Superfund Record of Decision: Scientific Chemical Processing, NJ


Unieti States
Environmenal Protection
Agency
Office ol
Emergency and
Remedial Response
EPA/ROO/R02-90/109
September 1990
Superfund
Record of Decision
Scientific Chemical
Processing, NJ

-------
50272-101
REPORT DOCUMENTATION 1. REPORT NO. 2.
PAGE EPA/ROD/R02-90/109
4.'Tltl« and Subtitle
SUPERFUND RECORD OF DECISION
Scientific Chemical Processing, NJ
First Remedial Action
7. Authors)
9. Performing Organization Name and Address
12. Sponsoring Organisation Name and Addreea
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
1. Recipient's Accession No.
S. Report Date
09/14/90
«.
•. Performing Organization Rept. No.
10. PTo|act/Taak/Work Unit No.
11. Contrsct
-------
EPA/ROD/R02-90/109
Scientific Chemical Processing, NJ
First Remedial Action

Abstract (Continued)

ground water remedial activities. The primary contaminants of concern affecting the
soil and ground water are VOCs including benzene, PCE, phenols, TCE, toluene, and
xylenes; organics including PAHs, PCBs, and pesticides; metals including arsenic,
chromium, and lead; and other inorganics.

The selected remedial action for this site is an interim remedy, which includes
installing a slurry wall around the site perimeter to a depth of 15 to 20 feet
(corresponding to the top of a confining clay layer); installing a temporary
infiltration barrier over the site surface to minimize entry of precipitation;
extracting ground water from within the slurry wall boundary for the purpose of
dewatering onsite soil and controlling movement of contaminated ground water away from
the site; transporting extracted ground water offsite for pretreatment, -treatment, and
disposal; ground water and surface water monitoring; and maintaining a fence around the
site. The estimated present worth cost for this remedial action is $2,933,000, which
includes an annual O&M cost of $42,000 for 3 years.

PERFORMANCE STANDARDS OR GOALS: Cleanup levels for the contaminants of concern have
not been set due to the interim nature of this remedy. Chemical-specific ARARs will be
met for final remedies, and will be presented in subsequent RODs.
-------
DECLARATION STATEMENT

RECORD OF DECISION

SCIENTIFIC CHEMICAL PROCESSING SITE
SITE NAME AND LOCATION

Scientific Chemical Processing Site
216 Paterson Plank Road
Carlstadt, Bergen County, New Jersey

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected interim remedial action
for the Scientific Chemical Processing (SCP) site located at 216
Paterson Plank Road in Carlstadt, New Jersey. This interim remedy
was chosen by EPA in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986, and to the
extent practicable, the National Contingency Plan. This decision
document summarizes the factual and legal bases for selecting the
interim remedy for the site. The attached index identifies the
items that comprise the administrative record for the site upon
which this decision is based.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from the site,
if not addressed by implementing the response action selected in
this Record of Decision, may present an imminent and substantial
endangerment to public health, welfare or the environment.

DESCRIPTION OF THE SELECTED REMEDY

The soil and groundwater above the clay silt layer which exists
across the entire SCP site (i.e., the first operable unit zone)
constitute the most highly contaminated materials at the site.
Numerous hazardous substances and pollutants and contaminants are
present in this zone, many of which have migrated out of this zone
into the underlying aquifers and Peach Island Creek which adjoins
the site. The primary objective of the interim remedy identified
in this decision document is to reduce the migration of such
hazardous substances into the groundwater and surfare water until
a permanent remedy for the site is selected and implemented.
-------
-2-

EPA intends to issue one or more Records of Decision in the future
relating to this site. These Records of Decision will select those
final remedial actions for addressing the soils in the first
operable unit zone, as well as any areas located outside this zone
which may have been adversely affected by the migration of hazardous
substances and/or pollutants and contaminants from the site.

The elements of this interim remedy are prerequisite components of
a permanent remedial action for the first operable unit zone and are
consistent with the final remedial actions which are likely to be
selected for this site.

The interim remedy selected in this decision document contains the
following components:

1. Installation of a slurry wall around the entire site and
a temporary infiltration barrier over the site;

2. Installation of a groundwater collection system and
extraction of groundwater from the first operable unit
zone within the slurry wall to maintain the water level
in this zone at the lowest practicable level;

3. Transportation of all extracted groundwater to an
appropriate off-site facility (or facilities) for
treatment and/or disposal; and

4. Operation and maintenance of the components of this
interim remedy and environmental monitoring to ensure
continued achievement of the objectives of the interim
remedy.

Additional details and discussions of the selected interim remedy
are found in the Decision Summary for this Record of Decision.

STATUTORY DETERMINATIONS

Section 121(d)(l) of CERCLA requires that remedial actions attain
a degree of cleanup of hazardous substances, pollutants and
contaminants released into the environment and of control of further
releases which, at a minimum, assures protection of human health and
the environment. This interim action will reduce the migration of
hazardous substances, pollutants and contaminants out of the first
operable unit zone. Thus, the threat to human health and the
environment which is posed by the conditions at the site will be
reduced more quickly by implementing this interim action. This
interim action will not, however, in and of itself, be fully
protective of human health and the environment. It must be followed
by subsequent action(s) in order to achieve an acceptable level of
protection of human health and the environment.
-------
-3-
This interim action is cost effective. It is a component of a
remedy for the first operable unit zone which will, when completed,
meet applicable or relevant and appropriate requirements (ARARs)
which relate to this site. This interim action will only comply
with Federal and State requirements that are directly associated
with the implementation of this action. It is not designed to nor
will it attain chemical specific ARARs for hazardous substances
which will remain in the soil and/or groundwater in or under the
first operable unit zone.

This remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable, given the limited
scope of the action. Because the action does not constitute the
final remedy for this first operable unit zone, the statutory
preference for remedies that employ treatment as a principal element
to reduce the toxicity, mobility and volume of hazardous substances
will not be addressed until the final remedial action is selected.
EPA intends to select and require the implementation of remedial
actions which will fully address the principal threats posed by this
site and to achieve the level of cleanup at this site required by
CERCLA.
onstantine Sidamon-Eristoff,/Regional Administrator
U.S. EPA Region II ^^~T/

v /MO
-------
ROD FACT SHEET
SITE

Name:

Location:

HRS Score:

NPL Rank:

ROD
Scientific Chemical Processing Site

Bergen County, Carlstadt, New Jersey

55.97

75
Date Signed: 9/14/90

Remedy: The primary objective of the interim remedy
identified in the ROD is to reduce the migration
of hazardous substances into the groundwater and
surface water until a permanent remedy for the
site is selected and implemented. The interim
remedy consists of a slurry wall around the entire
site, a temporary infiltration barrier over the
entire site, a groundwater collection and
extraction system, transportation of all extracted
groundwater to an appropriate off-site facility
for treatment and/or disposal, and operation and
maintenance and environmental monitoring of the
the components of this interim remedy.

Capital Cost: $2,557,000

O&M: $42,000 (for 3 years)

Present Worth: $2,933,000 (including 10% contingency)

LEAD
Potentially
Responsible
Party (PRP)
Lead:

EPA Primary
Contact:

WASTE

Type:

Medium:

Origin:
158 PRPs are identified for the Site

Pat Evangelista, (212) 264-6311

Commercial and industrial wastes.

Soil, groundwater, surface water and sediments,

Dumping
-------
DECISION SUMMARY

SCIENTIFIC CHEMICAL PROCESSING SITE
SITE LOCATION AND DESCRIPTION

The Scientific Chemical Processing Carlstadt site (the SCP site or
the site) is located at 216 Paterson Plank Road, in the Borough of
Carlstadt, Bergen County, New Jersey. The site is bounded by
Paterson Plank Road on the south; Gotham Parkway on the west; Peach
Island Creek, a tributary to Berry's Creek on the north; and a
trucking company on the east (See Figure 1) . The site covers
approximately 5.9 acres of relatively flat, sparsely vegetated land.
The site is fenced on three sides (east, west, and south), with a
locked main entrance gate on Paterson Plank Road.

Land use in the vicinity of the site is classified as light
industrial. Businesses in the immediate vicinity of the site
include warehouses, freight carriers, light chemical, leather goods,
electronics and other service sector industries. The site is
located across the street from the Meadowlands Sports Complex, a
large facility for professional sports and public recreation events
(See Figures 1 and 2).

The population of the Borough of Carlstadt resides mainly within the
residential and commercial areas of the borough (as shown on Figure
2) , however, there are three dwellings which exist within
approximately one mile of the site.

Lands bordering Peach Island Creek and Berry's Creek are classified
as waterfront recreation zones. The site is located within the
Hackensack Meadowlands District, an extensive area of salt water
marshes drained by the Hackensack River and its tributaries.
Berry's Creek, one of those tributaries, drains approximately 800
acres of marshland including Walden Swamp and Eight-Day Swamp.
Although there are wetlands in the vicinity of the site, the site
itself is classified as an upland area.

Groundwater in the water table aquifer underlying the site flows
into Peach Island Creek. Water in this aquifer also flows towards
Gotham Parkway, Paterson Plank Road and the adjoining property to
the east. A significant component of groundwater flow is also
downward. Although the water table and till aquifers in the
immediate vicinity of the site are not known to be used for drinking
water, the bedrock aquifer which extends beneath the site is used
for potable as well as industrial purposes.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

The site, which is owned by Inmar Associates, Inc., was operated
during the 1970s by Scientific Chemical Processing, Inc., for the
handling, treatment and disposal of a wide variety of industrial and
chemical wastes. Similar operations also occurred on the site prior
-------
to 1970. In 1980, operations at the facility ceased. In 1983, the
site was placed on the National Priorities List.

On or about May 17, 1985, the U.S. Environmental Protection Agency
(EPA) issued notice letters to approximately 140 Potentially
Responsible Parties (PRPs), offering them the opportunity to
undertake a Remedial Investigation and Feasibility Study (RI/FS) at
the site. The purpose of the RI/FS was to determine the nature and
extent of contamination at the SCP site, and to develop remedial
alternatives to address that contamination. On September 30, 1985,
EPA issued an Administrative Order on Consent to 108 of the PRPs
who agreed to conduct the RI/FS. On October 23, 1985, EPA issued
a Unilateral Administrative Order to 31 PRPs who failed to sign the
Consent Order, requiring them to cooperate with the 108 consenting
parties and participate in the RI/FS.

On October 23, 1985, EPA also issued an Administrative Order to the
site owner, Inmar Associates, Inc., requiring the company to remove
and properly dispose of the contents of five tanks containing wastes
contaminated with polychlorinated biphenyls (PCBs) and numerous
other hazardous substances. Inmar completed the removal of four of
these tanks by the summer of 1986. EPA subsequently sued Inmar for
late performance of the work required by that order and recovered
more than $300,000 in penalties for violation of that order.

The PRPs initiated the RI/FS in April, 1987. The results of the
RI/FS work conducted to date are discussed below.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

The RI/FS Report, the Proposed Plan and other documents which
comprise the administrative record for this interim remedy for the
SCP site were released to the public for comment on May 19, 1990.
These documents were made available to the public at the EPA Docket
Room in Region II and at the William E. Dermody Free Public Library
in Carlstadt, New Jersey. On May 19, 1990, EPA also published a
notice in the "Bergen Record" which contained information relevant
to the public comment period for the site, including the duration
of the public comment period, the date of the public meeting and
availability of the administrative record. The public comment
period began on May 19, 1990 and ended on June 18, 1990. In
addition, a public meeting was held on June 5, 1990, at which
representatives from EPA and the New Jersey Department of
Environmental Protection (NJDEP) answered questions regarding the
site and the interim actions under consideration. Responses to the
significant comments received during the public comment period are
included in the Responsiveness Summary, which is part of this Record
of Decision (ROD).
-------
SCOPE AND ROLE OF THIS RESPONSE ACTION WITHIN OVERALL SITE STRATEGY

The SCP site is extremely complex, because of the wide variety of
contaminants present, the high concentrations of contaminants
detected, and the many potential migration routes for these
contaminants. Consequently, EPA has divided the response actions
for the site into several operable units (OUs) . The OUs for the
site are defined as follows:

OU 1: this OU will address remediation of conditions in the FOU
zone at the site, including remediation of contaminated soils
and groundwater above the clay layer; and,

OU 2: this OU will address remediation of conditions outside
the FOU zone, including remediation of the contamination in the
till and bedrock aquifers and Peach Island Creek.

Some of the PRPs conducted studies to evaluate potential remedial
alternatives for soils and groundwater in the First Operable Unit
(FOU) zone. In addition to the No Action Alternative, various
technologies for treating the most heavily contaminated zone were
evaluated, including solidification of the soils/sludges, chemical
extraction of contaminants from the soils/sludges, and incineration
of the soils/sludges in the FOU zone. Treatability studies were
also performed in order to test the effectiveness of several
treatment methods for remediating contaminated soils, sludges and
groundwater. Specific studies conducted included incineration,
contaminant extraction, and solidification/stabilization of the site
soils and sludges, as well as peroxidation, carbon adsorption, steam
stripping and critical fluid extraction of the shallow groundwater.

The results of these studies indicated that, although there are
several treatment methods which may be viable for remediating soils
and sludges in the FOU zone, there are uncertainties regarding the
relative effectiveness of various treatment technologies.
Consequently, it is desirable to further assess treatment
alternatives prior to the selection of a permanent remedy for the
FOU zone which will be protective of human health and the
environment.

The FS demonstrated that, in order to treat the heavily contaminated
saturated soil, it would be necessary to first remove the shallow
groundwater from this zone (i.e., dewater this zone). Consequently,
each of the alternatives evaluated in the FS (with the exception of
the No Action Alternative) includes implementation of a "dewatering"
system. This system consists of:

1) installation of an underground slurry wall around the site
perimeter, down to the clay layer;

2) extraction of groundwater from within the boundary of this
wall; and,

3) subsequent treatment and disposal of the groundwater.
-------
Dewatering the FOU zone will facilitate implementing a final remedy
for the soils and sludges located within this zone.

Although further work is planned to evaluate treatment technologies
for the soils and sludges, there is enough information currently
available for EPA to select an interim action to temporarily reduce
migration of contaminants out of the FOU zone until further studies
of the site are completed and a final remedy for the FOU zone is
selected.

Since the dewatering system is a common component of all
alternatives evaluated to date (with the exception of the No Action
Alternative), it will be consistent with any potential future remedy
which EPA will select for the site. This dewatering system will
also be part of a future permanent remedy which will protect human
health and the environment. Although this alternative is not fully
protective in and of itself, it is expected to be effective in
temporarily reducing further migration of contaminants from the
shallow zone until a permanent remedy can be implemented.

SUMMARY OF SITE CHARACTERIZATION

1. Site Geology

The results of the RI indicate that the site stratigraphy consists
of the following units, in descending order with depth: earthen fill
material (average thickness of approximately 8.4 feet across the
site); peat (thickness ranging from 0 to approximately 1.8 feet
across the site); gray silt (average thickness of approximately 2
feet across the site) ; varved clay (thickness ranging from 0 to 18
feet across the site) ; red clay (thickness ranging from 0 to 8 feet
across the site); till (consisting of sand, clay and gravel, average
thickness of approximately 20 feet across the site) ; and bedrock
(See Figure 3).

The site is underlain by three hydrologic units which are described
as the "shallow aquifer", the "till aquifer" and the "bedrock
aquifer" in descending order with depth. The water table is found
in the shallow aquifer at a depth of approximately two feet below
the land surface. The till aquifer consists of the water-bearing
unit between the clay and the bedrock. The bedrock aquifer is the
most prolific of the three aquifers and is used regionally for
potable and industrial purposes. Results of hydrogeologic tests
conducted during the RI indicate that the three aquifers are
hydraulically connected. Chemical analyses of groundwater from the
three aquifers provides further support to this finding.
Specifically, chemical data demonstrates that contaminants from the
shallow aquifer have migrated across the clay-silt layer into the
till and bedrock aquifers.
-------
2. Soil Contamination

Soil samples were collected and analyzed for Priority Pollutants and
certain additional parameters from seventeen locations at the site
(See Figure 5). Samples were collected at depth, at the following
intervals: 0-2 feet, 5-6 feet, and at the top of the clay-silt
layer. Tables 1, 2, and 3 summarize the number of occurrences and
maximum concentrations of chemicals detected in soils at each of the
three sampling depths. The results indicate that a wide variety of
contaminants, including volatile organic compounds (VOCs), acid
extractable compounds, base/neutral compounds, PCBs, metals,
petroleum hydrocarbons and pesticides were detected at high levels
at all depths sampled.

In addition, soil samples were collected from three locations within
the clay layer. Table 4 summarizes the number of occurrences and
maximum concentrations of hazardous substances detected in the clay-
silt layer. The results demonstrate that many of the chemicals
detected in the overlying soils and fill material have migrated down
into the clay-silt layer. For example, the levels of VOCs detected
in these three deep borings are indicated on Figure 6. As evidenced
by the analytical results, VOCs have migrated down into and through
the clay-silt layer. This layer is not preventing downward
migration of hazardous substances from the FOU zone into the till
aquifer.

Provided below are the average concentration for the various classes
of contaminant compounds detected at the four depths sampled.

Average Concentration in Parts Per Million

0-2 feet1 5-6 feet2 Top of the Within the
Clay Clay
Compound Class

Volatile Organic 1,068.0 2,069.0 153.0 361.0
Base/Neutral 147.0 343.0 20.0 0.5
Acid Extractable 12.0 169.0 9.2 0.3
PCBs 1,048.0 62.0 1.8 0.2
Cyanides 4.7 8.5 3.5
Phenolics 50.0 66.0 6.6 1.5
Petroleum
Hydrocarbons 13,167.0 8,507.0 1,164.0 82.5
'Unsaturated zone.

Saturated zone.
-------
Average Concentration in Parts Per Million

0-2 feet 5-6 feet Top of the Within the
Clay Clay
Compound Class

Selected Metals3:
Chromium 171 92 22 28
Copper 8,788 1,425 786 30
Lead 667 735 111 12
Zinc 623 564 2,865 73

As demonstrated by the above data, although the highest levels of
contaminants are found in the soils above the clay layer,
contaminants have migrated from the unsaturated, surficial soils
into the saturated soils and down into the clay layer.

3. Tank Sludge

Four tanks containing PCB contaminated sludge were removed and
disposed of as part of the removal actions conducted by the site
owner during 1986. A fifth tank containing extremely high levels
of PCBs, metals and other contaminants was not removed because
disposal facilities capable of accepting such wastes were
unavailable. Table 5 shows the results of the analyses conducted
on the material in the remaining tank. The tank has been placed in
a roll-off container and secured with a tarpaulin. Because the
constituents of the tank sludge are similar to those found in the
site soils, the ultimate disposal and/or treatment method for the
sludge will be considered with those methods evaluated for the
soils.

4. Groundwater Contamination

As stated previously, three aquifers have been identified at the
site: the water table, the till aquifer, and the bedrock aquifer.
During the RI, ten groundwater monitoring wells were installed:
seven in the water table aquifer, and three in the till aquifer (See
Figure 5). Sampling results from these wells demonstrated severe
contamination of the shallow aquifer and migration of hazardous
substances down into the till aquifer. An additional well was
installed in the bedrock aquifer to determine if it had been
impacted by hazardous substances in the water table and till
aquifers above it. Data from this monitoring well revealed that
many of the same hazardous substances which were present in the FOU
zone and the till aquifer were present in the bedrock aquifer. The
analytical results from the groundwater sampling efforts conducted
during the RI are discussed below.
is a limited list of metals which were detected at the
site.
-------
The water table aquifer is contaminated with a variety of hazardous
substances. Table 6 provides a summary of the number of occurrences
and maximum concentrations of chemicals detected. Contaminants
detected included volatile organic compounds, semi-volatile organic
compounds, pesticides, PCBs, and metals. Many of the hazardous
substances found in the water table aquifer are identical to those
detected in soils in the FOU zone. For example, benzene,
chloroform, 1,2-dichloroethane, toluene, trichloroethylene, PCB
Aroclor 1242, vinyl chloride, arsenic and copper were detected in
both the FOU zone soils and the water table aquifer.

Groundwater quality data collected from the till aquifer demonstrate
that hazardous substances have migrated from the soils in the FOU
zone and from the water table aquifer down through the clay layer
into the till aquifer. Table 7 provides a summary of the number of
occurrences and maximum concentrations of chemicals detected in the
till aquifer. Contaminants detected include volatile organic, semi-
volatile organic, pesticides, PCBs, and metals. Many of the
hazardous substances found in the till aquifer are similar in type
and/or identical to those detected in soils in the FOU zone and in
the water table aquifer. For example, chloroform, 1,2-
dichloroethane, toluene, trichloroethylene, vinyl chloride, and
copper were all detected in the soils in the FOU zone, the water
table aquifer and the till aquifer.

The bedrock aquifer is hydraulically connected to the till aquifer.
Pump tests conducted during the RI/FS demonstrated this connection.
Groundwater quality data also demonstrate that hazardous substances
have migrated from the till aquifer into the bedrock aquifer. For
example, chloroform, 1,2-dichloroethane, vinyl chloride and copper
were all detected in both the till aquifer and bedrock aquifer.

The groundwater quality data collected in all three aquifers also
reveals that, although the highest levels of hazardous substances
and pollutants and contaminants are found in the soils in the FOU
zone and in the water table aquifer, some of these contaminants,
particularly VOCs, have migrated from this aquifer into the till and
bedrock aquifers.

5. Surface Water and Sediment Contamination

Peach Island Creek, a tributary of Berry's Creek, flows adjacent to
the site. The RI included limited sampling and analyses of surface
water and sediment from Peach Island Creek.

Water quality and sediment samples were collected at four sampling
stations along Peach Island Creek. The locations are depicted on
Figure 7 and include the following: the confluence of Peach Island

10
-------
Creek and Berry's Creek (approximately one-half mile downstream from
the site) ; 100 feet downstream of the site; adjacent to the center
line of the site; and 100 feet upstream of the site. One surface
water sample and two sediment samples (from 0 to 6 inches and from
12 to 18 inches below the surface of the stream bed) were collected
at each location.

Studies performed in conjunction with the RI indicated that the
water table aquifer at the site flows into Peach Island Creek. As
discussed above, this aquifer is grossly contaminated by numerous
hazardous substances and pollutants and contaminants.

The RI results indicate that the surface water and sediment in Peach
Island Creek are also contaminated with hazardous substances. Table
8 provides a summary of the number of occurrences and maximum
concentrations of chemicals detected in the Creek. Tables 9 and 10
provide the number of occurrences and maximum concentrations of
chemicals detected in the sediment samples taken from the Creek.

Many of the hazardous substances found in the surface water and
sediment in Peach Island Creek are identical to those detected in
soils and groundwater at the site. For example, 1,1,1-
trichloroethane, chloroform, mercury, arsenic, dieldrin and PCB
Aroclors (1242, 1254, 1260, and 1248) were all detected in soils and
groundwater at the site and in the surface water and sediment of
Peach Island Creek.

The RI indicated that hazardous substances have been released onto
the soils and into the groundwater at the site. Furthermore, such
hazardous substances have migrated and continue to migrate from the
soils and water table aquifer in the FOU zone into underlying
groundwater aquifers and into Peach Island Creek, a tidal waterway
adjoining the site. The presence of the many hazardous substances,
pollutants and contaminants in the soil and in the water table
aquifer in the FOU zone at the site, particularly without the
presence of any control or containment facilities, pose a threat of
continued release and future releases of such substances into the
environment in the future.

In summary/ the RI results indicate the following:

- on-site soils, both at the surface and down to a depth of at
least 10-12 feet, are heavily contaminated with hazardous
substances/ including volatile and semi-volatile organic
compounds, pesticides, PCBs, and inorganic compounds;

- the shallow groundwater at the site is heavily contaminated
with hazardous substances, including volatile and semi-
volatile organic compounds, pesticides and inorganic compounds;

- hazardous substances have migrated from the FOU zone down
into and through the clay layer (which lies between the water
table aquifer and deeper aquifers) into the till and bedrock
aquifers at the site;

11
-------
- groundwater in the till and bedrock aquifers at the site is
contaminated with a number of hazardous substances and
pollutants and contaminants, including some volatile and semi-
volatile organic compounds;

- hazardous substances similar in type and/or identical to
those found in the soils in the FOU zone have been found in the
water table, till and bedrock aquifers; and

- surface water and sediment in Peach Island Creek, which flows
adjacent to the site, are contaminated with hazardous
substances similar in type and/or identical to those which were
found in the soils and groundwater at the site.

The RI did not fully define the extent of contamination in off-site
areas, the bedrock aquifer and in surface water bodies. Such
characterization will be the subject of further investigation during
and/or after the implementation of this interim remedy.

SUMMARY OF SITE RISKS

A baseline risk assessment was conducted by EPA through its
contractor during the RI/FS to evaluate the health and environmental
risks posed by contamination at the SCP site. The data collected
during the RI revealed that at least 87 chemicals exist in the soil
and shallow groundwater at the site. The highest concentrations of
hazardous substances found on site are found in the soil and/or
groundwater above the clay layer. Many of the chemicals detected
in the soils and groundwater at the site are known human carcinogens
(e.g. vinyl chloride, arsenic, and benzene). Many others are known
carcinogens in animals and are suspected human carcinogens (e.g.
PCBs, chloroform, 1,2-dichloroethane, methylene chloride.)
Many of the hazardous substances detected in groundwater at the site
were present at levels which far exceed Federal and State standards
and guidelines for groundwater quality. In particular, the levels
of numerous VOCs, PCBs, and several inorganic compounds exceed the
Federal Maximum Contaminant Levels (MCLs) established for these
chemicals under the Safe Drinking Water Act and the New Jersey MCLs,
sometimes by several orders of magnitude. In addition, contaminant
levels in soils in the FOU zone exceed the New Jersey Soil Action
Levels for VOCs, PCBs, base-neutral compounds, metals, and petroleum
hydrocarbons.

The data collected to date demonstrate the following: (1) there has
been migration of hazardous substances from the soils in the FOU
zone into the water table, and from the FOU zone down into the till
and the bedrock aquifers (the bedrock aquifer is presently used
regionally for potable and industrial purposes); (2) surface water
runoff and/or direct groundwater discharge from the site has
resulted in contamination of sediments and surface water in Peach
Island Creek; (3) the potential for further lateral migration of
hazardous substances out of the FOU zone in groundwater to off-site

12
-------
areas and into the till and bedrock aquifers beneath the site
exists; and (4) the potential also exists for contaminant migration
from the site into the atmosphere by volatilization and/or
particulate suspension also exists.

The baseline risk assessment identified pathways through which
humans may be exposed to site contaminants. The potential human
exposure pathways include direct contact with surface soil,
inhalation of volatile organics, inhalation of suspended solids and
ingestion of groundwater and surface water.

The baseline risk assessment and the RI results indicate that the
conditions at the SCP site pose an unacceptable risk to public
health, welfare and the environment. In addition, there will be a
continued threat of migration of hazardous substances from the site
absent the implementation of remedial actions. The interim remedial
action selected in this ROD will mitigate, for the short term, the
unacceptable risk posed by the conditions at the site and future
migration of hazardous substances from the site.

The interim remedy identified in this ROD will not achieve the level
of protection for the public health welfare and the environment
required by CERCLA for a final remedial action. It will also not
achieve the requisite reduction in mobility, toxicity and volume of
hazardous substances at the site required by that statute. The
interim remedy, however, will be a component of a final remedy for
the FOU zone that will ultimately be protective of public health
and the environment.

In summary, actual or threatened releases of hazardous substances
from this site, if not addressed by implementing the interim remedy
selected in this ROD, may present an imminent and substantial
endangennent to public health, welfare, or the environment.

DESCRIPTION OF ALTERNATIVES

Alternatives analyzed for the interim action are presented below.

Alternative 1; No Action

Capital Cost: $ 0
Annual Operation and
Maintenance (O & M) Costs': $ 42,000
Present Worth: $ 120,000 (est.)

Months to Design and Construct: 0
The NCP requires that the No Action alternative be evaluated at
every site to establish a baseline for comparison of other
alternatives. Under the No Action alternative, EPA would not take
an interim action at the site to control migration of contaminants
40&M costs are based on the three year expected duration of
the interim remedy.

13
-------
to groundwater and Peach Island Creek. The fence around the site
property would continue to be maintained to restrict access to the
site, however. The No Action alternative also includes periodic
monitoring of groundwater.

Alternative 2; Site Dewaterinq through Installation of a Slurry Wall
and a Groundwater Collection and Treatment System

Capital Cost: $ 4,586,000
Annual 0 & M Cost4: $ 109,000 (for 3 years)
Present Worth: $ 5,164,000

Months to Design and Construct: 12-24

In addition, an infiltration control barrier would be placed over
the site. The sole function of this temporary barrier is to reduce
the infiltration of precipitation into the FOU zone. This will tend
to reduce the volume of water which would require treatment, and
thus reduce the cost of treatment.

Alternative 3; Site Dewatering through Installation of a Slurry Wall
and Groundwater Collection and Qff-site Disposal

Capital Cost:5 $ 2,557,000
Annual 0 & M Cost4: $ 42,000 (for 3 years)
Present Worth: $ 2,933,000

Months to Design and Construct: 9-15

This alternative is identical to Alternative 2, except that
groundwater would be transported to and disposed of at an EPA
approved off-site facility (or facilities) capable of accepting the
extracted groundwater without any pretreatment on site.
Consequently, construction of an on-site groundwater treatment
facility would not be necessary.
cost of off-site transportation (i.e., via tanker truck)
and disposal have been incorporated into the capital cost. The
off-site transportation and disposal cost are based upon cost
estimates for transportation to and disposal of extracted
ground-water: at the E.I. Dupont de Nemours facility in Deepwater,
New Jersey, as provided to EPA by some of the PRPs.

14
-------
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

The selected alternative is to take interim action at the site by
implementing Alternative 3. This alternative is a necessary
component of any permanent future remedy for the FOU zone and would
appear to provide the best balance of trade-offs among the
alternatives with respect to the criteria that EPA uses to evaluate
alternatives. This section profiles the performance of the selected
alternative against the criteria which apply to this interim action,
noting how it compares to the other options under consideration.

Overall Protection of Human Health and the Environment; This
criterion addresses whether 'or not a remedy provides adequate
protection and describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment, engineering
controls or institutional controls. Alternative 1 would not be
protective of human health and the environment since contaminants
would continue to migrate from the soils and shallow aquifer to
deeper aquifers and Peach Island Creek. Alternatives 2 and 3 would
reduce the risk to human health and the environment in the short
term by reducing migration of hazardous substances away from the FOU
zone until a final remedy is in place.

Compliance with ARARs; This criterion addresses whether or not a
remedy will meet all of the applicable or relevant and appropriate
requirements (ARARs) derived from Federal and/or State statutes
and/or regulations and/or provide grounds for invoking a waiver.

There are several types of ARARs: action-specific, chemical-
specific, and location-specific. Action-specific ARARs are
technology or activity-specific requirements or limitations.
Chemical-specific ARARs establish the amount or concentrations of
a chemical that may be found in, or discharged to, the environment.
Location-specific requirements are restrictions placed on the
concentrations of hazardous substances or the conduct of activities
solely because they occur in a specific location.

Section 121 of CERCLA does not require chemical specific ARARs for
hazardous substances remaining onsite be achieved by an interim
measure. These requirements must be achieved, however, upon
completion of the permanent remedy. Therefore, since Alternatives
2 and 3 constitute interim actions, final cleanup levels for soil
and groundwater do not have to be achieved by these Alternatives.

However, certain action-specific requirements, discussed below,
would have to be attained as part of the implementation of
Alternatives 2 or 3. Alternative 2 must comply with effluent
limitations for any discharge from groundwater treatment plant into
Peach Island Creek. In addition, the treatment plant must be
designed and operated in compliance with Federal and State air

15
-------
emissions requirements. For Alternative 3, requirements pertaining
to any off-site disposal facility will be met.

Both Alternatives 2 and 3 would comply with the Executive Orders on
Flood Plain Management, and Wetlands Protection, the Clean Water Act
Section 404 General Standards for Permitting Stream Encroachment,
and the New Jersey Soil Erosion and Sediment Control Requirements
(N.J.A.C. 4:24-1) to the extent practicable. In addition, both
alternatives would comply with the regulations of the HackensacJc
Meadowlands Development Commission.

Short-Term Effectiveness; This criterion refers to the time in
which the remedy achieves protection, as well as the remedy's
potential to create adverse impacts on human health and the
environment during the construction and implementation period.

Alternative 1 presents the least short-term risks to on-site workers
since no construction activities are involved in implementing the
No Action alternative. However, it would not reduce any of the
existing risks at the site. Alternatives 2 and 3 would require
health and safety protection measures during the remedial
construction to adequately protect workers. These measures may
include requirements for protective clothing and respiratory
protection. Health and safety measures to protect the community,
such as dust or vapor suppression, may also be required. However,
neither Alternative 2 nor 3 present implementation problems which
cannot be properly addressed by available construction methods.

Alternative 2 will take 9 months to design and 9 months to
construct. Alternative 3 would take 6 months to design and 6 months
to construct. Therefore, Alternative 3 would reduce the migration
of hazardous substances from the site more quickly. Both
Alternatives 2 and 3 will accelerate ultimate remediation of the FOU
zone since both alternatives contain components which are consistent
with and are likely elements of a final remedy for the site.

Implementability: Implementability is the technical and
administrative feasibility of a remedy, including the availability
of materials and services needed to implement the selected
alternative.

Alternative 1 is the simplest alternative to implement from a
technical standpoint since it only involves actions to periodically
inspect and sample the site, ensure restricted access to the site,
and continue to provide information about the site to the
surrounding community.

The operations associated with Alternative 2 (construction of a
slurry wall, dewatering system, and groundwater treatment system)
generally employ well established, readily available construction
methods and materials. However, the placement of a treatment plant
on site may pose some difficulties with respect to implementing a
; 3rmanejpt.. remedy f-r soils, since the plant would physically
ifcstrud access to the soils for any potential future treatment.

16
-------
In addition, the ability of a treatment system to meet the
administrative requirements (see below) for discharge to Peach
Island Creek, cannot presently be determined.

The operations associated with Alternative 3 (construction of a
slurry wall, dewatering system, and off-site treatment and disposal
of groundwater) employ well established, readily available
construction methods and materials. . This alternative would
necessitate contingency plans to ensure that adequate storage
capacity exists for collected groundwater, in the event of a
significant increase in the estimated flow because of unanticipated
infiltration. Administrative requirements associated with
Alternative 2 include compliance with NJPDES requirements for
discharge of treated groundwater to Peach Island Creek while
Alternative 3 will require compliance with standards established
for off-site treatment facilities. In particular, the receiving
facility must be in compliance with Sections 3004 and 3005 of the
Solid Waste Disposal Act, as amended. Any off-site transport of
contaminated groundwater must also comply with Department of
Transportation regulations.

Since both Alternative 2 and Alternative 3 involve dewatering of the
FOU zone which will change the site hydrology, there may be
potential impacts to Peach Island Creek and/or the wetlands. Either
alternative could be designed in such a manner as to minimize the
potential impact to these areas.

All alternatives are implementable from an administrative and
technical perspective.

Long-term Effectiveness; This criterion refers to the magnitude of
residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time, once
cleanup goals have been met. Since this is an interim action,
effectiveness need only be maintained for the duration of the
interim action, which is expected to be no more than three years
after implementation of this interim action. Therefore, this
criterion will evaluate long-term effectiveness over a three year
period.

Alternative 1 is not effective in either the long term or short
term. Both Alternatives 2 and 3 would be effective, once
implemented, and should maintain their effectiveness for the
expected duration of the interim remedial action. Both Alternatives
2 and 3 would effectively reduce, but not eliminate, migration of
contaminants via groundwater beyond the slurry wall boundary until
a permanent remedy is in place.

Reduction of Toxicity. Mobility or Volume; This criterion addresses
the degree to which a substantial reduction of toxicity, mobility,
or volume of contaminants at the site is achieved through treatment.
Since none of the Alternatives evaluated for this interim remedy
employ treatment of the soils/sludges in the shallow zone, this
criterion is not applicable to this interim remedy. Alternatives

17
-------
2 and 3, however, involve the treatment of contaminated groundwater.
Both should therefore reduce the volume of contaminated groundwater
in the FOU zone.

The No action Alternative does not involve treatment and does not
meet the objective of this criterion.

Cost: This criterion includes evaluating both capital and operation
and maintenance costs.

Alternative 1, No Action, has an estimated present worth of
$120,000. The primary constituents of this cost are inspection and
sampling. The present worth costs of Alternatives 2 and 3 are
$5,164,000 and $2,933,000, respectively. The major cost items
associated with Alternative 2 and 3 are construction of the slurry
wall and groundwater treatment or disposal.

The cost estimates are based on the assumption that approximately
1,000,000 gallons of groundwater will be treated. If the actual
volume to be treated exceeds this amount, the cost associated with
off-site disposal will increase, and may approach that of on-site
treatment.

State Acceptance: This criterion indicates whether, based on its
review of the RI/FS and Proposed Plan, the State concurs with,
opposes, or has no comment on the preferred alternative.

Community Acceptance: Based on the comments received on the
Proposed Plan, the community accepts Alternative 3.

SELECTED REMEDY

The selected interim remedy is Alternative 3: site dewatering
through installation of a slurry wall, groundwater collection and
off-site disposal. This interim remedy contains the following
components:

1. Installation of a slurry wall along the perimeter of the
entire 5.9 acre SCP site which will extend from the
surface of the site, down into the clay-silt layer located
at the lower boundary of the FOU zone (approximately 15
to 20 feet below the surface of the site);

2. Installation of a groundwater collection and extraction
system in the FOU zone which will be capable of lowering
and maintaining the water table in this zone at the lowest
practicable level;

3. Extraction of groundwater from the FOU zone to achieve and
continuously maintain the water level in this zone at the
lowest practicable level;
18
-------
4. Transportation of all groundwater extracted from the FOU
zone to an appropriate facility (or facilities) located
off site;

5. Proper treatment and disposal of all groundwater extracted
from the FOU zone at an appropriate facility (or
facilities) located off site;

6. Installation of a temporary infiltration barrier across
the entire surface of the site which will be capable of
minimizing the entry of precipitation into the FOU zone;

7. Operation and maintenance of the groundwater collection
and extraction system, and maintenance of the infiltration
barrier and maintenance of the slurry wall surrounding the
site to ensure continued achievement of the objectives of
the interim remedy identified in this decision document;

8. Maintenance of fencing and provision of other site
security measure(s), as deemed necessary by EPA, until
such time that the final remedy is in place; and

9. Implementation of a program for groundwater and surface
water monitoring to measure the presence within and the
potential migration of hazardous substances from the FOU
zone, until such time that the final remedy is in place.

The goal of this interim remedy is to reduce contaminant migration
from the SCP site until a permanent remedy is implemented. The cost
estimate for Alternative 3 is as follows:

Capital Cost: $ 2,557,000
Annual 0 & M Cost: $ 42,000 (for 3 years)
Present Worth: $ 2,933,000

Table 12 provides further detail regarding the components of this
alternative and the cost estimates.

Alternative 3 best satisfies EPA's evaluation criteria for this
interim remedy. While none of the interim remedial alternatives
evaluated are fully protective of public health and the environment
in and of themselves, once implemented, Alternative 3 is more
protective than Alternative 1 and at least as protective as
Alternative 2. Because Alternative 3 can be implemented more
expeditiously than Alternative 2, it would attain short-term
reduction with respect to contaminant migration more quickly.
Primarily for this reason, Alternative 3 would provide greater
protectiveness for the interim and greater short-term effectiveness
than the other alternatives. Furthermore, it should be noted that
Alternative 3 is less likely to interfere with future site
remediation activities than Alternative 2 . It is also less costly
than Alternative 2. With respect to the criterion of reduction of
toxicity, mobility or volume through treatment, although the
alternatives evaluated do not involve treatment of contaminated

19
-------
soils and sludges, Alternative 3 will reduce the volume of
contaminated groundwater above the clay layer to the same extent as
Alternative 2, while Alternative 1 offers no reduction due to
treatment. Although some members of the community have had some
questions and concerns regarding the site, no one expresses
opposition to Alternative 3. With respect to all remaining
criteria, Alternative 3 ranks equal to or higher than the other
alternatives. Therefore, based upon the above considerations, EPA
has selected Alternative 3 as the interim remedy for the FOU zone
at the site.
STATUTORY DETERMINATIONS
Protection of Human Health and the Environment

This interim remedy (Alternative 3) is part of an overall remedy for
the FOU zone which will ultimately protect human health and the
environment. This interim remedy will reduce continued migration
of hazardous substances out of the FOU zone until a permanent remedy
is in place. This remedy is interim in nature and, as such, will
not be protective in the long term. Although this interim remedy
is not protective in and of itself, it will be consistent with an
overall remedy which will attain the statutory requirement for
protectiveness.

Compliance with Applicable or Relevant and Appropriate
Requirements

Section 121 of CERCLA provides that during interim measures ARARs
do not have to be met, as long as these requirements will be
achieved upon completion of the permanent remedy. Accordingly,
final cleanup levels for specific chemicals in the soil and
groundwater at the site do not have to be achieved for this interim
action.

This interim remedy will comply with all Federal and State
requirements which are applicable or relevant and appropriate to its
implementation. In particular, requirements pertaining to any off-
site disposal facility will have to be met. In addition,
Alternative 3 will comply with, to the extent practicable given the
interim nature of this remedy, the Executive Orders on Flood Plain
Management, and Wetlands Protection, the Clean Water Act Section 404
General Standards for Permitting Stream Encroachment, and the New
Jersey Soil Erosion and Sediment Control Requirements (N.J.A.C.
4:24-1). In addition, Alternative 3 will comply with the
regulations of the Hackensack Meadowlands Development Commission.

Cost-Effectiveness

Alternative 3 is cost effective. It is also more cost effective
than Alternative 2 in reducing the risk to human health and the

20
-------
environment in the short tern by reducing the migration of hazardous
substances from the site.

Utilization of Permanent Solutions and Alternative Treatment
for resource recovery) Technologies to the Maximum Extent
Practicable

Alternative 3 does not represent a permanent solution with respect
to the principal threats posed by the site. However, it is not
practicable to use permanent solutions at this time because further
studies are desirable before a permanent remedy for the FOU zone is
selected. The statutory preference for use of permanent solutions
and alternative treatment technologies will be addressed at the time
of selection of a permanent remedy for the site.

Preference for Treatment as a Principal Element

Alternative 3 does not utilize treatment as a principal element, in
that the primary source of contamination (i.e., soils and sludges
in the FOU zone) are not addressed. However, a limited amount of
treatment will be accomplished by extracting contaminated
groundwater and treating and disposing of it off site. Given the
interim nature of this action, this alternative uses treatment to
the maximum extent practicable. This interim action constitutes a
measure to reduce contaminant migration from the site and does not
constitute the final remedy for the FOU zone. The statutory
preference for treatment as a principal element will be fully
addressed in the decision document(s) for the final remedy for the
FOU zone.

DOCUMENTATION OF SIGNIFICANT CHANGES

There have been no significant changes in the selected interim
remedy from the preferred interim remedy described in the Proposed
Plan.
21
-------
TABLE 1
SUMMARY OF CHEMICAL CONCENTRATIONS
IN SHALLOW SOIL (0-2'} SAMPLES
CHEMICAL (Concent r»t ion Units)
Volatile Organic Compounds (ug/kg)
leratne
Chtorobenzene
Chloroform
1,1-Oichloroethane
1,2-Dichloroethane
1,1-Dichloroethylene
1, 2- trans -Dichloroethy I ene
Ethylbenzenc
Methyl tthyl ketene
Methytene chloride
1 , 1 ,2,2-Tet rach I oroethane
Tetrachloroethylene
Toluene
1 , 1 , 1-Trich loroethane
1 , 1 ,2-Trieh I oroethane
Trichlorethylene
(rXylene
e»p-Xylen*s
Scnf-VolatUe Conpotnds (wg/kg)
Cnaphthene (NC)
hracene (NO
zo(a)anthraeer»e (C)
zo(a)pyrene (C)
•enzo(b)f lucrar.thene CC3
lenzo(g,h,i)perylene (NC)
Benzo(k)f luorantfiene (C)
lis-(2-ethylhexyl)phthalate
luryl benzyl pr.thalate
2- Ch I oronaoh tha ( ene
Chrysene (C)
Oibenzo(a,h)»nthracene (C)
1,2*0ichlorofcpenzene
2,4-Dichtoropnenol
2,4-Dinethylpftenol
Oiethylphthalate
Oi-n-butyl pnthalate
Oi-n-octyl pr.thatate
Fluoranthene (NC)
Fluorene (NC)
lndeno-(1,2,3-e,d)pyrent (C)
Naphthalene (NC)
N i t robenzene
N-Nitrosodiphenvtamine
Thenanthrene (NC)
Phenol
Pyrene (NC)
1,2.4-Triehlorobenzene
FREQUENCY
OF DETECTION

4/17
V17
4/17
2/17
4/17
2/17
5/17
7/17
2/17
11/17
1/17
12/17
8/17
1/17
2/17
12/17
7/17
9/17

9/17
9/17
5/17
9/17
6/17
6/17
1/17
17/17
8/17
2/17
11/17
3/17
8/17
1/17
2/17
1/17
13/17
6/17
16/17
8/17
6/17
16/17
1/17
3/17
13/17
4/17
15/17
2/17
MAXIMUM
DETECTED
CONCENTRATION

53,900
336,000
17,800
64,700
10,200
182
241
652,000
8,560
2,390
476
4,290,000
3,380,000
1,228
1,810
2,060,000
2,000,000
1,450,000

2,700
3.910
4.540
9,390
17.700
6,950
3,790
281,000
48,304
122,000
5,500
2,400
47,300
1,102
1,120
4,994
71,000
9.050
15,300
6,909
12,100
102,000
78.299
2,980
15,300
58.200
12.700
1,228
GEOMETRIC
MEAN
CONCENTRATION

90
128
44
72
60
10
9
384
104
143
NC
934
739
NC
31
270
734
825

359
392
1,040
836
1,990
851
NC
33,600
1,540
174
753
693
543
NC
188
NC
3,080
1,570
1,850
428
1,010
2,020
NC
245
2,120
145
1,800
152
-------
TABLE 1 (Continued)
SUMMARY OF CHEMICAL CONCENTRATIONS
IN SHALLOW SOIL (0-2') SAMPLES
CHEMICAL f Concent rat ion Units)
Pest ie ides /PCBs (ug/kg)
Aldrin
ptelorin
PCBs:
Aroclor 1242
Aroclor 1248
Aroclor 1260
Aroclor 1254
Inorganic Cftemicals Cms/kg)
Antimony
Arsenic
•cry Hi un
CaoJniun
Chromiun
Copoer
Cyanide
Lead
Hereury
Nickel
Set emir
Silver
2inc
FREQUENCY
OF DETECTION

3/17
5/17

11/17
4/17
2/17
3/17

3/17
14/17
17/17
17/17
17/17
17/17
16/17
17/17
17/17
15/17
5/17
7/17
17/17
MAXIMUM
DETECTED
CONCENTRATION

57,000
57,000

15,000,000
23,000
43,000
12,000

16
60
26
95.1
721
71,600
£.02
2,750
21.3
39
4.9
19
4,170
GEOMETRIC
MEAN
CONCENTRATION

44
170

2,680
345
351
579

3.8
8.1
0.56
6.1
78.5
2,320
1.85
490
1.4
12.2
0.49
1.1
398
NO * NOT oetectec.
NC « Nat calculate: since chemical was detected in only one canple.

fC) * Ca-cinoge-n'c PAH.
CNC) « Nonsarcinoger.ic PAhs.
-------
TABLE 2

SUMMARY OF CHEMICAL CONCENTRATIONS
IN MEDIUM DEPTH (5-6') SOIL
Chemical
(Concentration Units)
Frequency
of Detection
Maximum
Detected
Concentration
Geometric
Mean
Concentration
Volatile Organic Compounds (ug/kg)
ber^ene
chlorobenzene
chloroform
1.1 - dichloroethane
1,2 - dichloroethane
1,2 - trans -dichloroethylene •
ethylbenzene
methyl ethyl ketone
oethlyene chloride
1,1,2,2 - tetrachioroethane
terrachloroethylene
toluene
1,1,1 - rrichloroe thane
1,1,2, - trichloroethane
tr i chl ore thy 1 ene
vinyl chloride
n-xylene
o+p - xylenes
Seal-Volatile Compounds (ug/kg)
•cenaphthene (NC)
acenaphthylene (NC)
anthracene (NC)
benzidine
benzo (a) anthracene (C)
benzo(a)pyrene (C)
benzo(b)fluoroanthene (C)
benzo(g,h, Dperylene (NC)
bis (2-ethylhexyl)phthlate
butylbenzylphthalate
2 - chl oronaph thai ene
ehrysene (C)
1,2 - dichlorobenzene
diethyl phthalate
2,4 - dime thy Iphenol
di-n-butyl phthalate
di-n-octyl phthalate
fluoranthene (NC)
fiuorene (NC)
8/17
7/17
2/17
3/17
4/17
5/17
15/17
5/17
8/17
1/17
12/17
16/17
3/17
1/17
8/17
1/17
16/17
16/17

8/17 '
1/17
7/17
1/17
5/17
7/17
6/17
5/17
14/17
6/17
4/17
7/17
6/17
1/17
3/17
6/17
5/17
13/17
9/17
52,300
258,000
379,000
179,000
290,000
512,000
529,000
795,000
14 , 900
703
1,690,000
2,270,000
1,770,000
15,700
1,670,000
28.9
1,580,000
710,000

21,200
21.000
2,950
244 , 000
84,200
108,000
164,000
73,300
381,000
73,600
18,200
106,000
385,000
28,500
10.800
98,200
19,500
176,000
94,100
621
887
257
461
413
288
4,330
1,300
565
NC
2,760
15,700
473
NC
856
NC
12,200
10,500

443
NC
474
NC
1,200
649
1,730
671
14,400
1,990
282
633
499
NC
382
1,750
1,190
1,460
549
-------
TAST.Z 2 (Continued)

SUMMARY OF CHEMICAL CONCENTRATION IN DEEP SOIL SAMPLES
Chemicals (Concentration Units)
Volatile Organic Compounds (us/kg)
Benzene
Chlorobenzene
Chloroform
1 , 1 -0 i cti 1 oroethan*
1,2-Dichloroethane
1,2- trans -Dichtoroethylene
Ethylbenzene
Methyl ethyl ketone
Methylene chloride
1,1.2,2-Tetrachloroethane
1,1,1-Trichloroethane
•rXylene
o»p-Xylenes
Styrene
Tetrachloro«thylene
Toluene
Triehloroethylene
Vinyl chloride
Semi-Volatile Compounds (ug/kg)
Aeenapnthene (NO
Anthracene (NO
Ber.zo( a) anthracene (O
Ber.zo(a)pyrene CO
Benzo(S)f luoranthene (C3
Benzo(s,h,i)perylene (NO
Bis(2-ethylhexyl)prthalate
Butylbenzylpfcthalate
Chrysene (O
1 , 2 -0 i ch I orobenzene
Di-n-butylpft thai ate
Di-n-oetyipnthaiate
Fluorantnene (NO
Fluorene (NO
Inoeno(1,2,3-cd)pyrene (O
Isoprorone
Napntnalene (NO
Phenanthrene (NO
Phenol
Pyrene (NO
Pesticides/PCBs (ug/kg)
Oieldrin
Aroelor 1242
Aroclor 1248
Aroelor 1254
Aroclor 1260
Inorganic Chemicals (mg/kg)
Antimony
Arsenic
Beryl t ium
CaOniifn
Chromium
Copoer
Lead
Mercury
Nickel
Selenium
Si Iver
Zinc
Frequency
Of Detection

3/17
2/17
2/17
2/17
4/17
6/17
7/17
10/17
8/17
1/17
3/17
10/17
8/17
1/17
7/17
U/17
7/17
1/17

1/17
3/17
1/17
10/17
1/17
1/17
13/17
3/17
4/17
6/17
3/17
3/17
7/17
2/17
1/17
3/17
10/17
5/17
2/17
8/17

3/17
11/17
3/17
3/17
3/17

2/17
10/17
17/17
10/17
17/17
17/17
15/17
10/17
17/17
2/17
2/17
17/17
Maxiitun Detected
Concentration

1,010
115
10,300
234
6,500
12,200
45,600
31,500
7,260
$2.4
57,600
135,000
87,900
212
917,000
216,000
363,000
11,774

100
181
564
4,740
576
227
3,360
4,690
1,340
10,800
2,440
5,610
23,201
186
213
725
2,270
3,250
14,400
1,840

210
5,400
2,600
2,200
1,000

29
18
0.74
132
56
11,900
916
13.6
44
1.3
1.2
4,400
Geometric Mean
Concentration

43
21
22
21
36
37
106
360
77
NC
36
237
201
NC
113
290
45
NC

NC
52
NC
261
NC
NC
2,140
380
83
108
388
379
125
52
NC
83
168
196
86
108

4.1
121
22
38
39

3.6
2.8
0.48
0.72
20.2
66.7
28.7
0.16
14.1
0.28
0.55
92
NC = NC: calculated because chemical was detected in only one sanpie.
NO = NC: oetected.

(O » C jreinogenic PAH
(NO s Noncarcinogemc PAH
-------
TABLE 4
SUMMARY OF CHEMICAL CONCENTRATIONS
DETECTED IN VERY DEEP SOIL SAMPLES
Chemical
(Concentration Units)
Frequency
of Detection
Maximum
Detected
Concentration
(ugAg)
Ceonetrie
Mean
Concentration
(ugAg)
Volatile Organic Compounds (ug/kg)
chlorobenzene
chloroform
1,1 - dichloroe thane
1,2 - dichloroe thane
1,2 - trans -dichloroethylene
ethyl benzene
methyl ethyl ketone
methlyene chloride
tetrachloroethylene
toluene
1,1,1 - trichloroethane
trichlorethylene
m-xylene
o+p - xylenes
Semi-Volatile Compounds (ugAg)
2-chlorophenol
1,2- dichlorobenzene
isophorone
nitrobenzene
phenol
2/16
6/16
1/16
3/16
2/16
2/16
8/16
15/16
14/16
13/16
2/16
16/16
9/16
5/16

1/7
2/7
1/7
5/7
1/7
31,523
333,000
698
59,900
13,820
69,606
69,000
99,100
536,013
469,276
200,449
1,071,522
191,660
117,053

238
465
151
718
434
199
217
NC
206
88
221
1,180
2,250
2,220
1,120
348
6,630
523
319

NC
79
59
154
NC
Pesticides/PCBs (ugAg)

PCBs: Aroclor 1242
3/7
370
33
-------
TABLE 4 (Continued)
SUMMARY OF CHEMICAL CONCENTRATIONS
DETECTED IN VERY DEEP SOIL SAMPLES
Chemical
(Concentration Units)
Frequency
of Detection
Maximum
Detected
Concentration
(ug/kg)
Geometric
Mean
Concentration
(ug/kg)
Inorganic Compounds (ag/kg)
arsenic
beryllium
cadmium
chromium
copper
lead
nickel
zinc

5/7
7/7
1/7
7/7
7/7
6/7
7/7
7/7

5.5
1.2
0.28
33
39
17
37
87

1.7
1.0
0.15
28
30
7.2
3.0
71
NC - Not calculated since chemical was detected in only one sample.

ND - Not detected.
-------
TABLE 5

TANK SLUDGE SAMPLING DATA
SCP/CARLSTADT, NEW JERSEY

Characteristics and
Constituent Concentrations

Specific Gravity 1.37
Total Solids . 64.76%
Water Content • 4%
Flash Point >212°F
Ash Content 23.62%
Heating Value 6.940 BTU/lb
Aluminum, as Al 29.30 mg/L '
Arsenic, as As " 7.07 mg/L
Barium, as Ba 2620 mg/L
Cadmium, as Cd 98.7 mg/l
Chromium, as Cr 12,300 mg/L
Copper, as Cu 2,830 mg/L
Lead, as Pb 50,700 mg/L
Mercury, as Hg 1,560 mg/L
Nickel, as Ni 32.3 mg/L
Selenium, as Se < 0.020 mg/L
Silver, as Ag 2.90 mg/L
Zinc, as Zn 1,410 mg/L
Beryllium, as Be 4.51 mg/l
Potassium, as K 291 mg/L
Total Sulfur 4,930 mg/L
Total Chlorides, as Cl 109,000 mg/L
Total Fluorides, as F 879 mg/L
Total Cyanides <10 mg/L
Oil and Grease 23.6%
PCB, Aroctor 1242 32,300.00 mg/L
Note: Concentrations based on a single sample taken
by USEPA and analyzed by Chemical Waste Management
on 9 May 1986
Source: USEPA Region II SCP/Caristadt File

mg/L;ppm
-------
TABLE 6
CONCENTRATIONS OF CHEMICALS DETECTED IN THE WATER
UBLE AQUIFER AT THE SCP SITE

(UNF1LTERED SAMPLES)
Concentration (ug/l)

Geometric Naxiaun
Frequency Mean (b) Detected Value (b)
Chemical of Detection (•)

Volatile Compounes
ienzene 10/14 319 7,270
Chlorobenzene 3/14 9.5 4,020
CM ore* thin* 1/U ' NC 2,420
Chloroform 4/14 38.1 614,000
1,1-Dichloroethane 8/14 86.5 11,700
1,2-Dichloroethane 4/14 33.9 473,000
1.1-Diehloroethylene 1/14 NC 32
1,2-trans-0ichloroethyl«ne 12/14 2,270 64 700
Ethytberaene 6/14 35.9 3,900
Metnylene Chloride 10/14 522 200,000
Methyl ethyl ketone 5/14 168 2,000,000
1,1,2,2-Tetrachloroethane 4/14 17.0 7,350
Tetrechloroethylene 3/14 16.2 24,500
Toluene 14/14 10,500 90,900
1,1,1-Trichloroethane 7/14 58.8 81,200
TrieMoroethylene 8/14 565 161,000
Vinyl Chloride 9/14 106 7,290
»-Xylene 6/14 49.2 20,400
o » p-Xylenes 8/14 123 15,200

Setii-volatile
Total CPANS (e) 2/14 6.8 379.5
Total NCPAM$ (d) 13/14 30.7 2706.9
bis(2-Chloro«tnyl)ether 2/14 11.1 1 390
bis(2-Ethyl hexyl)phthalate 5/14 17.1 654
fturyl benzyl pnthaiite 1/14 NC 10.4
2-CMoronatfitrialene V14 NC 18.9
2-CMo'00henol 2/14 5.9 17.8
1,2-Dichioroberuene 12/14 34.8 192
2,4-CicMoroenenol 2/14 9.1 463
O^ethyl phtnaiatc 2/14 7.4 416
2,4-Oimethyl phenol 11/14 53.9 1,090
Diaethyl pttthalate 1/14 nc 316
Oi-n-butyl phtnalate 2/14 7.2 318
Isopriorane 5/14 26.3 8,450
nitrobenzene 4/14 65.0 57,900
2-Hitropftenol 1/14 MC 4.73
Ptvencl 14/14 510 17,100

P est I'c ides/PCS s
Bett-BHC 1/14 NC 0.56
Total DDT and campoinds 3/14 0.09 1.7
Enarir, aideftyOe 2/14 0.09 15.0
Endosultan 1 1/14 NC 0.25
Endrin 1/14 NC 0.65
Total PCB$ (e) 6/14 1.9 17,000

Inorganics
Arsenic
Berylliun
CadB'iiTt
Chromiun
Copper
Cyanioe
Lead
tiercury
Nickel
Zinc
10/14
4/14
4/14
7/14
14/14
11/14
5/14
10/U
12/U
14/14
30.7
1.2
3.5
26.3
341
0.07
14.3
0.49
55.5
92.4
3,100
4.3
16
450
1,580
4.52
1,500
4.4
180
2.970
(a) Frequency ot Detection based on U tamo its, two from each campling station.
(b! Geometric means and maximum were calculated a'ter the geometric mean of the two
sairc.es T-OT-. e»ch station were calculateo. The listed maxinun is, however, the
max-.ITVJT- VBIJ* aetectec in any sample.

(e) CP*HS * Carcir»9enic PAMS. Those deteeteo in grot*id*i»ter were: benzo(a)pyrene,
cn.-ysene, fiuonnthene arc fluorene.
(d) NC?*ris * Moncarcinogenic PAHS. Those oetectec ir grovmdxater were: acenapnthene,
•cenas^.thytene, anthracene, nao*itnalene, pnenar.tnrene are pyrene.
(e) ine.uoes all Aroclors oeteeted at site [12423.

NC - Net calculated since chemical nas deteetefl in only one sample.
-------
TABLE 7
CONCENTRATIONS OF CHEMICALS DETECTED IN THE
TILL AQUIFER AT THE SCP SITE

(UNFILTERED .SAMPLES)
Chemical
Frequency
of Detection (•)
Concentration (ug/l)
Geometric
Mean (b)
Maximum
Detected value (b)
Volatile Compounds

Ch1orobenzene
Chloroform
1,1-Diehloroethane
1,2-Dichloroethane
1,1-Dichloroethytene
1,2-trans-Dichloroethylene
Methylene Chloride
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
Trichloroethylene
Vinyl Chloride

Semi-Volatile Compounds

1,2-0 i ch Iorobenzene
Nitrobenzene
Phenol
2/6
5/6
1/6
5/6
3/6
3/6
6/6
4/6
2/6
4/6
6/6
1/6
2/6
3/6
1/6
4.6
324
NC
1U
17.3
11.6
101
26.7
3.1
29.5
410
NC
5.4
7.2
>C
39.7
28,600

9,230
313
190
1210
996
10.1
417
16.400
$4.3
7.46
23.3
2.16
Pesticides /PCBs
Total PCBs (c)
Inorganics
Copoer
Zinc

1/6

1/6
5/6

NC
29.5

1.8

19
57
(a) Frequency of detection based on 6 samples, two from each of the three
sanpl ins Stations.
(b) Geometric means and maxinurs were calculated after the geometric wean of the two
samples frotr each statior. were calculated. The listed nxiaun it, however,
the maximum value detected in any sample.
(c) Includes all Aroclors detected at site.
NC * Not calculated because chemical was detected in only one sample.
-------
TABLE 8
CONCENTRATIONS' OF CHEMICALS DETECTED IN THE BEDROCK AQUIFER
AT THE SCP SITE

(UNFILTERED SAMPLES)

Concentration (ug/1)
Frequency Geometric Maximum
Chemical of Detection (a) Mean Detected Value

Volatile Compounds
Chloroform 2/2 670 830
1.2-Dichloroethane 2/2 ' 420 460
1.1-Dichloroethylene 1/2 NC 2
1.2-trans-Dichlproethylene 1/2 NC 3
Methylene chloride 1/2 NC 21
Tetrachloroethylene 1/2 NC 2
Toluene 1/2 NC 15
1.1.1-Trich lore-ethane 1/2 NC 6
Trichloroethylene 2/2 240 310
Vinyl chloride 2/2 28 56

Inorganics
Aluminum
Barium
Calcium
Chrom i urn
Copper
Lead .
Magnesium
Potassium
Sodium
Vanadium
Zinc
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
863
142
209.000
27.6
52.3
2.6
1.380
3.100
60.500
7
7.8
(a) Frequency of detection based on two samples for organics and one sample for
inorganics. The samples were taken from a single monitoring well on two
separate dates.

NC * Net calculated since chemical was detected in only one sample.
-------
TABLE 9
CHEMICAL CONCENTRATIONS IN SURFACE WATER SAMPLES
AT PEACH ISLAND CREEK

(All concentrations in ug/liter)

Chemical
Volatile Organic Compounds
^. .........
Chlorobenzene
Chloroform
1,2-trans-Dichloroethylene
Methyl ethyl ketone
Methylene chloride
IL , 1 , 1 -Trichloroe thane
(Toluene
Trichlorethylene
p-Xylene
p+p-Xylenes
Inorganic Chemicals
Chromium
Topper
lercury
Nickel
Zinc

100 Feet
Upstream •
(Loc. 4)

ND
ND
ND
75
4.63
ND
ND
ND
ND
ND

56
100
4.8
57
370

Adjacent
to site
(Loc. 3)

8.34
3.58
35.20
45.40
6.12
6.32
20.60
3.83
ND
ND

ND
29
0.96
33
160

100 Feet
Downstream
(Loc. 2)

12.20
3.56
33.30
49.20
12.90
5.54
48.10
ND
10.70
10.00

28
27
1.1
27
150
Confluence
with
Berry's
Creek
(Loc. 1)

ND
ND
3.91
ND
14.90
ND
ND
ND
ND
ND

ND
12
2.1
ND
87
SD - Not detected.
-------
TABLE 10

SUMMARY OF CHEMICAL CONCENTRATIONS
IN SHALLOW SEDIMENTS (0-6 INCHES)
Concentration

[
I
Chemical
|
r
Volatile Organic Compounds (ug/kg)
Benzene
Chlorobenzene
Chloroform
Ethylbenzene
Methyl ethyl ketone
Kethylene chloride
i-Xylene
w-p-Xylenes
retrachloroethyletie
Foluene
L.l, 1-Trichloroe thane
^chlorethylene

100 Feet
Upstream
(Loc. 4)

ND
3,990
ND
4,610
ND
ND
13,300
11,000
ND
41,500
ND
ND

Adjacent
to Site
(Loc. 3)

ND
ND
ND
39,000
ND
ND
1,060,000
647 , 000
953,000
2,970,000
222,000
9,950,000
100 Feet
Downstream
of Sice
(Loc. 2)

ND
17,100
3,690
35,100
18,300
ND
72,000
74,200
ND
322,000
ND
ND
Confluence
with
Berry's Creek
(Loc. 1)

82.5
200
ND
ND
65.2
42.3
168
' 467
ND
ND
ND
ND
Pesticides/?C3s (ug/kg)

Dieldrin
PCBs:
Arochlor 1242
Arochlor 1248
Arochlor 125«
Arochlor 1260
ND

21,000
ND
ND
10,000
11,000

55,000
ND
ND
ND
ND

35,000
ND
ND
6,000
ND

ND
19,000
5,200
ND
Seni-Volariles (ug/kg)

1^2,4-Trichlorobenzene
ir2-Dichlorobenzene
2-Chloronaph chalene
Acenaphthene
Benzo(a)pyrene
Bis(2-e:hylhexyl)phrhlate
Butyl benzyl phrhalace
Chrysene
Di-n-ocrylphchalace
525
1,850
ND
ND
ND
108,000
ND
ND
ND
ND
3.670
ND
ND
ND
32,600
ND
ND
ND
ND
424
115
166
148
32,000
736
332
600
ND
ND
ND
ND
ND
2. 920
"ND
ND
NT)
-------
TABLE 10 (Continued)
SUMMARY OF CHEMICAL CONCENTRATIONS
IN SHALLOW SEDIMENTS (0-6 INCHES)

Chemical
Semi-Volatiles (ugAg) (Cont'd)
Di-n-butylphthalate
Fluoranthene
Fluorene
Naphthalene
Phenanthrene
Pyrene
2 , 4 - Dime thy Ipheno 1
Phenol
Inorganics (mgAg)
Arsenic
Beryllium
Cadmium
Chromium
Copper
Cyanide, total
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc

100 Feet
Upstream
(Loc. 4)

2,350
928
536
1,330
1,820
916
1,360
24,900

37
2.4
84
819
9,510
0.12
320
41
467
ND
2.4
1.0
3,110
Conce

Adj acent
to Site
(Loc. 3)

ND
ND
ND
816
ND
ND
ND
10,200

ND
1
43
345
2,000
0.21
520
25
110
ND
2.7
ND
2,320
tntrat.ion
100 Feet
Downstream
of Site
(Loc. 2)

ND
374
202
1,230
712
339
ND
ND

ND
0.39
12
156
1,240
0.001
340
0.34
96
ND
ND
ND
411

Confluence
with
Berry's Creek
(Loc. 1)

ND
ND
ND
ND
ND
ND
ND
4|

34
0.7
32
1,060
861
0.005
360
139
100
0.89
8.6
1.1
2,880
ND - Not detected.
-------
TABLE 11
SUMMARY OF CHEMICALS CONCENTRATIONS IN SAMPLES OF DEEP SEDIMENTS
Concentration

Chemical
VOLATILE ORGANIC COMPOUNDS (ug/kg)
1,1,1-Trichloroethane
1,2-Dichloroethane
1,2-trans-Dichloroethylene
•enzene
Chtorobenzene
Chloroethane
Chloroform
Ethylbenzene
Methyl ethyl ketone
Me thy 1 en* chloride
Tetraehloroethylene
Toluene
T r i eh I oroethy I ene
n-Xylene
e*p-Xylenes
•ASE NEUTRALS (ug/kg)
1, 2, 4-Tri Chtorobenzene
1,2-Diehlorobenzene
|is(2-ethylhexy I >phthalate
Butyl benzyl phthalate
Chrysene
Oibefizo(a,h)anthracene
Di-n-butyt phthalate
Di-n-octyl phtnalate
Fluorinthene
Naphthalene
Phenanthrene
Phenol
Pyrene
PESTIClDES/PCBs
PCBs:
Aroelor 1242
Aroclor 12^8
Aroelor 1254
Aroelor 1260
INORGANICS (ing/kg)
Arsenic
•eryl liun
Cadmium
Chromium
Copper
Lead
Cyanides, total
Mercury
Nickel
Silver
Thai liun
Zinc

100 Feet
Upstream
(Location 4)

NO
1,960
1,160
1,990
4,930
NO
3,790
7,420
31,900
3,690
NO
74,500
1,890
17,200
16,000

177
445
32,600
ND
NO
NO
884
NO
381
379
556
6,560
343

8,880
ND
ND
2,800

15
1.4
29
257
2,230
96
0.02
18
203
NO
NO
1,060

Adjacent
to Site
(Location 3)

75,500
ND
NO
ND
ND
ND
ND
174,000
NO
ND
304,000
1,700,000
3,260,000
486,000
348,000

2,330
261,000
240,000
9,700
ND
ND
24,800
12,200
ND
20,300
ND
44,700
ND

770,000
ND
ND
ND

22
2
74
504
2,590
230
0.01
41
413
ND
1.1
2,540
100 Fe«t
Downstream
of Site
(Location 2)

ND
ND
ND
5,785
NO
2,127
ND
ND
ND
ND
ND
726
ND
5,796
9,481

ND
852
95,651
ND
1.010
870
2,791
938
1,465
1,014
2,569
NO
1,254

21,675
ND
HO
11,099

7.4
0.62
30
258
1,213
232
0.014
1.93
228
ND
ND
945

Confluence With
terry's Creek
(Location 1)

NO .
NO
ND
33.4
47.3
ND
ND
29.7
ND
ND
ND
ND
ND
93.8
141

ND
ND
5.700
ND
ND
ND
ND
ND
534
ND
ND
NO
ND

ND
42,000
5,500
ND

31
0.63
28
1.170
835
370
0.002
T.390
140
7.6
1.2
3,680
-------
TABLE 12
COST ESTIMATE - INTERIM REMEDY
ALTERNATIVE 2 I ON-SITE TREATMENT

Cost Estimate
Conceptual Items in Thousands

Mobilization/demobilization 150,000
Fencing: 2,400 If x $30/lf (incl. resetting once) 72,000
Perimeter road: 3'H x 15'W x 2,400'L - 60,000
4,000cy x $15/cy
Steel sheetpiling along creek: 600'L x 20'D x 240,000
$20/sf
S/B slurry wall w/ membrane: 36,000 sf x $16/sf 576,000
Respread excavated material: incl. 25% vol. inc.- 10,000
5,000 cy x $2/cy
Foam for VOC control: 5,000 cy x $30/cy 150,000
Clearing: 6 acres x $3,000/acre 18,000
Grading: 29,000 sy x $2/sy 58,000
Membrane: 60 mil HOPE - 257,000 sf x $l/sy 257,000.
Perimeter erosion control, runoff diversion 40,000
Dewatering (from existing wells into holding tank) 130,000
Treatment: 1,000,000 gal treated on-site via GW-61 1,926,000
Site security: estimated at 12,000 man-hours x
$6/hr2 72.000

Total Construction Cost $3,759,000
Eng'g. & Constr. Oversight3 827,000
Monitoring (quarterly, 3 yrs)' 109.000

Subtotal $4,695,000
Contingency £ approx. 10% 469.OOP
TOTAL COST $5,164,000
1 GW-6 includes chemical precipitation, steam stripping and
UV oxidation. Capital cost estimate * $1,706,000; O & M cost
estimate = $220,000 (for an 8 month operating period).

2 Assumes 6-moth construction duration.

3 Including design, preparation of specifications* and bid
packages, meetings, contractor selection and negotiation.

4 Assumes a 3-year period before permanent remedy is
implemented, and includes 12 rounds of sampling the three on-
site till wells and the on-site bedrock well, analyses for VOCs
and PCEs, and water level readings of all on-site wells and
piezometers. Cost shown is the present worth value of $40,000
per year for 3 years using a 5% interest rate.
-------
TABLE 13
COST ESTIMATE - INTERIM REMEDY
ALTERNATIVE 3: OFF-SITE DISPOSAL

Cost Estimate
Conceptual Items in Thousands

Mobilization/demobilization $150,000
Fencing: 2,400 If x $30/lf (incl. resetting once) 72,000
Perimeter road: 3'H x 15'W x 2,400'L - 4,000 cy x $15/cy 60,000
Steel sheetpiling along creek: 600'L x 20'D x $20/sf 240,000
S/B slurry wall w/ membrane: 36,000 sf x $16/sf 576,000
Respread excavated material: incl. 25% vol. inc.- 10,000
5,000 cy x $2/cy
Foam for VOC control: 5,000 cy x $30/cy 150,000
Clearing: 6 acres x $3,000/acre 18,000
Grading: 29,000 sy x $2/sy 58,000
Membrane: 60 mil HOPE - 257,000 sf x $l/sf 257,000
Perimeter erosion control, runoff diversion 40,000
Dewatering (from existing wells into holding tank) 130,000
Loading: 2 hrs/truck x 200 trucks x $60/hr 24,000
Transportation: 200 trucks x $500/truck 110,000
Treatment: 1,000,000 gal x $0.13/gal (DuPont)1 130,000
Site security: estimated at 12.,000 man-hours x $6/hr2 72.00Q

Total Construction Cost $2,097,000
Eng'g & Constr. Oversight3 460,000
Monitoring(quarterly, 3 yrs)4 109,000
Subtotal $2,666,000
Contingency §approx. 10% 267,000
TOTAL COST $2,933,000
1 On a preliminary basis, Du Pont has indicated that the
FOU water would be acceptable.

2 Assumes 6-month construction duration.

3 Including design, preparation of specifications and bid
packages, meetings, contractor selection and negotiation.

4 Assumes a 3-year period before permanent remedy is
implemented, and includes 12 rounds of sampling the three on-
site till wells and the on-site bedrock well, analyses for VOCs
and PCBs, and water level readings of all on-site wells and
piezometers. Cost shown is the present worth value of $40,000
per year for 3 years using a 5% interest rate.
-------
.v/*«r«v '- WSrx
"° **'•&&;*•&*
/
lOC'I'D"
SITE LOCATION MAP
SCP SITE
CARLSTADT, NEW JERSEY
0 2000 4000 FEET
REFERENCE:
U.S.Q.S. 7.6' QUADRANGLE:
WEEHAWKEN. N.J..N.Y..1967.
PHOTO REVISFO 1881
DAMES & MOOR
FIGURE 1
-------
OQ
C
N)
I If I INDUUII

[. | MtlMNMOl
ra
OU•SI-PUttlC (AMOS UNO
I AMOS
• IMAIKH 01' (HI

H(»V» iHDUSIHr
LAND USE MAP

CARLSTAOT. N J
or c««i',r»ot
COU>»lf, ».J .
rid/
-------
l-
n
B
0-
X
x
w -40-
-•0-J
•"> H
INI SI/IIMI«I«II sii'ioi SHOWN Mpmsims mm
IV4IIMIIDN 01 IHI NOSI '«nil«lll| IDHDIIIONS

• Rll OAIA SIWI W««I«IIOHS I HOI1 IMISI lOnOIMOHS
Mll\l «| I I
« I »

I I ntsctUAHCOus nil

j|lQfjH]l CHAT SKIT riN( SAHO

f'"'.'\ CM» i SHOWN CIA»|» SHI
I I I HAY IIAIUSIKINI )

1*^1 «f on ISM i«nwH MiiruDC or
L»-^»l ((«'. Sill. SAND I CKAVll
(I.IAIIAI tllll

• llini'.M ft*nwN miil»SWl(K SMAI I

MKIINID INM«y«l

MRII sum AH
B
W', I vl "I H <| | lll I UN
I Oil IK It SUHI*ll
HOII W«l|l. IIVII S r.|*SllHII>
OH AHI.ilM 1 I'lN/
-------
INDUSTRY IN THE
VICINITY OF THE SCP SITE
CANLSTADT. H.J.
-------
MW-2S MW-2D
PROPERTY LINE
PATERSON PLANK ROAD
NOTE: REPLACEMENT BORINGS WITH PREFIX "R" WERE DRILLED ADJACENT TO
ORIGINAL BORING LOCATIONS. FOR CLARITY THE "R" BORINGS ARE
NOT SHOWN ON THIS FIGURE. SEE SECTION k.2.1 FOR DISCUSSION.

LOCATION PLAN

BORINGS, PIEZOMETERS AND WELLS
• i
SO'l IO«i«G
.OmTOimC WtU
8CP SITE, CARL8TADT, N.J.
0 100 ?00 FEET
Figure 5
-------
BORING RMW-2D

it
OQ
C
•-(
n>
O
*
c
c
O
O
a>
m
241.01
LEGEND:
BORING RMW-5D

t»
6.337)
« I
~ - ° C *M*
i ': J 5
srntOLS

Jmm
1 toft

'0 » - •
It IMS
• r MOO
" 1 '.DO II
i soon
i •••
**~
1 T\
••
jr=g
ss;
I'ffi
h-
^
,

FT
ML
ClT-ML
CL
CM
CL
CM
SP
siv
MCT ruvtrt
2.608
10.966
0.355
229.28
248.42
76.32
89.61
I. 5
» • S i
BORING RMHV-70

tutmcf eifMrto* > t
rr*»oit
VOLATILE ORGANIC COMPOUNDS, mg/kg
NOTE: BORINGS SHOWN TO BOTTOM OF CLAY

BORINGS MW-20. MW-5D. AND MW-7D EXTEND
TO TOP OF BEDROCK .

PROFILE OF VOLATILE ORGANIC COMPOUNDS

DEEP BORINGS

SCP SITfi, CARLSTADT, N.J.
c/
5rw*-

*4%
10 rurB
< ««B
" '**•
'•* -WT
1 1MB
iO i Hi
• •»
^^
«J B

• i a

• B
* too B

*m
•OT
^
:==
^
=
.'''I
ill!!

•«*•

•';

;7|
••••••••

B*T
" 1
ML
CL

CL
C~M

cusc
GM

• « W M
0.476
98886

34.942
4 123.5 (DUPLICATE
327.8 1683.9)

257.09
107.18
0.83
0.27
0.32
2.35
0.05

2.84
OO * T
.217

-------
CO

I
0
EMBANKMENT I
STREAM WATER AND

SEDIMENT SAMPLING LOCATIONS

SCP CARLSTADT

CARLSTADT, N.J.

0 500 1000 FEET
KEY:
SAMPLING STATION
BASE FROM AERIAL PHOTOGRAPHY

12/13/78 017-79 2-160
DAMES i MOO
-------
RESPONSIVENESS SUMMARY
FOR THE PROPOSED REMEDIAL ACTION
AT THE SCIENTIFIC CHEMICAL PROCESSING SUPERFUND SITE
CARLSTADT, NEW JERSEY
TABLE OF CONTENTS

SECTION PAGE

I. INTRODUCTION 1

II. PUBLIC MEETING COMMENTS 2

A. EFFECTIVENESS OF THE INTERIM
REMEDY 2

B. REMEDIAL INVESTIGATION
ACTIVITIES 2

C. HEALTH AND ENVIRONMENTAL PROTECTION
ISSUES 3

D. SCHEDULE FOR REMEDIAL
ACTIVITIES 3

III. RESPONSE TO WRITTEN COMMENTS 4

A. COMMENTS ON THE PROPOSED
PLAN 4

B. COMMENTS RELATING TO ARARS/TBCS
FOR THE FINAL REMEDY 10

C. ENDANGERMENT ASSESSMENT 14
IV. COMMUNITY RELATIONS ACTIVITY
CHRONOLOGY 21
V. REMAINING CONCERNS 22
-------
I. INTRODUCTION
The Scientific Chemical Processing Superfund site (SCP site
or the site) is located at 216 Paterson Plank Road in Carlstadt,
New Jersey. The site, which is owned by Irunar Associates, was used
during the 1970s by the Scientific Chemical Processing, Inc. for
treatment of a wide variety of industrial chemical wastes. In 1980,
operations at the facility were ceased. The site was placed on the
National Priorities List of uncontrolled hazardous waste sites in
1983. A Remedial Investigation and Feasibility Study (RI/FS) was
conducted by some of the potentially responsible parties under
administrative orders issued in September and October 1985.

In accordance with the U.S. Environmental Protection Agency's
(EPA) community relations policy and guidance and the public
participation requirements of the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), the EPA Region
II office held a public comment period from May 19, 1990 to June
18, 1990, to obtain comments on the Proposed Plan for the site.

On June 5, 1990, EPA and the New Jersey Department of
Environmental Protection (NJDEP) held a public meeting to receive
public comments on the Proposed Plan. Copies of the Proposed Plan
were distributed at the meeting and placed in the information
repositories for the site.

Public comments received during the comment period are
documented and summarized in this Responsiveness Summary. Section
II presents a summary of questions and comments expressed by the
public at the June 5 public meeting. Section III presents EPA's
responses to written comments received during the public comment
period. All questions and comments are grouped into general
categories, according to subject matter. Each question or comment
is followed by EPA's or NJDEP's response.

Attached are three appendices. Appendix A contains the
Proposed Plan for the Interim Remedy. Appendix B contains the
sign-in sheet of attendees at the June 5, 1990 public meeting.
Appendix C contains the public notice issued to the Bergen Record
and printed May 19, 1990 announcing the public comment period and
availability of the RI/FS and Proposed Plan for public review.
-------
II. PUBLIC MEETING COMMENTS

Comments raised during the public meeting for the SCP Carlstadt
Site and the EPA's response to them are summarized in the following
section. Comments received during the public meeting are organized
into four categories: Effectiveness of the Interim Remedy, Remedial
Investigation Activities, Health/Environmental Protection Issues,
and Schedule for Remedial Activities.

A. Effectiveness of the Interim Remedy

1. Both a local environmental/emergency planner and a resident
suggested that a regional plan should be developed to address
the SCP Carlstadt site and other hazardous waste sites in the
area. They noted that there is a mercury contamination
problem regionally, and that mercury has been identified as
a contaminant at the SCP site. They maintained that because
of the tidal nature of the area (i.e., Berry's Creek and its
tributaries), contaminants could migrate freely from site to
site.

EPA Response: (Developed from the response at the public meeting.)
Currently, there is a regional investigation of Berry's Creek and
its tributaries which is being conducted by the New Jersey
Department of Environmental Protection (NJDEP). The selection of
a remedial alternative at a Superfund site is a joint effort
between EPA and the State. EPA and NJDEP will consider the effect
of the interaction between the SCP site and other sites in the area
when evaluating remedial alternatives for any remedy which affects
Berry's Creek or its tributaries.

2. A local environmental/emergency planner thought that the
construction of a slurry wall would result in the inadvertent
creation of a cesspool in the tidal zone. Additionally, he
suggested that because of the fluctuation in the ground water
table, due to tides and flooding, that the slurry wall would
be ineffective in dewatering the area.

EPA Response: While dewatering of the site may pose some technical
problems, EPA believes that dewatering of the first operable unit
(FOU) zone through implementation of this Interim Remedy is
attainable without detrimental affects to the tidal zone. The
primary objective of the interim remedy identified in this decision
document is to reduce the migration of hazardous substances,
pollutants and contaminants into the groundwater and surface water
until a permanent remedy for the site is selected and implemented.
As a component of the interim remedy, the slurry wall will be
designed and constructed such that it will not preclude any final
remedy and it will assist in providing significant hydraulic
isolation of the FOU and temporary structural support for any
-------
possible future excavation of the FOU. In addition, an
infiltration control barrier will be placed over the site to reduce
the infiltration of precipitation into the FOU zone.

B. Remedial Investigation Activities

1. A local environmental/emergency planner asked whether off-
site sampling had been conducted.

EPA Response: In the past, obtaining access has been a problem in
conducting off-site sampling. However, EPA currently is reviewing
a plan submitted by a potentially responsible party (PRP) to
conduct off-site sampling activities. This may begin as early as
the fall of 1990.

C. Health and Environmental Protection Issues

1. A resident asked about contamination of Peach Island Creek
and the potential for health risks associated with both eating
vegetables grown in gardens downstream and children playing
in the stream.

EPA Response: Several investigations are currently being conducted
by the NJDEP in the vicinity of Peach Island Creek and Berry's
Creek to determine the nature and extent of any contamination. The
limited data collected to date indicates that contaminants from the
SCP site have migrated into Peach Island Creek. Currently, EPA is
reviewing a plan submitted by a PRP to conduct additional off-site
sampling in order to better characterize the nature and extent of
off-site contamination. Furthermore, it should be noted that since
it is evident, based on areal photos, surveys and investigations,
that the portion of Peach Island Creek downstream of the site runs
through a predominantly industrial area, it is not likely that a
residential area where vegetables may be grown in gardens or
children may be playing in the stream is or will be adversely
impacted by the site.

D. Schedule for Remedial Activities

1. A resident asked about the schedule for remedial activities
at the site. He felt that the investigations to date had
taken too long.

EPA Response: (Developed from the response at the public meeting.)
The site owners, under EPA oversight, properly disposed of several
tanks in 1986 that contained hazardous substances. The subsequent
remedial investigation was delayed because EPA had to obtain access
to properties. During the course of the remedial investigation,
the site was found to be more complex than originally anticipated
which necessitated expanding the scope of the RI. The EPA has
projected that the preferred alternative could be designed and
implemented within nine to fifteen months. Treatability studies
-------
for FOU zone soils may be conducted concurrently to help select a
permanent remedy for soils in the FOU zone.

2. A local environmental/emergency planner asked about the
schedule for disposing of a tank that has been on-site for
several years.

EPA Response: (Developed from the response at the public meeting.)
The complex mixture of contaminants contained in the tank presents
significant technical difficulties in developing a method that will
adequately address all of its contaminants properly. Treatability
studies to identify methods of disposal will be undertaken shortly.
III. RESPONSE TO WRITTEN COMMENTS

The Hackensack Meadowlands Development Commission (HMOC) submitted
comment that they "agree that the proposed plan Alternative 3 would
be the best choice for the short-term remedy". The only concern
the EMDC had was that they felt the estimated costs for operation
and maintenance/ trucking and treatment of groundwater with no pre-
treatment appeared low.

EPA Response: The off-site transportation and disposal costs are
based upon cost estimates for transportation to and disposal of
extracted groundwater at the E.I. Dupont de Nemours facility in
Deepwater, New Jersey, as provided to EPA by some of the PRPs.

Cohen, Shapiro et al.. on behalf of some PRPs, submitted comments
which may relate to the selection and/or implementation of a final
remedy at the SCP Carlstadt site in a letter dated June 18, 1990.
Schenk, Price et al.. also submitted comments on behalf of Inmar
Associates, Inc., and Marvin Mahan on June 18, 1990. The PRP
comments are organized into three general categories according to
subject matter: The proposed interim remedy, ARARs and TBCs, and
the Endangerment Assessment.

A. Comments on the Proposed Plan

1. The PRPs have commented that if the infiltration barrier
includes a synthetic membrane (e.g., a HOPE liner) it will
prevent (emphasis added) infiltration of rainwater into the
FOU.

EPA Response: This interim remedy is temporary in nature;
therefore, the infiltration barrier must be designed in such a way
as to a) not interfere with the collection of additional samples
and b) not obstruct the implementation of the final remedy and c)
minimize the amount of contaminated materials generated. As such,
the infiltration barrier will not meet the standards of a permanent
-------
RCRA Subtitle C cap. The temporary infiltration barrier will only
reduce the amount of infiltration entering the FOU zone but will
not completely prevent such infiltration.

2. The PRPs have submitted several comments which relate to the
design details for the temporary infiltration barrier. The
PRPs discuss the merits of concepts such as conducting fine
grading of the ground surface, installing a geotextile cushion
(instead of a sand layer to prevent liner tearing or
puncturing of the liner), and providing a soil cover (to
protect the surface of the synthetic liner). The PRPs assert
that such measures will provide an effective barrier, that
will be easily removed for disposal, once the final remedy is
selected.

EPA Response: As stated above, the design objectives for the
infiltration barrier will include minimizing the amount of
infiltration entering the FOU, without interfering with sample
collection or obstructing implementation of the final remedy. The
Agency conceptually concurs with the PRPs1 concerns to design the
infiltration barrier in such a way as to ensure its effectiveness
for the duration of the interim remedy (i.e., approximately 3
years), while providing for minimization of hazardous waste and
materials generated. However, EPA believes it is premature to
determine the design specifications for the infiltration barrier
in this Record of Decision. Determining the design specifications
is one of the primary functions of the remedial design process.
Consequently, such specifications should be considered among other
things, during the remedial design for this interim remedy.

3. The PRPs have made several comments criticizing the manner in
which effluent limitations for treated groundwater were
developed for discharge to Peach Island Creek. The
consequence of their comment with respect to remedy selection
is that the effluent limitations would be unnecessarily
stringent which would result in over-estimating the cost of
on-site treatment. Furthermore, it is the PRPs1 opinion that
imposition of such limitations could virtually preclude the
direct discharge option from consideration.

EPA Response: With respect to selecting a remedial action for this
interim remedy, EPA fully considered the direct discharge option.
The on-site treatment option was not selected by EPA for reasons
including the time frame necessary to design and construct an on-
site treatment facility, and the cost to implement this alternative
relative to off-site disposal. EPA anticipates that the interim
remedy will be required for approximately three years. The time
frame to design and construct the on-site treatment facility is
estimated to range from 12-24 months as compared to 9-15 months for
off-site disposal. Consequently, EPA believes that off-site
disposal will achieve EPA's objectives for implementing an interim
-------
remedy at the site, including abating the risk to public health and
the environment in the short term, more expeditiously.

4. The PRPs have submitted several comments with respect to the
design details for the slurry wall. The PRPs discuss the
various potential design options including using sheet piling
for stability during installation of the vail, using an HOPE
liner and installing temporary berms. They also comment on
the merits of different construction materials for the vail.

EPA Response: While the Agency concurs with the PRPs1 concerns
that the wall's construction not preclude implementation of any
final remedy and conceptually agrees with the PRPs1 discussion of
the merits regarding various potential design options, EPA believes
it is premature to determine the design specifications for the wall
in this Record of Decision. As stated above, determining design
specifications is one of the primary purposes of the remedial
design process. Consequently, such specifications should be
considered, among other things, during the remedial design for this
interim remedy.

5. The PRPs attempt to quantify various parameters relating to
the dewatering of the FOU, in a speculative manner. For
example, the PRPs conjecture that the dewatering process vill
be "a one time event11, that the estimated volume removed vill
be in the range of five hundred thousand to one million
gallons, and that the vater remaining after dewatering vill
be approximately one foot above the clay layer.

EPA Response: While EPA believes that the majority of the
groundwater can be extracted from the FOU during an initial
dewatering effort, subsequent dewatering events may be necessary.
In addition, although the range with respect to the volume of
groundwater to be extracted seems reasonable, it represents an
estimate. One objective of this interim remedy is to dewater the
entire FOU zone. Therefore, the actual amount of contaminated
groundwater extracted may exceed this range.

6. The PRPs comment that devatering the FOU vill prevent
(emphasis added) contaminant migration into deeper aquifers.

EPA Response: Dewatering the FOU will mitigate, not prevent
contaminant migration from the FOU to the underlying aquifers.

7. The PRPs comment that the material to be excavated during the
construction of a slurry vail vill probably contain levels of
volatile organic compounds (VOCs) vhich vill varrant the use
of control measures. They assert that the slurry vithin the
trench and mixed with the excavated material vill provide some
degree of vapor suppression, however, it may be necessary to
apply foam to control VOC emissions adequately.
-------
EPA Response: While EPA is concerned about potential VOC emissions
during the construction of a slurry wall, it is too early to
determine whether these emissions will pose a health and safety
problem. EPA conceptually agrees with the PRPs1 proposed method
to respond to VOC emissions, however, the Agency believes that any
response or control method(s) for addressing this and other health
and safety concerns should be included in a health and safety plan
developed during the remedial design.

8. The PRPs comment that a temporary infiltration barrier will
immediately break a direct contact pathway which would remain
broken for the duration of the interim remedy, will preclude
wind-borne transport of contaminated dust particles/ and
prevent further contamination of Peach Island Creek due to
erosion of contaminated soil and rainwater runoff into the
Creek (emphasis added).

EPA Response: The construction of a temporary infiltration barrier
will mitigate the potential for direct contact with contaminated
material for the duration of the interim remedy not "immediately
break a direct contact pathway". EPA believes the infiltration
barrier will mitigate, not "preclude or prevent" the air transport
of contaminated dust particles and further contamination of Peach
Island Creek via contaminated soil and rainwater runoff from the
site.

9. The PRPs assert that it is possible that VOCs could volatilize
in the unsaturated FOU material and collect beneath the
infiltration barrier. Consequently, the PRPs conclude that
vents will have to be installed through the membrane to
preclude the possible accumulation of vapors beneath the
infiltration barrier.

EPA Response: The PRPs concern regarding the potential
accumulation of VOC vapors beneath the infiltration barrier does
not seem to be well supported. The Agency has had experience at
other Superfund sites implementing the elements of this interim
remedy. Venting has not been a concern in these situations, and
there does not appear to be any information which would warrant
the installation of vents at this site.

10. The PRPs comment that it is estimated that no more than 300
gallons of water could infiltrate into the dewatered FOU
during the assumed 3-year duration of the interim remedy.

EPA Response: While the Agency agrees that the interim remedy will
significantly reduce the quantity of water infiltrating the FOU,
an estimated 300 gallons of infiltration during the entire assumed
3-year duration of the interim remedy seems unrealistically low as
it is calculated assuming ideal conditions. Since a major
objective of this interim remedy is to dewater the entire FOU and
-------
mitigate the infiltration of water into the FOU, it should be
recognized that the volume estimates may be exceeded and,
therefore, additional groundwater extraction may be necessary to
maintain a dewatered FOU.

11. The PRPs comment that the resultant RI data does not
demonstrate that the site is adversely affecting Peach Island
Creek or the surrounding wetlands. They further comment that
although there are chemical substances in the surface water
of Peach Island Creek and in the stream sediments, it has not
been demonstrated that these chemical substances have had an
adverse effect or that the chemical substances are solely from
the 8CP Carlstadt site.

EPA Response: A comprehensive evaluation of the site's
environmental impacts on Peach Island Creek and the surrounding
wetlands has not yet been conducted. The RI results indicate that
surface water and sediment in Peach Island Creek are, however,
contaminated with many hazardous substances which are similar to
and/or identical to those which were found in the soils and
groundwater at the site. Many of these hazardous substances have
migrated and continue to migrate from surface soils into the water
table aquifer and other underlying groundwater aquifers, as well
as Peach Island Creek. Moreover, the PRPs have admitted that
groundwater from the water table aquifer, which is grossly
contaminated with hazardous substances, discharges to this Creek.
Further investigation of contaminant migration from the site into
groundwater, surface water and sediments is currently underway, and
a second operable unit remedy will be selected to address impacts
of such migration.

The RI results indicate that surface water and sediment in Peach
Island Creek are contaminated with hazardous substances similar to
and/or identical to those which were found in the soils and
groundwater at the site. For example, 1,1,1-Trichloroethane,
chloroform, mercury, arsenic, dieldrin and PCB Aroclors (1242,
1254, 1260, and 1248) were all detected in soils and groundwater
at the site and in the surface water and sediment of this Creek.

12. The PRPs assert that due to the higher levels of contaminants
in Peach Island Creek upstream from the site, it could be
assumed that there are other sources impacting the stream.

EPA Response: Peach Island Creek is tidally influenced.
Therefore, the site cannot be ruled out as a source of higher
levels of contaminants upstream.

13. The PRPs comment that the Administrative Record does not
support that certain action-specific ARARs will be met (e.g.,
Flood Plain Management and Wetlands Protection requirements).
8
-------
EPA Response: Action-specific ARARs will be met with respect to
implementation of this interim remedy. The manner in which such
ARARs will be complied with will be fully determined during the
remedial design process.

14. The PRPs comment that the construction of the slurry vail now
could be incompatible with the final remedy selected for the
site. The interim remedy should not be finalized until
additional studies for the POD and the second operable unit
(SOU) are completed. The results of the studies are needed
to select the appropriate slurry vail type and depth for
design to assure compatibility vith the final remedy.

EPA Response: The elements of this interim remedy are consistent
with any future remedy for the FOU zone. The FOU zone must be
dewatered before treatment can be employed to remediate this zone
or if a containment option is selected. The selection of the
appropriate construction material and method for installing the
containment wall will be determined during the remedial design
process. One of the design objectives for the containment wall
will be to evaluate options which will provide maximum support
during excavation and long term effectiveness.

15. Insufficient information is available regarding
characterization of the site geologic/hydrogeologic
conditions.

EPA Response: While some limited characterization work is needed
to select a permanent remedy for the FOU zone and more extensive
work is needed for SOU, this information is not relevant to the
selection of this interim remedy. Specifically, this interim
remedy does not address remediation of contaminated soils within
the FOU zone or contaminated groundwater beneath the zone.
Consequently, further soil sampling of the FOU zone and geologic
and hydrogeologic evaluation of the underlying aquifers would not
factor into the remedy selection process for this interim response
action. Moreover, there is sufficient data available to
demonstrate the need to take an interim action to reduce further
contaminant migration from the FOU zone into underlying aquifers
and Peach Island Creek.

16. No data in the Remedial Investigation indicated that a "leaky"
condition existed across the clay-silt layer separating the
shallow and till aquifers.

EPA Response: EPA disagrees with this statement. The data
collected at the site strongly suggest that hazardous substances
have migrated from the shallow aquifer downwards across the clay-
silt layer into the underlying till aquifer. This is evidenced by
the following observations, among others:
-------
1. Piezometric data collected at the site indicated a downward
hydraulic gradient exists between the surfaces of the water table
and till aquifers; this gradient would tend to force fluids and
contaminants downwards across the clay lens into the till aquifer.

2. The RI data revealed that many of the same hazardous
substances, particularly, volatile organic compounds, which are
pervasive in the highly contaminated FOU zone also exist in the
underlying clay-silt layer and in the two aquifers beneath this
layer. For example, the RI data indicates that many VOCs including
chloroform, 1,1-dichloroethane, 1,2-dichloroethane, 1,2-trans-
dichloroethylene, 1,1,1-trichloroethane, methylene chloride,
trichloroethylene, tetrachloroethylene, toluene, chlorobenzene, and
xylenes exist in the clay lens. All of these VOCs are hazardous
substances. All of these VOCs exist in the water table above the
clay lens. All these VOCs, with the exception of xylenes, were
also detected in the till aquifer beneath the clay lens.

3. The clay lens is highly variable in thickness. It does not have
the same characteristics under all areas of the site. It does not
act as an impermeable barrier to downward migration of contaminants
from the water table aquifer. The PRP contractor, Dames & Moore,
indicated that ".. water in the till aquifer contains primarily
[VOCs] .. it appears that the compounds detected in the till
aquifer migrated through [the] clay layer from the overlying fill
and the water table aquifer" (Draft RI Report, 9/88, p.64). Dames
& Moore also indicated that, although some "attenuation" of VOCs
occurs across the clay lens at one station (RMW-7D) , that
attenuation is present "to a much lesser degree" at station RMW-
5D and is "almost absent" at station RMW-2D (Draft RI Report, 9/88,
p. 63).

The RI data referred to above clearly show that some VOCs (and
possibly other hazardous substances) have migrated from the shallow
aquifer into the till aquifer under the site. This downward
migration of contaminants is likely to continue absent any control
measures. Therefore, the contention that "leaky" conditions do not
exist is obviously not supported by the RI data collected at this
site to date.
B. Comments Relating to ARARs/TBCs for the Final Remedy

Many views have been expressed in the Cohen, Shapiro et al
submission on behalf of some PRPs to EPA-Region II, dated June 18,
1990, concerning ARARs and TBCs which may relate to the selection
and/or implementation of a final remedy at the 8CP Carlstadt site.
Comments concerning ARARs were also submitted by Schenk, Price et
al, on behalf of Inmar Associates, Inc. and Marvin Mahan. Examples
of such comments include the following:

10
-------
1. Comments relating to the State and Federal classifications of
the three aquifers underlying the sit* and the potential uses
of these aquifers;

2. Comments relating to required cleanup levels for specific
contaminants which exist in the three aquifers [i.e., the
water table, till and bedrock aquifers under the site (e.g.,
whether State and Federal maximum contaminant levels (MCLs)
are applicable or relevant and appropriate target levels for
any or all of these three aquifers)];

3. Comments relating to required cleanup levels for specific
contaminants which exist in soil at the site (e.g., comments
concerning use of the EPA PCS Spill Policy and New Jersey ECRA
action levels to establish soil cleanup levels);

4. Comments relating to the classification of waters in Peach
Island Creek which adjoins the site;

5. Comments concerning chemical specific cleanup levels for the
waters in Peach Island Creek;

6. Comments relating to potential waiver(s) of groundwater ARARs
or use of alternate concentration levels (ACLs) as cleanup
objectives in groundwater at the site;

7. Comments relating to the location of compliance point(s) for
achieving cleanup target levels in groundwater at the site;

8. Comments relating to the use of TBCs in selecting required
cleanup levels for specific contaminants in the groundwater,
the soil and the atmosphere at the site and in Peach Island
Creek;

9. Comments relating to off-site treatment or disposal of any
contaminated soil or debris taken from the site;

10. Comments relating to other potential chemical specific,
location specific and action specific ARARs which may relate
to selecting and/or implementing a final remedy at the site
(e.g., the potential effect of LDRs on on-site actions; of
State siting criteria for new hazardous waste facilities on
on-site incineration, etc.)

EPA Response: EPA disagrees with many of the ARAR and TBC comments
which were submitted by the PRPs in their submission of June 18,
1990. The majority of the ARAR/TBC comments submitted by the PRPs,
however, do not relate to the interim remedy nor do they challenge
any of the components of the interim remedy or the underlying
rationale for that remedy which is the subject of this ROD. The
irterim remedy selected in the ROD is merely an initial containment

11
-------
measure intended to reduce the migration of hazardous substances
out of the FOU zone. It does not include any measures for cleaning
up soil and groundwater at the site or the waters and sediment in
Peach Island Creek to achieve some in-situ target level(s). Any
measures which may be required to achieve these objectives will be
the subject of additional remedial measures which EPA will identify
in future ROD(s) for this site. EPA, therefore, has elected not
to provide a detailed response to these comments, including the
types of comments noted in 1. through 10., above, since these
comments address issues which are not significant with respect to
or relevant to the interim remedy which is the subject of this ROD.
Comments, such as those described in 1. through 10. above, which
relate to the final remedial measures for the site, will be
addressed, as appropriate, in the administrative record(s) which
will be prepared by EPA for those future ROD(s).

EPA has decided, however, to provide an initial response to some
of the more common ARAR/TBC comments which, although not related
to this interim remedy, address future remedial actions for the
site. These comments and the initial EPA responses are stated
below. The Agency provides these comments as a courtesy to
interested parties without any waiver of its right to comment on
and take any position on any ARAR/TBC issues in any administrative
records which may be prepared by EPA relating to this site in the
future.

11. Safe Drinking Water Act (SDWA) MCLs apply only at the tap.
They do not appear to be applicable to the shallow and till
aquifers because neither of these aquifers is a drinking water
source. Cleanup criteria applied to the upper aquifers should
only assure that the bedrock aquifer meets MCL standards.

EPA Response: MCLs are enforceable drinking water standards. Both
MCLs and non-zero MCLGs promulgated under the SDWA may be relevant
and appropriate to remediation of groundwater at CERCLA sites and
may be used as cleanup levels in groundwater itself.

The State of New Jersey has designated all three aquifers
underlying the site as Class GW2 waters. EPA also used its own
Groundwater Protection Strategy to determine the appropriate
remediation for contaminated groundwater under this site, as
required by the NCP (See 55 Fed. Reg. 8732). Pursuant to that
guidance, EPA-Region II determined that all three aquifers under
the site should be categorized as Class II waters. MCLs and non-
zero MCLGs are generally the relevant and appropriate requirements
for groundwater that is or may be used for drinking (55 Fed. Reg.
8754). The remediation goals for Class II waters are generally set
at MCLs and non-zero MCLGs where relevant and appropriate (55 Fed.
Reg. 8732).

The water table aquifer is highly contaminated with many hazardous

12
-------
substances, including many VOCs. This aquifer is hydraulically
connected to the till aquifer beneath it. This is evidenced by,
among other indicia, the fact that the silt-clay layer located
between these aquifers does not act as an impermeable barrier
separating these two aquifers. A number of the same hazardous
substances, including many VOCs, which exist in the water table
have been found in the silt-clay layer and in one or both of the
aquifers beneath it. Many VOCs have clearly migrated across the
clay-silt layer from the more highly contaminated water table
aquifer into the till aquifer beneath it.

Notwithstanding the presence of VOCs in the till aquifer, this
aquifer is presently either being used directly as a source of
water and/or is hydraulically connected to one or more aquifers
from which withdrawals are occurring. The periodic pattern
(reported by Danes & Moore) in this aquifer revealing a noticeable
change in hydraulic characteristic(s) every weekend (when
groundwater withdrawal rates would likely differ substantially from
weekday rates) supports this premise.

The bedrock aquifer is being used as a potable supply at present.
More than 50 wells, including at least one domestic well, are
installed in the bedrock aquifer within a two mile radius of the
site. The bedrock aquifer is hydraulically connected to the till
aquifer. Pump tests performed during the RI support this
conclusion. Some VOCs which exist in the water table and till
aquifers also exist in this aquifer.

All three aquifers under the site, including the highly
contaminated water table aquifer, are hydraulically interconnected.
Meeting MCLs and non-zero MCLGs standards only at the tap would not
protect many potential future users from adverse effects caused by
exposure to VOCs and other hazardous substances which exist in
these aquifers especially if any wells were to be placed into and
water was withdrawn from either the water table or till aquifers
in the future. EPA's policy is to attain ARARs so as to ensure
protection at all points of potential exposure (55 Fed. Reg. 8753).
Requiring compliance with MCLs and non-zero MCLGs just at the tap
rather than in groundwater would be inconsistent with this policy
and would also undercut the clear Congressional intent that under
CERCLA "groundwater should be restored to protective levels" (55
Fed. Reg. 8753). MCLs and non-zero MCLGs are therefore both
relevant and appropriate for remediation of all aquifers under this
site. Application of these standards to all three aquifers under
the site is consistent with the Congressional mandate expressed in
CERCLA.

12. Groundwater in the area of the site is mineralized, has total
dissolved solids (TDS) concentrations greater than 500 parts
per million (ppm) and is not suitable for human consumption.
It should therefore be categorized as Class GW3, not Class GW2

13
-------
waters.
EPA Response: The State of New Jersey has designated all three
aquifers under the site as Class GW 2 waters. EPA does not
disagree with that determination. The TDS data collected in
groundwater at and near the site shows sporadic TDS readings above
500 ppm. This data does not, however, support the contention that
the background (i.e., unaffected by the site) TDS levels in any of
the three aquifers under the site exceed 500 ppm. Furthermore, the
mixture of contaminants which were disposed of at the site and
which now exist in the FOU zone could be a major TDS source
contributing to the elevated TDS levels detected in groundwater
beneath and near the site.

Pursuant to the EPA Groundwater Protection Strategy, EPA has
determined that the groundwaters under the site are Class II
waters. Even under that guidance, groundwaters may be considered
as potentially potable as long as TDS levels do not exceed 10,000
ppm. TDS levels in none of the aquifers under the site exceed this
threshold.

13. The Land Disposal Restrictions (LDRs) under RCRA may apply to
the contaminated soils excavated during the construction of
the slurry vail.

EPA Response: Placement outside a waste management unit must occur
before LDRs are triggered. Contaminated soils will be excavated
and consolidated near the slurry wall trench and within the same
waste management area. These activities are not likely to
constitute placement outside the waste management unit and,
therefore, LDRs will not be triggered.

C. Endangerment Assessment

TERRA Consultants submitted comments on the Base Line Risk
Assessment (BRA) on behalf of the PRPs represented by Cohen,
Shapiro, et al.,. Wheran Engineering Corporation also submitted
comments on the BRA/ on behalf of Inmar Associates/ Inc./ and
Marvin Mahan.

1. One of the PRPs1 main contentions is that the risk assessment
"exaggerates and distorts the actual risks to human health
under current site and nearby land use conditions.*'

EPA Response: EPA strongly disagrees with this assertion. The BRA
was performed in accord with the standard methodology and
procedures used by EPA to assess risks posed by conditions at
Superfund sites. It should also be noted that one of the purposes
of the BRA is to evaluate risks under current site land use
conditions in the absence of remediation (the no-action
alternative) . EPA is mandated by law to protect public health and
the environment. EPA is authorized to act under CERCLA when there

14
-------
"... may be an imminent and substantial endangerment...H or if
"...there is a release or substantial threat of release which may
present an imminent and substantial danger...11 (emphasis added).
Therefore, EPA must evaluate risk in a conservative manner which
ensures that the risk is not underestimated. Consequently, the
purpose of a BRA is to provide an indication of the range of risks
associated with the SCP site in the absence of remediation.

2. TERRA further states that a reader "would mistakenly conclude
that residents and workers are being exposed to chemicals from
the SCP site." TERRA additionally states that "there is no
evidence that these exposures are actually occurring."

EPA Response: The RI studies did not indicate that any specific
resident or worker was "being exposed to chemicals from the SCP
site". This does not support a conclusion, however, that no
individual or group of individuals is being exposed to chemicals
from the site. Numerous chemicals are migrating out of the site
in groundwater, among other routes, which may in fact now be
resulting in exposure to some individuals. When conducting a
baseline risk assessment, evidence of actual exposure is not a
prerequisite to evaluating an exposure pathway. If there is a
potential for an exposure pathway to be complete, such a pathway
may be evaluated. Potentially complete exposure pathways were
evaluated under current site use conditions in the SCP BRA. The
assumptions used in evaluating exposure pathways were selected to
provide an indication of what the potential risks would be under
a range of scenarios. In the absence of detailed site-specific
data, values provided in USEPA's Risk Assessment Guidance for
Superfund (RAGS) were used as defaults. This element of
conservatism, and the reliance on use of values provided in RAGS,
is noted in the BRA. Contrary to the implication made by TERRA,
the BRA is clear with respect to the assumptions used to evaluate
exposure pathways.

TERRA recognizes EPA's use qualifiers in the BRA to clarify the
manner which exposure pathways are evaluated. EPA believes that
it has properly communicated the risks posed by the site to the
public. Based upon comments received during the public comment
period, EPA has no reason to believe that the general public
misunderstands the information in the BRA.

3. The second of TERRA'S main objections relates to the
conclusions concerning adverse effects of the SCP site on
Peach Island Creek because of the reliance on results from
only four samples.

EPA Response: The potential impacts of the SCP site on Peach
Island Creek are not fully defined. An examination of the
available data from surface water, sediment, shallow groundwater,
and soil at the site indicates that migration of hazardous

15
-------
substances from the site to Peach Island Creek has occurred. A
discussion supporting this conclusion is provided in Section 3.1.2
of the BRA.

4. TERRA disagrees with the us* of a maximum detected
concentration when making any conclusions in the report, and
states that average case risks should be used to temper the
results of the maximum case scenarios.

EPA Response: We agree that the results of both exposure cases
should be considered when making risk management decision regarding
the SCP site. EPA has, however, followed the standard methodology
developed for and used by EPA to determine risks posed by
conditions at Superfund sites. The results presented in the BRA
reflect potential risks under current and possible future site and
land use conditions. EPA has made conclusions regarding the need
for remediation at the SCP site by considering all relevant
factors, only one of which is the results of the BRA. The maximum
case results have been considered in conjunction with other results
in the BRA, such as those for the average case.

5. TERRA indicates that inhalation risks to metals in soil are
estimated using concentrations that are within background
levels.

EPA Response: It should be noted that a comprehensive
investigation to establish off-site background levels of metals in
soil has not been conducted. Therefore, the conclusion cannot be
drawn that the concentrations are within background levels. The
BRA states that for some of the selected indicator chemicals,
background sources may be contributing to the concentrations
detected. The uncertainty associated with the inhalation risks
calculated for naturally occurring metals, as well as the
uncertainty regarding the speciation of chromium, have been
recognized by EPA in its evaluation of the SCP site.

6. TERRA disagrees with the summation of PCB results and
application of a slope factor based on Aroclor 1260 for this
sum because Aroclor 1242, the predominant PCB detected at the
site, has not been demonstrated to be carcinogenic.

EPA Response: While different PCB Aroclors may have different
potencies and evidence for carcinogenicity, EPA has not developed
an approach for differentiating between Aroclors in Superfund site
risk assessments. Current EPA policy is to treat all PCBs as
probable carcinogens which is a prudent approach for protection of
public health. The approach used in the BRA conforms with current
EPA policy.
16
-------
7. TERRA also indicates that relative potency factors should have
been applied for specific carcinogenic PAHs.

EPA Response: As for PCBs, while different carcinogenic PAHs are
known to have different potencies, EPA has not developed and
approved an approach based on relative potency factors for use in
Superfund site risk assessments. As a result, the current EPA
policy of treating all carcinogenic PAHs using the cancer slope
factor for benzo(a)pyrene was followed in the BRA.

8. TERRA notes that subchronic reference doses (RfDs) should have
been used for evaluating the trespasser scenario.

EPA Response: The results contained in the BRA would not be
affected significantly if subchronic reference doses (RfDs) were
used. The hazard index for this pathway would still exceed unity
since, for roost of the chemicals, the chronic and subchronic RfDs
are the same (e.g., for aldrin, dieldrin, PCBs, and
trichloroethylene.

9. TERRA believes that the air pathway is not "complete" for
nearby workers and residents. TERRA believes there is "no
relevant environmental transport medium for dust or
volatilization" because ambient air monitoring did not detect
volatiles during non-intrusive activities/ the remedial
investigation work plan did not consider air a relevant
exposure route. In addition/ much of the site is covered with
vegetation/ and surface soil is comprised of rubble/ concrete
slabs and gravel.

EPA Response: EPA disagrees that these factors indicate there is
no potential transport medium for any chemicals present in soil at
the SCP site. While the presence of vegetation can reduce fugitive
dust emissions, its presence does not significantly affect
emissions of volatile chemicals. Finally, as noted in the BRA, the
rubble-like surface of the site was considered in estimating
fugitive dust emissions. The conclusion was reached that it would
not preclude dust emissions from occurring at the site. Despite
the assertion by TERRA, the potential for volatilization of some
chemicals from the site does exist as does the potential for some
suspension of surface materials into air. Once airborne, these
materials could be transported to nearby areas where individuals
are located.

10. TERRA contends that the July 1987 surface water data was not
included in the BRA and that this data would have affected
the conclusion drawn in the BRA.
17
-------
EPA Response: Apparently, the July 1987 surface water data were
not included in the .BRA. These data would have indicated lower
concentrations for some chemicals than the December data. However,
this would not have altered the primary conclusions regarding the
potential impact of the site on Peach Island Creek. The RI and the
data from surface water, sediment, shallow groundwater, and soil
at the site indicates that hazardous substances have migrated from
the site to Peach Island Creek. A discussion supporting this
conclusion is provided in Section 3.1.2 of the BRA and in response
to Comment 3, above, It should also be noted that additional
surface water and sediment sampling will be conducted. Potential
risks to ecological receptors will then be re-evaluated based on
the results of the additional sampling program.

11. Terra questioned whether or not the Koe values used in the
health assessment were already adjusted for organic carbon
content (foe). Terra also asserted that the comparison of
total metals to ambient water quality criteria (AWQC) is
incorrect. Terra believes that use of the dissolved metals
data for such comparison is more appropriate.

EPA Response: The Koc values used in the health assessment were
obtained from the Dames and Moore Remedial Investigation Report.
The calculation of sediment quality criteria (SQC) included only
one adjustment for organic carbon content. Total metals data was
used to compare with AWQC as it provides a more conservative,
protective approach in the absence of acid-soluble fraction of
metals data. Using the dissolved metals data for such comparison
may have underestimated the actual risks present.

12. Terra questions if muskrats actually drink salty (brackish)
water.

EPA Response: Muskrats live in brackish environments and it is
assumed that they ingest brackish water to some extent.
Communications with the Department of Mammalogy at the Harvard
Museum of Natural History (Boston, MA) and the Department of
Mammalogy at the National Zoo (Smithsonian Institution, Washington,
D.C.) revealed their support of this assumption.

13. Terra suggests that one must decide whether freshwater or
saltwater standards are more applicable to the brackish Peach
Island Creek. Terra also asserts that "...EPA incorrectly
estimated water concentrations of several chemicals."

EPA Response: The brackish water of Peach Island Creek is a
transition zone between marine and freshwater aquatic environments
and, as such, it may contain both freshwater and marine species,
as. well as organisms that are endemic to estuarine environments.
Thus, to be more conservatively protective of the wide range of
organisms that may occur in this area, the lowest AWQC was selected

18
-------
from the available freshwater and marine AWQCs.

The estimated water concentrations are correct in the context they
were used for estimating exposures to benthic invertebrates.

14. Terra could not determine from Table 6-2 of the health
assessment when a freshwater or saltwater AWgC was used to
calculate a SQC or determine what Koc was used for each
chemical. Terra also asserts that the action level for PCBs
and the discussion on the toxicity of metals in sediments
needs revision based on some recent studies conducted by the
U.S. Army Corp of Engineers on Berry's Creek.

EPA Response: The SQCs in Table 6-2 for benzo(a)pyrene,
flouranthene, pyrene, dieldrin, and Acoclor 1254 are from EPA's
1988a Application of Interim Sediment Quality Criteria Values at
Sullivan's Ledge Superfund Site. The SQCs for acenaphthene,
phenanthrene, Aroclor 1242, and Aroclor 1260 were calculated
from information also provided in the above described EPA
document. The SQCs for bis(2-ethylhexyl phthalate, di-n-butyl,
phthalate, chrysene, flourene, naphthalene, and Aroclor 1248 were
calculated from Koc values available in the literature and the
AWQCs.

EPA was not aware of the studies performed by the U.S. Army Corp
of Engineers when developing the Health Assessment. Please be
assured that the Agency will take such studies into consideration
and make any modifications to the health assessment as are deemed
appropriate prior to the implementation of the final remedy. It
should also be noted that during interim measures ARARs (i.e.,
action level for PCBs) do not have to be met, as long as these
requirements will be achieved upon completion of the permanent
remedy. Accordingly, final cleanup levels for soil and groundwater
do not have to be achieved for this interim action, but will be
addressed in the final remedy.

15. Terra asserts that EPA calculated concentrations far in excess
of the detection Limit (TAble 6-4 of the health assessment)
instead of using the actual data collected to estimate levels
in invertebrates and ultimately risks to waterfowl.

EPA Response: The chemical concentrations in water in Table 6-4
are the concentrations estimated for interstitial (sediment-pore)
water based on measured sediment concentrations. The
concentrations recommended for use by Terra are, in contrast, water
column concentrations. These are not the same as sediment pore
water concentrations (SPWC) and, in fact, would be expected to be
much lower than the SPWC. SPWC more accurately reflect the
concentrations to which benthic invertebrates could be exposed to
than water column concentrations measured in the overlying water.
Thus, the concentrations used in the health assessment to estimate

19
-------
chemical concentrations in invertebrates are considered
appropriate.

The U.S. Army Corp of Engineers (COE) study was not available when
the health assessment was developed. EPA will take the COE's study
into consideration and make any modifications to the health
assessment as are deemed appropriate prior to the implementation
of the final remedy. in the absence of valid site-specific
bioconcentration factors (BCFs), the BCFs used in the health
assessment are appropriate.

16. The PRPs assert that because the nearest residence is about
one mile from the site/ the inclusion of inhalation pathways
where "nearby residents" are the receptors is questionable.

EPA Response: The inhalation pathway is included in the risk
assessment due to the potential routes of exposure via inhalation
of volatile contaminants and/or fugitive dust released from the
soil. The potential receptors include on-site trespassers, "nearby
residents" and workers on adjacent properties.

17. The FRFs comment that the BRA excluded copper as an indicator
chemical because it is an essential nutrient, yet this
approach was not taken with other metals such as chromium,
zinc and selenium.

EPA Response: Metals should not have been excluded from
consideration due to their potential to be an essential nutrient
in certain doses.

18. The PRPs disagree with EPA's inclusion of vinyl chloride as
an indicator chemical due to biotransformation.

EPA Response: It should be noted that precursor compounds to vinyl
chloride were detected at high levels in both soils and
groundwater. Vinyl chloride may have been detected less frequently
than its precursor compounds because of the time frame necessary
for the biotransformation process or its presence below the
contract laboratory program (CLP) detection limit. This is,
however, no reason to assume that biotransformation processes may
not occur and is not a valid reason to exclude vinyl chloride as
an indicator chemical.

19. The PRPs comment that the aquifer discussion in the Risk
Assessment does not indicate whether the till and/or bedrock
aquifers discharge into Peach Island Creek. They assert that
such information is relevant to an understanding of
contaminant migration.
20
-------
EPA Response: EPA agrees that groundwater flow direction and
aquifer discharge areas are relevant to understanding contaminant
migration. The risk assessment includes such information to the
extent that it references the Dames and Moore Remedial
Investigation Report.

20. The PRPs comment that using half of the detection limit or
Contract Required Quantitation Limit (CRQL) for nondetected
analytes in calculating the geometric mean is only justifiable
when the majority of the samples contain the analyte and there
is reason to believe that the analyte may in fact exist in the
nondetect samples at a belov-detect concentration.

EPA Response: The risk assessment guidance for Superfund states
that "unless site-specific information indicates that a chemical
is not likely to be present in a sample, do not substitute the
value zero in place of the sample quantitation limit". "Also, do
not simply omit the non-detected results from the risk assessment."
The fact that a chemical was detected in more than one sample on-
site indicates that such chemical may be present in those samples
where it was not detected. Therefore, it is reasonable to assign
a value of one-half the detection limit for non-detects when
averaging data for risk assessment purposes, thus, avoiding biasing
the results high or low. (See Risk Assessment Guidance for
Superfund, Volume I, Human Health Evaluation Manual (Part A) ,
EPA/540/1-89/002.)

21. The PRPs comment that the rationale for inclusion of exposure
pathways is somewhat inconsistent. They assert, for example,
that while it is true that surface water and sediment pathways
are probably incomplete due to the lack of recreational
interest, it should follow therefore that the site is not a
likely target for trespassing. The PRPs further comment that
the inclusion of on-site drinking water pathways is so highly
theoretical that their inclusion should justify the inclusion
of all pathways having a remote potential for completeness.

EPA Response: EPA disagrees with the conclusion that the site is
not a likely target for trespassing because the surface water and
sediment pathways are probably incomplete due to the lack of
recreational interest. The evaluation of each pathway should be
pathway-specific. Because the surface water and sediment pathways
are incomplete due to the lack of recreational interest does not
mean that the potential for site trespassing becomes insignificant.
While the Agency believes that a conservative approach should be
taken when evaluating exposure pathways, it is understood that "all
pathways" may not be included based on the results oi a screening
analysis.
21
-------
22. The PRFs comment that volatile organic emission rates should
not have been calculated based on concentrations found at all
depths. They assert that it would have been more reasonable
to use concentrations in the 0-2 foot surface soil interval
to calculate the emission rates into the air.

EPA Response: EPA believes that the use of the geometric mean,
which is based on volatile organic concentrations found at each
depth sampled, is more appropriate as it provides a more
representative means of calculating the volatile organic emission
rates into the air.

23. The PRPs also provide several other comments which relate to
what they believe are inadequacies in the risk assessment.
Such observations include the absence of a drinking water
pathway from the bedrock aquifer and the lack of
quantitatively evaluating ecological pathways.

EPA Response: While the Agency believes that certain observations
made by the PRPs may be legitimate, it should be noted that the
incorporation and/or addressing of such comments by the risk
assessment would potentially increase the risk levels associated
with the site. As a result, the justification for implementing the
interim remedial action selected in the Record of Decision would
be further substantiated.
IV. COMMUNITY RELATIONS ACTIVITY CHRONOLOGY

Since 1985, there has been generally a relatively low level of
community involvement and concern about the SCP Carlstadt site.
The limited concerns that have been expressed by residents and
local officials in the past focused on the following:

concerns regarding a tank remaining on-site;
potential health risks associated with the site;
•
site access; and,

EPA's role at the site.
Further information on these concerns can be found in the Public
Information Meeting Summary of August 1987 which is available for
review at the information repositories outlined in the public
notice for the site (see Appendix C).
22
-------
V. REMAINING CONCERNS

Recently, as evidenced by the comments above, community
environmental/emergency planners have expressed interest in the
site and site remedial activities. The identification of a
regional hazardous waste problem seems to have created an interest
in the remediation of the SCP Carlstadt site, particularly, as it
affects the area regionally and how it may be affected by other
hazardous waste sites in the area. Issues related to the close
coordination of remedial efforts with community planners will
continue to be a critical area of concern.

EPA has and will continue to work closely with the Hackensack
Meadowlands Development Commission and other community
environmental/emergency planners. The community will continue to
be kept apprised of the remedial actions which will be implemented
at the site. The Agency will also continue to coordinate site-
related activities in conjunction with the New Jersey Department
of Environmental Protection.
23
-------
APPENDIX A

Proposed Plan for the Interim Remedy
-------
Super-fund Program
Proposed Plan

Scientific Chemical Processing Site
Caristadt, New Jersey
Region
May, 1990
EPA ANNOUNCES PROPOSED PLAN

This Proposed Plan describes the preferred option
for reducing ibe migration of contamination from
the Scientific Chemical Processing Site (SCP Site).
This document is issued by the United States
Environmental Protection Agency (EPA), the lead
agency for site activities, and the New Jersey
Department of Environmental Protection
(NJDEP), the support agency for this response
action. EPA, in consultation with NJDEP, will
select an interim remedy for the site only after the
public comment period has ended and the
information submitted during this time has been
reviewed and considered.

EPA is issuing this Proposed Plan as pan of its
public participation responsibilities under Section
117(a) of the Comprehensive Environmental
Response, Compensation and Liability Act
(CERCLA). This Proposed Plan summarizes
information that can be found in greater detail in
the Remedial Investigation and Feasibility Study
(R1/FS) reports and other documents contained in
the administrative record file for this site. EPA
and NJDEP encourage the public to review these
other documents in order to pin i more
comprehensive understanding of the site and
Superfund activities that have been conducted
there. The administrative record file contains the
information upon which the selection of the
response action will be based. The file is
available at the following locations:
William E Dermody Free Public Library
420 Hackensack Street
Caristadt, New Jersey
(201) 43S-8866
Hours: M-Th: IChOOam-SJOpm, 7.-00-9K)Opm
Fri: 10:OOam-5:30pm, Sat: lOflOam-lrOOpm

and
U.S. EPA Region n
Emergency & Remedial Response
Division File Room
26 Federal Plaza 29th Floor
New York, NY 10278

Hours: M-F: 9:OOam-5KX)pm

EPA, in consultation with the NJDEP may modify
the preferred alternative or select another
response action presented in this Plan based on
new information or public comments. Therefore,
the public is encouraged to review and comment
on all of the alternatives identified here.
DATES TO REMEMBER
MARX YOUR CALENDAR

May 19 - June IS, 1990
Public Comment period on interim remedy to
reduce migration of contaminants

June 5, 1990
Pubb'c meeting at Caristadt Borough Hall
STTE LOCATION MAP
-------
SITE BACKGROUND

The SCP Site is located it 216 Paterson Plank
Road in Carlstadt, New Jersey. Tte site, which
is owned by Inmar Associates, was used during the
1970s by the Scientific Chemical Processing, Inc.
for treatment of a wide variety of industrial
chemical wastes. In 1980, operations it the facility
were ceased. The site was placed on the National
Priorities List in 1983. Between 1983 and 1985,
NJDEP required the site owner to remove
approximately 250,000 gallons of wastes stored in
tanks, which had been abandoned at the site. In
April 1985, EPA assumed the lead role in
response actions, and contacted approximately 140
Potentially Responsible Parties (PRPs) to offer
them the opportunity to undertake an RI/FS at
the site. In the fall of 1985, EPA issued
Administrative Orders to these panics, requiring
them to undertake these studies under EPA
oversight At that time, EPA also issued an
Administrative Order to the site owner, Inmar
Associates, requiring the company to remove and
properly dispose of the contents of five tanks
containing wastes contaminated with
Polychlorinated Biphenyls (PCBs) and numerous
other hazardous substances.

Inmar completed the tank removal in late 1986,
and the PRPs initiated the Rl/FS in April 1987.
The RiyFS was conducted to identify the nature
and extent of contamination at the SCP site, and
to develop remedial alternatives to address the
contamination. The results of the investigation
indicated that hazardous substances are present
in site soils and groundwater. These substances
are migrating from the soils and groundwater in
the shallow zone of the SCP site into the
underlying groundwater aquifers, as well as into
Peach Island Creek, a tidal waterway adjoining
the site.

The detailed results of the RI can be found in
the Remedial Investigation Report, contained in
the administrative record file noted above. The
results of the investigation can be summarized as
follows:

•the geology of the site is comprised of
the following units, in descending order-
the shallow aquifer (which occurs
approximately 2 feet below the ground
surface), a day layer (which occurs
approximately 12 feet below the ground
surface), a tfll aquifer, and a deeper
bedrock aquifer,
• on-site soils, both at the surface and
down to a depth of at least 10-12 feet,
are heavily contaminated with hazardous
substances, including volatile organics
(total concentration as high as 12,167
parts per million (ppm)), base/neutral
compounds (as high as 3,913 ppm), PCBs
(as high as 15,000 ppm), petroleum
hydrocarbons (as high as 81,600 ppm), as
well as acid exiractable compounds,
phenolics, cyanide, pesticides, and
inorganic compounds at similarly high
concentrations.
- the shallow groundwater at the site is
heavily contaminated with hazardous
substances, including volatile organics (as
high as 2,564 ppm), base/neutral
compounds (as high as 68 ppm), acid
extractable compounds (as high as 17
ppm), PCBs (as high as 17 ppm),
petroleum hydrocarbons (as high as 2\270
ppm), as well as pesticides and inorganic
compounds;
- contaminants have migrated from the
shallow zone down into and through the
clay layer which separates the shallow
aquifer and the deeper aquifers;
• deeper groundwater at the site is
contaminated with volatile organics and
and semi-volatile organic compounds; and
• surface water and sediment in Peach
Island Creek, a tributary of Berry's Creek
which flows adjacent to the site, is
contaminated with hazardous substances
which were found in the soils and
groundwater at the site.

The PRPs also conducted an FS to evaluate
potential remedial alternatives for the most heavily
contaminated zone at the site, (contaminated soils,
sludges and shallow groundwater down to, but not
including the clay layer). Various technologies for
-------
treating the most heavily contaminated zone were
evaluated, including, solidification of the
soils/sludges, chemical extraction of contaminants
from the soils/sludges, and incineration of the
soils/sludges. In addition, the FS evaluated the
No Action Alternative.

The FS demonstrated that in order to treat the
heavily contaminated saturated soil, it would first
be necessary to remove the shallow froundwater
from this zone. Consequently, each of the
alternatives evaluated (with the exception of the
No Action Alternative) includes implementation
of a Mewatering" system. This system consists of:

1) installation of an underground slurry
wall around the site perimeter, down to
the clay layer,

2) extraction of ground water from within
the boundary of this wall; and,

3) subsequent treatment and disposal of
the groundwater.

After dewatering, it could then be possible to
treat the con lamina ted soils, either by excavation
or treatment in place fin-situ").

As described above, during the FS, treatabiliry
studies were performed to test the effectiveness
of several treatment methods for soils and
groundwater. The results of the studies indicate
that, although there are several treatment methods
which are potentially viable for remediation of
soils and sludges, there are uncertainties regarding
the relative effectiveness of various remediation
technologies. Due to the high concentrations and
wide variety of chemicals present in the soil and
sludge, it is unknown whether any one technology
will be adequate to remediate the soils and
sludges. Consequently, additional data must be
gathered in order to select a permanent remedy
for the shallow zone which is protective of human
health and the environment

SCOPE AND ROLE OF PROPOSED RESPONSE
ACTION

Though further work is planned to evaluate
treatment technologies for the soils and sludges,
EPA is proposing an interim action to temporarily
reduce migration of contaminants from the
shallow zone until further studies of the site are
completed. This proposed interim action consists
of site dewatering through installation of a slurry
wall, collection of groundwater, and off-site
treatment and disposal

The SCP site, as characterized by the RI field
investigations, is extremely complex, due the wide
variety of contaminants present, the high
concentrations of contaminants detected, and the
many potential migration routes for these
contaminants.

Consequently, EPA has divided the work at the
site into components called "operable units*
(OUs). These OUs for the site are defined as
follows:

OU 1: the shallow zone of the site,
including contaminated soils and
groundwater above the clay layer, and,

OU 2: the deeper zone of the site and
potential off-site contamination, including
the deeper groundwater aquifers and
Peach Island Creek,

The combination of chemical contaminants present
within the area comprising OU 1 (including
volatile organics, semi-volatile organics, PCBs,
metals and petroleum hydrocarbons) poses
significant technical issues in terms of treatabiliry
of the soils. Further data collection and testing
of various potential treatment methods are
desireable prior to identification of an effective
remedy for this operable unit. It is anticipated
that such studies will take approximately 12
months to complete.

Although a permanent remedy for OU 1 cannot
be selected at this time, EPA is proposing
implementation of a site dewatering system as the
first phase of OU 1 in the interim. Since the
dewatering system is a common component of all
alternatives evaluated to date, (with the exception
of the No Action Alternative), it will be consistent
with any potential future remedy which EPA will
select for the site. This alternative will be part of
a future permanent remedy which will protect
human health and the environment. Although
this alternative is not fully protective in and of
itself, it is expected to be effective in temporarily
reducing further migration of contaminants from
the shallow zone until a permanent remedy can be
implemented.
-------
SUMMARY OF SITE RISKS

An analysis was conducted by EPA through its
contractor during the RL/FS to estimate the health
and environmental impacts that could potentially
result from the con lamination at the SCP site.
This analysis is commonly referred to as a baseline
risk assessment

The data collected as pan of the RI revealed that
at least 87 chemicals exist in the soil and shallow
groundwater at the site. The highest
concentrations of chemicals are found in the soils,
sludge and/or groundwater above the clay lens at
the site.

Many of the chemicals detected in the soils and
groundwater are known carcinogens in animals
and are suspected human carcinogens (e.g. PCBs,
chloroform, 1,2-dichloroetnane, metbylene
chloride.) Other chemicals detected at the site
are known human carcinogens (e.g. vinyl chloride,
arsenic, and benzene).

Many of the hazardous substances detected in the
groundwater at the site were present at levels
which far exceed Federal and State standards and
guidelines for groundwater. In particular, the
levels of numerous volatile organic compounds,
PCBs, and several inorganics exceed the Federal
Maximum Contaminant Levels (MCLs) under the
Safe Drinking Water Act, and the New Jersey
MCLs by orders of magnitude.

As evidenced by the data collected to date, there
has been migration of contaminants from the
shallow zone to deeper groundwater and Peach
Island Creek, and there is a potential for
continued migration absent the implementation
of interim remedial action. Contamination
released from the site may also pose risks to
aquatic life and endangered species, such as the
Pied-billed Grebe, through exposure to Peach
Island Creek sediments and surface water.

SUMMARY OF ALTERNATIVES

Many alternatives for remediation of the first
operable unit were evaluated in the FS, which is
available in the information repositories noted
above. However, because EPA is proposing an
interim action for OU 1, only limited interim
action alternatives are presented here. The three
alternatives analyzed for the interim action to
control migration are presented below. Following
implementation of any of the alternatives,
monitoring would be conducted until the
permanent remedy for OU 1 is implemented. For
costing purposes, it was assumed that quarterly
monitoring would be conducted for three years.

Alternative 1: No Further Action

Capita] Cost: S 0
Annual Operation and
Maintenance (O & M) Costs: S 40,000
Present Worth (PW) S 109,000

Months to Design and Construct 0

Superfund regulations require that the No Action
alternative be evaluated at every site to establish
a baseline for comparison. Under this alternative,
EPA would take no interim action at the site to
reduce migration of contaminants to groundwater
and Peach Island Creek, but would continue to
maintain the existing fence around the site
property to restrict access to the site. The No
Further Action alternative also includes periodic
monitoring of groundwater.

Alternative 2: Site Dewatering through installation
of • Slurry Wall, Groundwater Collection and
Treatment System

Capita] Cost: S 4,586,000
Annual O & M cost S 109,000 (for 3 years)
Present Worth, S 5,164,000
(including 10% contingency)

Months to Design and Construct: 12-24

Major features of this alternative include:
installation of an underground slurry wall around
the perimeter of the site, installation of a
groundwater collection system within the boundary
of the slurry wall, and construction of groundwater
treatment plant to treat collected groundwater
prior to discharge of the treated effluent to Peach
Island Creek. The treatment plant would be
designed to meet NJPDES requirements for
discharge of treated groundwater to Peach bland
Creek. (See preliminary discharge standards,
provided to EPA by NJDEP by letter dated April
16, 1990, contained in the administrative record
file for this site.)
-------
In addition, an infiltration control barrier would
be placed over- the site. Th; function of this
temporary barrier would be solely to prevent the
infiltration of rainwater, limiting the volume of
water requiring treatment, and thus the cost of
treatment

Alternative 3: Site Dewatering through Installation
of a Slurry Wall, Grouncfwater Collection and Off-
site Treatment and Disposal

Capital Cost: S 2457,000
Annual O & M cost S 42,000 (for 3 years)
Present Worth $ 2,933,000
(including 10% contingency)

Months to Design and Construct: 9-15

This alternative is identical to Alternative 2,
except that groundwater would be transported and
disposed of at a facility capable of accepting the
water with no pretreatment at the site.
Consequently, construction of an on-site treatment
facility would not be necessary.

Both Alternatives 2 and 3 would effectively
reduce, but not eliminate, migration of
contaminants via groundwater beyond the slurry
wall boundary until a permanent remedy is in
place.

EVALUATION OF ALTERNATIVES

The preferred alternative is to take interim action
at the site by implementing Alternative 3. This
alternative is a necessary component of any
permanent future remedy for OU 1 (e.g. treatment
of the soils/sludges) and would appear to provide
the best balance of trade-offs among the
alternatives with respect to the criteria that EPA
uses to evaluate alternatives. This section profiles
the performance of the preferred alternative
against the criteria which apply to this interim
action, noting bow it compares to the other
options under consideration.

Overall Protection of Human Health and the
Environment: This criterion addresses whether or
not a remedy provides adequate protection and
describes bow risks posed through each pathway
are eliminated, reduced, or controlled through
treatment, engineering controls or institutional
controls. Alternative 1 would not be protective
of human health and the environment since
contaminants would continue to migrate from the
soils and shallow aquifer to deeper aquifers and
Peach Island Creek. Alternatives 2 tnd 3 would
protect human health and the environment in the
short term by reducing further migration of
contaminants through the above migration
pathways until a final remedy is in place.

Compliance with ARARs: This criterion
addresses whether or not a remedy will meet all
of the applicable or relevant and appropriate
requirements (ARARs) of Federal and State
environmental statutes (other than CERCLA)
and/or provide grounds for invoking a waiver.

There are several types of ARARs: action-specific,
chemical-specific, and location-specific Action-
specific ARARs are technology or activity-specific
requirements or limitations related to various
activities. Chemical-specific ARARs are usually
numerical values which establish the amount or
concentrations of a chemical that may be found
in, or discharged to, the ambient environment.
Location-specific requirements are restrictions
placed on the concentrations of hazardous
substances or the conduct of activities solely
because they occur in a special location.

CERCLA provides that if an interim measure is
conducted, ARARs may be waived, since these
requirements will be achieved upon completion
of the permanent remedy. Because Alternatives
2 and 3 constitute interim actions, final cleanup
levels for soil and groundwater do not have to be
achieved, but will be addressed in the final
remedy.

However, certain action-specific requirements,
discussed below, will be attained as pan of
implementation of Alternatives 2 or 3.

Actions taken in Alternative 2 will comply with
effluent limitations for any discharge from
groundwater treatment plant into Peach Island
Creek. In addition, the treatment plant will be
designed and operated in compliance with Federal
and State air emissions requirements. For
Alternative 3, requirements pertaining to any off-
site disposal facility will have to be met Both
Alternatives 2 and 3 will comply with the
Executive Orders on Flood Plain Management,
and Wetlands Protection, the Clean Water Act
Section 404 General Standards for Permitting
Stream Encroachment, and the New Jersey Soil
-------
Erosion and Sediment Control Requirements
(NJAC 4:24-1), and the regulations of the
Hackensack Meadowlands Development
Commission.

Long-term Effectiveness: This criterion refers to
the magnitude of residual risk and the ability of
a remedy to maintain reliable protection of human
health and the environment over time, once
cleanup goals have been met Given that this is
an interim action, effectiveness need only be
maintained for the duration of the interim action,
which is expected to be no more than three yean.
Therefore this criterion will evaluate long-term
effectiveness over a three year period.

Alternative 1 is not effective in the long or short
term. Both Alternatives 2 and 3 will be effective
in reducing the migration of contaminants from
the shallow zone of the site, once implemented,
and should maintain their effectiveness for the
expected duration of the interim remedial action.

Red union of Toxicirv. Mobility or Volume:

This criterion addresses the degree to which a
remedy utilizes treatment to reduce the toxicity,
mobility, or volume of contaminants at the site.

Since neither of the Alternatives evaluated for
this interim remedy employ treatment of the
soils/sludges in the OU 1 zone, this criterion is
not applicable to the soil/sludge in the OU 1
zone. Alternatives 2 and 3 do involve the
treatment of contaminated groundwater, and
should reduce the volume of contaminants in the
shallow groundwater.

Short-Term Effectiveness: This criterion refers to
the time in which the remedy achieves protection,
as well as the remedy's potential to create adverse
impacts on human health and the environment
that may result during the construction and
implementation period.

Alternative 1 presents the least short-term risks
to on-site workers since no construction activities
are involved in implementing the No Action
alternative. However, it will not reduce any of
the existing risks at the site. Alternatives 2 and
3 will require the execution of health and safety
protection measures during the remedial
construction to adequately protect workers. These
measures may include requirements for protective
clothing and respiratory protection. Health and
safety measures to protect the community, such as
dust ore vapor suppression, will also be required.
However, neither Alternative 2 nor 3 present
health and safety problems which cannot be
successfully addressed by available construction
methods.

The estimated time periods for design of the
Alternatives and periods for construction are as
follows: Alternative 2-9 months for design and
9 months for construction; Alternative 3-6
months for design and 6 months for construction.
Therefore, Alternative 3 will reduce the migration
of contaminants most quickly. However, both
Alternatives 2 and 3 will provide benefits in terms
of the time required for ultimate remediation of
OU 1, since implementation of the dewatering
now will expedite implementation of the
permanent remedy ultimately selected.

Implememability: Implementability is the
technical and administrative feasibility of a
remedy, including the availability of materials and
services needed to implement the selected
alternative.

Alternative 1 is the simplest alternative to
implement from a technical standpoint since it
only involves actions to periodically inspect and
sample the site, ensure restricted access to the
site, and continue to provide information about
the site to the surrounding community.

The operations associated with Alternative 2
(construction of a slurry wall, dewatering system,
and groundwater treatment system) generally
employ well established, readily available
construction methods. However, the placement
of a treatment plant on site may pose some
difficulties upon implementation of the permanent
remedy for the soils, since the plant would need
to be moved in order to obtain access to the soils
for any future treatment. In addition, the ability
of a treatment system to meet the administrative
requirements (see below) for discharge to Peach
Island Creek, will require further investigation.

The operations associated with Alternative 3
(construction of a slurry wall, dewatering system,
and off-site treatment of groundwater) employ
well established, readily available construction
methods. This alternative would necessitate
contingency plans to ensure that adequate storage
-------
capacity exists for collected groundwater, in the
event of a significant increase in the estimated
flow due to unanticipated infiltration.

Administrative requirements associated with
Alternative 2 include compliance with NJPDES
requirements for discharge of treated groundwater
to Peach Island Creek, or for Alternative 3,
disposal of groundwater at an approved off-site
facility will require compliance with standards
established for the receiving facility. In addition,
both alternatives would include periodic
monitoring to ensure their effectiveness.

Both alternatives are implementable from an
administrative and technical perspective.

Cost: Cost includes capital and operation and
maintenance (O & M) costs.

Alternative 1, No Action, has an estimated present
worth of $109,000. The primary constituents of
this cost are inspection and sampling. The
present worth cost estimates of Alternatives 2 and
3 are $5,164,000 and $2,933,000, respectively. The
major cost items associated with Alternatives 2
and 3 are construction of the slurry wall and
groundwater treatment or disposal

The cost estimates are based on the assumption
that approximately 1,000,000 gallons of
groundwater will be treated.

State Acceptance indicates whether, based on its
review of the Rl/FS and Proposed Plan, the State
concurs with, opposes, or has no comment on the
preferred alternative. This criterion will be
addressed when State comments on the Proposed
Plan are received.

Community Acceptance will be assessed in the
Record of Decision following a review of the
public comments received on the RLTS reports
and the Proposed Plan,
SUMMARY OF THE PREFERRED
ALTERNATIVE

In summary. Alternative 3 would achieve risk
reduction in the snort term by minimizing further
migration of contaminants from the site.
Alternative 3 will not conflict with any future
remedy which will be selected to address the
contaminants remaining at the site. Therefore,
Alternative 3 is believed to provide the best
balance of tradeoffs with respect to the evaluation
criteria and is proposed by EPA as the preferred
alternative.

THE COMMUNITY'S ROLE IN THE
SELECTION PROCESS

EPA solicits input from the community on the
cleanup methods proposed for each Superfund
response action. EPA has set a public comment
period from May 19 through June 18, 1990 to
encourage public participation in the selection of
an interim remedy for the SCP Site. The
comment period includes a public availability
session at which EPA will discuss the Rl/FS
repon and Proposed Plan, answer questions, and
accept both oral and written comments.

The public meeting for the SCP Site is scheduled
for June 5, 1990 from 7pm until 9pm, and will
be held at the Carlstadt Borough Hall, 500
Madison Street, Carlstadt, New Jersey.

Comments will be summarized and responses
provided in the Responsiveness Summary section
of the Record of Decision (ROD). The ROD is
the document that presents EPA's final selection
for response action. Written comments on this
Proposed Plan should be sent to by close of
business June 18, 1990:

Pat Evangelista
Project Manager
U.S. Environmental Protection Agency-Region II
Emergency & Remedial Response Division
26 Federal Plaza, Room 747
New York, New York 10278
-------
APPENDIX B

Sign-in Sheet of Attendees at the June 5, 1990 Public Meeting
-------
UNITED STATES PR
-------
UNITED STATES PROTECTION AGENCY
REGION II
PUBLIC MEETING
FOR
SCIENTIFIC CHEMICAL PROCESSING 8UPERFUND BITE
CARL8TADT, NEW JERSEY

JUNE 5, 1990
ATTENDEES
(Please Print)
NAME
STREET
CITY
ZIP
HONE
REPRESENTING
MAILING
LIST
-------
UNITED STATES PI
REGI
ION AGENCY
PUBLIC MEETING
FOR
SCIENTIFIC CHEMICAL PROCESSING 8OPERFOND SITE
CARL8TADT, NEW JERSEY

JUNE 5, 1990
ATTENDEES
(Please Print)
NAME
1?omomni HP
T-^fft, /o
r
/o
STREET
CITY
2IP

,9-74-07
Q796o

07160
PHONE
MAILING
REPRESENTING LIST

Ldhtfam
^/aaz^
-------
APPENDIX C

May 19, 1990 Public Notice in the Bergen Record
-------
THEUNfTiDSTATES^

• ENVIRONMENTAL PROTECTION A6ENCY ,

; INVITSS vv.v:':'-. .; ••./.. .;

PUBLIC COMMENT ON THE r s

PROPOSED INTERIM REMEDY t

FOR THE SCIENTIFIC CHEMICAL PROCESSING SITE

LOCATED IN

CARLSTADT, NEW JERSEY. -

The U.S. Environment!! Protection Agency (EPA) ti lead agency for the Scientific
Chemical Processing (SCP) tfte will hold • Public Meeting to discuss the Remedial
Investigation/Feasibility Study (Rl/FS) and the Proposed Plan for an interim
Remedy at the cite. The New Jersey Department of Environmental Protection
(NJDEP) as a support agency will also b« In attendance. The meeting will be held on
June 5, 1990 at 7:00 p.m. In the Carlstadt Borough HaJl, $00 Madison Street,
Carlstadt, New Jersey. ' • ;
As a result of the Rl/FS conducted to date, EPA determined that although there are
several treatment methods which are potentially viable for the remediation of
contaminated soils and sludges, there are uncertainties regarding the relative
effectiveness of various remediation technologies. Due to the high concentrations
and wide variety of chemicals present In the sou and sludge, It Is unknown at this
time whether any one technology will be adequate to remediate the soils and
sludges Consequently. EPA Is proposing an Interim Remedy to temporarily reduce
migration of contaminants from the shallow zone of the site, while additional data Is
gathered. This Interim Remedy wil1 be the first component of the permanent
remedy to be selected for the shallow zone of the site. Amongst the options
evaluated for an interim Remedy at the SCP site are the following:

INTERIM REMEDY ALTERNATIVES
Alternative - 1: No Further Action
Alternative • 2:
Alternative • 3:
Site Dewaterlng through Installation of a Slurry
Wall, Ground Water Collection. On.site
Treatment and Disposal

Site Dewaterlne through Installation of a Slurry
Wan. Ground Water Collection. Off-site
Treatment and Disposal
The no further action alternative was evaluated as required by the National Oil and
Hazardous Substances Pollution Contingency Plan.

Based on available information, the proposed Interim Remedy at this time is
Alternative - 3. EPA and NJDEP welcome the public's comments on all alternatives
identified above. EPA win choose the Interim Remedy after the public comment period
ends and consultation with NJDEP Is concluded. EPA may select an option other than
the proposed alternative after consideration of ali comments received.
Complete documentation of the project findings is presented In the Administrative
Record Fi!e, which .contains the Rl and FS Reports and the Proposed Plan. These
documents are available at either the William E. Dermody Free Public Library or
EPA's Region li office In New York.

The public may comment In person at the public meeting and/or may submit
written comments through June 18,1990 to:
Pat Evangelitta
Remedial Project Manager
Emergency and Remedial Response Division
U.S. Environmental Protection Agency
26 Federal Piaza
New York, New York 10278
(212)264.e311
-------