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

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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
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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.

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                       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.

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                               -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.

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                                -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

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                         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

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                         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

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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).

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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.

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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.

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     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.

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                        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.

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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  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 into the underlying till 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

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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;

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     - 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

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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.

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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

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 to Peach Island
Creek.   The  treatment plant  would be  designed  to meet  NJPDES
requirements for discharge of  treated groundwater to Peach Island
Creek.   (See  preliminary  discharge standards, provided  to  EPA by
NJDEP  by   letter  dated  April   16,   1990,  contained  in  the
Administrative Record for this site.)

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

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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

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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.

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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

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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;
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     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

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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


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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.
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            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 CONCENTRATIONS
                            IN MEDIUM  DEPTH (5-6')  SOIL
  Chemical
  (Concentration Units)
 Frequency
of Detection
  Maximum
  Detected
Concentration
  Geometric
    Mean
Concentration
Semi -Volatile Compounds (ug/kg)
indeno(l,2,3-c,d)pyrene (C)
naphthalene 
-------
                                                 TABLE 3


                   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

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)

1


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


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ra
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                                                                             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
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IV4IIMIIDN 01 IHI NOSI '«nil«lll| IDHDIIIONS


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                                                                     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 » - •
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i soon
i •••
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jr=g
ss;
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,


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
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CL
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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

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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

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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

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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.

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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

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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

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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:

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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:

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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

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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

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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

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     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

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"... 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

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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

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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

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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

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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

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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

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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

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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

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          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

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            APPENDIX  A



Proposed Plan for the  Interim Remedy

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              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

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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

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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.

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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.)

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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

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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

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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

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                         APPENDIX   B



Sign-in Sheet of Attendees  at  the  June  5,  1990  Public Meeting

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                           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

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                           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^

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                  APPENDIX  C



May 19, 1990 Public Notice in the Bergen Record

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                   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

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