMENT PLANT
TREATMENT OF CONTAMINATED GROUNDWATER
ONLY WITH DISCHARGE TO THE ATLANTIC
OCEAN
To treat the contaminated groundwater in the CIBA-GEIGY
treatment plant to meet ocean discharge criteria, the foilowinc
modifications in existing units and new unit processes would
be required:
1) both equalization tanks would be refurbished for volatile
organic carbon removal;
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-33-
2) new mixers would be installed in the secondary neutrali-
zation reactors;
3) an aeration basin would be upgraded;
4) a new flocculation tank may be needed;
5) a new carbon regeneration system would be added.
Figure 13 shows the flow diagram of a modified plant for
treating groundwater only with discharge to the Atlantic Ocean.
It is envisioned that under this alternative, process wastewater
would be handled in a separate treatment facility either on
or off site. The handling of the process waste is not included
as part of this Record of Decision.
ALTERNATIVE GT-1D CIBA-GEIGY WASTEWATER TREATMENT PLANT
SEPARATE TREATMENT OF PROCESS WASTEWATER
AND CONTAMINATED GROUNDWATER WITH DISCHARGE
TO THE TOMS RIVER OR UPPER SAND AQUIFER
The discharge criteria for the Toms River or the Upper Sand
Aquifer require additional removal of volatile organics,
metals, and total dissolved solids. Significant plant modifi-
cations are deemed necessary in order to meet these discharge
criteria. Also, additional metals precipitation, carbon
adsorption, and solids removal with a reverse osmosis unit
would be required. Of note, is the need for the reverse osmosis
unit to reduce the total dissolved solids from an estimated
concentration of 2,000 mg/1 to 50 mg/1.
The modifications described for Alternative GT-1C'represent
the treatment operations which would treat the groundwater to
ocean discharge criteria. However, a greater degree of treat-
ment could be achieved by optimizing the chemical precipitation
of metals and operating two aeration basins in series.
The following new treatment processes would be applied to the
effluent from the secondary clarifiers:
1) a filtration unit to remove suspended solids, organics
and metals;
2) a reverse osmosis unit to remove dissolved solids (the
side stream generated fron this process would be treated
on site to reduce the volume and then disposed off site);
and
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-34-
3) 12 granular activated carbon units to remove residual
organic compounds;
Figure 13 shows the process modifications needed for treatment of
the groundwater through separation of the two waste streams
in the existing treatment plant.
ALTERNATIVE GT-1E CIBA-GEIGY WASTEWATER TREATMENT PLANT1
TREATMENT OF CONTAMINATED GROQNDWATER
' ONLY WITH DISCHARGE TO THE TOMS RIVER
OR UPPER SAND AQUIFER
The same treatment units described in Alternative GT-1D would
be required for this alternative. Figure 14 shows the process
modifications needed to treat groundwater only with use of
the entire treatment plant.
ALTERNATIVE GT-1F CIBA-GEIGY WASTEWATER TREATMENT PLANT
TREATMENT TO NONDETECTABLE LEVELS
During the extended public comment period, citizens' environ-
mental groups requested that treatment of contaminated ground-
water to undetectable levels also be evaluated to determine
the treatment requirements for attaining nondetectable levels.
In response to this request, process trains capable of treating
the contaminated groundwater to "nondetectable" levels were
also developed in the treatment report previously referenced
(COM, April 1989). Nondetection was defined as 0.5 micrograns
per liter (ug/1) for volatile organic compounds'. The treatment
requirements would be similar to those of Alternatives GT-1D
and GT-1E with the exception that a two-stage PACT* process
would be added to maximize removal of organics. The filtration
and reverse osmosis processes would remain the same. It is
estimated that the number of carbon adsorbers would be increased
from 12 to 24 units. Figures 15 and 16 depict the treatment
modifications necessary to achieve these discharge limits.
However, as will be discussed in subseauent sections of this
document, since there are other treatment alternatives that
would produce a high quality treated groundwater which would
be fully protective of public health and the environment, E?A
does not believe that the additional treatment costs to attain
nondetectable levels are justifiable. For this reason, treat-
ment to nondetectable levels will not be included as part of
the comparative analysis of alternatives according to the nine
remedial criteria.
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Alternatives for a Newly Constructed On-Site Wastewater
Treatment Plant:
As shown in Table 9, four alternatives involving the construction
of a new on-site wastewater treatment plant were evaluated.
Included were a physical/chemical treatment plant which was
conceptually designed in the FS and a separate biological
treatment plant which was designed in the treatment report
previously referenced (CDM, April 1989).
ALTERNATIVE GT-2A NEW PHYSICAL/CHEMICAL TREATMENT PLANT
WITH DISCHARGE TO THE ATLANTIC OCEAN
The major design elements for the physical/chemical treatment
plant were mecals and organics separation with flocculation/
sedimentation; volatile organics removal through air stripping,
and additional organics and inorganics removal by carbon
adsorption and filtration. In addition, it is envisioned that
a fixed-film, biological reactor would also be required to attain
the ocean discharge standards.
The process train required for such a plant would include the
following:
1) a rapid mix tank for coagulation;
2) a flocculation tank to precipitate metals;
3) an air stripper to remove volatile organics;
4) a fixed-film biological reactor;
5) a clarifier to settle suspended solids;
6) a gravity filtration, unit to remove particulates; and
7) a granular activated carbon system for additional carbon
adsorption.
Figure 17 illustrates the treatment train which would be recuired
for this alternative.
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ALTERNATIVE GT-2B NEW BIOLOGICAL TREATMENT PLANT WITH
DISCHARGE TO THE ATLANTIC OCEAN
The process train for this alternative consists of five stages
of contaminant removal:
1) iron, aluminum and particulate removal by coagulation,
sedimentation and filtration;
2) volatile organics removal through air stripping;
3) BOD and semi-volatile organics removal through an activated
sludge/PACT® system;
4) suspended solids removal .through sedimentation and filtration;
and
5) nonbiodegradable semi-volatile organics removal through
a PACT* system.
A schematic of the process train for this alternative is presented
in Figure 18.
ALTERNATIVE GT-2C NEW BIOLOGICAL TREATMENT PLANT WITH
DISCHARGE TO THE TOMS RIVER OR UPPER
SAND AQUIFER
The treatment processes required to discharge the treated
groundwater to the Toms River or Upper Sand Aauifer are
basically the same. The plant would be similar to that
discussed in Alternative GT-3B with the following modifications
and additions:
1) a carbon adsorption unit would be required for final
adsorption of organics;
2) a reverse osmosis unit would be added after the filtration
step to remove total dissolved solids which must be
reduced to less than 500 mg/1 for discharge to the acuifer
and to 50 mg/1 for discharge to the Toms River;
3) the reject stream from the reverse osmosis unit would be
treated by evaporation and then disposed off site.
Figure 19 shows the treatment processes for this alternative.
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- 37 -
ALTERNATIVE GT-2D NEW BIOLOGICAL TREATMENT PLANT WITH
TREATMENT TO NONDETECTABLE LEVELS
The treatment requirements for this, alternative are the same
as those described in Alternative GT-3C. However, for the
additional removal of organic contaminants which would be re-
quired to reach nondetectable levels, the sizes and/or numbers
of air strippers, vapor-phase carbon adsorption units and
liquid-phase carbon adsorption units would be expanded. Figure
20 illustrates the treatment units which would be required for
this alternative. For the reason stated under the discussion of
Alternative GT-1F, treatment to nondetectable levels will not
be included as part of the comparative anal/sis of alternatives
according to the nine remedial criteria.
ALTERNATIVE GT-3 OCEAN COUNTY UTILITIES AUTHORITY
WASTEWATER TREATMENT PLANT
The Ocean County Utilities Authority (OCUA) operates three
wastewater treatment plants of which the central plant serves
the areas surrounding the CIBA-GEIGY site. The central plant
achieves secondary treatment before discharging into the
Atlantic Ocean.
An OCUA facility would be a potential alternative for the
treatment of contaminated groundwater at the CIBA-GEIGY site.
However, there were several constraints and disadvantages
associated with this alternative:
i
1. The central plant does not have the hydraulic capacity to
handle the additional 4.0 MGD of contaminated groundwater.
2. The secondary treatment of the municipal plant does not
meet the level of treatment currently attained by CIBA-GEIGY.
Under this alternative, the contaminated groundwater would
undergo a lower degree of treatment and be discharged into
the Atlantic Ocean.
3. The northern and southern plants are located at excessive
distances from the CIBA-GEIGY site. Major modifications,
including constructing a pipeline from the CIBA-GEIGY plant
to a tie-in point for the northern and southern OCUA plants,
would be needed.
In consideration of the above, the OCUA was not considered
further as a treatment and discharge alternative for the
contaminated groundwater.
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ALTERNATIVE GT-4 IN SITU BIORECLAMATION SYSTEM
The in-situ bioreclamation alternative requires the use of
microorganisms in the ground to degrade the contaminants in
the groundwater. Figure 21 is a generalized flow sheet of
the system. Extraction wells located downgradient or within
the plume would collect the contaminated groundwater. The
groundwater would then be' pumped to surface-mounted bioreactors
in which microorganisms are acclimated to the specific chemicals
in the groundwater and to the desired subsurface environment.
The microbe-rich and nutrient-rich effluent from the bioreactors
would be reinjected into the subsurface via reinjection
wells. The biodegradation process would then continue in the
subsurface system.
The implementation of an in-situ biodegradation aauifer
restoration system is complicated at the CIBA-GEIGY site by
the large area of the contaminant plumes, the numerous con-
taminant sources, the diversity of organic and inorganic
contaminants and the depth of the contamination within the
aquifer. Comprehensive tests are needed to indicate whether
the groundwater can be acclimated to biological degradation,
what species of microorganisms are best suited, and site-specific1
kinetic considerations. There is concern regarding the level
of treatment achievable and the possibility of partially treated
or untreated contaminated groundwater continuing to migrate
from the site.
Operation and maintenance requirements of a bioreclamation ;
system are similar to those of a groundwater extraction and
treatment system. In addition, monitoring of physical and
chemical parameters such as dissolved oxygen, pH, nutrients
and organic constituents would be necessary.
Due to the uncertainties mentioned in the previous paragraphs,
in-situ bioreclamation was not considered further for the
treatment of the contaminated groundwater.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
EPA's selection of a remedial alternative must be in accordance
with the requirements of CERCLA, 42 U.S.C. Sees. 9601 et
seq., and the requirements of its governing regulations, the
National Oil and Hazardous Substances Pollution Contingency
Plan (NCP), 40 C.F.R. Part 300.
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-39-
In this section, the relative performance of the alternatives
are summarized by highlighting the key differences between
the alternatives in terms of nine criteria.
The nine remedial criteria summarize the recruirements of
CERCLA 121(b) and are as follows:
1. overall protection of human health and the environment,
2. compliance with applicable or relevant and appropriate
requirements (ARARS),
3. long-term effectiveness and permanence,
4. reduction of toxicity, mobility or volume,
5. short-term effectiveness,
6. implementability,
7. cost,
8. state acceptance and
9. community acceptance.
1. OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion addresses whether or not a remedy provides
adequate protection of human health and the environment and
describes how risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engineering controls,
or institutional controls.
COMPONENT 1:
ALTERNATIVE GE-1 NO FURTHER ACTION WITH MONITORING
This alternative would not result .in reducing the public
health and environmental risk associated with exposure to
contaminated groundwater. Specifically, contaminated ground-
water would continue to migrate off-site, potentially into
deeper aquifers, and into both public and private drinking
water supplies. Additionally, contaminated groundwater would
continue to migrate into the Toms River, potentially adversely
impacting aquatic populations.
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The long-term public health and environmental impacts of
selecting this alternative would be significant, if no further
action were taken and source control were not achieved.
COMPONENT 1:
ALTERNATIVE GE-2 GROUNDWATER EXTRACTION
ALTERNATIVE GE-3 GROUNDWATER EXTRACTION AND INJECTION OF
CLEAN WATER
The objective of both of these extraction scenarios is to stop
off-site migration of contaminated groundwater at the property
line, remediate the contaminated groundwater in the off-site
areas, and create upward vertical gradients beneath the
contaminant source, areas. The risks to public health and the
environment from current- and future-use exposure scenarios
would be mitigated, resulting in protection of public health
and the environment.
Alternative GE-2, extraction of contaminated groundwater with-
out any reinjection of treated groundwater or injection of
clean water, would produce a stagnation zone where contaminated'
groundwater may not migrate in any direction. This remedy,
by mitigating the contaminated groundwater and eliminating
the human exposure route, would be protective of human health
and the environment. Within the stagnation zone, there would
be the potential that exposure to contaminated groundwater
could persist longer than.in the cases of the other alternatives,
if residential wells were to be used in this area. This
situation could be alleviated if the extraction system were
designed so as to minimize or eliminate the stagnation zone.
Alternative GE-3 also consists of groundwater extraction.
However, the injection of clean water in the Cardinal Drive
residential area would create a flushing action which would
eliminate the stagnation zone discussed above and accelerate
the remediation of the off-site contamination. There would be
a possibility that the injection of water into the aquifer
could cause some horizontal or downward vertical migration
of contaminants. If this were to occur, and exposure to
contaminated groundwater were to result, protection of human
health and the environment would not be attained.
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COMPONENT 2:
ALTERNATIVE GD-1 DISCHARGE TO ATLANTIC OCEAN
ALTERNATIVES GD-2A and 2B DISCHARGES TO TOMS RIVER
ALTERNATIVES GD-3A, 3B and 3C DISCHARGES TO UPPER SAND AQUIFER
Risks that the public could be exposed to as a result of
discharging the treated groundwater into the ocean, the river
and back into the ground were calculated. They are as follows:
Discharge
Atlantic Ocean
Toms River
Risk
2
2
Upper Sand Aquifer | 2
x 10-7
x 10-8
x 10-5
The ocean and river discharge numbers were similar (approximately
one order of magnitude difference) with river discharge producing
a slightly lower risk. The risks ranged from two additional
cancer deaths in one hundred thousand (10-5) people exposed over
a seventy-year period (aquifer discharge) to two in one hundred
million (10-8) people (river discharge). The calculations were
based on human exposure via ingestion of contaminated water,
ingestion of contaminated fish and dermal exposure. The
calculations assumed the treatment process would meet the
discharge limitations set by NJDEP.
The above risk numbers can be used to compare one discharge
alternative to another. For the purpose of comparison, the
risk due to exposure to the river discharge is 10 times less
than the risk due to exposure to the ocean discharge, and
1000 times less than the risk due to exposure to the recharged
water in the aquifer. This risk assessment for groundwater is
based upon exposure to treated groundwater only. If an altered
groundwater flow regime results in moving contaminated ground-
water into adjacent areas or into the deeper aquifer, and thus,
into private or municipal drinking water wells, the risks from
exposure increase to unacceptable levels.
Among the various discharge alternatives for the Upper Sane
Aquifer, it is expected that Alternative GD-3A, 30% Reinjection,
would alter the flow regime less than Alternatives GD-3B or
GD-3C, which include 100% recharge. This is due to the lesser
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volume of water being reinjected into the aauifer. Thus, the
potential among the aauifer recharge alternatives, to spread
contamination to drinking water wells is lowest for GD-3A.
Therefore, GD-3A would be more protective of human health and
the environment than GD-3B or GD-3C.
In summary, while the risk to human health of any of the
discharge alternatives is within acceptable levels, the river
discharge is the least risky, the ocean discharge is slightly
more risky, while reinjection into the ground is the most
risky.
COMPONENT 3: .
ALTERNATIVES GT-1A to IE UTILIZING EXISTING CIBA-GEIGY
WASTEWATER TREATMENT PLANT
ALTERNATIVES GT-2A TO 2C UTILIZING A NEW SEPARATE TREATMENT
PLANT
All of the above treatment alternatives, if implemented to
meet appropriate discharge levels, would be protective of
human health and the environment. It should be noted, however*
that treating the contaminated groundwater to the levels regui4
for discharge to the Toms River would be most protective,
treatment to levels required for ocean discharge would be
second, and treatment to levels recjuired for discharge to the
aquifer would be the least protective.
2. COMPLIANCE WITH ARARS
This criterion addresses whether or not a remedy will meet
all of the applicable or relevant and appropriate requirements
(ARARS) of other environmental statutes.
As discussed previously, Tables 5 and 6 list the ARARs for
remediating the Upper Sand Aquifer and discharging treated
groundwater back into the aquifer. Tables 3 lists the ARARs
for the Atlantic Ocean discharge and Table 4 presents the T3C
values for the Toms River discharge. Appendix B lists the
additional location-specific and action-specific ARARs which
may be required for various activities related to the extraction
treatment and discharge of the groundwater.
COMPONENT 1:
ALTERNATIVE GE-1 NO FURTHER ACTION WITH MONITORING
This alternative would not result in attaining the Federal
and State ARARs. Since the contaminants would continue to be
present in the groundwater, the aquifer would not be in
compliance with the standards required for a drinking water
aqui fer.
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COMPONENT 1:
ALTERNATIVE GE-2
ALTERNATIVE GE-3
GROUNDWATER EXTRACTION
GROUNDWATER EXTRACTION AND INJECTION OF
CLEAN WATER
Both groundwater extraction scenarios would be implemented
until ARARs (MCLs) are attained in the aquifer. If the
groundwater extraction system designed under Alternative GE-2
results in a stagnation area, the ARARs would not be attained
in this area. If Alternative GE-3 pushes contaminants downward
into the lower aquifer, ARARs would not be attained in this
area.
During the remedial design of the extraction system, a wetlands
assessment will be performed in the marshland area to evaluate
both the contamination present in this area and the potential
impacts of the extraction system on the wetlands. This is re-
quired under Executive Order 11990, Protection of Wetlands.
Also, the proposed remedial design will be reviewed to ensure
that it is consistent with the New Jersey State Coastal Zone
Management Program.
COMPONENT 2:
ALTERNATIVE GD-1
ALTERNATIVES GD-2A and 2B
DISCHARGE TO ATLANTIC OCEAN
DISCHARGES TO TOMS RIVER
During the remedial design for any of the discharge scenarios,
a floodplains assessment will be performed to ensure that the
location of the holding basins will not violate the requirements
of Executive Order 11988, Protection of Floodplains.
For any of these Alternatives: GD-1, GD-2A and GD-29, conta-
minated groundwater would be treated to the levels required
by the Clean Water Act and would therefore be expected to rr.eet
ARARs and TBC values for the discharges to the Toms River.
These discharge criteria are considered to be protective of
most aquatic organisms including species protected under the
Marine Mammal Protection Act and the Endangered Species Act
of 1973. As with the holding basins discussed above, the
seepage network in Alternative GD-2B would be located such
that any floodplains protection requirements would be met.
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COMPONENT 2:
ALTERNATIVES GD-3A, 3B and 3C DISCHARGES TO UPPER SAND AQUIFER'
Any treated groundwater which would be recharged into the
Upper Sand Aquifer (a public drinking water source) would be
treated to drinking water standards and would therefore be
expected to meet ARARs. Potentially for Alternative GD-3A
and most likely for Alternatives GD-3B and GD-3C, if the
reinjected groundwater moves contamination into areas where
the contamination does not presently exist, or into the
deeper aquifer through the semi-confining unit, groundwater
ARARs would not be attained in these areas.
Additionally, any requirements under the Underground Injection
Control Regulations for the injection of treated groundwater
into a drinking water source would be met for these alternatives.
COMPONENT 3:
ALTERNATIVES GT-lA TO IE UTILIZING EXISTING CIBA-GEIGY
WASTEWATER TREATMENT PLANT
ALTERNATIVES GT-2A TO 2C UTILIZING A NEW SEPARATE TREATMENT
PLANT
For each of the treatment scenarios discussed in Alternatives
GT-lA to IE and GT-2A to 2C, the treatment plant would be expected
to meet the appropriate discharge criteria for each discharge
alternative (Atlantic Ocean, Toms River or Upper Sand Aquifer.)
To ensure that the treatment plant would function as. reauired,
pilot studies would be conducted to develop the operating and
design criteria to meet the necessary degree of treatment.
Since the ARARs for ocean discharge are less stringent, they
are more likely to be met than the ARARs for the Toms River
and Upper Sand Aquifer discharges.
3. LONG-TERM EFFECTIVENESS AND PERMANENCE
This criterion refers to the ability of a remedy to maintain
reliable protection of human health and the environment over
time, once cleanup goals have been met.
COMPONENT 1 :
ALTERNATIVE GE-1 NO FURTHER ACTION WITH MONITORING
Performance of only site monitoring activities without taking
any action to control migration of groundwater contamination
would not provide for long-term effectiveness in protecting
human health and the environment. There would continue to be
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groundwater contamination which poses a threat to public
health. The magnitude of the public health and environmental
risks would remain unchanged and potentially increase, if
contaminant leaching from sources were to increase.
COMPONENT 1:
ALTERNATIVE GE-2
ALTERNATIVE GE-3
GROUNDWATER EXTRACTION
GROUNDWATER EXTRACTION AND INJECTION OF CLEAN W
For both of these alternatives, the groundwater contamination
would be reduced to levels which are protective of public
health. However, for both scenarios, there is some degree of
uncertainty that all of the contamination will be remediated.
If a stagnation zone is formed in the Cardinal Drive residential
area in Alternative GE-2, some groundwater contamination
would be left indefinitely and long-term effectiveness would
not be attained. The stagnation zone in Alternative GE-2
would be eliminated in Alternative GE-3 by flushing with clean
water. However, this flushing action may push contaminants
downward into the lower aquifer again placing human health
and the environment at risk.
Alternative GE-2 would be expected to be more effective in
achieving long-term protection than Alternative GE-3, if the
stagnation zone were eliminated. As stated previously, this
could be accomplished by increasing the number of wells.
COMPONENT 2:
ALTERNATIVE GD-1
ALTERNATIVES GD-2A and 2B
ALTERNATIVES GD-3A, 3B and 3C
DISCHARGE TO ATLANTIC OCEAN
DISCHARGES TO TOMS RIVER
DISCHARGES TO UPPER SAND AOUIFER
Alternatives GD-1, GD-2A and 2B would provide long-term
effectiveness. Alternatives GD-3A, 3B and 3C may not provide
long-term effectiveness if the recharge of treated groundwater
spreads contamination either vertically or horizontally to
other areas.
There is a greater likelihood that contamination may be
pushed horizontally and/or vertically into uncontaminated
areas (off site or into a deeper zone of the aquifer) in
Alternatives GD-3B and GD-3C than in Alternative GD-3.A.
Thus, Alternatives GD-3B and GD-3C are the least likely to
attain long-term protection of human health.
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COMPONENT 3:
ALTERNATIVE GT-1A TO IE UTILIZING EXISTING CIBA-GEIGY
WASTEWATER TREATMENT PLANT
ALTERNATIVE GT-2A TO 2C UTILIZING A NEW SEPARATE TREATMENT
PLANT
Alternatives GT-1A, GT-1B, GT-1C, GT-2A and GT-23 (ocean
discharge) are expected to provide the same degree of long-term
effectiveness. The alternatives utilize existing technologies
which have been used frequently for treatment of industrial
and hazardous wastes. All of these treatment alternatives are
reliable and present no major operational problems provided
proper maintenance is performed.
It is less certain whether Alternatives GT-1D, GT-1E and
GT-2C (river or aquifer discharge) can provide the same
degree of long-term effectiveness as the other treatment
alternatives discussed above. Pilot studies will be reouired
to develop the design criteria for meeting the discharge
limitations for the river and aquifer.
4. REDUCTION OF TOXICITY, MOBILITY 'OR VOLUME
This criterion refers to the anticipated performance of the
treatment technologies, with respect to these parameters,
that a remedy may employ.
COMPONENT 1:
ALTERNATIVE GE-1 NO FURTHER ACTION WITH MONITORING
By allowing the contaminated groundwater to continue to migrate
off site and into the Toms River, this alternative would not
reduce the toxicity, mobility or volume of contamination either
on or off site. The sources would continue to contribute to
the groundwater contamination and therefore, the volume of
contaminants in the groundwater may actually increase.
COMPONENT 1:
ALTERNATIVE GE-2 GROUNDWATER EXTRACTION
ALTERNATIVE GE-3 GROUNDWATER EXTRACTION AND INJECTION OF CLEAN
These alternatives do not reduce toxicity. However, both of
these alternatives significantly reduce the volume of conta-
minated groundwater by extracting it from the ground and
eliminating further migration of contaminants. Alternative
GE-2 attains the greatest reduction of contaminants except
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for the stagnation zone because no reinjection of treated
water occurs. Assuming that the stagnation zone associated
with Alternative GE-2 is eliminated or minimized, Alternatives
GT-2 and GT-3 would be effective in reducing contaminants.
However, since reinjection may produce a downward migration
of contaminants, this alternative may be potentially less
effective.
COMPONENT 2:
ALTERNATIVE GD-1
ALTERNATIVES GD-2A AND 2B
ALTERNATIVES GD-3A, 3B AND 3C
DISCHARGE TO ATLANTIC OCEAN
DISCHARGES TO TOMS RIVER
DISCHARGES TO UPPER SAND AQUIFER
This criterion is generally not applicable to Alternatives
GD-1, GD-2A and GD-2B, as these discharge options do not reduce
toxicity, mobility or volume of contaminants. Alternatives
GD-3A, GD-3B and GD-3C include returning the treated groundwater
to the Upper Sand Aquifer and in these cases, some low residual
levels of contaminants would be returned to the aquifer system
and the quantity or volume of contaminants in the aquifer
would be greater than that for the alternatives which do not
include recharge. Alternatives GD-3B and GD-3C place the
greatest amount of contaminants back into the aquifer because
100% of the treated groundwater is recharged.
COMPONENT 3:
ALTERNATIVES GT-lA TO IE
ALTERNATIVES GT-2A TO 2C
UTILIZING EXISTING CIBA-GEIGY
WASTEWATER TREATMENT PLANT
UTILIZING A NEW SEPARATE TREATMENT
PLANT
All of the above treatment plant alternatives woul
toxicity, mobility and volume of waste by removing
from the groundwater and treating them.
would reduce the
contarinants
If the groundwater were treated to nondetectable levels, the
toxicity, mobility and volume of waste in the groundwater
would be reduced to the greatest extent. Discharge to the
Toms River requires the second most stringent levels; the
aquifer discharge scenario has the third most stringent
requirements, with the ocean discharge criteria being the
least stringent.
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5. SHORT-TERM EFFECTIVENESS
This criterion addresses the period of time needed to achieve
protection and any adverse impacts on human health and the
environment that may be posed during the construction and
implementation period until cleanup goals are achieved.
COMPONENT 1:
ALTERNATIVE GE-1 NO FURTHER ACTION WITH MONITORING
This alternative would take no time to implement as the
monitoring wells which would be used currently exist. This
alternative presents no short-term risks to on-site workers
or the community, however, it provides little or no protection
to human health and the environment.
COMPONENT 1:
ALTERNATIVE GE-2 GROUNDWATER EXTRACTION
ALTERNATIVE GE-3 GROUNDWATER EXTRACTION AND INJECTION OF
CLEAN WATER
Both of these alternatives reduce the threat to public health
in generally the same length of time, although Alternative GE-2
would take longer than Alternative GE-3 by not including some
form of groundwater recharge. Also, each alternative takes
approximately the same amount of time to implement.
Short-term risks to workers are associated with installation
of the collection system and through direct contact pathways
with contaminated water resulting from pipeline leaks and
normal construction hazards during remedial action. These
risks can be mitigated through the use of appropriate controls
and adherence to proper health and safety protocols during con-
struction activities.
COMPONENT 2:
ALTERNATIVE GD-1 DISCHARGE TO ATLANTIC OCEAN
ALTERNATIVES GD-2A AND 2B DISCHARGES TO TOMS RIVER
ALTERNATIVES GD-3A, 3B AND 3C DISCHARGES TO UPPER SAND AQUIFER
Alternative GD-1 would require the least time to implement
since the ocean discharge pipeline is already in existence.
Alternatives GD-2A and 2B would require a small amount of
time to construct the pipeline or seepage network to the Toms
R i ve r.
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Alternatives GD-3A, 38 and 3C would require the installation of
reinjection wells or infiltration basins. Piping systems to
transport the treated groundwater to the reinjection wells or
infiltration basins would also have to be designed and constructed
These discharge alternatives would require significantly more
time to implement than either Alternatives GD-1, GD-2A or
GD-2B.
It should be noted that the length of time required to implement
a remedy for this operable unit is dependent upon the length
of time needed to perform pilot studies and design and construct
the treatment plant (as discussed in Component 3.) Any of the
discharge alternatives can be implemented concurrently with
the treatment alternatives.
The short-term risks to .workers for Alternatives GD-2A, GD-2B,
GD-3A, GD-3B and GD-3C include those presented by normal
construction hazards during the construction and operation
activities. The risks can be mitigated through adherence to
proper health and safety protocols.
COMPONENT 3:
ALTERNATIVES GT-lA TO IE
ALTERNATIVES GT-2A TO 2C
UTILIZING THE EXISTING CIBA-GEIGY
TREATMENT PLANT
UTILIZING A NEW SEPARATE TREATMENT
PLANT
The following lists the estimated times required to implement each
of the treatment and discharge options for Alternatives GT-1
and GT-2.
Ocean-Existing Plant
Ocean-New Plant
Toms River-Existing Plant
Toms River-New Plant
(GT-lA,
(GT-2B)
(GT-1D,
(GT-2C)
IB, 1C)
IE)
34-36 months
38-44 months
38-44 months
48-54 months
It is noted that the alternatives generally will recuire
between 3 and 4.5 years to implement. Alternatives GT-lA, IB
and 1C require the least amount of time to implement. Although
the plant is currently built and operating, pilot studies for
an ocean discharge would be reauired before plant modifications
could be designed and constructed.
Pilot studies would also be reauired for Alternatives GT-2A
and 2B for discharge to the Atlantic Ocean. A new plant
would then have to be designed and constructed before any
groundwater remediation would occur.
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The discharge criteria for the Toms River and Upper Sand Aquifer
are more stringent than for the ocean discharge criteria.
Due to the additional treatment processes required to meet
river/aquifer discharge criteria, the pilot studies required
for the river discharge Alternatives GT-1D, IE and 2C would
be more extensive than for the ocean discharge Alternatives
GT-1A/ IB, 1C and 2B and therefore the river discharge alternative
would require a longer time to implement.
For all treatment plant alternatives, short-term risks to
workers include those presented by normal construction hazards
during the construction and operation and maintenance of the
plant. The risks can be mitigated through adherence to
proper health and safety protocols.
6. IMPLEMENTABILITY
This criterion addresses the technical and administrative
feasibility of a remedy, including the availability of materials
and services needed to implement a particular option.
COMPONENT 1: .
ALTERNATIVE GE-1 NO FURTHER ACTION WITH MONITORING
This alternative, requiring only groundwater monitoring, is
the simplest to implement. It has no construction or land
requirements. The monitoring wells which would be utilized
in this alternative are currently in existence and would
require no construction activities.
COMPONENT 1:
ALTERNATIVE GE-2
ALTERNATIVE GE-3
GROUNDWATER EXTRACTION
GROUNDWATER EXTRACTION AND INJECTION OF
CLEAN WATER
Alternatives GE-2 and GE-3 can be implemented without construc-
tion difficulties and in a relatively short period of time.
There is some concern related to potential operation and
maintenance problems associated with the injection of clean
water into the aquifer under Alternative GE-3. Therefore,
Alternative GE-2 is believed to be the more implementable of
the two alternatives, since no reinjection is included in
this scenario.
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COMPONENT 2:
ALTERNATIVE GD-1
ALTERNATIVES GD-2A AND 2B
DISCHARGE TO ATLANTIC OCEAN
DISCHARGES TO TOMS RIVER
It is expected that the discharge alternatives for the ocean
and river are implement able. The ocean discharge pipeline
currently exists and is in use, and the construction materials
for the discharge to the Toms River are available, as well as
the land required for construction. However, if at some
future time, the use of the ocean discharge pipeline is
banned by law, the ocean discharge alternative would not be
implement able.
COMPONENT 2:
ALTERNATIVES GD-3A, 3B AND 3C RECHARGE TO UPPER SAND AQUIFER
The construction materials and land required for the injection
and reinjection wells and infiltration basins used in these
alternatives are available. There is some concern that
recharging the large volume of water into the aquifer in
Alternatives GE-3B and GE-3C will create operation and main-
tenance problems. The concern is due to the possibilty of
clogging from metals precipitation and bacterial growth in
the wells and basins and in the aquifer. Therefore, since
Alternative GD-3A includes only 30% reinjection, this alterna-
tive is believed to be more implementable than Alternatives
GD-3B or GD-3C.
COMPONENT 3:
ALTERNATIVES GT-lA TO IE
ALTERNATIVES GT-2A TO 2C
UTILIZING THE EXISTING CIBA-GEIGY
WASTEWATER TREATMENT PLANT
UTILIZING THE NEW SEPARATE TREATMENT
PLANT
Alternatives GT-lA, GT-lB, GT-1C, GT-2A and GT-2B, (ocean
discharge) can be readily implemented. The proposed treatment
technologies and equipment required for construction of any
treatment plant modifications or additions are available.
There is less certainty regarding the implementability of
Alternatives GT-1D, GT-lE and GT-2C (treatment with discharge
to .the Toms River or Upper Sand Aquifer). Pilot studies will
be required prior to implementation of the groundwater treatment
system to develop the design criteria to ensure attainment of
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the discharge criteria. The requirements for discharge to the
Upper Sand Aquifer are less stringent than the requirements
for discharge to the Toms River/ and thus, slightly more
implementable.
7. COST
This criterion includes estimated capital, operation and main-
tenance costs and net present worth costs. The costs estimates
are summarized in Tables 10A, 10B and IOC, respectively, for
Component 1, the Extraction Alternatives, Component 2, the
Discharge Alternatives and Component 3, the Treatment Alterna-
tives. Detailed information regarding the assumptions which
were made in developing these costs is presented in the
groundwater-modeling and treatment documents previously
referenced (COM, April 1989).
For Component 1, the No Further Action with Monitoring Alterna-
tive is the least costly alternative with a present worth
value of approximately $5.2 million. Alternative GE-2,
Groundwater Extraction only, would cost approximately $10.0
million. However, if the stagnation zone were to be eliminated
in this alternative, the cost would increase to approximately
$13.5 million. Alternative GE-3, with some reinjection would
cost approximately $13.2 million.
For the Component 2 alternatives, the cost of discharging to
the Atlantic Ocean via the existing pipeline is estimated at
$3.7 million. The costs of discharging to the Toms River are
estimated at $864,000 for discharge through a pipe, versus
$1.7 million for discharge via a seepage network.
For the alternatives related to discharge to the Upper Sand
Aquifer, the cost for Alternative GD-3A (with 30% reinjection)
is estimated to be $22.1 million. Alternative GD-33 (100%
recharge using reinjection) is estimated to be S24.2 million
and Alternative GD-3C (with 100% recharge using reinjection
wells and infiltration basins) is estimated to be $20.0 million
For the Component 3 alternatives, the present worth
treat the groundwater are as follows:
values to
Existing CIBA-GEIGY Wastewater
Treatment Plant
GT-1A (ocean) $ 58,921,000
GT-1B (ocean) $ 63,909,000
GT-1C (ocean) $ 58,921,000
GT-1D (river/aquifer) $155,099,000
GT-1E (river/aquifer) $150,115,000
GT-1F (nondetect) $158,136,000
New On-Site Treatment
Plant
GT-2A (ocean) S 66, ^B,
GT-2B (ocean) S ~>l,^2,
GT-2C (river/acuifer ) 5157,344,
GT-2D (nondetect) 3181,315,
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This information indicates that the costs to treat the groundwater
for discharge to the ocean range from approximately $59 million
to $72 million. The costs for Toms River or Upper Sand Aquifer
discharge range from approximately $150 million -to $167 million.
The main difference in costs between the Atlantic Ocean and
Toms River/Upper Sand Aquifer scenarios is due to the reverse
osmosis and activated carbon units which are required to
remove additional total dissolved solids and residual organic
compounds from the groundwater.
The reverse osmosis unit would result in high operation and
maintenance costs due to the production of a large sidestream
flow which is concentrated in total dissolved solids. The
sidestream would be first treated on site to reduce the
volume and the remaining concentrated stream will be disposed
off site.
It is noted that if the existing facility were modified to
provide treatment to nondetectable levels, the cost for
modifying the existing plant is estimated to increase from
approximately $150 million (Alternative GT-lE) to $158 million.
Similarly, the cost for building a new plant to achieve
nondetectable levels is estimated to increase from approximately
$167 million (Alternative GT-2C) to $182 million.
8. STATE ACCEPTANCE
This criterion addresses the concern and degree of support
that the state government has expressed regarding the remedial
alternatives being evaluated.
COMPONENT 1:
ALTERNATIVE GE-1 NO FURTHER ACTION WITH MONITORING
This alternative would not adequately reduce the public health
and environmental risks posed by the contaminated groundwater.
In addition, neither Federal or State ARARs would be met.
Therefore, the State would not support this alternative.
COMPONENT 1:
ALTERNATIVE GE-2 GROUNDWATER EXTRACTION
ALTERNATIVE GE-3 GROUNDWATER EXTRACTION AND INJECTION OF
CLEAN WATER
NJDEP concurs that the contaminated groundwater should be
extracted and treated. The State has indicated that it would
not want reinjected water to force contaminants into the
lower aquifer.
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COMPONENT 2:
ALTERNATIVE GD-1 DISCHARGE TO ATLANTIC OCEAN
ALTERNATIVES GD-2A and 2B DISCHARGES TO TOMS- RIVER
The state would accept any of these discharge alternatives
provided all discharge criteria are met.
COMPONENT 2:
ALTERNATIVES GD-3A, 3B and 3C RECHARGE TO UPPER SAND AQUIFEF
The NJDEP would accept these alternatives, only if none of the
reinjected groundwater would migrate off site or into deeper
subsurface zones. All.reinjected water would have to be re-
captured downgradient by the extraction wells.
COMPONENT 3:
ALTERNATIVES GT-1A TO IE UTILIZING THE EXISTING CIBA-GEIGY
WASTEWATER TREATMENT PLANT
ALTERNATIVES GT-2A to 2C UTILIZING THE NEW SEPARATE TREATMENT
PLANT
The NJDEP would accept any of these treatment alternatives.
The NJDEP agrees with EPA that pilot studies will be required
to develop the design criteria for treating the contaminated
groundwater to the stringent levels required for ocean, Toms
River/ or aquifer discharge.
9. COMMUNITY ACCEPTANCE
This section summarizes the public's general response to the
alternatives described in the Proposed Remedial Action Plan,
the RI/FS reports and the weekly meetings held through the
extended public comment period. Specific responses to public
comments are addressed in the Responsiveness Summary which is
an attachment to this document.
COMPONENT 1:
ALTERNATIVE GE-1 NO FURTHER ACTION WITH MONITORING
This alternative would not be acceptable to the public, as the
threat to public health and the environment will not be reduced.
Contamination would continue to spread and could contaminate
additional wells.
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COMPONENT 1:
ALTERNATIVE GE-2
ALTERNATIVE GE-3
GROUNDWATER EXTRACTION
GROUNDWATER EXTRACTION AND INJECTION OF
CLEAN WATER
The public is in general agreement that the contaminated ground-
water should be extracted and treated.
COMPONENT 2:
ALTERNATIVE GD-1 DISCHARGE TO ATLANTIC OCEAN
The public, particularly those who live along the shore, is
adamantly opposed to discharging the treated groundwater to
the ocean.
COMPONENT 2:
ALTERNATIVES GD-2A AND GD-2B DISCHARGES TO TOMS RIVER
Some of the public is against discharging the treated groundwater
to the Toms River, however, for the majority of the public,
this is preferable to the ocean discharge.
As described in a previous section of this document, the
majority of the public favors a seepage network for discharging
the treated groundwater into the Toms River rather than a single
pipeline.
COMPONENT 2:
ALTERNATIVES GD-3A, 3B AND 3C RECHARGE INTO UPPER SAND AOUIFER
Many people prefer this alternative and would like the water
reinjected back into the aauifer. However, some nembers of
the public who live adjacent to the site share EPA's concerns
regarding the possibility of spreading contamination in other
areas such as Pine Lake Park and into deeper subzones of the
aquifer. Additionally, the water companies in the area are
concerned that reinjection may spread contamination to their
wells.
COMPONENT 3:
ALTERNATIVES GT-lA TO 1E UTILIZING EXISTING CIBA-GEIGY TREATMENT
PLANT
ALTERNATIVES GT-2A TO 2C UTILIZING THE NEW SEPARATE TREATMENT PI
The public expressed major concerns related tc the level of
treatment achieved, the point of discharge, and whether the
groundwater woul.d be treated separately or combined with the
-------
-56-
CIBA-GEIGY process waste. The public wants the groundwater
to be treated to the most stringent standards possible and
want the groundwater treated separately from the process
waste. In addition, as discussed in an earlier section of
this document, the public indicated a strong preference for
using holding basins for the treated groundwater prior to
discharge.
SELECTED REMEDY
The EPA has been explicitly directed by Congress in Section
121(b) of CERCLA, as amended, to select remedial actions
which utilize permanent solutions and alternative treatment
technologies or resource recovery options to the maximum
extent practicable. In addition, the Agency is to prefer
remedial actions that permanently and significantly reduce
the mobility, toxicity or volume of site wastes.
A) Description of the Selected Remedy
After careful review and evaluation of the alternatives presented
in the Feasibility Study as achieving the best balance of all
evaluation criteria, on June 23, 1988, EPA presented that ex-
traction and treatment of the contaminated groundwater and
discharge of the cleansed water to the Atlantic Ocean was the
best alternative. Since the risks to public health and the
environment from both an ocean or river discharge were low,
EPA indicated that a river discharge would also be an acceptable
alternative.
Due to the strong concerns expressed by the public regarding
the ocean discharge and the public's request to explore other
alternatives and the existing alternatives in greater detail,
EPA extended the public comment period to November 4, 1988
and conducted additional studies and evaluations, the results
of which were presented to members of the public, CIBA-GEIGY
and State and local governments. The input which EPA received
during the public comment period is presented in the Responsive-
ness Summary, which accompanies this report.
Based on the results of supplemental studies and evaluations
and the information contained in the. original Feasibility
Study, and input received during the public comment period,
EPA has chosen the following alternatives for the remedy for
the first operable unit at the CIBA-GEIGY site:
-------
-57-
0 Component 1 GE-2
0 Component 2 GD-2A
Component 3 GT-1E
Groundwater Extraction,
Discharge to the Toms River
by Pipeline
and
CIBA-GEIGY Wastewater Treatment
Plant-Treatment of Contaminated
Groundwater Only
As indicated above, EPA's selected remedy is essentially the
same as the proposed remedy with the exception that the
treated groundwater will be discharged to the Toms River
rather than the Atlantic Ocean. EPA believes that there are
several considerations and factors that make the selected
remedy/ which includes a river discharge, a unique determination
for the site. Currently/ the CIBA-GEIGY ocean outfall is the
only direct industrial discharge from a chemical manufacturing
facility in the State of New Jersey. EPA is aware that there
is pending state legislation to prohibit such discharges.
Furthermore, in late 1988/ EPA under former . Administrator Lee
Thomas , issued the Agency's National Coastal and Marine
Policy recognizing the serious degradation of the nation's
coastal and marine waters. One of the goals of this policy
is to minimize the use of coastal and marine waters for waste
disposal. Also, the federal Ocean Dumping Ban Act prohibits
new permits for ocean dumping for industrial and acid wastes
by 1991. In addition/ within the last two years, two major
industries, namely, Allied Chemical and E.I. du Pont de
Nemours & Company have voluntarily discontinued their practices
of ocean dumping industrial wastes. As indicated in an
earlier section of this document, CIBA-GEIGY also intends to
terminate the use of its existing ocean outfall for process
wastes by December 31, 1991.
It is due to primarily these circumstances and events as well
as the opposition and concerns voiced by the general public
that EPA has decided not to include ocean discharge as part
of the selected remedy for the first operable unit of the
CIBA-GEIGY site.
The major components of the Remedial Action are as follows:
0 Sealing contaminated residential irrigation wells in the
Cardinal Drive area to prevent human exposure to conta-
minated groundwater.
Installation of an extraction well system both on and
site to capture the contaminated groundwater in the
off
-------
-58-
off-site areas and stop migration of contaminated ground-
water at the property line. The system will be designed
such that the stagnation zone produced in Alternative GE-2
will be eliminated or minimized to the maximum extent
practicable. In addition, the system will be"designed to
limit the downward vertical^migration of contaminants and
protect the semiconfined aquifer by creating an up flow
gradient. The exact design of the extraction system will
be determined during the design phase of the project.
The quality of the deeper aquifer will also be evaluated
during the design phase.
0 Extraction of contaminated groundwater at a rate estimated
between 2.7 and 4 MGD until the federal and state cleanup
standards listed in Tables 5 and 6 are met to the maximum
extent that is technically practicable.
0 After extraction, treatment of the contaminated groundwater
separately from process wastewater in the existing CIBA-GEIGY
wastewater treatment plant. This will be accomplished by
modifying the wastewater treatment plant to accommodate
only the groundwater flow. Any process wastewater would
be treated in a separate facility. However, during the
pilot and design phases an evaluation for modifying the
existing CIBA-GEIGY wastewater treatment plant to accommodate
the (hydraulically) separate treatment of both the groundwater
and process wastewater will be made to determine if any
cost savings can be realized. The contaminated groundwater
will be treated to the discharge levels required by the
NJDEP, and determined to be practicable based on pilot
studies; the levels will be developed based on the Effluent
Limitations Guidelines for the Organic Chemicals and
Plastics and Synthetic Fibers Category (40 CFR Parts 414
and 416) and the 1988 proposed New Jersey State Surface
Water Quality Standards for discharge to the Toms River
(refer to Table 4).
0 Conduct of pilot studies to confirm the practicability of
achieving the discharge levels and to develop the design
and operating criteria for the treatment processes and
design modifications to the existing CIBA-GEIGY treatment
plant which will be required to meet the Toms River discharge
criteria. If based on the results of pilot studies, EPA
determines that the above-mentioned effluent standards
are technically impracticable or cannot be achieved, then
an evaluation will be made to determine the standards
that can be achieved.
-------
- 59 -
0 After treatment, the groundwater will be retained in basins
to allow monitoring of residual levels prior to discharge
through a pipeline to the Toms River. The use of a diffuser
for the discharge will be evaluated during.the remedial
design phase.
Additional activities which will be performed as part of this
ROD are the following:
0 Monitoring of the Toms River will be performed during the
design phase of this project. The monitoring will provide
a baseline for current water quality in the river upstream,
downstream and adjacent to the site. The data generated
from the monitoring effort will be used to supplement
existing information in assessing the current impact of
the contaminated groundwater on the Toms River. Monitoring
will continue during the implementation of the remedial
action to evaluate the effects of the extraction system
and discharge over time.
0 Groundwater monitoring will be performed while the extrac-
tion system and treatment plant modifications are being
designed and will continue during the implementation of
the remedial action.
The purpose of the river and groundwater monitoring program
as indicated above is twofold:
1. The river monitoring will provide a baseline to which
the effects of all future activities can be compared.
By obtaining data on present river water Quality
conditions, the effects of the extraction system,
when operational, and river discharge can be measured
and evaluated.
2. The groundwater and river monitoring program will
generate information to ensure that, while the pilot
studies and treatment plant design are being performed,
the groundwater contamination problem is not migrating
further and the quality of the Toms River is not
deteriorating. If it appears that the contamination
may be spreading either laterally or vertically, the
option may exist to pump and treat the contaminated
groundwater and discharge it to the ocean.
-------
-60-
The costs (expressed as present worth values) associated with
the selected alternatives are the following:
Alternative GE-2 S- 13,500,000
Groundwater Extraction
(modified to eliminate stagnation
zones and enhance upflow gradients)
Alternative GD-2A S 900,000
Discharge to Toms River by pipe
Alternative GT-1E $150,100,000
(CIBA-GEIGY Wastewater Treatment
Plant for Discharge to Toms River)
Total Estimated Cost of Remedy $164,500,000
It is noted that the above values do not include the costs for
river monitoring. It is further noted that the cost may be
reduced by up to $4 million by using the 75 million gallon
emergency reservoir in place of the two holding tanks.
Pre-design work including, but not limited to pilot studies
and preliminary engineering are estimated to take approximately
8 months to complete. Design of the selected remedy is
estimated to take an additional 12 months. The time required
to construct the remedy is estimated to be approximately 18
to 24 months. Therefore, the estimated timeframe to implement
the selected remedy is 38 to 44 months.
B) Future Work
A Supplemental Remedial Investigation will be reauired to
characterize adequately the nature and extent of the contami-
nant sources, both known and suspected, and to study the
Lower Sand Aquifer further. Upon completion of the Supplemental
Remedial Investigation, a Feasibility Study will be conducted
to develop and evaluate remedial alternatives. A subsequent
ROD(s), which will document the selection of a remedy for the
control of the sources of contamination and will address the
remediation of the Lower Sand Aquifer (if necessary), will be
prepared.
-------
- 61 -
THE STATUTORY DETERMINATIONS
Protection of Human Health and the Environment
The selected remedy is protective of human health and the
environment in that the contaminated groundwater will be
controlled and treated on site and remediated in off-site
areas. In addition, the remedy will significantly reduce the
toxicity and volume of contaminants in the groundwater and
prevent further degradation of groundwater quality in the
Upper Sand Aquifer. It will mitigate the risk to public
health by eliminating the principal threat posed by the site,
i.e., ingestion of contaminated groundwater from public and
residential wells.
The contaminated groundwater will be treated to the required
limits before discharging to the Toms River, thereby reducing
the toxicity and volume of contaminants. The extraction and
treatment of the contaminated groundwater will produce no short-
term risk to public health and the environment.
Attainment of Applicable or Relevant and Appropriate Requirements
During development of the Feasibility Study, applicable or
relevant and appropriate requirements, (ARARs) and to be
considereds (TBCs) were established for groundwater remediation
based on current EPA guidance.
Location-Specific
The remedy will comply with all location-specific ARARs. The
floodplain will be evaluated during the designs of the extraction
system and the holding basins. As required by Executive Order
11988, Protection of Floodplains, the remedial design will include
efforts to minimize potential harm and avoid adverse effects
to the floodplain area.
The wetlands will also be evaluated during the design of the
groundwater extraction system. Executive Order 11990,
Protection of Wetlands, requires that actions be taken to
minimize the destruction, loss or degradation of wetlands.
The discharge of the treated groundwater will comply with all
requirements of the Endangered Species Act of 1973 and the
Marine Mammal Protection Act. EPA has consulted with the
Department of Commerce (National Oceanic and Atmospheric
Administration) (NOAA) on the proposed remedies and NOAA has
concurred that the remedy is protective of endangered or
threatened species.
-------
-62-
During the remedial design, the requirements of the New Jersey
State Coastal Management Program will be evaluated to ensure
that remedial activities are consistent with the Coastal
Management Program.
Also during the remedial design, the site and the remedial
action will be reviewed to determine the potential impacts to
cultural resources which could result from the remedial
activities as required under National Historic Preservation
Act.
Action-specific
The remedy will comply with all Clean Water Act requirements
for discharge of treated groundwater to the Toms River. The
groundwater will be treated to the levels listed in Table 4.
These values were derived from the proposed New Jersey State
Water Quality Standards and are TBCs. In anticipation of
promulgation of the proposed standards, EPA has chosen to use
them in developing the Toms River discharge criteria.
Chemical-specific
The aquifer will be remediated to the New Jersey MCLs listed
in Tables 5 and 6. These standards are applicable requirements
for a drinking water aquifer.
X
Cost Effectiveness
EPA believes that the Selected Remedy affords the highest
overall effectiveness proportionate to its cost. The Selected
Remedy will be designed to maximize the removal of contaminant
mass from the aquifer. The groundwater will then be treated
to the levels required for discharge to the Toms River. The
costs of treatment for a river discharge are greater than for
ocean discharge because the river discharge criteria are more
stringent than ocean discharge criteria. Thus, a greater
proportion of pollutants are removed. EPA believes that the
benefits in terms of the total volume of contaminants removed
justify the added costs involved.
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Practicable
This remedy represents the best balance of the nine criteria
and is determined to be the most appropriate remedy for the
site at this time. It utilizes permanent solutions by extract-
ing and treating the contaminated groundwater and uses alter-
native treatment technologies to th maximum extent practicable
-------
-63-
The groundwater treatment will reduce the contaminants of
concern to health protective levels. After treatment of the
off-site groundwater is complete, the aquifer will no longer
present potential future risk to the public health; neither
monitoring nor management will be required.
The groundwater at the site will continue to become contami-
nated as long as the sources of contamination remain. There-
fore, the extraction wells pumping the on-site groundwater
contamination will continue until the contamination sources
and the groundwater are remediated. The sources will be
investigated and remediated in the second operable unit.
Preference for Treatment as a Principal Element
The Selected Remedy satisfies the statutory preference for
remedies employing treatment that permanently and significantly
reduces the toxicity, mobility or volume of hazardous substances.
The Selected Remedy includes the installation and operation
of extraction wells for contaminant recovery. Contaminated
groundwater pumped from the extraction wells will be treated
in the existing CIBA-GEIGY treatment plant before being dis-
charged to the Toms River. This pumping and treatment is
expected to reduce permanently and significantly the toxicity,
mobility, and volume of the hazardous substances in the
groundwater at the site and in the off-site areas.
-------
TABLE 1
TOTAL "NO ACTION" CARCINOGENIC RISKS AND CHRONIC HAZARD EVALUATION
FOR RESIDENTIAL EXPOSURE ROUTES
Exposure Route Carcinogenic Total Chronic
Risk Hazard3
Ingestion of Water From 1 x 10-2 4 x 10
a Residential Well
Dermal Absorption of Water 1 x 10-5 l x 10-2
From a Residential Well
Inhalation Exposure 5 x 10-5 8 x 10-1
From Residential Well Water
The total carcinogenic risk per million people exposed is:
1 x 10-2.
The total chronic hazard is: 4 x 10.
a The chronic hazard is the ratio of the amount of a chemical
to which an individual might be exposed to the amount of the
chemical that will not cause any adverse effect. A hazard
index that is less than 1.0 indicates that no adverse health
impacts would be expected.
-------
TABLE 2
TOTAL "NO ACTION" CARCINOGENIC RISKS AND CHRONIC HAZARD EVALUATION
FOR RECREATIONAL EXPOSURE ROUTES
Exposure Route Carcinogenic Total Chronic
_ Risk Hazard^
Ingestion of Surface 4 x 10-9 7 x 10-6
Water From the Toms
River
Ingestion of 1 x 10-6 6 x 10-6
Marshland Sediment
Ingestion of Fish 2 x 10-6 4 x 10-2
Which Inhabit the
Toms River
Dermal Absorption of 2 x 10-8 7 x 10-5
Surface Water From the
Toms River
Dermal Absorption of 6 x 10-8 3 x 10-5
Contaminants From
Marshland Sediment
Inhalation of Contaminated 2 x 10-10 4 x 10-6
Air From the Toms River
Inhalation of Contaminated 5 x 10-6 8 x 10-3
Air in the Marshland
The total carcinogenic risk per million people exposed is:
8 x lO'6.
The total chronic hazard is: 5 x 10-2.
a The chronic hazard is the ratio of the amount of a chemical
to which an individual might be exposed to the amount of the
chemical that will not cause any adverse effect. A hazard
index that is less than 1.0 indicated that no adverse health
impacts would be expected.
-------
TABLE 3
ACTION-SPECIFIC ARARs
DISCHARGE CRITERIA FOR THE ATLANTIC OCEAN (MASS UNITS)*
POLLUTANT
4 MGD DISCHARGE TO TH'E
ATLANTIC OCEAN (kq/day)
averaqe/maximum
Benzene
Chlorobenzene
Chloroform
Chlorinated Benzenes
1 ,2-Dichloroethane
Carbon Tetrachlor ide
Ethylbenzene
Toluene
Dichloroethenes
1 ,1-Dichloroethene
Trans -1 ,2-Dichloroethene
Tetrachloroethene
Trichloroethene
1 , 1 ,1-Trichloroethene
Methylene Chloride
1 , 2-Dichlorobenzene
1 , 3- Di Chlorobenzene
1, 4- Di Chlorobenzene
Total Dichlorobenzenes
Bis(2-Ethylhexyl)Phthalate
Naphthalene
Nitrobenzene
Phenol
1 ,2 ,4-Tri Chlorobenzene
Vinyl Chloride
Cadmium
Chromium Trivalent
Chromium Hexavalent
Total
Copper
Lead
Nickel
Zinc
Arsenic
Pentavalent
Trivalent
Mercury
Selenium
Iron
TSS
TDS
Petroleum Hydrocarbons (mrj/1)
Acute toxicity (LC50)-%eff
Chronic Toxicity (NOEC)-%eff
pH Standard Units
0.561/ 2.060
0.227/ 0.425
0.318/ 0.698
*231
1.030/ 3.200
0.273/ 0.576
0.485/ 1.640
0.394/ 1.219
*3400
0.243/ 0.379
0.318/ 0.819
0.334/ 0.849
0.318/ 0.819
0.318/ 0.819
0.607/ 1.350
1.170/ 2.470
0.470/ 0.667
0.227/ 0.425
*29.9
1.560/ 4.230
0.334/ 0.895
0.409/ 1.030
0.227/ 0.394
1.030/ 2.120
1.580/ 4.060
1.516/ 3.033
*156
*89.5
3.030/ 6.060
*5.19
2.270/ 4.550
11.40 /22.70
7.580/15.20
3.030/ 6.060
*23.3
*64.4
0.045/ 0.091
*96.6
22.7 /45.5
_
_
10 /15
*50
*8.5
6 minimum - 9 maximum
A minimum 85% TOC removal is required when influent TOC >100 mq/1.
When influent TOC is <100 mq/1, a maximum TOC effluent limitation
of 15.0 mg/1 is required.
+Technology based discharge criteria except where noted.
*Federal Water Quality Criteria
-------
ACTION-SPECIFIC ARARs
DISCHARGE CRITERIA FOR THE ATLANTIC OCEAN fCONCENTRATION UNITS
>er 9. 1988)
POLLUTANT
DISCHARGE TO THE ATLANTIC
QCEANfua/1)
*Benzene
*Chlorobenzene
*Chloroform
^Chlorinated Benzenes
*1,2-Dichloroethane
*Carbon Tetrachloride
*Ethylbenzene
*Toluene
+Dichloroethenes
*1,1-Dichloroethene
*Trans-l,2-Dichloroethane
*Tetrachloroethene
*Trichloroethene
^1,1,1-Trichloroethane
*Methylene Chloride
*1,2-Dichlorobenzene
*1,3-Dichlorobenzene
*1,4-Dichlorobenzene
*Total Dichlorobenzenes
*Bis(2-Ethylhexyl)Phthalate
*Naphthalene
*Nitrobenzene
*Phenol
*1,2,4-Trichlorobenzene
*Vinyl Chloride
*Cadmiuin
Chromium
•fTrivalent
+Hexavalent
*Total
•^Copper
-(-Lead
^Nickel
+Zinc
Arsenic
-»-Pentavalent
•••Trivalent
•fMercury
-t-Selenium
*Iron
TSS (mg/1)
TDS (mg/1)
Petroleum Hydrocarbons (mg/1)
Acute Toxicity (LC50)-%eff
Chronic Toxicity (NOEC)-%eff
pH Standard Units
37.0
15.0
21.0
129.0
68.0
18.0
32.0
26.0
224,000.0
16.0
21.0
22.0
21.0
21.0
40.0
77.0
31.0
15.0
1,970.0
103.0
22.0
27.0
15.0
68.0
104.0
100.0
10,300.0
50.0
500.0
2.9
5.6
8.3
86.0
13.0
36.0
0.025
54.0
1,500.0
10.0
>50.0
>8.5
6.0 - 9.0
*Technology based discharge criteria.
•(•Federal Water Quality Criteria.
-------
TA5LE 4
PROPOSED DISCHARGE CRITERIA FOR THE TOMS RIVER (.MASS UNITS)
TO BE CONSIDERED
POLLUTANT
4 MGD DISCHARGE TO THE
TOMS RIVER (kg/day)
WATER QUALITY BASED - DIFFUSER
NO DIFFUSER
Benzene
Chlorobenzene
Chloroform
1 , 2-Dichloroethane
Carbon Tetrachlor ide
1 ,1-D ichloroe thene
Trans-1 , 2-Dichloroe thene
Tetrachloroethene
Tr ichloroe thene
Methylene Chloride
1,2,4-Trichlorobenzene
Vinyl Chloride
Cadmium
Chromium Trivalent
Chromium Hexavalent
Total
Copper
Lead
Nickel
Zinc
Arsenic
Mercury
Selenium
Iron
TSS
TDS
Acute Toxicity (LC50)-%eff
Chronic Toxicity (NOEC)-%eff
pH Standard Units
0. 1704
0.6816
0.0324
0.3408
0.3408
0.3408
1.0704
0.1704
none
0.3408
1.364
. 3.408
1 .70
5.28
1.88
8.52
0.28
8.52
3.75
2.56
8.52
0.34
1.70
92.9
5270
2934
50
89
4 minimum - 7
0.0151
0..0606
0.0029
0.0303
0.0303
0.0303
0. 1515
0.0151
detect ed
0.0303
0.1212
0.303
0.1511
0.4693
0.1671
0.7573
0.0245
0.7573
0.3333
0.2276
0.7573
0.0302
0.1511
15.2
607
758
50
100
maximum
TECHNOLOGY BASED
average/maximum
Ethylbenzene
Toluene
1 / If 1-Tr ichloroe thane
1 , 2-Dichlorobenzene
1 , 3-Dichlorobenzene
1 /4-Dichlorobenzene
bis(2-Ethylhexyl)Phthalate
Naphthalene
Nitrobenzene
Phenol
Petroleum Hydrocarbons-mg/1
0.485/1.6-4
0.394/1.219
0.318/0.819
1.170/2.470
0.470/0.667
0.227/0.425
1.560/4.230
. 0.334/0.895
0.409/1.030
0.227/0.394
10 /15
A minimum of 95% TOC removal is required when influent TOC >100
mg/1. When influent TOC <100 mg/1, a maximum TOC effluent
limitation of 5.0 mg/1 is required.
**Toms River discharge is
quality based discharge
based discharge
the more stringent of the water
criteria or the average technology
-------
TABLE 4 A
PROPOSED DISCHARGE CBITEBIA FOR TOMS RIVER (CONCENTRATION UNITS)**
TO BE CONSIDERED
(Revised December 9, 1988)
POLLUTANT
DISCHARGE TO THE TOMS RIVER
fua/11 (no diffuser)
Benzene
Chlorobenzene
Chloroform
1,2-Dichloroethane
Carbon Tetrachloride
*Ethylbenzene
*Toluene
1,1-Dichloroethene
Trans-1,2-Dichloroethene
Tetrachloroethene
Trichloroethene
*1,1,1-Trichloroethanfe
Jfethylene Chloride
*1,2-Dichlorobenzene
*1,3-Dichlorobenzene
*l,4-Dichlorobenzene
*bis(2-Ethylhexyl)Phthalate
*Naphthalene
*Nitrobenzene
*Phenol
1,2,4-Trichlorobenzene
Vinyl Chloride
Cadmium
Chromium
Trivalent
Hexavalent
Total
Copper
Lead
Nickel
Zinc
Arsenic
Mercury
Selenium
Iron
TSS mg/1
TDS mg/1
Acute Toxicity
(LC50) - % eff
Chronic Toxicity
(NOEC) - % eff
pH Standard Units
1
4
0.19
2
2
32
26
2
10
1
1
21
2
77
31
15
103
22
27
15
8
2
10
31
11
50
1.65
50
22
15
50
2
10
1000
40
459
>50
>100
4-7
* Pollutant criteria that are technology based.
**Toms River discharge is the more stringent of the water
quality based discharge criteria without diffuser or the
average technology based discharge.
6 or 1.33 times background where the discharger demonstrates
the increase will not adversely affect the aquatic biota.
-------
TABLE 5
CHEMICAL-SPECIFIC ARARs FOR GROUNDWATER PROTECTION
NEW JERSEY DRINKING WATER STANDARDS; JANUARY. 1989
CONTAMINANTS
(mg/L unless otherwise
notedj
TREATED WATER
Physical:
Turbidity
Color
Odor
Total Dissolved Solids
Microbiological:
Total Coliform
Inorganic Chemicals:
Arsenic
Barium
Cadmium
Chloride
Chromium
Copper
Corrosivity
Fluoride
Foaming Agents
Hardness (as CaCO3)
Iron
Lead
Manganese
Mercury
Nitrate
pH Units
Selenium
Silver
Sodium
Sulfate
Zinc
1 TU (Nepthalometric
Turbidity Unit)
10 CU (Color Units)
3 TON (Threshold Odor
Number)
500
1 per 100 ml
0.05
1
0.01
250
0.05
1
Within 1 of Optimum pH
as determined by Langlier
Index
2
0.5
250
0.3
0.05
0.05
0.002
10
6
0.01
0.05
50
250
5 - 8.5
-------
TABLE 5 (continued)
CHEMICAL-SPECIFIC ARARs FOR GROUNDWATER PROTECTION
NEW JERSEY DRINKING WATER STANDARDS; JANUARY. 1989
CONTAMINANTS
(mg/L unless otherwise
noted)
TREATED WATER
Organic Chemicals:
Endrin
Lindane
Methoxychlor
Toxaphene
2,4-D
2,4,5-TP (Silvex)
Trihalomethane (THM)
Radioactivity:
Gross Alpha
Combined Radium
Manmade: Beta
(226 & 228)
NJA-280 Compounds (ug/1):
Benzene
Carbon Tetrachloride
Chlordane
Chlorobenzene
m-Dichlorobenzene
o-Dichlorobenzene
p-Dichlorobenzene
1,2-Dichloroethane
1,1-Dichloroethylene
cis-Dichloroethylene
trans-1,2-Dichloroethylene
Methylene Chloride
PCBs
Tetrachloroethylene
Trichlorobenzenes
1,1,1-Trichloroethylene
Trichloroethylene
0.0002
0.004
0.1
0.005
.1
0.01
0.10
15 pCi/L
5 pCi/L
4 millirem/yr.
1
2
0.5
4
600
600
75*
2
2
10
10
2
0.5
1
8
26
1
*The EPA established MCL will apply because NJDEP will not be
reproposing an MCL for this contaminant in the near future.
-------
TABLE 6
CHEMICAL-SPECIFIC ARARs FOR GROUNDWATER PROTECTION
GENERAL GUIDELINES FOR UNREGULATED VOCs
EPA Carcinogenicity
Classification*
Recommended
Guideline/Level
a,b
c,d,e
Total for all
unregulated VOCs
5 ppb (Single contaminant level
not to exceed)
50 ppb (Single contaminant level
not to exceed)
50 ppb (Total for all VOCs not
to exceed)
Based on U.S. EPA 1986 as shown below
U.S. EPA CATEGORIZATION OF WEIGHT OF EVIDENCE
FOR HUMAN CARCINOGENICITY
GROUP A: HUMAN CARCINOGEN -
Sufficient evidence from human epidemiological studies.
GROUP B: PROBABLE HUMAN CARCINOGEN -
Group Bl: Limited evidence from human epidemiological
studies.
Group B2: Sufficient evidence from animal studies and
inadequate or no data from human
epidemiological studies.
GROUP C: POSSIBLE HUMAN CARCINOGEN -
Limited evidence of carcinogenicity from animal studies
in the absence of human data.
GROUP D: MOT CLASSIFIABLE AS TO HUMAN CARCINOGENICITY -
Inadequate human and animal evidence for
carcinogenicity or no data available.
GROUP E: EVIDENCE OF NONCARCINOOENICITY FOR HUMANS -
No evidence for carcinogenicity in at least two
adequate human epidemiological and animal studies.
-------
TABLE 7
COMPONENT 1 - GROUNDWATER EXTRACTION ALTERNATIVES
Alternative GE-1 No further action with monitoring
Alternative GE-2 Groundwater extraction (groundwater
monitoring, sealing of residential
wells)
Alternative GE-3 Groundwater extraction with injection
of clean water (groundwater monitoring,
.sealing of residential wells)
-------
TABLE 8
COMPONENT 2 - GROUNDWATER DISCHARGE ALTERNATIVES
Alternative GD-1 Ocean discharge through the existing
CIBA-GEIGY pipeline
Alternative GD-2A Discharge to the Toms River by pipe
Alternative GD-2B Discharge to the Toms River by
seepage network
Alternative GD-3A Discharge to Upper Sand Aquifer,
30% reinjection of treated ground-
water
Alternative GD-3B Discharge to Upper Sand Aquifer,
100% reinjection of treated ground-
water
Alternative GD-3C Discharge to Upper Sand Aquifer,
100% recharge of treated ground-
water using reinjection wells and
infiltration basins
Alternative GD-4 Discharge to Ocean County Utilities
Authority
-------
TABLE 9
COMPONENT 3 - GROUNDWATER TREATMENT ALTERNATIVES
Existing Wastewater Treatment Plant Operation;
Alternative GT-1A CIBA-GEIGY wastewater treatment plant
combined treatment of process wastewater
and groundwater with discharge to the
Atlantic Ocean
Alternative GT-1B CIBA-GEIGY wastewater treatment plant
separate treatment of process wast--
water and groundwater with dischar >
to the Atlantic Ocean
Alternative GT-1C CIBA-GEIGY wastewater treatment plant
treatment of contaminated groundwater
only with discharge to the Atlantic
Ocean
Alternative GT-1D CIBA-GEIGY wastewater treatment plant
separate treatment of process waste-
water and contaminated groundwater
with discharge to the Toms River or
upper sand aquifer
Alternative GT-1E CIBA-GEIGY wastewater treatment plant
treatment of contaminated groundwater
only with discharge to the Toms River
or upper sand aquifer
Alternative GT-1F CIBA-GEIGY wastewater treatment plant
treatment to nondetectable levels
Newly Constructed On-Site Wastewater Treatment Plant;
Alternative GT-2A New physical/chemical treatment plant •
with discharge to the Atlantic Ocean !
Alternative GT-2B New biological treatment plant with £
discharge to the Atlantic Ocean £
Alternative GT-2C New biological treatment plant with
discharge to the Toms River or upper
sand aquifer
Alternative GT-2D New biological treatment plant with
treatment to nondetectable levels
Ocean County Utilities Authority (OCUA) Treatment Facility;
Alternative GT-3 OCUA wastewater treatment plant
In-3itu Bioreclamation System;
Alternative GT-4 In-situ bioreclamation system
-------
TABLE 10A
COMPARISON OF PRESENT WORTH FOR COMPONENT ONE (GROUNDWATER EXTRACTION) REMEDIAL ALTERNATIVESa
ALTERNATIVE
GE-1
GE-2
GE-3
DESCRIPTION
NO FURTHER ACTION WITH
MDNITORING
GROUNDWATER EXTRACTION
(GROUNDWATER MDNITORING,
SEALING OF RESIDENTIAL
WELLS)
GROUNDWATER EXTRACTION
WITH INJECTION OF CLEAN
WATER, (GROUNDWATER
MDNITORING, SEALING OF
RESIDENTIAL WELLS)
CAPITAL COST (?)
293,000
4,432,000
(7, 950, 000 )b
6, 907, 000
O & M COSTS (?/yr)
517,000
592,000
(592, 000 )b
614,000
PRESENT WORTH VALUE ($)
5,163,000
10,009,000
(13,526,000)b
13,156,000
a Costs taken from "Final Report-CIBA-GEIGY Technical Enforcement Support Document, Groundwater
Modelling Report," (CDM, April 1989).
b The cost to implement this alternative with additional wells to eliminate the stagnation zone.
-------
TABLE 10B
COMPARISON OF PRESENT WORTH FOR COMPONENT TWO (TREATED GROUNDWATER DISCHARGE) REMEDIAL ALTERNATIVES
ALTERNATIVE
GD-lb
GD-2A
GD-2B
GD-3A
GD-3B
GD-3C
DESCRIPTION
OCEAN DISCHARGE THROUGH
THE EXISTING CIBA-GEIGY
PIPELINE
DISCHARGE TO TCMS RIVER
BY PIPE
DISCHARGE TO TCMS RIVER
BY SEEPAGE NETWORK
DISCHARGE TO UPPER SAND
AQUIFER/30% REINJECTION
OF TREATED GROUNDWATER
DISCHARGE TO UPPER SAND
AQUIFER/100% REINJECTION
OF TREATED GROUNDWATER
DISCHARGE TO UPPER SAND
AQUIFER/100% RECHARGE
OF TREATED GROUNDWATER
USING REINJECTION WELLS
AND INFILTRATION BASINS
CAPITAL COST (§)
-
675,000
4,452,000
13,599,000
15,549,000
12,692,000
O & M cOoTD (?/yr)
380,000
20,000
80,000
717,000
729, 000
729,000
PRESENT WORTH VALUE ($)
3,582,000
864,000
5,206,000
22,138,000
24,204,000
20,024,000
a Costs taken from "Final Report-CIBA-GEIGY Plant, Groundwater Treatment Alternatives," (COM, April 1989).
b Costs provided by CIBA-GEIGY
-------
TABLE loc
COMPARISON OF PRESENT WORTH FOR COMPONENT THREE (GROUNDWATER TREATMENT) REMEDIAL ALTERNATIVES
ALTERNATIVE
OT-lAb
GT-1B
GT-1C
GT-1D
DESCRIPTION
CIBA-GEIGY WASTEWATER
TREATMENT PLANT (CGWWTP)
COMBINED TREATMENT OF
PROCESS WASTEWATER &
GROUNDWATER WITH
DISCHARGE TO OCEAN
CGWWTP SEPARATE TREAT-
MENT OF PROCESS WASTE-
WATER AND GROUNDWATER
WITH DISCHARGE TO OCEAN
OGWWTP TREATMENT OF
CONTAMINATED GROUNDWATER
ONLY WITH DISCHARGE TO
OCEAN
CGWWTP SEPARATE TREAT-
MENT OF PROCESS WASTE-
WATER & CONTAMINATED
GROUNDWATER WITH
DISCHARGE TO TOMS RIVER
OR UPPER SAND AQUIFER
CAPITAL COST (?)
20,534,000
25,522,000
20,534,000
42,663,000
0 & M COSTS ($/yr)
4,072,000
4,072,000
"
4,072,000
11,927,000
PRESENT WORTH VALUE ($7
58,921,000
63,909,000
58,921,000
155,099,000
Costs taken from "Final Report-CIBA-GEIGY Plant, Groundwater Treatment Alternatives, Tons River,
New Jersey," (COM, April 1989).
Costs estimated from "CIBA-GEIGY Feasibility Study," (NUS, April 1989)
and "Final Report-CIBA-GEIGY Plant, Groundwater Treatment Alternatives, Tons River, New Jersey,"
(CDM, April 1989).
-------
TABLE IOC (continued)a
ALTERNATIVE
QT-1E
GT-1F
GT-2A
GT-2B
OT-2C
GT-2D
DESCRIPTION
OGWWTP TREATMENT OF
CONTAMINATED GROUNDWATER
OILY WITH DISCHARGE TO
TCMS RIVER OR UPPER SAND
AQUIFER
OGWWTP TREATMENT TO
NONDETBCTABLE LEVELS
NEW PHYSICAL/CHEMICAL
TREATMENT PLANT WITH
DISCHARGE TO OCEAN
NEW BIOLOGICAL TREATMENT
PLANT WITH DISCHARGE TO
OCEAN
NEW BIOLOGICAL TREATMENT
PLANT WITH DISCHARGE TO
TCMS RIVER OR UPPER SAND
AQUIFER
NEW BIOLOGICAL TREATMENT
PLANT WITH TREATMENT TO
NONDETECTABLE LEVELS
CAPITAL COST (?)
37,679,000
42,269,000
32,994,000
36,281,000
56,869,000
64,760,000
0 & M COSTS ($/yr)
11/927,000
12,291,000
3,544,000
3,750,000
11,719,000
12,470,000
PRESENT WORTH VALUE ($)
150,115,000
158,136,000
66,403,000
71,632,000
167,344,000
182,315,000
a Costs taken fron "Final Report-CIBA-GEIGY Plant, Grounduater Treatment Alternatives, Toms River,
New Jersey," (CDM, April 1989).
-------
CtBA-iSEIGY SITE
(QUAD) TOM» MIVCR. N.J.
(approxiMt* scale: 1" - 2333')
J
FIGURE 1
SITE LOCATION MAP
CIBA-GEIGY SITE, DOVER TOWNSHIP, NEW JERSEY
-------
LIOEND
NAIIKOAO
•UNVIVID MUNOAHV
— MUNOAIIY MNCC
•OUMOANV HOAO
(•pprexiaat* »c«l«: !• • 1543')
I i t
FIGURE 2
CIBA-GEIGY SITE PLAN
-------
»»un
— — — SUHVITIO lOUMDAUT
-- - MUHOMT MMCI
- MUHOAMT ROAD
u«rr or
........ APMOXWATI uarr or
(••JL COHTOIM-UHITIO
IMPCftfVO fl •—.••.-•—••.!•
CMTOM
M «W-Wtll mMM ITTMI
x^ip
I . ! . ! . ; i^W^
J 1 I 1 I I I I I I I I 1
FIGURE 3
APPROXIMATE LATERAL EXTENT TOTAL VOLATILE PRIORITY POLLUTANTS
CONTAMINATION >5 ug/L AND ELECTROMAGNETIC
CONDUCTIVITY CONTOURS >5 MILLIMHOS/M
-------
IMIHO
" ' " «««UW40 MIM
(IMVITIO •OIMOMT
•— "- MUMMY MMCI
«0«*OMY IOAO
*"* "*» I«t/Ll
• -" • "lu. womoM mat mm M UMT MM
FIGURE 4
MAXIMUM DETECTED TOTAL VOLATILE PRIORITY POLLUTANTS (TVPP)
-------
FIGURE 5
WELLS WITH INORGANIC CONTAMINANT CONCENTRATIONS
ABOVE MAXIMUM CONTAMINATION LIMITS (MCL)
-------
IIOIHO
1 I MIUIOAO INI*
—— timviTie MWIPAIIV
- SOWXOAKT MNCf
•OUHOAIIT MO*0
IXT1UCTIOM Wilt
(•pprOHiMt* •»!•: 1* - 1S4J-)
FIGURE 6
COMPONENT 1 - REMEDIAL ALTERNATIVE GE-2
INSTALLATION OF GROUNDWATER EXTRACTION WELLS
-------
\
h I
r^ ^ v?rc^
*s»sC^'/'s**Jr^
p^// ^%>y/
LIQIND
1 ' MAILMOAO »'\i*
——— SUNVEYIO MUNOAMY
—— •OUNOANY FENCE
— •' • tOUNOAMV MOAO
•*• BITHACTIOH WELL
•$ INJECTION WELL
(•ppre*lB«t« •«!•: I' - 1543')
i
_1 i ± i L t I 7
FIGURE 7
COMPONENT 1 - REMEDIAL ALTERNATIVE GE-3
INSTALLATION OF A GROUNDWATER EXTRACTION SYSTEM
AND PARTIAL INJECTION OF CLEAN WATER
-------
I
LEGEND
' * RAILROAD SPUR
I **••
— SURVEYED BOUNDARY
BOUNDARY FENCE
BOUNDARY ROAD
+ EXTRACTION WELL
•$• INJECTION WELL
••"• (approximate seal*: l" - 1543*)
i
•
' ' L.
' ' ' ' '
-I 1 1
FIGURE 8
COMPONENT 2 - REMEDIAL ALTERNATIVE GD-3B
DISCHARGE TO UPPER SAND AQUIFER
100% REINJECTION OF TREATED GROUNDWATER
THROUGH REINJECTION WELLS
-------
I
tMIHD
IUIUIOAD «»un
•— MIMOAKY rind
— MUHOAIIY *OAO
»• HTHACTIOK WILL
* HUICTWM WIU
S •VH.TUTIM •*!•
I I
•^^^^^^^_^^_
1* - 154)
i
•
I I t| |
FIGURE 9
COMPONENT 2 - REMEDIAL ALTERNATIVE GD-3C
DISCHARGE TO UPPER SAND AQUIFER
100Z RECHARGE OF TREATED GROUNDWATER
THROUGH REINJECTION WELLS AND INFILTRATION BASINS
-------
Chwncil
Addition
1400 gpm
1400 g^n
MOO gpm
2MO gpm
. Eliding Primary
Nautralltailan Tink
•lln 4 Calla and yixar*
Lift
•ttllen
dialing
fajwalltatlon
Tank
Eilttlng tacondary
Nautralliatlen Tank
wltti I C«lla (1 Siand-Br)
Primary Clarltlara
fland-§r)
Watte
' Oltpeail
Flllar Praia
••eandary Clarlflara
(1
A
'
At <*rt air tram
Aaroble
Olgaatar Sacandary
Oravlty
Tklckonar
FIGURE 10
SCHEMATIC OF EXISTING CIBA-GEIGY WASTEWATER TREATMENT PLANT
-------
Tanfe
Tank
FIGURE 11
COMPONENT 3 - REMEDIAL ALTERNATIVE GT-1B
CIBA-GEIGY WASTEWATER TREATMENT PLANT SEPARATE TREATMENT OF PROCESS
WASTEWATER AND GROUNDWATER WITH DISCHARGE TO THE ATLANTIC OCEAN
-------
C*nvwl«4 f «MNtMlMi
T*nh
FIGURE 12
COMPONENT 3 - REMEDIAL ALTERNATIVE GT-1C
CIBA-GEIGY WASTEWATER TREATMENT PLANT TREATMENT OF CONTAMINATED
GROUNDWATER ONLY WITH D^fciARGE TO THE ATLANTIC OCEAN
-------
FIGURE 13
COMPONENT 3 - REMEDIAL ALTERNATIVE GT-lD
CIBA-GEIGY WASTEWATER TREATMENT PLANT SEPARATE TREATMENT OF PROCESS WASTEWATER
AND CONTAMINATED GROUNDWATER WITH DISCHARGE TO THE TOMS RIVER OR UPPER SAND AQUIFER
-------
FIGURE 14
COMPONENT 3 - REMEDIAL ALTERNATIVE GT-1E
CIBA-GEIGY WASTEWATER TREATMENT PLANT TREATMENT OF CONTAMINATED GROUNDWATER
WITH DISCHARGE TO THE T^fc RIVER OR UPPER SAND AQUIFER
-------
CMMMl ^.V. •«•-••«
*U«k
FIGURE 15
COMPONENT 3 - REMEDIAL ALTERNATIVE GT-1F
CIBA-GEIGY WASTEWATER TREATMENT PLANT SEPARATE TREATMENT TO NON-DETECTABLE LEVELS
-------
E**,
FIGURE 16
COMPONENT 3 - REMEDIAL ALTERNATIVE GT-1F
CIBA-GEIGY WASTEWATER TREATMENT PLANT TREATMENT OF CONTAMINATED GROUNDWATER ONLY^
TO NON-DET^KkfiLE LEVELS
-------
FIGURE 17
COMPONENT 3 - REMEDIAL ALTERNATIVE GT-3A
NEW PHYSICAL/CHEMICAL TREATMENT PLANT WITH DISCHARGE TO THE ATLANTIC OCEAN
-------
•* Mia**
Mvtata *••»•*•>
FIGURE 18
COMPONENT 3 - REMEDIAL ALTERNATIVE GT-2B
NEW BIOLOGICAL TREATMENT PLANT WITH DISCHARGE TO THE ATLANTIC OCEAN
-------
••I
FIGURE 19
COMPONENT 3 - REMEDIAL ALTERNATIVE GT-3C
NEW BIOLOGICAL TREATMENT PLANT WITH DISCHARGE TO THE TOMS RIVER OR UPPER SAND AQUIFER
-------
-tetQ
voc
••I I Tl
FIGURE 20
COMPONENT 3 - REMEDIAL ALTERNATIVE GT-3D
NEW BIOLOGICAL TREATMENT PLANT WITH TREATMENT TO NON-DETECTABLE LEVELS
-------
PUMPING
AIR STRIPPING
OFF-GAS
CONTROL
ION EXCHANGE
SLUDGE
TREATMENT/DISPOSAL
FIXEO-FJLM
BIOREACTOR
INJECTION
FIGURE 21
COMPONENT 3 - REMEDIAL ALTERNATIVE GT-4
IN SITU BIORECLAMATION SYSTEM
-------
APPENDIX A
AVERAGE AND MAXIMUM CONCENTRATIONS OF PRIORITY POLLUTANTS IN VARIOUS ENVIRONMENTAL MEDIA
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-------
APPENDIX A (continued)
AVERAGE AND MAXIMUM CONCENTRATIONS OF PRIORITY POLLUTANTS IN VARIOUS ENVIRONMENTAL MEDIA
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-------
APPENDIX ^Fcont inued)
AVERAGE AND MAXIMUM CONCENTRATIONS OF PRIORITY POLLUTANTS IN VARIOUS ENVIRONMENTAL MEDIA
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Action b/
B (continued)
ACTION-SPECIFIC ARARs
Requirements
Prerequisites
Citation
Direct discharge
of treatment system
effluent (cent.)
The BMP program must:
0 Establish specific procedures for
the control of toxic and hazardous
pollutant spills.
0 Include a prediction of direction,
rate of flow, and total quantity of
toxic pollutants where experience
indicates a reasonable potential for
equipment failure.
0 Assure proper management of solid and
hazardous waste in accordance with
regulations promulgated under RCRA.
Discharge must be monitored to assure
compliance. Discharge will monitor:
0 The mass of each pollutant
0 The volume of effluent
0 Frequency of discharge and other
measurements as appropriate.
Approved test methods for waste
constituents to be monitored must be
followed. Detailed requirements for
analytical procedures and quality
controls are provided.
Sample preservation procedures, container
materials, and maximum allowable holding
times are prescribed.
40 CFR 125.104
40 CFR 122.44(i)
40 CFR 136.1-
136.4
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Actions b/
APPENDIX B (continued)
ACTION-SPECIFIC ARARs
Requirements
Prerequistes
Citation
Direct discharge
of treatment system
effluent (cont.)
Direct discharge
to ocean
Permit application information
must be submitted including a
description of activities, listing
of environmental permits, etc.
On-site discharges to surface
waters are exempt from procedural
NPDES permit requirements.
c/ Off-site discharges would be
required to apply for and obtain
an NPDES permit.
40 CFR 122.21
Monitor and report results as required
by permit (minimum of at least annually),
Comply with additional permit
conditions such as:
0 Duty to mitigate any adverse
effects of any discharge; and
0 Proper operation and maintenance
of treatment systems.
Discharges causing "unreasonable
degradation of the marine environment"
are not permitted.
Determination of whether a discharge
will cause reasonable degradation of
the marine environment is based on
consideration of:
* Quantity, composition, or persistence
of pollutants to be discharged.
0 Potential transport of pollutants
by biological, chemical or physical
processes.
0 Composition and vulnerability of
exposed communities.
40 CFR
122.44(1)
40 CFR
122.41(1)
40 CFR
125.123(b)
40 CFR 125.122
c/ Section 1
However,
SARA exempts on-site CERCLA activities from
ubstantive requirements of a permit must be
ininq permits.
-------
(continued)
ACTION-SPECIFIC ARARs
Actions b/
Requirements
Prerequisites
Citation
Direct discharge to
ocean (cant.)
lischarge to POW d/
0 Importance of the receiving water
to spawning, migratory paths, and
surrounding biological community.
0 Existence of specific aquatic sites.
0 Impact on human health and
commercial fishing.
Comply with the limiting permissible
concentrations (IPGs) at the mixing
zone boundary that are established
in the permit.
Permit applicants may be required
to submit the following: analyses
of chemical constituent of the discharge
and the affected biological community,
appropriate bioassays necessary to determine
LPCs, a description of the facility and treatment
process, and evaluations of alternative disposal
options.
Permit applicants shall be required to comply
with a monitoring program specified in the
permit. This program must assess the impact
of the discharge on water, sediment, and biological
quality.
Pollutants that pass-through the POTW without
treatment, interfere with POTW operation, or
contaminate POW sludge are prohibited.
Specific prohibitions preclude the discharge
of pollutants to POIWs that:
0 Create a fire or explosion hazard in the POTO;
0 Are corrosive (pH<5.0);
40 CFR
125.123(d)(l)
40 CFR 125.124
40 CFR 125.123
40 CFR 403.5
/ Same reanlaHnns
r,f
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Action b/
APPENDIX B (continued)
ACTION-SPECIFIC ARARs
Requirements
Prerequisites
Citation
Discharge to PCHW
(cont.)
0 Obstruct flow resulting in interference;
0 Are discharged at a flow rate
and/or concentration that will
result in interference; and
0 Increase the temperature of wastewater
entering the treatment plant that would
result in interference, but in no case
raise the POTW influent temperature
above 104°F (40°C).
0 Discharge must comply with local POW
pretreatment program, including POTW-
specific pollutants, spill prevention
program requirements, and reporting
and monitoring requirements.
* RCRA permit-by-rule requirements
must be compiled with for discharges
of RCRA hazardous wastes to PpTWs by
truck, rail, or dedicted pipe.
40 CFR 403.5
and local POW
regulations
40 CFR 264.71
and 264.72
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