United Slates
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R02-87/041
September 1987
SEP A
Superfund
Record of Decision:
Chemical Control, NJ
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing/
RPA/pnn/pn2-87/Q41
I. TITLE AND SUBTITLE
3. RECIPIENT'S ACCESSION NO.
SUPERFUND RECORD OF DECISION
Chemical Control, NJ
First Remedial Action
5. REPORT DATE
September 23, 1987
I. PERFORMING ORGANIZATION CODE
I. PERFORMING ORGANIZATION REPORT NO
HE AND ADDRESS
10. PROGRAM ELEMENT NO.
I. CONTHACT/GHANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
15. SUPPLEMENTARY NOTES
The Chemical Control Corporation (CCC) site, consisting of 2.2 acres and a portion of
the Elizabeth River, is located in Union County, New Jersey-. The site area, formerly a
marsh, is flat and barely above sea level. The surrounding area is mostly industrial.
However, one residence is within 200 feet of the site. Densely populated neighborhoods
are located across the Elizabeth River. From 1970 to 1978, CCC operated as a hazardous
waste storage, treatment and disposal facility accepting various types of chemicals
including: acids, arsenic, bases, cyanides, flammable solvents, PCBs, compressed bases,
biological agents and pesticides. Throughout its operations, CCC was cited for
discharge and waste storage violations. In March 1979, the State of New Jersey
initiated a site cleanup of bulk solids and liquids, drums at and below the surface, gas
cylinders, infectious wastes, radioactive wastes, highly explosive liquids, debris,
tanks and three feet of soil. Excavated soil areas were replaced with a three foot
gravel cover.
An April 1980 explosion and fire interrupted the site cleanup and created additional
cleanup needs by destroying the site and reportedly launching drums of burning waste
into the air. From November 1980 until July 1981, the State operated a ground water
recovery and treatment system. Initial Remedial Measures conducted at the site have
mitigated the immediate hazards. The site closure RI, completed in July 1986,
(See Attached Sheet)
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lOENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Chemical Control, NJ
First Remedial Action
Contaminated Media: soil, sediments, river
Key contaminants: organics, VOCs,
pesticides, metals
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EPA/ROD/RO2-87/041
Chemical Control, NJ
First Remedial Action
16. ABSTRACT (continued)
determined that soils beneath those previously removed are highly contaminated with a
variety of organic compounds and to a lesser degree with metals. These contaminants are
strongly absorbed into the soil. Sediments along the Elizabeth River are also
contaminated. However, the greatest potential risk from this site is associated with
the possible exposure of the contaminated soil. The primary contaminants of concern
effecting the soil include: organics, VOCs, pesticides, acid and base-neutral
extractables and metals.
The selected remedial action includes: treatment of approximately 18,000 cubic yards
of contaminated soils using in-situ fixation (solidification); removal of debris
including drill cuttings, monitoring well development water, items recovered from the
river under the IRM, used disposable equipment and the decontamination pad; sealing of
the sanitary sewer line under the site; and repair of the site/river berm. The
estimated capital cost for this remedial action is $7,208,000 with annual O&M of $57,400
for years 1-5 and $22,400 for years 6-30.
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DECLARATION STATEMENT
RECORD OF DECISION
Chemical Control Corporation
SITE NAME AND LOCATION
Chemical Control Corporation, Elizabeth, Union County, New Jersey
STATEMENT OF PURPOSE
This decision document presents-the selected remedial action for
the Chemical Control Corporation site, developed 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 Oil and Hazardous Substances Pollution Contingency
Plan, 40 CFR Part 300, November 20, 1985.
STATEMENT OF BASIS
I am basing my decision primarily on the following documents, !
which are contained in the administrative record and characterize.
the area and evaluate the relative merits of remedial alternatives
for the Chemical Control site:
• Draft Remedial Investigation Report, Chemical Control Corp-
oration, prepared by NUS Corporation, July 1986
- Draft Feasibility Study Report, Chemical Control Corporation,
prepared by Ebasco Services inc., June 1987
- Proposed Remedial Action Plan, Chemical Control Corporation,
July 1987
- The attached Decision Summary for the Chemical Control site
- The attached Responsiveness Summary for the site, which
incorporates public comments received
- Staff summaries and recommendations
DESCRIPTION OF THE SELECTED REMEDY
The remedial alternative presented in this document is a perm-
anent solution for closure of the Chemical Control site. It
addresses the contaminated soil remaining at the site. Contained
wastes, contaminated buildings and some- contaminated soil were
addressed in previous response actions.
This-action consists of the following components:
- Treatment of the contaminated soil at the site using in-situ
fixation
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- 2 -
- Removal of debris remaining from earlier response actions/
including drill cuttings, monitoring well development water,
items recovered from the Elizabeth River under the initial
remedial measure, used disposable equipment, and the decon-
tamination pad
- Sealing of the sanitary sewer line under the site where it
connects to the South Front Street storm sewer
- Repair of the berm that separates the site from the Elizabeth
River
- Collection and analysis of environmental samples, as required,
to ensure the effectiveness of the remedy, including an eval-
uation after five years to assess its protectiveness to public
health and the environment.
DECLARATIONS
Consistent with the Comprehensive Environmental Response, Comp-
ensation, and Liability Act, as amended, and the National Oil
and Hazardous Substances Pollution Contingency Plan, 40 CFR Part
300, I have determined that the selected remedy is protective
of human health and the environment, attains federal and state
requirements that are applicable or relevant and appropriate
for this action, and is cost-effective. Furthermore, this
remedy satisfies the preference for treatment that reduces
toxicity, mobility, or volume as a principal element. Finally,
I have determined that this remedy utilizes permanent solutions
and alternate treatment technologies to the maximum extent
practicable.
The State of New Jersey has been consulted and agrees with the
selected remedy, as is documented in the attached letter of
concurrence.
I have also determined that the actions being taken at the
Chemical Control site are appropriate when balanced against the
availability of Superfund monies for use at other sites.
Date ' Christophe
J.
Regional Administrator
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STATE OF NEW JERSEY
DEPARTMENT OF ENVIRONMENTAL PROTECTION
RICHARD T. DEWLINC, Ph.D.. P.E.. COMMISSIONER
CN402
TRENTON, N.J. 08625 ;-
609 • 292 - 2885
.18 SEP 1987
Mr. Christopher J. Daggett
Regional Administrator
USEPA - Region II
26 Federal Plaza
New York, NY 10278
Dear Regional Administrator Daggett:
This is to formally -notify you that the New Jersey Department of
Environmental Protection has reviewed the draft Record of Decision for the
Chemical Control Corporation Site and concurs with the recommended remedy.
This remedy will consist of the following:
- Treat the contaminated soil at the site using in-situ fixation.
- Remove debris remaining from earlier response actions, including drill
cuttings, monitoring well development- water, items recovered from the
Elizabeth River under the Initial Remedial Measure, used disposable
equipment* and the decontamination pad.
- Seal the sanitary sewer line under the site where It connects to the
South Front Street storm sewer.
• Repair the berm that separates the site from the Elizabeth River.
- Collect andT analyze environmental samples, as required, to ensure the
effectiveness of the remedy.
New Jersey fully appreciates the importance of the Record of Decision
in the cleanup process and will continue to take all reasonable steps to
ensure that the State's commitments in this area are met.
Sincerely,
AJ^LJ^Q^^
Richard T. Dewllng
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Decision Summary
Chemical Control Corporation
SITE LOCATION AND DESCRIPTION
The Chemical Control Corporation property is located at 23 South
Front Street in Elizabeth, Union County, New Jersey. The.site
consists of this 2.2-acre property and the portion of the
Elizabeth River adjacent to the property. It is part of a
narrow peninsula formed by the Elizabeth River and the Arthur
Kill (Figure 1). This peninsula was a marsh until it was
filled to prepare it for industrial development. The Elizabeth
River, the Arthur Kill, and the water table aquifer at the site
are all saline and tidally influenced. The site is flat and
barely above sea level.
Although the surrounding area is mostly industrial, there is a
residence 200 feet northeast of the site. Densely populated
neighborhoods are located across the Elizabeth River, and the
total population of the City of Elizabeth exceeds 100,000. The
site itself is currently fenced and covered with coarse gravel.
The buildings and storage tanks that were used by Chemical Control
during its operations were removed under earlier response actions.
Commercial ship traffic is heavy in the Arthur Kill, and both the
Arthur Kill and the Elizabeth River are used for recreational
boating. Although shellfishing in the Arthur Kill has been
restricted by the State of New Jersey since 1980, city officials
report it is still actively pursued by recreational fisherman
within three-quarters of a mile of the site.
SITE HISTORY
Origin of Problem
Chemical Control Corporation operated from 1970 until 1978
hauling, treating, and disposing of a wide variety of industrial
wastes. Throughout its operations, it was cited for violations
that included discharging liquids onto the ground adjacent to the
Elizabeth River and accumulating thousands of drums of incom-
patible wastes. After failing to comply with an order from the
State of New Jersey to clean up its operations, Chemical Control
Corporation was placed into operational receivership by a judge
.of the Superior Court of New Jersey.
Initial Response Actions
The State began a clean-up of the site in March 1979 that by
April 1980, when the site was destroyed by fire, had removed
55,400 pounds of bulk solids, 1800 gallons of bulk liquids,
nearly 10,000 drums of waste, 83 gas cylinders, 10 pounds of
infectious wastes, 7 pounds of radioactive wastes, and 24 gallons
of highly explosive liquids. On April 21, 1980, an explosion
and fire occurred at the site that was not brought under
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-2-.
CHEMICAL CONTROL
CORPORATION SITE
loop aooo »eoo «OOP
FIGURE 1
SITE LOCATION
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-3-
control for over ten hours. The explosion and fire destroyed
buildings at the site and reportedly launched drums of burning
waste into the air.
New Jersey continued its (pre-Superfund) clean-up operation after
the fire and removed all building debris, drums (found on and
below the surface), and tanks from the site. Three feet .of
surface soil was also removed from the site and from a property
across the street that had been used as a staging area during the
clean-up. This soil was replaced with three feet of gravel. Gas
cylinders, which were discovered during this operation, were
stored at the site. The State also operated a groundwater recovery
and treatment system from November 1980 until July 1981.
Remedial Actions taken by EPA
Initial Remedial Measures
In 1981, the site was ranked for inclusion on the Superfund
Interim Priorities List. A State Superfund Contract was signed
by the Environmental Protection Agency (EPA) and the New Jersey
Department of Environmental Protection (NJDEP) in September 1983.
The Scope of Work (SOW) for the contract identified remedial
actions that remained to be completed at the site. These actions
are described below. The SOW also called for a feasibility study
(FS) to determine the appropriate remedial action for closing the
site. This Record of Decision selects a remedial action based on
the findings of the remedial investigation (RI) and the FS and
public comments as summarized in the Responsiveness Summary,
which is attached.
At the end of New Jersey's response action, eleven box trailers
and one vacuum truck, which were used during the response, were
left at the site. As part of an Initial Remedial Measure (IRM)
undertaken by the EPA, the trailers and the vacuum truck were
decontaminated at the site and removed for disposal. This IRM also
involved-~repairing the storm sewer system at South Front Street
adjacent to the site. The system had been damaged by heavy
equipment used in the response action and had been plugged with
sand during the fire to prevent contaminated water from discharging
to the Arthur Kill. The storm sewer was cleared of any blockage
and the manholes, catch basins, and curbs were repaired.
Based on reports that the Chemical Control Corporation may have
dumped drums into the Elizabeth River and that drums might have
entered the river during the fire, an IRM was conducted by the
EPA to locate and identify metallic objects in the river and
recover those objects that might contain hazardous waste. The
first phase of this IRM determined that there were many fewer
containers in the river than had been expected. Nevertheless,
five drums, three cylinders, three pails, one can, two drum lids,
and a piece of sheet metal were recovered. The one intact gas
cylinder was placed in an overpack and is now awaiting disposal
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-4-
as part of the gas cylinder project described below. The rest of
the recovered items are being stored in drums and are awaiting
disposal as part of the site closure action. This project is
described in more detail in the Project Summary Report for the
Chemical Control Corporation Elizabeth River Drum Removal submitted
to the EPA by NUS Corporation in May 1986.
The purpose of the final IRM to be conducted at the site is to
sample and remove 189 deteriorated gas cylinders. The original .
plan to dispose of the cylinders involved detonating them at a
Department of Defense facility in New Jersey. However, subsequent
discussions with Defense Department officials revealed they were
not willing to allow the use of one of their facilities for this
purpose. Further, the cylinders could not be manifested for removal
from the site.because the contents were unknown. The cylinders
were overpacked in August 1984 to prevent further deterioration
and to contain potential releases while a cylinder sampling device
was being designed. Specifications for the sampling and disposal
of the gas cylinders were completed in the summer of 1987. The
contract for the IRM should be awarded in the fall of 1987. :
The remedial measures that have been implemented at the site have b
mitigated the immediate hazards. The site is surrounded by a
security fence, and a layer of gravel (ranging from one to three ..
feet thick) covers the entire surface. The only contained wastes
remaining at the site are the'gas cylinders, which are being
addressed under a separate action, and drums of waste from the RI
and the Elizabeth River IRM. These drums contain drill cuttings
from the soil borings, water from the development of the monitoring
wells, used protective equipment, and objects recovered from the
Elizabeth River. There is also some loose trash from the RI at
the site, including used hoses and protective equipment. An
earthen berm separates the site from the Elizabeth River. Before
the storm sewer was repaired, this berm prevented storm water
from running into the Elizabeth River. To alleviate flooding on
South Front Street, two openings were cut in the berm. Now that
the storm sewers are once again functional, the openings in the
berm are unnecessary.
Remedial Investigation
The site closure RI, completed in July 1986, determined that
soils beneath those removed by the NJDEP are highly contaminated
with a variety of organic compounds and to a lesser degree with
metals. It also found that these contaminants are strongly
adsorbed to the soil and are present in the groundwater in rela-
tively low concentrations. A similar partitioning of contaminants
also ex.ists in the Elizabeth River where sediments are contaminated.
The contaminants found in the sediments, however, are not all
attributed to the Chemical Control site. The FS which followed
examined several potential remedial actions. The findings are
summarized in the following sections.
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"5-
Beneath the gravel at the site, there is a layer of silty marsh
deposits mixed with fill material that was used to raise the
ground surface above the water table. This stratum, which
averages approximately ten feet thick, is highly contaminated
with a wide range of organic chemicals and less severely with
metals. A list of hazardous substances detected at the site is
provided in Table 1. Beneath this contaminated stratum, -there is
a layer of relatively clean, impermeable clay. Chemical data
for the subsurface samples are presented in Figure 2, and a cross-
section of the site is illustrated in Figure 3.
Although the soil at the site is highly contaminated, the ground-
water in contact with this soil is relatively clean. Three
physical factors may be responsible for the strong adsorption of
contaminants on the soil: the soil itself is composed of highly
organic marsh deppsits (which have a high affinity for organic
contaminants), many of the contaminants present in the soil are
nearly insoluble in water, and the high salinity of the groundwater
tends to further reduce the solubility of these compounds.
Although many of the contaminants are held tightly to the soil,
some of the more mobile chemicals continue to leach into the
groundwater. Chemical data for two rounds of groundwater samples
are provided in Figure 4. The groundwater from the site discharges
to the Elizabeth River through the river banks .and from two
leachate seeps, which have formed where the berm along the river
has been damaged.
The human health risks associated with the contamination in the
groundwater and the subsurface soil were evaluated in the RI.
The greatest potential risk from this site is associated with the
possible exposure of the contaminated soil. Significant health
threats are posed by direct contact, fugitive dust emission, and
volatilization. However, the contaminated soils are below the
water table and a layer of gravel, and the site is fenced. These
factors significantly reduce the risks posed by the exposure
pathways identified. Contaminants are only leaving the site via
the groundwater. Although the groundwater is saline and therefore
not a source of drinking water, some contaminants leave the site
and discharge to the Elizabeth River. The quality of the surface
water is discussed below.
Extensive sampling of water and sediment- in the Elizabeth River
was performed during the RI. The results of the analysis of
samples showed that sediments in the Elizabeth River were highly
contaminated while only low concentrations of very few contaminants
were detected in the river water. The Elizabeth River was sampled
inland (upstream at low tide) to where Route 1&9 crosses it. At
this point, the river becomes a concrete channel so sediment
sampling farther upstream is not possible. Downstream, water and
sediment samples were collected out to and in the Arthur Kill.
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TABLE 1
RANGES OF CHEMICAL CONCENTRATIONS BY MEDIUM
Concentration ranges for organic contaminants in groundwater,
surface water/ subsurface soil, and river sediments are provided
below. Ambient Water Quality Criteria (AWQC) for the protection of
saltwater aquatic life are also included in this table. AWQC
values are qualified with either:
C-chronic levels
A-acute levels
The AWQC are an Applicable or Relevant and Appropriate Requirement
(ARAR) for concentrations in water only. There are no ARARs for
concentrations in soil. Concentration ranges presented only rep-
resent the detected levels of the various chemicals. For each
chemical, there was at least one sample that did not contain a
detectable concentration. All water concentrations are in micrograms
per liter (parts per billion-ppb); soil concentrations are in
micrograms per kilogram (ppb).
CHEMICAL
Volatiles
acetone
2-butanone
4-methyl-2-pentanone
benzene
toluene
ethylbenzene
total xylenes
styrene
chlorobenzene
1,1,1-trichloroethane
1,1-dichloroethane
1,2-dichloroethane
tetrachloroethene
trichloroethene
1,2-dichloroethene
1,1-dichloroethene
vinyl chloride
carbon tetrachloride
chloroform
methylene chloride
chloromethane
1,2-dichloropropane
bromodichloromethane
carbon disulfide
GROUND WATER
SAMPLES
110 - 280
13 - 13
6-170
8 - 36
5 - 120
2-54
3-90
20 - 20
4-5
ND
13 - 13
2-47
2-64
4 - 110
3 - 620
ND
6 - 190
ND
5-42
2-85
ND
ND
ND
3-3
SURFACE WATER
SAMPLES
6.4 - 92
ND
ND
1 - 2.2
3.6 - 14
4-12
2-50
ND
ND
1 - 6.3
ND
ND
1.8 - 30
2 - 300
1 - 2100
ND
600 - 600
2-2
1 - 7.4
1-17
4-12
1-1
2 - 2.4
ND
AWQC
N/A
N/A
N/A
5,100 A
5,000 C
430 A
N/A
N/A
129 C
31,200 A
N/A
113,000 A
450 C
2,000 A
224,000* A
224,000* A
N/A
50,000 A
6,400* C
6,400* C
6,400* C
3,040 C
N/A
N/A
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TABLE 1 (cont.)
RANGES OF CHEMICAL CONCENTRATIONS BY MEDIUM
CHEMICAL
GROUND WATER
SAMPLES
Acid Extractables
2-methylphenol
Base/Neutral Extractables
bis(2-ethylhexyl)phthalate
di-n-octyl phthalate
di-n-butyl phthalate
butylbenzyl phthalate
acenaphthene
benzo(g,h,i)perylene
benzo(a)pyrene
dibenzo(a,h)anthracene
fluoranthene
indeno(1,2,3-cd)pyrene
naphthalene
2-raethylnaphthalene
pyrene
1,2-dichlorobenzene
benzyl alcohol
Pesticides/PCBs
alpha-BHC
4,4'-DDT
4,4'-DDE
endosulfan sulfate
chlordane
Arochlor(1260)
CHEMICAL
Volatiles
acetone
2-butanone
2-hexanone
4-raethyl-2-pentanone
benzene
toluene
ethylbenzene
4 - 4
SURFACE WATER
SAMPLES AWQC
ND N/A
!
4
2
5
4
- 100
-
-
-
4
23
5
ND
2
2
2
-
—
-
2
8
2
ND
•
•
•
2
2
4
15
04
36
•
-
ND
ND
-
ND
2
4
18
.
2.6
2.2
3.2
2
2.2
4
2
54
2.8
- .15
ND
- .28
- .36
ND
ND
.59
3.5
-
ND
3
.2
- 460
-
-
ND
ND
ND
-
ND
ND
-
-
3
2
.2
2,944*
2,944
*
2,944*
2,944*
710
300
300
*
*.
300*
2
.2
16
k
300*
4
2
2,350
300*
.2
- 54
—
ND
ND
ND
ND
-
•
3
•
3
SUBSURFACE
SOIL
SAMPLES
130 -
8
1
2
25
.5
3
.2
7
-
-
750,000
1,
25
- 2,
-
-
-
3,
2,
3,
200,000
700
800
800
100
.
.2
77
.5
SEDIMENT
SAMPLES
14 - 870
20 - 340
27 - 27
14 - 20
4 - 640
1 - 6,000
1 - 4,300
300
1,970
N/A
0.34
0.13
14
N/A
0.004
0.03
*
A
A
A
A
C
A
A
A
C
A
A
A
A
A
A
C
A
C
C
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-8-
TABLE 1 (cont.)
RANGES OF CHEMICAL CONCENTRATIONS BY MEDIUM
CHEMICAL
Volatiles
total xylenes
styrene
chlorobenzene
1,1,2,2-tetrachloroethane
1,1,1-trichloroethane
1,1-dichloroethane
1,2-dichloroethane
chloroethane
tetrachloroethene
trichloroethene
1,2-dichloroethene
vinyl chloride
chloroform
methylene chloride
chlororaethane
bromomethane
carbon disulfide
Acid Extractables
phenol
2-methylphenol
4-methylphenol
2,4-diraethylphenol
Base/Neutral Extractables
bis(2-ethylhexyl)phthalate
di-n-octyl phthalate
di-n-butyl phthalate
. diethyl phthalate
butylbenzyl phthalate
acenaphthene
acenaphthylene
anthracene
benzo(a)anthracene
benzo(b)fluoranthene
benzo(k)fluoranthene
benzo(g,h,i)perylene
benzol a)pyrene
chrysene
dibenzo(a,h)anthracene
SUBSURFACE
SOIL SAMPLES
2.7
45
3.4
20
7.4
350
170
280
3.7
4
4
3
3.1
34
250
160
1.6
800
500
94
60
54
51
49
990
1,900
40
320
79
51
66
57
40
47
51
350
-
-
-
-
-
-
-
-
-
-
—
-
-
-
-
—
_
-
-
"
-
-
-
-
-
-
-
-
-
-
-
-
-
-
5,500
3,600
270
20
110
350
2000
280
1,400
32,000
15,000
250
1,700
630,000
250
160
130
4,800
680
6,000
720
5,000
1,300
25,000
990
6,000
760
320
1,300
2,500
3,100
3,100
770
2,000 .
2,200
350
SEDIMENT
SAMPLES
5 - 13,000
ND
2 - 5,000
ND
ND
ND.
ND
ND
15 - 15
15 - 15
15 - 47
ND
3.1 - 7.6
6.2 - 180
ND
ND
3.7 - 23
ND
ND
ND
1,700 - 1,700
670
260
45
340
110
110
230
110
255
330 -
190 -
130 -
580 -
220 -
- 42,000
- 1,200
- 19,000
ND
- 7,100
-27,000
- 3,400
- 16,000
- 20,000
- 13,000
- 17,000
- 1,700
17,000
13,000
470
-------
-9-
TABLE 1 (cont.)
RANGE OF CHEMICAL CONCENTRATIONS BY MEDIUM
SUBSURFACE SEDIMENT
CHEMICAL SOIL SAMPLES SAMPLES
Base/Neutral Extractables
fluoranthene 60 - 5,300 1,000 - 35,000
fluorene 44 - 850 140 - 21,000
indeno(l,2,3-cd)pyrene 40 - 750 170 - 1,400
naphthalene 62 - 1,600 110 - 51,000
2-methylnaphthalene 49 - 800 43 - 27,000
phenanthrene 66 - 6,000 170 - 61,000
pyrene 100 - 4,100 190 - 22,000
1,2-dichlorobenzene 40 - 1,000 620 - 10,000
1,3-dichlorobenzene ND 110 - 510
1,4-dichlorobenzene ND 95 - 7,100
1,2,4-trichlorobenzene 80 - 590 ND
N-nitrosodiphenylamine 80 - 80 400 - 400
4-chloroaniline ND 300 - 4,200
benzole acid . 380 -380 ND
benzyl alcohol 80 - 630 ND
bis(2-chloroethoxy)methane 94 - 94 ND
dibenzofuran 290 - 740 100 - 13,000
isophorone 230 - 1,700 ND
Pesticides/PCBs
4,4'-DDT38 - 38 19 - 970
4,4'-ODD ND 20 - 420
4,4'-DDE 12 - 24 17 - 340
dieldrin ND 210 - 210
Arochlor(1242) ND 5,100 - 5,100
Arochlor(1254) 40 - 973 440 - 440
Arochlor(1260) 6,000 - 6,000 5,200 - 5,200
* Ambient Water Quality Criteria marked with an asterisk represent
the total allowable concentration for-the sum of all of the
contaminants in that particular chemical class.
-------
UBL
M "K*! """«"«
a i
u
2"
2 -CftVOTlM
• • |
S :i
•««
MluU *>tt •! (kick Mill MM uwl!
I. lr«Mlc nolli «r» ftmoU* I* Mrti Mr till to (M/>I|.
I. fMrfMlC null! M fnMM«4 I* NTII Mr BlIIlM (|«/M).
4. My |MTM>I< NMIU IW MttclM ckMluli tntmttt. klr
ItoH rmlU nMrUt ikltk MCM< t». tMrafi k> IM tirMir*
*tltlto>.
MOSE STArTOMJGE
I
M
O
FIGURE 2
ANALYTICAL RESULTS-SUBSURFACE SOIL SAMPLES
CHEMICAL CONTROL CORP. SITE. ELIZABETH. NJ
-------
A1
NOT!' KOUMIC CONTACT! M1HCO IMCNC AfVMUUMTC OH MnUMCO.
I OLD FU.-SN.TV SWO
TO MAVEL
ou> nu-nco «u
8ILTY CUkT TO
I CU«» SILT
04.ACIM. TILL-MM SUY
SAND TO SUCH SU
OLACIAL TIU-KED SILTV
MHO TO UNW MJ
>:-:>-:H MOHOCK
FIGURE 3
GEOLOGIC CROSS SECTION A-A1
CHEMICAL CONTROL CORP. SITE. ELIZABETH. NJ
This cross section Is based on findings from the borings for monitoring wells
1,2,4,5,8,9, and 10. (see Figure 2, line A-A')
-------
STAFTMUGC
ro
i
FIGURE
ANALYTICAL RESULTS -GROUNDWATER SAMPLES
CHEMICAL CONTROL CORP. SITE. EUZABETH. NJ
tCAlf
-------
-13-
The data for chemical concentrations in the river sediment
samples fail to show any trend linking the contaminants to the
site. This is probably because there are so many other potential
sources of contamination along the river. The river is lined
with junk yards, oil tank farms, and chemical manufacturers, and
storm water runoff from much of the city's streets carries oil
and other contaminants into the river. Although Chemical Control
was probably a source of contamination to the river at one time
and it continues to leach some contaminants, there are many other
sources of contamination along the river.
The Elizabeth River and the Arthur Kill are both polluted,
unhealthy environments. Contact with sediments in both surface
water bodies would expose an individual to potentially dangerous
levels of hazardous substances. Recreational boaters and fishermen
(despite State-imposed restrictions on shellfishing) use both
the Elizabeth River and the Arthur Kill, so direct contact .with
sediments as well as ingestion of contaminated shellfish are both
potential exposure routes.
t
Objectives for remedial action were developed based on the findings
of the risk assessment and the presence of highly contaminated *"
soils at the site. The high levels of contaminants in the soil/
represent the greatest potential risk to public health and the -
environment. Therefore, the remedial action for this site should
reduce the mobility and toxicty of the contaminants in the soil.
To the greatest extent possible, the action should protect against
any possibility of the contaminated soils being exposed, it should
insure that the leaching of contaminants will not increase, and it
should return the site to a condition that is compatible with
future development that could reasonably be expected in this indus-
trial area. Remediation of the river sediments was not identified
as an objective of this action. The site is no longer a significant
source of this contamination, and other sources continue to
contaminate the river. It would be premature to consider remedial
actions for the river sediments while major, active sources of
this contamination exist.
ENFORCEMENT
Notice letters were sent to 31 parties identified, as generators of
.wastes disposed of at the site on August'17, 1987. The EPA held a
conference on August 26, 1987 for recipients of the notice letters
to provide information about its proposed activities at the site,
to answer questions, and to invite a discussion of a settlement
that would involve funding of the proposed activities by private
parties. Informal discussion of a possible settlement is expected
to continue, and it may lead to more formal negotiations.
-------
-14-
COMMUNITY; RELATIONS ACTIVITIES
The RI report was released to the public on 29 July 1986. The FS
report and the Proposed Remedial Action Plan/ which identified
the EPA's preferred remedial alternative, were released on 30 June
1987 and 2 July 1987, respectively. A reprint of the RI was re-
leased at the same time to ensure that a complete package of site
information was available. The RI and FS reports were placed in
public repositories on these respective dates. The public comment
period, initiated on this date, was open until 14 August 1987.
A public meeting was held on 6 August 1987 to present the study
and the Proposed Remedial Action Plan and solicit public input.
The issues raised during the comment period are addressed in the
Responsiveness Summary, which is attached to this document.
DESCRIPTION OF REMEDIAL ALTERNATIVES
This section describes the remedial alternatives that were
identified and assembled using suitable technologies in order to. '-
meet the objectives of the National Oil and Hazardous Substances ;
Pollution Contingency Plan (NCP). These alternatives were >-
developed by screening a wide range of technologies for their
applicability to site-specific conditions and evaluating them for
effectiveness, implementability, and cost.
ALTERNATIVE 1: NO ACTION
The No Action alternative does not include any remedial action to
address the contaminants in the subsoil. However, it does include
groundwater monitoring to provide an early warning of any increase
in leaching of contaminants into the groundwater. It also includes
repairing the berra between the site and the Elizabeth River,
removing all debris remaining at the site, and sealing a sanitary
sewer line that leads from the site to the storm sewer line under
South Front Street.
All of the remaining remedial alternatives also include monitoring
the groundwater, repairing the berm, sealing the sanitary sewer
line connection, and removing the trash.
ALTERNATIVE 2: CONTAINMENT • .
This alternative includes construction of a groundwater barrier,
either a slurry wall or a sheet pile wall, and a multimedia cap.
The containment system would reduce the flow of water through the
site, thereby reducing the migration of contaminants from the
site. It would also offer some protection from the release of
contaminants that would occur if the contaminated soil were
exposed.
-------
-15-
ALTERNATIVE 3: IN-SITU SOIL WASHING
This alternative includes the construction of a groundwater
barrier and an active soil washing system. Groundwater would be
extracted through wells, treated using an air stripper and carbon
treatment system, and recirculated by spray irrigation (Figure 5).
A modified system, using a surfactant or solvent to expedite the
removal of contaminants from the soil, a treatment system appro-
priate for the additive used, and reinjection wells instead of
spray irrigation, was also developed as an option within this
alternative. The groundwater barrier is required to keep water
from the river and the aquifer surrounding the site from entering
the treatment system and to keep any additives used from leaving
the site. After the soil washing is completed, it would protect
the clean soil from being contaminated by the surrounding environ-
ment. The objective of this action is to remove the contaminants
from the soil, thereby eliminating the potential for futher leaching
of contaminants from the soil or exposure to contaminants from the
soil.
ALTERNATIVE 4: IN-SITU FIXATION
This alternative involves drilling through the gravel cover at
the site with an expandable bit drill rig (Figure 6). The con-
taminated soil zone is penetrated by the drill bit, which is then
expanded. The fixation chemicals are then injected into the
column of soil and mixed. A series of overlapping columns would
be formed converting all of the contaminated soil at the site
into a solid mass (Figure 7). This would inhibit water from
flowing through the site, thereby preventing the production of
leachate. In addition, some contaminants may be chemically
altered and incorporated in the the solid matrix formed by this
action, reducing the toxicity as well as the mobility of the
contaminants* The potential for exposing the contaminated soil
would be eliminated.
ALTERNATIVE 5: EXCAVATION AND OFF-SITE DISPOSAL
This alternative would involve digging up all of the contaminated
soil at the site and taking it to a hazardous waste landfill.
Although the contaminated soil would be entirely removed from the
site, it would merely be deposited in a secure landfill without
treatment. The production of leachate and the potential for
exposing contaminated soil at the site would be eliminated.
ALTERNATIVE 6: EXCAVATION, ON-SITE TREATMENT, AND
OFF-SITE DISPOSAL
This alternative would involve excavating the contaminated soil,
treating it on-site, and removing it for disposal off-site. The
soil may be treated by using solvent extraction (similar to in-situ
soil washing described under Alternative 3), fixation (similar to
in-situ fixation described in Alternative 4), or incineration.
-------
FIGURE 5
EQUIPMENT KEY
0 © LEAD/LAG GRANULAR ACTIVATED CARBON UMTS
0 AIR STOPPING COLUMN
-Kt— GATE VALVE (TYPICAL)
(7 PUMP(TYPICAL)
IRRIGATION SYSTEM
EX6TNG MONITORNG WELL'
(TYPICAL OF 6)
NEW EXTRACTION WELL
(TYPICAL OF 2)
SOUTH-FRONT-STREET
en
I
v_
BOLD LINE INDICATES GROUNDWATER CONTAINMENT
WALL (STEEL SHEET PILE OR SLURRY TRENCH)
LOIZEAUX READY-MIX PLANT
ALTERNATIVE N* 3:
GROUNDWATER EXTRACTION/SOIL FLUSHING SYSTEM
CHEMICAL CONTROL CORR SITE, ELIZABETH; MJ
SCALE-r=IOO'
-------
FIGURE 6
DELIVERY LINE FOR
SOLIDIFICATION MATERIAL
-WATER SWIVEL
DRILLING MACHINE
DELIVERY LINE FOR
DRILLING MUD
INJECTION PUMP r- FLOWMETER
A. .
*:•.:»•-.*::••.•.••
•>•;• ••'v.V'oV- '
m' • ... • • 0 '-
• •'••'•.;.'«; >'.'". '"'"'
COARSE GRAVEL
SPREADABLE WINGttft-
FILL MATERIAL TO BE SOLIDIFIED
CLAY LAYER
ALTERNATIVE NS 4
GENERAL ARRANGEMENT FOR "SWING" IN-glTUr SOLIDIFICATION METHOD
CHEMICAL CONTROL CORP. SITE. ELIZABETH. N J
-------
FIGURE 7
PHASE I
PHASE H
PHASES man
NEWLY INJECTED CYLINDER
NEWLY INJECTED CYLINDER
CONGEALED CYLINDER
PHASE HI CYLINDER
CONGEALED CYLINDER
00
I
PHASE JSL CYLINDER
ALTERNATIVE N« 4
LOGISTICS OF INJECTION PROCEDURE
CHEM8CAL CONTROL CORP S8TE. ELIZABETH. N J
-------
-19-
Under this alternative, the soil extraction and solidification
would be above ground and not in-situ as in Alternatives 3 and 4.
It is assumed that the treated soil would no longer qualify as a
hazardous waste (ie. it would pass a clean closure analysis)/ and
it could therefore be removed to a sanitary landfill for disposal.
This assumption would have to be confirmed during design.. This
alternative would satisfy the remedial objectives by removing and
treating the contaminants.
ALTERNATIVE 7: EXCAVATION, ON-SITE TREATMENT, AND
ON-SITE DISPOSAL
This alternative is identical to Alternative 6 except the treated
soil would be retained at the site for disposal. This alternative
was developed:in the FS assuming the treated soil could pass a
clean closure analysis and be returned to the excavation. If this
is not the case, the material would have to be taken to a hazardous
waste landfill at a much greater cost. Disposal of hazardous
waste at the site was not considered an acceptable alternative
because of its small size and its location in a flood plain.
ALTERNATIVE 8: EXCAVATION, OFF-SITE INCINERATION AND DISPOSAL
This alternative would involve excavating the contaminated soil
and removing it to an off-site facility for incineration and
disposal of the ash. The excavated material would be replaced
with clean fill. As in the Excavation with Off-site Disposal
Alternative, the remedial objectives would be satisfied by total
removal of the contaminants.
EVALUATION OF ALTERNATIVES
Pursuant to the Comprehensive Environmental Response, Compensation,
and Liability Act, as amended, the EPA must develop and evaluate a
range of remedial action alternatives for each site on the National
Priorities List. The six major criteria used are: degree of pro-
tection provided and relative reduction of mobility, toxicity, or
volume, of contaminated material (effectiveness), technical feasi-
bility, administrative feasibility, and availability of resources
and facilities for disposal or treatment (implementability), and
cost. These six factors are considered over both the short term
— i.e., through remedial construction and initial operations —
and the long term, which represents the final status of the site
when any operation and maintenance functions involved have ceased*
Table 2 indicates the various levels of evaluation criteria and
the interrelationships between them. The following text discusses
each alternative relative to the elements of these evaluation
criteria. Those elements not discussed in detail in the text are
either the same for all or most of the alternatives, or are con-
sidered to be adequate or at least comparable to similar aspects
of other options. The text focuses on the most significant
elements of each option. The capital and operation and maintenance
costs of all of the remedial alternatives are presented in Table 3.
-------
TABLE 2
EVALUATION FACTORS FOR REMEDY SELECTION
EFFECTIVET
Protect iveness
Reduction of
existing risks
.1 • i • i
Compliance with i
sane ARARs . i
Compliance with
some criteria j
advisories* and
guidances
Protection of
community and
workers during
remedial actions
Time until protec-
tion is achieved
Magnitude of
residual risk
'
Long-term
reliability
Compliance
with some
ARARs or TBCs
Likelihood
of future
exposure to
residuals
Potential need
for replacement
1ESS
Reduction of
Toxicity,
Mobility,
or Volume
Immediate or
short-term
reduction in ;
toxicity, |
mobility, or :
volume
•
Permanent and
significant
reduction in
toxicity,
mobility, or
volume
Technical
Feasibility
i
Ability to
construct
technology
Short-term
reliability
of technology
Compliance
with some
ARARs
(primarily
action-
specific)
Ease of
undertaking
additional
remedial
action, if
necessary
Ability to
monitor
effectiveness
of remedy
Ability to
perform
operation &
maintenance
functions '
IMPLEMENTABILITY
Administrative
Feasibility
Ability to obtain
approvals from other
agencies
Likelihood of
favorable, community
response
.
Need for coordination
with other agencies
Compliance with
some location-
specific ARARs
Relative demand on
available resources
within EPA
Availability
Availability of
treatment, storage,
and disposal ser-
vices and capacity
Availability of
necessary equipment
and specialists
»
'
COST
Capital and O&h
Development and
construction
costs
Operating costs
to implement
remedial action
Other capital
and short-term
costs required
to complete
remedial action
Operation and
maintenance
costs, for
as long as
necessary
Costs of 5-year
reviews
Potential
future remedial
action costs
-------
-21-
TABLE 3
CAPITAL AND ANNUAL OPERATION AND MAINTENANCE COSTS
Capital Cost Annual O&M Cost Present-Worth Cost
Alternative ($1000) ($1000) - ($IQQQ)
1. No Action 53.4 87.4 22.9 415
2. Containment 1,168 . 71.4 29.4 1,411
3. In-situ Soil
Washing 1,297 339.5 275.0 4,026
4. In-situ •
Fixation 7,208 57.4 22.4 7,425
5. Excavation
Off-site
Disposal 8,781 57.4 - 8,999;
6. Excavation b
& On-site Treatment
& Off-site Disposal -
a. Fixation 18,986 57.4 - 19,204
b. Soil Washing 27,349 57.4 - 27,567
c. Incineration 34,000 57.4 - 34,218
7. Excavation
& On-site Treatment
& On-site Disposal
a. Fixation 14,326 57.4 22.4 14,544
b. Soil Washing 14,311 57.4 22.4 14,528
c. Incineration 22,045 57.4 - 22,262
8. Excavation
Off-site
Incineration 34,931 57.4 - 35,149
The first figure given for Annual Operation and Maintenance (O&M)
cost represents the annual cost for each of the first five years
plus the cost of re-evaluating the site after five years as
required by the Superfund Amendments and Reauthorization Act.
The second figure in this column represents annual O&M cost for
years 6 through 30 including periodic monitoring and site
re-evaluations at five year intervals.
-------
-22-
Each alternative will be discussed with regard to two major
categories - effectiveness and impleraentability - from both
short- and long-term perspectives. The discussions of criteria
will follow the same order as that given in the tables. Those
included in every alternative discussion/ to ensure consistency
and minimize subjectivity.
ALTERNATIVE 1: NO ACTION
The No Action Alternative would leave approximately 18,000 cubic
yards of highly contaminated soil at the site without reducing
its mobility, toxicity, or volume. This soil would continue
to leach organic contaminants into the groundwater. In addition,
the risk assessment found that exposing the soil would present
significant health risks via dermal contact and inhalation of
contaminants that have volatilized or have adhered to fugitive
dust. Alternative 1 would not address the ongoing problem of
contaminant migration in the groundwater or the more significant
potential problem of exposure of the contaminated soils. It
would also allow a large volume of contaminated soil to remain at;
the site in violation of guideline concentrations under New fe
Jersey's Environmental Cleanup Responsibility Act (ECRA).
ALTERNATIVE 2: CONTAINMENT
Containment would also allow the contaminated soil to remain at
the site. However, migration of contaminants would be mitigated
by installing a groundwater barrier and a cap. This containment
system would offer increased protection over existing conditions.
It could be implemented using standard construction practices,
and because relatively small volumes of contaminated soil would
be exposed at any one time, it should be easy to protect against
releases during construction. A disadvantage to this alternative
is that the combination of highly contaminated soil and saline,
tidally influenced groundwater may weaken the wall and, in time,
it may need to be replaced. The containment system would offer
effective protection if institutional controls were imposed to
prohibit any future digging at the site.
ALTERNATIVE 3* IN-SITU SOIL WASHING
In-situ Soil Washing is intended to remove the bulk of the contam-
inants from the site, thereby eliminating the threat of exposure
of highly contaminated soil or migration of contaminants. However,
the contaminants are tightly bound to the soil, so flushing with
groundwater alone would take a very long time to achieve its goal
and may still leave a concentrated residue of contaminants in the
soil. Surfactants or solvents could be recirculated through the
site to expedite the removal of contaminants, but the use of such
chemicals would increase the cost of the alternative. The use of
these additives would also increase the danger of contaminants
escaping the temporary containment system because the mobility of
-------
-23-
the contaminants must be increased to remove them by soil washing.
A treatability study would be needed during design to determine
the best method and additives for soil washing.
The containment, groundwater extraction, and treatment systems
should be relatively easy to construct. Monitoring wells, which
were installed during the RI, may be used as extraction wells.
Additional extraction wells that may be needed will be shallow
and should be easily installed. The water treatment system is a
standard package plant that is generally available. Disposal or
regeneration of spent carbon from the water treatment system is
part of the operation cost of this alternative. If chemical
additives are used to facilitate soil washing, injection wells and
a more sophisticated treatment plant would be required. At the
end of the soil washing phase, the containment system will need
to be maintained to protect against the release of any residual
contaminants or the recontamination of the site from surrounding
groundwater or surface water.
Although the ultimate goal of this alternative is to reduce the
risk at the site by removing contaminants, the mobility of the
contaminants (and therefore the potential for contaminant releaseX.
must be increased during the operation phase of this alternative
to achieve this goal. Protection against flooding during the
years that the system would be operated must be a top priority.
Flooding happens occasionally at the site now and must be prevented
during the remedial action to avoid releases of contaminated
material and damage to equipment. In-situ operations are generally
less susceptible to damage by flooding than excavation, because
it is not necessary to expose a large area of contaminated soil.
However, since this alternative would take many years to complete,
the likelihood of a flood occurring during remediation is higher.
ALTERNATIVE 4: IN-SITU FIXATION
In-situ Fixation is intended to eliminate the potential for exposing
the contaminated soil and to reduce the leaching of contaminants.
This would be accomplished by solidifying the contaminated soil.
The permeability of the soil would be significantly reduced by
the solidification process, which would virtually eliminate the
infiltration of surface water and the flow of groundwater through
.the site* The mobility of the contaminants would be significantly
reduced, since the groundwater cannot be contaminated if it does
not come into contact with the waste. The leaching of contaminants
may also be reduced by a reaction of the fixation chemicals with
the contaminants, which would chemically bind some contaminants
to the solid matrix making them resistant to leaching even in a
very harsh chemical environment. The toxicity'of other contaminants
may also be reduced by this chemical reaction.
As with all of the alternatives that involve treatment, a treata-
bility study would be required during the design of the remedial
action, to determine the most cost-effective fixation process.
-------
-24-
Aithougn in-situ fixation is not yet a standard construction prac-
tice, several vendors are available that provide this service.
Chemical fixation has been used extensively to treat industrial
wastes/ and the in-situ process described in this document is
currently being studied for use at other hazardous waste sites.
The danger of exposure to or a release of hazardous substances is
especially low for this alternative because it is performed using
in-situ operations and the time to implement it is relatively
short. The long-term reliability of this alternative is especially
promising. Unlike the containment system in Alternative 2, which
would encase contaminated material in an impermeable skin (cap and
wall)/ the entire site would be converted into a solid mass. This
alternative would also incorporate the contaminants into the con-
tainment structure rather than simply enclosing the waste. There-
fore/ the likelihood of contaminants escaping the system or new
contaminants entering the system would be virtually eliminated.
The solid form of the fixated soil would also resist water infil-
tration/ which could reintroduce contaminants to the site in those
alternatives where the soil is cleaned but not contained.
ALTERNATIVE 5: EXCAVATION AND OFF-SITE DISPOSAL
Excavation and Off-site Disposal would remove all of the contami-
nated soil from the site. From the perspective of the site itself-/
this alternative provides significant and immediate risk reduction
since all of the contaminated material would be removed. However/
off-site disposal of contaminated material from a Superfund site
without treatment is described in the Comprehensive Environmental
Response/ Compensation/ and Liability Act/ as amended/ as "the least
favored alternative remedial action where practicable treatment
technologies are available." Excavating contaminated soils and trans-
porting them to a landfill without reducing the mobility/ toxicity/
or volume of the material merely transports the public health and
environmental problems to another location. A disadvantage to
creating a pristine site at Chemical Control is that it may become
recontaminated by the area surrounding it.
Excavation at this site would be complicated by several physical
conditions. Special construction practices would have to be
employed because of the high water table/ the proximity of the
river/ and the tidal action. Special precautions would also be
required because the site is in a flood plain.
The small size of the site (2.2 acres) also presents a problem of
working within a small area. Because the site is surrounded by
active industrial properties and the Elizabeth River/ equipment
for the implementation of the remedy must be confined to the
site or operated from barges adjacent to the site. As a result/
small areas of the site will have to be excavated while the rest
of the property is used to house equipment/ a loading area for
trucks to remove the contaminated material/ and a decontamination
zone.
-------
-25-
Excavating many small cells would leave more room at the site for
other equipment and make it easier to prevent contaminant releases
during excavation. However, it would increase the time and cost
of the alternative.
Another short-term hazard posed by this alternative is the incon-
venience and danger from the increased volume of heavy truck
traffic. South Front Street already accommodates a very heavy
volume of truck traffic .during business hours. The additional
traffic may require special traffic controls. Fortunately/ the
site is very close to several major transportation routes/
including interstate highways/ which would reduce the need to use
local roads and would facilitate the action.
ALTERNATIVE 61 EXCAVATION, ON-SITE TREATMENT, AND
OFF-SITE DISPOSAL
Excavation/ On-site Treatment/ and Off-site Disposal would also
remove all of the contaminants from the site thereby eliminating
the hazards at the site. The same short-term hazards posed by
Alternative 5 would also apply to this alternative. The
logistics problem is even worse for this alternative/ because a
treatment system would also be needed at the site.
The advantage of this alternative over Alternative 5 is that the
soil would be treated before it was removed from the site. The
cost developed in the FS for this alternative assumed that the
treated soil would not require disposal as a hazardous waste. If
the treated soil cannot be delisted as a hazardous waste/ it will
have to be removed to a hazardous waste facility at a much greater
cost. A treatability study would be required during design to
help define the cost-effective treatment process and the nature
of the treated waste*
ALTERNATIVE 7: EXCAVATION, ON-SITE TREATMENT AND DISPOSAL
Excavation/ On-site Treatment and Disposal would achieve a
level of protection and risk reduction similar to the in-situ
treatment alternatives presented above. Two of the treatment
options incorporate the same technologies as the in-situ treatment
alternatives: soil washing and fixation. The advantage of
excavating the material before treating 'it is that treatment
above ground can be directly observed and the treated soil can be
analyzed before returning it to the site. The third treatment
option, incineration/ is not possible for an in-situ operation.
It achieves nearly total destruction of the organic contaminants/
but metals would remain in the soil. The short-terra hazards
associated with this alternative are similar to those for other
excavation alternatives. Soil that has been treated using soil
washing or incineration may become recontaminated by the surrounding
environment since it would be returned to the site.
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The logistics problem associated with this alternative is similar
to that for Alternative 6. Although a loading zone will not be
required since treated soil will not be removed from the site,
contaminated soil would have to be stored in one area before
treatment and treated soil would have to be stored in a separate
area awaiting testing and replacement in the excavation pit.
The logistics problem may be solved by excavating small cells,
although this would increase the cost and time to implement this
alternative. The cost of this alternative is lower than the
cost of Alternative 6, reflecting the savings from not having
having to transport the 18,000 cubic yards of material, but
higher than the cost of similar in-situ treatment.
ALTERNATIVE 8: EXCAVATION, OFF-SITE INCINERATION AND DISPOSAL
Excavation, Off-site Incineration and Disposal would remove all
of the contaminated soil from the site. Unlike Alternative 5,
discussed previously, the excavated soil would be incinerated to
destroy organic contaminants before landfilling. This is the
most expensive alternative and does not offer a significantly
greater level of protection than any of the other treatment
alternatives.
The short-term hazard pf release of contaminants and the logistics-
problems are the same for this alternative as for the Excavation
with Off-site Disposal - Alternative 5. As with Alternative 7,
it is possible that clean soil used to fill the site may be recon-
taminated by the surroundings if a containment system is not in-
stalled.
SELECTED REMEDY
After review and evaluation of the remedial alternatives presented
in the FS, the EPA presented the In-situ Fixation Alternative
(Alternative No. 4) to the public as the preferred final remedy
for the site. Based on the input received during the public
comment period, this alternative has been selected by the EPA and
the NJDEP as the final permanent solution for the site.
This alternative involves treating the approximately 18,000 cubic
yards of contaminated soil with fixation chemicals that will
create a solid matrix that will have extremely low permeability.
One method for accomplishing this is to drill through the gravel
and into the contaminated soil with an expandable bit drill rig.
The bit is expanded in the contaminated soil zone and the soils
are mixed while fixation chemicals are delivered. This process
is illustrated in Figure 6. All of the contaminated soil at the
site will be converted into a series of overlapping columns of
treated soil. The stratum of contaminated soil is approximately
ten feet thick and extends from the bottom of the gravel layer,
approximately three feet below grade, to the top of the clay
layer.
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The remedy also includes repairing the berm that separates the
site from the Elizabeth River/ removing debris remaining from
previous response activities, and sealing the sanitary sewer line
under the site where it connects with the South Front Street
storm sewer. In addition, environmental samples will be collected
to monitor the effectiveness of the remedy.
Performance Goals
The major threat to public health- and the environment is from
potential contact with exposed contaminated soil and potential
migration of contaminants from the site into the Elizabeth River.
In-situ Fixation, as a source control measure, would incorporate
all of the contaminants in a solid matrix that would significantly
reduce, if not eliminate, the mobility of the contaminants and the
risk of contact with contaminants in the soil. In addition, some
contaminants may be bound to this solid matrix such that leachate
production would be virtually, if not totally, eliminated.
The contaminants found in the Elizabeth River sediments indicate •
that while the Chemical Control site may have been a past contribur
tor to this contamination, other major sources still exist. Until
these sources are identified and subsequently mitigated, remediation
of the river sediments is premature. Similarly, the contaminants
found in the surface water indicate that leachate from the Chemical
Control site has an undetectable influence and that other, active
sources exist. Therefore, remediation of the surface water is
also premature. Before remediation of the Elizabeth River could be
effective, an overall management scheme of these sources would have
to be implemented.
The recommended alternative would treat all of the 18,000 cubic
yards of contaminated soil at the site using in-situ fixation.
The implementation should take approximately 10 to 12 months and
should begin approximately 18 to 20 months after the signing of
this Record of Decision. The remedial design, which should take
12 to 18 months to complete, will begin as soon as possible after
the Record of Decision is signed. However, it is anticipated
that negotiations with potentially responsible parties for assump-
tion of responsibility for the remedial design and action may delay
the initiation of the design by as much as four months.
Protectiveness
The short- and long-term protectiveness of all of the remedial
alternatives were compared using the evaluation factors provided
in the first column of Table 2. This remedy does not introduce
any significant health or environmental risks during implementation
(short-term protectiveness factors) and offers a level of long-
term protection comparable to or exceeding that of any of the
other alternatives. The short-term risks are reduced by utilizing
in-situ operations that will not expose the contaminated soil. In
comparison -to In-situ Soil Washing, this remedy will be completed
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relatively quickly so full protection will be achieved quickly,
and extended operations at the site will not be necessary.
No Applicable or Relevant and Appropriate Requirements (ARARs) are
currently being violated at the site. The following section
examines ARARs in more detail. The On-site Treatment alternatives
and the In-situ Soil Washing alternative might temporarily violate
Executive Order 11988 on Management of Floodplains by requiring
the construction of a treatment system in a floodplain. The In-
situ Fixation alternative will involve a relatively quick on-site
operation, which because it is implemented primarily below ground,
offers protection against releases during a flood.
The In-situ Fixation alternative should provide durable, effective
protection from contaminant release. Although such an application
of this technology is fairly new, promising results have been
obtained in laboratory tests, and it is being tested at other
hazardous waste sites and evaluated under the Superfund Innovative
Technology Evaluation program. The Chemical Control project will
benefit from the experience gained at these sites.
Consistency with Other Laws
The Solid Waste Disposal Act, otherwise known as the Resource
Conservation and Recovery Act (RCRA), as amended, is the federal
legislation regulating hazardous waste that is generally the most
significant ARAR for Superfund actions. The soil at the Chemical
Control site was contaminated during the operation of the site in
the 1970's and during the fire in 1980. The RCRA does not apply
to the site because it did not operate under a permit issued
pursuant to this act: industrial activities ended at the site
before 1982 when the EPA began issuing such permits.
The selected remedy was evaluated for compliance with the RCRA as
a relevant and appropriate requirement by considering a hypothetical
site similar to Chemical Control except that it operated under a
permit. In this case, the selected remedy could be considered a
corrective action at a solid waste management unit. The EPA would
approve the use of in-situ fixation subject to ultimate confirmation
of the effectiveness of the action. The monitoring program that
is part of this remedy will satisfy the confirmation requirement.
The RI and FS reports and the Proposed Remedial Action Plan were
supplied to the Department of Interior (DOI) and the Department
of Commerce (DOC) as Natural Resource trustees. The DOC has
concurred with the EPA's preferred alternative, while the DOI did
not comment. The Agency for Toxic Substances and Disease Registry
performed a health assessment for the site that concurred that
the selected remedy offers adequate protection of public health.
this project was reviewed for concurrence with federal and state
environmental requirements. The selected remedy complies with
these requirements, including the floodplains executive order and
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the discharge limits allowed by federal and state permits for
surface water protection. Two federal statutes that were recog-
nized as ARARs of particular concern for the remedial action at
this site are the Endangered Species Act and the National Historic
Preservation Act. The surface water near the site is within the
breeding range of the short-nose sturgeon, a federal endangered
species. However, it is unlikely that this species will be found
in the vicinity of the site because of the disturbed condition
of the rivers in this area. Therefore, the proposed action should
not have a detrimental impact on this species. The EPA will confirm
this through informal contact with the appropriate federal wildlife
management agency. It also appears that the selected remedy will
have no effect on any cultural resources on or eligible for
nomination to the National Register of Historic Places.
The NJDEP has concurred with the selected remedy and has notified
the EPA that State ARARs will be satisfied by performing a bioassay,
for which plans are now being approved. The NJDEP has also indi-
cated that contaminant concentrations in the soil at Chemical
Control exceed State guidelines. Therefore, the No-Action alter-
native would not be acceptable. The selected remedy addresses
this contamination.
Cost-effectiveness and Utilization of Permanent Solutions and
Alternative Treatment Technologies
The selected remedy satisfies the preference in CERCLA for a
permanent solution with treatment as a principal element. It
also utilizes an alternative treatment technology that offers a
more cost-effective remedy.
The contaminated soil at Chemical Control is responsible for the
hazards posed by the site. The volume of this material is fairly
small and the contamination is distributed over the entire site.
Therefore, all of the alternatives addressed all of the contaminated
soil at the site.
The Inrsitu Fixation alternative is the least expensive alternative
that will quickly mitigate the hazards posed by the contaminated
soils. It introduces fewer hazards during implementation than
any of the other alternatives except the cap and groundwater
barrier containment alternative, and it will prevent contamination
from entering or leaving the site. Although treatment above
ground can be directly observed and controlled, available infor-
mation indicates that the in-situ operation offers a comparable
level of long-term protection with less short-term risk and at a
significantly lower cost. A treatability study and field test
will be required during design to prove the technology, but such
tests would be required for all treatment alternatives and the
EPA is already testing this technology at other hazardous waste
sites. Several companies offering chemical fixation have been
identified. Therfore, the technology and equipment for this
alternative should be available.
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ATTACHMENT I
CHEMICAL CONTROL CORPORATION SITE
ELIZABETH, NEW JERSEY
RESPONSIVENESS SUMMARY
The U.S. Environmental Protection Agency (EPA) held a public comment
period from July 6, 1987 through August 14, 1987 for interested citizens to
comment on EPA's final Feasibility Study (FS) and proposed remedial action
plan (PRAP) for the Chemical Control Corporation site. In addition, the EPA
also held a public meeting on August 6, 1987 at the Elizabeth City Hall, to
present the proposed remedial alternatives and preferred remedial action for
the site.
This responsiveness summary provides a summary of citizens' comments and
concerns about the Chemical Control Corporation site raised during the public-
comment period and the EPA's responses to those concerns. The comments i
addressed in this document will be factored into the EPA's final decision for:
addressing contamination at the site.
This responsiveness summary is divided into the following sections:
I. Background on Community Involvement and Concerns.
This section provides a brief history of community
involvement and concerns regarding the Chemical
Control Corporation site.
II. Summary of Major Questions and Comments Received
During the Public Meeting and EPA's Responses to
these Comments. This section summarizes comments
presented to EPA at the public meeting and provides
EPA's responses to these comments.
III. Written Correspondence Received During the Public
Comment Period and EPA's Responses.This section
summarizes written comments received by EPA during
the Public Comment Period and provides EPA's
responses to these comments.
I. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
The Chemical Control Corporation site is a former waste processing
facility which, in the 1970s, accepted various wastes for disposal or recovery
by neutralization, chemical treatment, or incineration. These wastes included
acids, bases, arsenic compounds, cyanide compounds, flammable solvents,
compressed gases, biological agents, explosive chemicals, pyrophoric
(spontaneously igniting) materials, radioactive wastes, and pesticides.
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Operations at the facility through the 1970s were frequently hampered by
operating and mechanical problems, particularly with the incinerator. In
addition, in January 1977, the Elizabeth, New Jersey police discovered that a
truck owned by Chemical Control Corporation was discharging waste solvents
onto the ground adjacent to the Elizabeth River. This was the first
documented illegal action by Chemical Control Corporation and resulted in th|s
owner of the facility being fined and sent to prison.
Starting in 1977, citizens and local officials complained on numerous
occasions of bad odors from the site and observations of discharges to the
ground and the nearby Elizabeth River. The Chemical Control Corporation
facility was cited by the New Jersey Department of Environmental Protection
(NJDEP) for violation of environmental regulations.
Community concern continued to increase until 1979 when the site was
closed and placed in operational receivership. In March 1979, NJDEP developed
a cleanup plan for the site. In April 1980, in the process of implementing
the cleanup plan, a fire broke out at the site. Numerous investigations by
local, State and Federal agencies were conducted during and after the fire in
attempts to discover whether or not the fire was the result of arson. To
date, the cause of the fire which resulted in a cloud of toxic gases, is
unknown. At the time of the fire, community concern was high. Specifically,
concerns focused on potential health risks to residents and fire fighting
personnel from the toxic gases; potential environmental degradation to the
site and the nearby Elizabeth River; and anger at the perceived improper
behavior of the potentially responsible party. Closure of the facility and
cleanup activity to date have alleviated much of the community concern.
In November 1986, the EPA began a remedial investigation and feasibility
study (RI/FS) at the Chemical Control Corporation site. Citizen concern had
leveled off substantially by this time and remained low throughout the RI/FS.
At the time of the public comment period, concern appeared to be highest
among local officials and the media. The August 6 public meeting attracted
more attention from the local news media than from the public. The main
concern of local officials is that a thorough, permanent remedy be
expeditously implemented.
II. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED
DURING THE PUBLIC MEETING AND EPA RESPONSES TO
THESE QUESTIONS
This section summarizes the comments made during the public meeting on the
draft Feasibility Study. EPA responses to the comments are also provided
below.
1. • Comment; A city health official speaking on behalf of the City of
Elizabeth stated that the administration supported combining
alternative four and alternative seven. As a pharmacologist and a
chemist, the individual expressed concern that because of the exotic
nature of the chemicals involved, he could not be sure that the
solidification fixation method would be sufficient. This official
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recomoiended using both alternative four (In-Situ Fixation/
Soldification) and alternative seven (Excavation, Treatment and
On-Sit* Disposal) so that if some contaminated material is missed
during excavation, the solidification would take care of it. The
official also was concerned that utility conduits not be placed in
the area because PCB oil base material can wear through any kind of
conduit. He also was concerned that EPA seemed mainly interested in
treating the organics because, in his opinion, there also-existed a
high number of inorganics (i.e., heavy metals). He approved of the
Agency concern that the treatment should be compatible with future
use of the land. He felt strongly that the site should not be used
for any kind of construction .that would require digging and footings.
EPA Response; The EPA will take these comments into consideration as
it makes the decision on the remedial alternative to be implemented
at the Chemical Control site. The EPA followed up on the response
with a letter to the City of Elizabeth. This letter is attached.
2. Comment; A representative of the National Oceanic Atmospheric
Administration (NOAA), which is the natural resources trustee for
coastal resources, stated that NOAA concurred with EPA on fixation
and not excavation due to the risks that might be involved in the
exposure of chemicals in the ground. The exposure during the
excavation could lead to extended release into ground water.
EPA Response; None.
3. Comment; A resident commented that regulating hazardous waste
handling and disposal would more efficiently address hazardous waste
releases than cleanup after the fact. He also commented on the
fixation method, expressing concern that at some point in the future
the fixing agents would react with some of the contaminants, thus
requiring complete removal of the contaminated soil. He suggested
mixing the radon contaminated soil in Montelair, N.J. with the
contaminated substance at Chemical Control, with the idea that they
would neutralize each other.
*
EPA Response; The State and Federal regulations now in place are
intended to prevent future problems like the Chemical Control site
from occurring. Mixing the soils from the two sites would not
effectively solve the problems at either site. The contaminated soil
in Montclair contains radioactive radium that will continue to decay,
producing radon gas, for many years and would not be rendered less
hazardous by mixing it with the chemically contaminated soil from
Chemical Control. The hazards associated with the chemical
contaminants in the Chemical Control soil would not be mitigated by
mixing the soil with the Montclair soil. The remedial action
proposed for the Chemical Control site should effectively address the
hazards currently posed by the site.
[The second comment raised by this individual was not addressed at
the public meeting but was considered in preparing the Record of
Decision. The In-situ Fixation remedial Alternative should effec-
tively immobilize the contaminants at the site and should prevent any
disturbance of the soil (such as digging). Before the remedy is
implemented, a treatability study will be performed to ensure that
fixation will form a stable matrix.]
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UNI ftD STA f £S CNVIRONMEN f AL PROTECTION AGENCY
REGION II
26 FEDERAL PLAZA "
NEW YORK. NEW YORK 10278
August 31, 1987
Mr. John Surmay, Director
Department of Health, Welfare & Housing
Elizabeth City Hall
50-60 Winfield Scott Plaza
Elizabeth, New Jersey 07201
Dear Mr. Surmay:
I am writing in regard to your comments which were provided
to the Environmental Protection Agency (EPA) during our recent
public meeting to discuss the results of the feasibility
study for the Chemical Control Superfund site.
At the public meeting,on August 4, 1987, you expressed a
preferrence, on behalf of the city administration, for a
combination of two of the remedial alternatives developed in
the feasibility study for this site. You recommended that we
implement excavation with on-site soil washing followed by
in-situ fixation/solidification of the treated soil. The
EPA has given your comments careful consideration in developing
the Record of Decision (ROD) for Chemical Control. The ROD
which should be signed by the Regional Administrator, Christopher
Daggett, in September will identify the selected remedial
action. As Eric Schwarz of my staff, indicated to you on
August 21, we feel that in-situ fixation will protect public
health and the environment from any hazards posed by the site
and, therefore, will recommend that Mr. Daggett select this
alternative. The rationale for our action is described
below.
The three treatment technologies that were considered for the
on-site treatment alternatives - soil washing, fixation/solidi-
fication, and incineration - should all treat the soil to such
a degree that it could be delisted as a hazardous waste under
Federal regulations. We would, in fact, be required to prove
that the treated soil was no longer hazardous, by testing it as
specified in federal regulations, before we could return it to
the site. Since the treated soil that would be returned to the
site under the Excavation and On-site Treatment and Disposal
alternative would not be hazardous, the use of in-situ fixation/
solidification on this soil would not be warranted.
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We have, however, considered the relative merits of excavation
with on-site treatment as compared to in-situ treatment such
as in-situ fixation. Treatment above ground can be directly
observed and controlled whereas in-situ treatment cannot.
However, available information indicates that in-situ fixation/
solidification should provide adequate mixing of the contaminated
soil with the fixation chemicals to create a uniform, concrete-
like block with very low permeability and may chemically bind
the contaminants to the solidified mass. Chemical fixation has
been used extensively to demobilize highly concentrated hazardous
wastes, and the EPA is currently testing the system that is
described in the Chemical Control feasibility study report at
another hazardous waste site.
Using an in-situ remedial action at the site will also help
avoid some problems that could arise during the implementation
of an excavation alternative. As you pointed out at the public
meeting, protective construction practices could be used to
lessen the risk of releasing contaminants during excavation.
However, especially in light of the history of flooding at the
site, there would still be some risk of a release of contaminated
soil if the site was excavated. The small size of the site
would also complicate excavation. To excavate and treat contami-
nated soil at the site, we may need to use barges in the Elizabeth
River to accomodate some of the equipment and the site may require
excavation in many small cells.
All of the alternatives mentioned above involve treating the
contaminated soil and, therefore, would require a treatability
study during the design phase to determine the most cost-effective
means of implementing the remedy. The design of the in-situ
fixation remedial action will most likely involve a two-phase
treatability study: a laboratory-scale study would combine
soil samples from the site with fixing agents to determine the
most effective agent and the degree of fixation obtained, and a
pilot-scale, on-site test of the injection/delivery equipment
would determine, in actual field conditions, the effectiveness
of the in-situ operation. We welcome your comments on the
planning and evaluation of these tests and intend to keep you
apprised of our progress during the design of this action. In
the event that these tests show that in-situ fixation would
fail to offer protection of public health and the environment,
the ROD would be amended as necessary.
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I hope this letter addresses your comments to your satisfaction.
If you have any additional comments or questions, please call me
at (212) 264-1870.
Sincerely yours,
John S. Frisco, Chief
New Jersey Remedial Action Branch
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I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
f REGION II
26 FEDERAL PLAZA '
NEW YORK. NEW YORK 10278
AUG I 8 1987
Ms. Stephanie Hogan
1042 Battle Hill Terrace
Union, New Jersey 07083
Dear Ms. Hogan:
Thank you for your letter concerning the Chemical Control
Corporation Superfund site. I would like to correct some misim-
pressions that must have been created by newspaper articles based
on the Environmental Protection Agency's (EPA's) press release.
Hopefully, I can also reassure you that the New Jersey Department
of Environmental Protection (NJDEP) and the EPA have already taken
steps to control the pollution at the site and limit the potential
risk from it. We are currently working to select a final remedy
to address the remaining hazards posed by the site.
The federal government was given the power to respond to releases
at uncontrolled hazardous waste sites by the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980,
commonly called Superfund. The Chemical Control site was included
in the first list of Superfund sites. Even before it was added
to this list, the State of New Jersey acted to close the facility
and begin cleaning it up under New Jersey laws. The NJDEP removed
tens of thousands of drums of hazardous wastes, several tons of
bulk hazardous liquids and solids, the remains of a large building,
and several large storage tanks from the site. The State also
removed the most contaminated soil (to a depth of three feet),
covered the site with gravel, enclosed it with a security fence,
and treated contaminated ground water. The objective of the
State's actions was to stabilize the site and address all of the
imminent hazards. As a result of this action, which was completed
in July 1981, the immediate hazards of direct contact with the
waste and the release of hazardous materials to the air were
eliminated.
The EPA has also completed several actions at the site pursuant
to.:'«L.coatract with the State. Contaminated sand was removed from
the storm sewer system near the site and this system was repaired.
The EPA also removed drums, pails, and other containers from the
Elizabeth River near the site and removed eleven contaminated
trailers and a vacuum truck from the site.
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The public meeting that was recently held at Elizabeth City
Hall was called to discuss the findings of a study conducted by
the EPA to determine the extent of contamination remaining at
the site. The findings of this study are described in detail
in reports that are available at Elizabeth City Hall. Briefly,
a layer of contaminated soil was found below the gravel cover
at the site. Although the soil is highly contaminated, the con-
taminants are adhering to the soil and very little contamination
is entering the groundwater or the surface water. Also/ all of
the surface water and groundwater affected by the site is
saline and therefore not used as a supply of drinking water.
'The principal danger at the site is that natural forces or man
could expose the contaminated soil. Accordingly, the EPA
intends to implement a remedial action that will reduce or
eliminate the possibility of exposing the contaminated soil at
the site and will also reduce any leaching still further. The
EPA is now considering comments that were received during the
public comment period, and a Record of Decision that will
select the final remedy is expected later this summer.
I hope this letter has satisfied your concerns about the Chemical
Control site. More information is available in the reports
kept at Elizabeth City Hall. If you have any questions, please
do not hesitate to writer to me or call me at (212) 264-1252.
Sincerely yours,
Eric J( Schwarz, PYoject Manager
Northern New Jersey Remedial Action Section
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3 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
_ REGION II
2S FEDERAL PLAZA ~
NEW YORK. NEW YORK 10278
SEP j 4 1987
Mr. George E. Miller
P.O. Box 0224
Elizabeth, New Jersey 07206-0224
Dear Mr. Miller:
Thank you for your letter of August 12, 1987 concerning the
Chemical Control Corporation Superfund site. In your letter;
you concurred with the Environmental Protection Agency's
preferred alternative (Alternative 4 - In-situ Fixation) for :
site closure. You also asked several questions about future '
activities at the site. •-
The Environmental Protection Agency (EPA) will formally select
a remedy for the soil contamination at the site later this
month. The rationale for selecting the remedy will be described
in a Record of Decision, which will be available at Elizabeth
City Hall by early October. The Record of Decision will reflect
comments the EPA received during the public comment period.
The next phase of the remedial action is to design the remedy.
Plans and specifications will be developed so that contractors
to implement the remedy will be able to bid on the job. The
design will also include a treatability study to determine
standards for the effectiveness of in-situ fixation.
Before the EPA begins a remedial action at any Superfund site,
a contingency plan for that site is prepared. This plan
identifies any emergency services that may be required during
the implementation of the remedial action. It also establishes
contacts within each organization that may be involved and
defines procedures to be followed for all foreseeable emergencies.
A contingency plan will be developed for Chemical Control before
begining the remedial action.
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I am afraid that we will not be able to allow you to have access
to the site during the remedial action as you requested. Every
effort is made to minimize the number of people present at the
site during a response action to minimize the potential for
exposing people to hazardous chemicals. We cannot grant access
to any people who are not directly involved in the field work
in. progress. However/ the small size of the Chemical Control
Corporation site will make it possible to view most of the
operations from South Front Street.
If you have any additional questions about the Chemical Control
site, please do not hesitate to contact me.
Sincerely yours,
Eric J(J Schwarz, /project Manager
Northern New Jersey Remedial Action Section
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