United States
           Environmental Protection
           Agency
             Office of
             Emergency and
             Remedial Response
EPA/ROD/R02-88/065
September 1988
SEP A
Superfund
Record  of  Decision
           Asbestos Dump,  NJ

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30272-10L
 REPORT DOCUMENTATION
        PAGE
                   1. REPORT NO.
                           EPA/ROD/RO2-88/065
                                                       2.
                                                                        3. Recipient's Accession No.
4. Title and Subtitle
 SUPERFUND RECORD OF  DECISION
 Asbestos  Dump, NJ
  fetst  Remedial Action
                                                                   5. Report Oite
                                                                       09/30/88
 7. Author(s)
                                                                   8. Performing Organization R'ept. No.
 9. Performing Organization Name and Address
                                                                   10. Protect/Task/Work Unit No.
                                                                        11. Contract(C) or Grant(G) No.

                                                                        (C)

                                                                        (G)
 12. Sponsoring Organization Name and Address
 U.S.  Environmental  Protection  Agency
 401 M Street, s.W.
 Washington, D.C.  20460
                                                                   13. Type of Report & Period Covered

                                                                       800/000
                                                                        14.
 15. Supplementary Notes
 16. Abstract (Limit: 200 words)
    The Asbestos  Dump site is  an  11-acre commercial property, formerly an asbestos
 processing plant,  in Millington,  New Jersey.   It is bounded by the  Passaic River,  the
 Millington Train Station, commercial properties, and private residences.  Part of  the
 site  lies within the flood plain  of the Passaic River which serves  as a public water
 supply source for  74,000 people.   Approximately 200 individuals are employed by  21
  usinesses operating on the active portion  of the site."  Asbestos,  Limited engaged in
     fiberization and sale of  asbestos at  the  site from  1927 until 1946.  From 1946 until
        the plant  was owned by  Bernard E. Smith and operated under the name of Smith
 Asbestos, Inc.,  a  manufacturer "of asbestos  roofing and  siding.  During these years waste
 water  from the manufacturing  process was  impounded on the site to permit settling  of
 asbestos fibers  suspended in  the  water.   Periodically,  the sediment was removed,
 disposed of onsite and covered with dirt,   in May 1953,  the property was acquired  by
 National Gypsum,  which manufactured cement  asbestos siding and roofing sheets at the
 plant  until 1975.   Most of the waste was  recaptured and  recycled during this period,
 although broken  siding and asbestos fibers  were dumped  on a five-acre area on the
 property.  From  1959 until 1972,  National Gypsum used phenylmercuric acetate (PMA) as a
 fungicide to coat  the asbestos shingles.  Waste generated by the cleaning of coating
 (See  Attached Sheet)
 17. Document Analysis a. Descriptors
 Record of Decision
 Asbestos Dump, NJ
 First  Remedial Action
 Contaminated Media:   air, soil,  gw
 Key  Contaminants:   asbestos
   b. Identifiers/Open-Ended Terms
   c. COSATI Field/Group
inability Statement
                                                         19. Security Class (This Report)
                                                              None
                                                         2O. Security Class (This Page)
                                                           .   None
21. No. of Pages
      32
                                                                                   22. Price
(See ANSI-Z39.18)
                                         See Instructions on Reverse
                                                                             OPTIONAL FORM 272 (4-77)
                                                                             (Formerly NTIS-35)
                                                                             Department of Commerce

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^PA/ROD/R02-88/065
^^sbestos Dump, NJ
  First Remedial Action

  16.  ABSTRACT  (continued)

  equipment was  disposed of in small pits onsite.  In May 1975, National Gypsum closed the
  Millington plant.  The total asbestos waste at the site is estimated to be 90,000 cubic
  yards.   The primary contaminant of concern affecting ground water and soil is asbestos.

    The  selected  remedial action for this site includes:  installation of a two-foot soil
  cover on areas of exposed or minimally covered asbestos, construction of slope
  protection/stabilization measures along the asbestos mound embankment, and surface
  run-off diversion channels on  top of asbestos mound; long-term monitoring including
  offsite ground water monitoring; access restrictions; institutional controls to restrict
  onsite  ground  water use and limit development on the asbestos fill area; and performance
  of treatability  studies to evaluate technologies that may permanently remediate
  asbestos.  The estimated present worth cost for this remedial action is $1,145,000 with
  annual  O&M of  $56,000 to $161,000.

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              DECLARATION FOR RECORD OF DECISION
SITE NAME AND LOCATION

Asbestos Dump - Millington Site
Millington, New Jersey

STATEMENT_OF BASIS AND PURPOSE

This decision document presents the selected remedial action
for the Asbestos Dump - Millington Site in Millington, New
Jersey, developed in accordance with the Comprehensive Environ-
mental Response, Compensation and Liability Act (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act
(SARA), and, to the extent practicable, the National Contingency
Plan.  This decision is based on the administrative record for
the site.  The attached index identities the items which comprise
the administrative record upon which the selection of the remedial
action is based.

The State of New Jersey has concurred on the selected remedy.

DESCRIPTION OF THE SELECTED REMEDY

The Asbestos Dump - Millington Site operable unit approach
was developed to protect public health and the environment by
containing the migration of asbestos and other contaminants
presently at the site.

The major components of the selected remedy are as follows:

    0  installation of a two-foot soil cover on areas
       of exposed or minimally covered asbestos,

    0  installation of a chain-link security fence to restrict
       access to the asbestos mound;

    0  construction of slope protection/stabilization measures
       along the asbestos mound embankment;

    0  construction of surface run-off diversion channels
       on top of the asbestos mound;

    0  operation and maintenance;

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    0  long-term monitoring;

    0  institutional controls to restrict on-site
       groundwater usage and limit development on
       the asbestos fill areas, and

    0  treatability studies of technologies for permanent
       destruction or immobilization of asbestos.

DECLARATION OF THE SELECTED REMEDY

Consistent with the Comprehensive Environmental Response, Com-
pensation, and Liability Act of 1980 as amended by the Superfund
Amendments and Reauthorization Act of 1986, and the National Oil
and Hazardous Substances Pollution Contingency Plan, 40 CFK 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 to
this remedial action and is cost effective.  This remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable tor this site.  Because treatment ot
the principal threat from the site was not found to be practicable
at the present time, this remedy does not satisfy the statutory
preference for treatment as a principal element of the remedy.
However,  EPA will provide for treatability studies to determine
the future applicability of innovative technologies that will
result in permanent remediation of asbestos.

Because this remedy will result in hazardous substances remaining
on-site above health-based levels, a review will be conducted withi
five years after commencement of remedial action to ensure that the
remedy continues to provide adequate protection of human health
and the environment.
  te             William J^Muszyrtslfi, P. E.
                 Acting Regional Administrator

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                        RECORD OF DECISION

                         DECISION SUMMARY

                 ASBESTOS DUMP - MILLINGTON SITE
SITE NAME, LOCATION AND DESCRIPTION

The subject of this Record of Decision (ROD), the Asbestos
Dump-Millington Site, ("Millington Site") is one of four properties
comprising the Asbestos Dump Site.

The other three sites, collectively referred to as the satellite
sites, will be the subject of a subsequent ROD.  They are as follows;

  (1) the Dietzman Tract located in the Great Swamp National
      Wildlife Rufuge in Harding Township, New Jersey;

  (2) the property at 257 New Vernon Road in Passaic Township,
      New Jersey'; and,

  (3) the property at 651 White Bridge Road also in Passaic
      Township, New Jersey.

The Millington Site is an 11 .acre commercial property located at
50 Division Avenue in Millington, New Jersey (Figure 1).  The
site is bounded on the west by the Passaic River, on the north by
the Millington Train Station, and on the east and south by commer-
cial and private residences, respectively.  Currently owned by Tita
Ltd., this site was formerly utilized as an asbestos processing
plant that was owned by National Gypsum Company  ("National Gypsum")
and previously, other manufacturers of asbestos products.

The asbestos mound portion of the site lies within the tloodplain
of the Passaic River.  The Passaic River is utilized as a public
water supply source.  Ten miles downstream from the Millington Site
the Commonwealth Water Company has a surface water intake that
serves 74,000 people.

The population of Millington is approximately 7800.  There are
approximately 200 individuals who are employed by twenty-one
businesses operating on the active portion of the site, which
has been converted to an industrial park by Tifa Ltd.

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                               -2-


SITE HISTORY AND ENFORCEMENT ACTIVITIES

Manufacturing of asbestos products at the Millington Site began
in 1927 by Asbestos, Ltd., which engaged in the fiberization and
sale of asbestos until 1946.  Prom 1946 until 1953, the plant was
owned by Bernard E. Smith and operated under the name of Smith
Asbestos, Inc., a manufacturer of asbestos rooting ana siding.

During this latter period, water from the manufacturing process
was impounded on the site by dams contructed to permit settling
of asbestos fibers suspended in the waste water.  Periodically,
sediment from the settling ponds was removed, disposed of on-site
and then covered with dirt.  In May 1953, the property was acquired
by National Gypsum, which manufactured cement asbestos siding ana
roofing sheets at the plant until 1975.  During National Gypsum's
period of ownership, most of the waste generated from the production
processes was recaptured and recycled.

Waste that was not recycled consisted of broken siding and asbestos
fibers.  These waste products were dumped on a five acre area ot
the property, (see Figure 1).  This included a 330-by-75 foot area
(referred to as the asbestos mound) where predominantly asbestos
fibers were disposed.  After the limited space for on-site dumping
reached full capacity, additional wastes were transported off-site.

From 1959 until 1972, National Gypsum used phenylmercuric acetate
(PMA) as a fungicide to coat the asbestos shingles.  Waste generated
by the cleaning of coating equipment was^disposed ot in small pits
west of the plant.

In May 1975, National Gypsum closed the Millington plant.  In 197fa,
ownership of the land was transferred to Tifa Ltd., Tifa Ltd. has
since divided the plant into several smaller parcels which have
been leased to other manufacturing and service companies.

The Asbestos Dump was proposed for inclusion on EPA's National
Priorities List in December, 1982.  As part of EPA's enforcement
activities, information request letters were mailed in October,
1983 to National Gypsum, as former owner and operator of the
facility and to Tifa Ltd., as current owner and operator.  National
Gypsum responded to the EPA's request for information, acknowledging
that it had generated and disposed of asbestos and other waste
during its operation at the Millington Site.  Tifa Ltd. responded
that they did not generate, transport or dispose of any hazardous
substances at the Millington site.

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                                        -3-
                                     FIGURE 1
                      ASBESTOS  DUMP—MILLINGTON  SITE
 PROPERTY LINE
LEGEND
Approximate Limits
of Asbestos Fill

• MW 901 Monitoring
      SCALE
     60   120
                                                                  MW 905
en
O
2
m
33
C/>
m
-<
O
O

z
                                                                              ASBESTOS
                                                                              'MOUND
                                                                          TJ

                                                                          C/3
                                                                          C/3
                                                                          >
                                                                          O
                                                                          5
                                                                          <
                                                                   907
  O

  z
  in
  I
  CD
  m
  33
  Z
  >
  33
  O
  C/>

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                               -4-


On November 2, 1983, EPA conducted a site visit in preparation
for initiation of the Remedial Investigation and Feasibility
Studies (RI/FS).  A notice letter along with the RI/FS workplan,
prepared by EPA, was sent to National Gypsum in September 1984 to
offer the company the opportunity to conduct the RI/FS with
private funds.  National Gypsum subsequently agreed to conduct
the RI/FS.  The RI/FS workplan that was prepared by. EPA was later
implemented by National Gypsum.

National Gypsum entered into an Administrative Order on Consent on
April 4, 1985 to perform the RI/FS at the Asbestos Dump Site.
Field work began in August, 1986 and was completed in November,
1987.

SCOPE AND ROLE OF OPERABLE UNIT

The Asbestos Dump Site was separated into two operable units.
The first unit is the Asbestos Dump - Millington Site, ana the
second operable unit is the Asbestos Dump - Satellite Sites,
which include the Dietzman Tract, 257 New Vernon Road and 651
White Bridge Road.  This approach was adopted after EPA determined
that additional data was needed to fully assess and characterize
potential damages to natural resources at the satellite sites,
specifically possible impacts to the Great Swamp National Wildlife
Refuge.

Therefore, as a separate operable unit, the RI/FS and ROD could
be completed for the Millington Site, while the additional data .
required for the satellite sites is being obtained.  A subsequent
ROD will address the remedial decision for the satellite sites.
The selected remedy in this ROD addresses the asbestos mound and
the "upland" portion of the Millington Site, which represent the
principal threat of release from the site.

COMMUNITY RELATIONS HISTORY

The Draft RI and Draft FS reports along with the Proposed Remedial
Action Plan (PRAP),  which identified the EPA's preferred remedial
alternative, were released to the public on August 19, 1988.   All
three documents were placed in the public repository at the Passaic.
Township Hall.  The public comment period was from August 19
until September 9, 1988.

A public meeting was held on August 29, 1988 at the Passaic
Township Hall to present the RI/FS, and EPA's proposed remedy and
to solicit public input.  The issues raised during the comment
period are addressed in the Responsiveness Summary Section of
this document.

An earlier public meeting was held on August.20, 1986 at the
Passaic Township Hall.  The purpose of that meeting was to explain
the scope of the activities that were to take place as outlined
in the RI/FS workplan.

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                               -5-

SUMMARY_OF SITE CHARACTERISTICS

Remedial investigation field activities to determine site charac-
terisitics, the full nature and extent of 'contamination and potential
pathways of contaminant migration were performed during the period
August 1986 through November 1987.

The primary contaminant of concern detected at the Millington site
was asbestos.  Asbestos was found in the form of broken asbestos
tiles, sidings and fibers.  The quantity of asbestos waste on-site
is estimated to be 90,000 cubic yards.  Soil borings and historical
information revealed that the "upland" portion of site contains
broken asbestos tiles and siding, while the asbestos mound was
found to contain predominantly asbestos fibers.  The "upland" and
asbestos mound portions of the site are covered with 4 to 6 feet
and 2 to 4 feet of topsoil, respectively.  However,  exposed areas
of asbestos fibers were observed on the slope of the asbestos mound
adjacent to the Passaic River.  The asbestos mound is heavily
vegetated with thick underbrush and deciduous trees.  On-site
ambient air monitoring did not detect significant concentrations
of airborne asbestos.

Extensive slope stability analyses indicated that the asbestos
mound was relatively stable and not in imminent danger of collapse.
However, the slope remains unprotected from surface erosion and the
potential destabilizing effects of flooding along the Passaic River

Soils analysis from on-site soil borings revealed elevated levels
of mercury and nickel.  The mercury appears to be related to PMA
which was applied to asbestos siding and shingles as a fungicide.

Analyses of 3 rounds of groundwater samples from 7 on-site moni-
toring wells revealed low concentrations of mercury and asbestos
related to disposal activities at the site.  Mercury was detected
in concentrations exceeding drinking water standards, 2 parts per
billion (ppb), in 4 of 21 samples.  The highest concentration of
mercury detected in the groundwater was 4.8 ppb.  Asbestos was
detected at concentrations ranging from 58,000 to 142,000 fibers/
liter, substantially below the proposed EPA drinking water standard
of 7,100,000 fibers/liter.

Three rounds of surface water sampling were conducted.  EPA's Ambient
Water Quality Criteria (AWQC) for asbestos (30,000 fibers/liter)
was exceeded in 3 of 12 samples.  However,- two of the these samples
were obtained from upstream sampling stations, which may indicate
the presence of other sources of asbestos.  Cadmium was detected in
excess of the AWQC (10 ppb), at one downstream location, at 563 ppb.
However, the presence of cadmium in the surface water is not likely
to be attributable to the Millington Site.   Nickel was found in
excess of the AWQC (13.4 ppb) in two downstream locations in the
initial round of sampling, at 47 and 84 ppb, and was not detected
in the two subsequent sampling events.  Nickel was detected in
on-site soils and groundwater and may be attributable to the
Millington Site.

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                                -6-

                            TABLE -  1

     AMBIENT ASBESTOS_AJR_SAMPLING RESULTS AND  WEATHER DATA

                         MILLINGTON  SITE
Event 1
Event 2
            Location
DW
DW
OS
UW
OS

DW
DW
DW
OS
UW
                 Fibers/cc
<-004
<.004
<.004
<.004
 .004

<-004
<.004
<.004
<.004
<.004
              NIOSH *
              Guideline
              Fibers/cc
                                               0.1
Wind Speed
8-10 mph
8-10 mph
8-10 mph
8-10 mph
8-10 mph

3-5 mph
3-5 mph
3-5 mph
3-5 mph
3-5 mph
DW  - Down wind
UW  - Up wind
OS  - On site
mph - miles per hour

* National Institute  for Occupational  Safety  and Health
  recommended 8-hour  exposure limit.

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                               -7-

                            TABLE - 2

 COMPARISON OF SUBSURFACE SOIL SAMPLES IN THE_ASBESTOS_MOUND AND
   UPLAND AREAS TO NJDEP ECRA GUIDELINES FOR CONTAMINATED SOILS"
Parameter
Sample
Range
(mg/kg)
Detected Indicator Chemicals

Arsenic               2.3  -   6.0
Mercury               0.1  -   7.8
Nickel               13.4  - 301.0
Benzene                ND  -   0.02
Trichloroethylene      ND  -   0.08

Other Detected Chemicals
Chromium
Copper
Lead
Zinc
Phenols

Total Volatile
Organics •
14.8
12.5
 6.2
17.5
 0.05  -

 0.14  -
0.35
      ECRA
      Guideline
      Jmg/kgJ	
                   20.0
                    1.0
                  100.0
83.3
68.2
39.4 .
309.0
0.06
100.0
170.0
100.0
350.0
	
1.0
                                                   No. of samples
                                                   exceeding guidelines
                      0 of
                      4 of
                      7 of
                  13
                  13
                  13
                      0 of 13
                      0 of 13
                      0 of 13
                      0 of 13
0 of 13
Not ej:

ND - None Detected
	 No Guideline

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                                   -8-

                                TABLE -  3

          COMPARISON OF SURFACE_SOIL_SAMPLES_JIN_UPLAND AREAS TO
             TO NJDEP ECRA GUIDELINES FOR CONTAMINATED SOILS
parameter

Detected Indicator Chemicals

Arsenic
Mercury
Nickel
Bis(2-ethylhexyl)phthalate

Othe r_ Detected Chemicals

Chromium
Copper
Lead
Zinc

Total Volatile
   Organics
 Sample
 Range
jmg/kgj
ECRA
Guideline
(mg/kg)	
ND -
0.2 -
35.6 -
ND -
7.4
1.7
51.5
0.62
20.0
1.0
100.0
	
      Base/Neutral
   Extractables
25.4 - 30.6   100.0
37.3 - 59.0   170.0
79.7 - 88.1   100.0
82.1 - 82.7   350.0
 ND  -  0.03    1.0


 8.02 - 9.63   10.0
No. of samples
exceeding guidelines
                            0 of 2
                            1 of 2
                            0 of 2
              0 of 2
              0 of 2
              0 of 2
              0 of 2
              0 of 2


              0 of 2
    Notes-;

    ND - None Detected
    	 No Guideline

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                                TABLE - 4
  COMPARISON OF GROUNDWATER SAMPLES TO POTENTIAL APPLICABLE OR_RELEVANT
  AND APPROPRIATE REQUIREMENTS TARARs7~AND "TO BE CONSIDERED'^TBC'? GUlpELINES
    Parameter
Sample
Range
(mg/1)
 ARAR/TBC
 Level
 (mg/1)
    Detected Indicator Chemicals
    Arsenic
    Mercury

    Nickel
    Bis(2-ethylhexyl)
      phthalate
    Benzene
    Trichloroethylene

    Asbestos
           No. of samples
 Source    exceeding ARAR

ND
0.0002 -

0.021 -
0.021 -
ND
0.002 -

58,000 -

0.004
0.0048

0.142
0.142
0.50
0.006

142,000
(fibers/liter)

0.
0.

0.
0.
0.
0.

1,
(f

05
002

700
700
005
005

100,000
ibers/liter)
(1)
SDWA-MCL
SDWA-MCL
(2)
RFD
RFD
SDWA-MCL
SDWA-MCL
(3)
Proposed
MCLG

0
4

0
0
1
1

0


of
of

of
of
of
of

of


21
21

21
21
21
21

21

    Other  Detected Chemicals

    Chromium

    Coppe r
    Lead
    Silver
    Zinc
    Acetone
    Ethylbenzene

    Trans-1,2-           ND
      dichloroethene
    Xylenes              ND
    Di-n-butyl-          ND
      phthalate
    Naphthalene          ND
    Endfin              ND
    Phenols             0.015
0

0
0
0
0
0


.005 -

.008 -
.012 -
.010 -
.012 -
.012 -
ND

0.

o.
o.
0.
0.
o.
o.

023

386
020
024
158
067
021

0.

1.
0.
0.
7.
3.
3.

05

295
05
05
35
50
50
(5)
SDWA-MCL
(4)
IRIS
SDWA-MCL
SDWA-MCL
IRIS
RFD
IRIS

0.

0
0
0
0
0
0

Of

Of
Of
Of
of
of
of

2

2
1

1
21
2
2
2
2

1
1
1
1

      -  0.006

      -  0.009
      -  0.001
 NA

70.0
 NA
         0.026   3.50
         2.6E-05 0.0002
         0.048   1.40
RFD-IRIS
               RFD
               SDWA-MCL
               IRIS
0 of 21
            0 of 21
            0 of 21
            0 of 21
    Notes;

(1)  Safe Drinking Water Act- Maximum Contaminant Levels  (SDWA-MCL)

(2)  No  established MCLs.   Guideline is  based  on the Reference Dose  Value (RFD)
    for chronic acceptable intake (oral route)  as developed by USLPA (IRIS,
    1988 and  the Superfund Public Health Evaluation Manual Update)

(3)  Safe Drinking Water Act- Maximum Contaminant Level Goal (MCLG)

(4)  Integrated Risk Information System, USEPA,  1988 (IRIS)

(5)  No  Standard Available

 ND - None  Detected

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??A!.£ ResP°nse to Written Comments

COMMENT:
Tifa Ltd, the current property owner, requested that the ". .
modify the Proposed Remedial Action Plan (PRAP) and include in thcs
Record of Decision a provision specifically to authorize Tifa to
construct the proposed parking lot facility.  In addition, Tifa
requests that USEPA provide further that Tifa may construct the
facility as soon as it wishes.  This provision is necessary because
Township approval of the proposal is due to expire in August, 1989,
if not extended further."

EPA_ RESPONSE:                ,':
The purpose of the PRAP is to solicit public comment on EPA's pre-
ferred remedy to be implemented at the site; it is not a
decision making' document.,  Any modifications to the PRAP based upon
public input are reflected in the Record of Decision (ROD).  Accord-
ingly, there is no need to modify the PRAP.  In regard to the Tifa
proposed parking lot, the EPA does not object to surficial uses
of the property, providing it does not involve disruption or exposure
of the asbestos waste.  Approval of such use would be reviewed and
approved by EPA, New Jersey Department of Environmental Protection
(NJDEP) and appropriate local authorities on a case by-case basis
prior to implementation.  EPA reserves the right to determine whether
such proposed action may be deemed an inconsistent response action
under Section §122 (e)(6) of CERCLA.

COMMENT:
The~Passaic River Coalition and a citizen recommended that the
remedy should be designed and implemented in harmony with the
natural surroundings of the Passaic River.

EPA RESPONSE:
EPA is sensitive to these concerns and will ensure such provisions
are addressed in the remedial design.

COMMENT:
The Passaic River Coalition suggested that an independent agency
other than National Gypsum, should perform sampling at the site.

EPA RESPONSE:
This question was addressed at the public meeting (see page 3 15 of
responsiveness summary).  EPA maintains a high level of confidence
in its field oversight and sample splitting program and will continue
this approach during site remediation and long term monitoring.

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                               -10-

                            TABLE - 5

     COMPARISON OF SEDIMENT SAMPLES TO NJDEP ECRA GUIDELINES
                      FOR CONTAMINATED SOILS
                   Sample
                   Range
Parameter          Jmg/kg)

Detected Indicator Chemicals
Arsenic
Mercury
Nickel
   ND  -
   ND  -
 28.8  -
10.9
 0.4
32.1
Other Detected Chemicals
Chromium
Copper
Lead
Zinc

Total Volatile
  Organics
 25.6 -  29.2
 29.0 -  67.2
 33.2 -  62.0
108.0 - 181.0

  0.012 - 0.015
                   ECRA
                   Guideline
                   152/kgJ	
 20.0
  1.0
100.0
           100.0
           170.0
           100.0
           350.0

             1.0
Total Base/Neutral  -  HD  -  6-6        10.0
   Extractables
                         No.  of samples
                         exceeding^ guidelines
0 of
0 of
0 of
                0 of
                0 of
                0 of
                0 of
                0 of 2
                                   0 of 2
ND - None Detected

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                               -11-

                            TABLE - 6

       COMPARISpN_OF SURFACE WATER SAMPLES TO AMBIENT WATER
   QUALITY CRITERIA JAWQCT"FOR"CONSUMPTION OF AQUATIC ORGANISMS
                        AND DRINKING WATER
                   Sample
                   Range
Parameters
Detected Indicator Chemicals
Cadmium
Nickel
Bi s(2-ethylhexyl)
  phthalate
Asbestos
 ND   - 0.563
0.047 - 0.084
 ND   - 0.110

67,200 - 100,000
(fibers/liter)
Other Detected Chemicals
Chromium
Copper
Lead
Selenium
Silver
Zinc
Di-n-butyl-
  phthalate
Phenols
0.005
0.008
0.002
 ND
 ND
0.011
 ND

 ND
- 0.020
--0.014
- 0.018
- 0.020
- 0.013
- 0.060
- 0.013
- 0.042
                     AWQC
                     (mg/1)
              0.010
              0.0134
             15.00

               30,000
               (fibers/liter)
 0.050 (Cr+6)
 1.00
 0.050
 0.010
 0.050
 5.00
34.0

 3.5
                                 No. of samples
                                 exceeding guidelines
                    1 of
                    2 of
                    0 of
0 of
0 of
0 of
1 of
0 of
0 of
0 of
     12
     12
     12
                    3 of 12
12
12
12
12
12
12
12
0 of 12
ND - None Detected

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                               -12-

SUMMARY OF SITE RISKS

The objective of the risk assessment is to define the nature and
extent of potential public health and environmental risk associated
with the presence of hazardous substances at and around the
Millington Site.  In assessing risk, the following are considered:
contaminants having known chemical and biological toxicity,
actual or potential exposure pathways,  and human and environ-
mental receptors.

The following chemicals were chosen as indicator chemicals:1

                    (1) asbestos
                    (2) mercury
                    (3) arsenic
                    (4) nickel
                    (5) cadmium
                    (6) bis(2-ethylhexyl) phthalate
                    (7) benzene
                    (8) trichcloroethylene (TCE)

Asbestos and mercury were determined to be the principal
contaminants of concern, based upon detection at a higher
frequency or a higher concentration level within each selected
medium.  The exposure pathways by which the chemicals of concern
may come into contact with humans or migrate into the environment
were evaluated.  Several potential exposure routes were identified
and include:

                    (1) soil/asbestos
                    (2) surface water
                    (3) ground water and
                    (4) air

The risks associated with the potential exposure routes are
discussed below.

Soil/Asbestos

The potential risk from direct contact with soil is primarily
due tovthe presence of asbestos.  The risk from dermal contact
with on-site surface soils is mitigated by the topsoil layer
over the soil/asbestos fill which prevents direct contact.
Under present conditions, the site is not posing a significant risk
via subsurface soil, because receptors cannot come in direct contact
with these soils.
    Indicator chemicals for the Site were chosen using the procedures
    described in the Superfund Public Health Evaluation Manual
    (USEPA 1986).  This ranking scheme incorporates information
    on each constituent chemical's toxicity, concentration, environ-
    mental persistence and mobility, in order to select those
    constituent chemicals predicted to have the greatest impact
    on human health or the environment.

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                                -13-


Surface Water

Based on surface water data, the Millington Site does not present a
significant risk to public health and the environment via the surface
water route.  Although nickel exceeded the Ambient Water Quality
Criteria in the first round of sampling,  the endangerment assessment
conducted for the site did not reveal a significant risk to public
health from direct contact and consumption of surface water or
ingestion of fish.

Groundwater

The groundwater within the asbestos mound contained contamination
slightly above MCL or recommended MCL levels.  However,  the con-
taminants detected were confined to the site and are not expected
to impact public health and the environment.  Groundwater from the
site migrates directly into the Passaic River, which has not been
adversely impacted by groundwater discharges from the site.  In
addition, the community is served by a public water supply system
and there are no downgradient potable wells within the vicinity of
the site.

Air

Employees working on site are the primary potential receptors of
possible release through the air route.  However, the asbestos
mound area is removed from the workplace.  Furthermore,  on-site
ambient air monitoring has not shown concentrations of asbestos
which constitute a health threat (See Table 1).  With no significant
changes in site conditions, the site should not present  a risk to
public health through airborne releases of asbestos.  However,
natural processes such as erosion of the existing soil and vegetative
cover would increase the potential for exposure of asbestos to the
atmosphere and result in future unacceptable risks.

Tables 2 through 6 provide the ranges of concentrations  found in
each medium and compare them to their respective potentially Appli-
cable or Relevant and Appropriate Requirements (ARARs) and other
guidelines or criteria to be considered.

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  Contingency
Plan (NCP).  These alternatives were developed by screening a wide
range of technologies for their applicability to site-specific
conditions and then evaluated in terms of the nine evaluation
criteria based on the statutory requirements of CERCLA/SARA.

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                                -14-


Source Control Alternatives;

Alternative Source Control - 1 (SC-1) - No Action with Long-term
     ~"                            ""•     Monitoring       ~~    ~

The no-action alternative provides a baseline for comparison of
other alternatives.  Under the no-action alternative, no remedial
measures would be undertaken at the Asbestos Dump - Millington Site.
However, a comprehensive sampling program would be implemented to
monitor the potential for future migration of contaminants and to
identify a point at which further remedial activities may be required.
The monitoring program would include air, sediment, groundwater and
surface water sampling for a minimum of 30 years.

This alternative neither reduces the potential for future airborne
release of asbestos from exposed areas, nor does it limit access
to the site.  Furthermore, it does not reduce surface erosion and/or
the potential for migration of asbestos to the Passaic River.  The
estimated cost of alternative SC-1 is $1,925,000.  This includes
total capital cost and present worth operations and maintenance
costs.  The high cost of the no-action alternative is due to the
comprehensive nature of the long term monitoring program.

Alternative SC -2/3 Completion of. Soil Cover/Site Security/Slope
                    Protection/Erosion & 'Sediment Control/Monitor-
                    rhg/Treatability StudTes

Alternative SC-2/3 provides for installation of a two foot soil
cover on areas of exposed or minimally covered asbestos, consistent
with the National Emission Standards for Hazardous Air Pollutants
(NESHAPs) requirements of the Clean Air Act.  Existing soil cover,
dense underbrush and deciduous trees will remain intact where this
cover has been determined to be a minimum of 2 feet.  Newly covered
areas would be vegetated to minimize erosion.  A retaining wall, a
pre-cast concrete mat or an equivalent system would be constructed
to protect the asbestos mound along the Passaic River from flood
events and surface erosion and to provide additional structural
support.  In addition, erosion and sediment controls would be
installed to reduce surface run-off and control erosion of the
embankment slope.  A security fence would be installed to restrict
access to the asbestos mound area.  Institutional controls would
be implemented to restrict on-site groundwater usage and limit
development in areas of known or suspected asbestos disposal.

This alternative would restrict site access, reduce the potential for
future airborne release of asbestos from exposed areas, control
future surface erosion, provide slope stability and mitigate the
transport of asbestos to the Passaic River.  Upon completion of
this remedy, there would be long-term monitoring and maintenance of
the site. In addition, treatability studies would be conducted to
determine if asbestos can be permanently remediated.  The cost of
alternative SC-2/3 is estimated between $1,800,000 and $2,111,000.

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                             -15-


Alternative SC-4;  Surface Regrading/Cover/Monitoring

This alternative involves clearing and grubbing of existing
vegetation on the asbestos mound and redistributing the
asbestos fill as necessary to provide a final slope of 3
Horizontal:  1 Vertical (3H:1V) which would provide for
greater slope stability and minimize erosion.  A two-foot -
soil cover would be installed and vegetated to control erosion
of the embankment.  A chain-link security fence would be
installed to restrict access to the asbestos mound.  Erosion
and sediment controls as described in Alternative SC-2/3, as
well as long-term monitoring, would also be implemented.  This
alternative would minimize future potential risks from releases
of airborne asbestos by minimizing future surface erosion and
long-term failure of the mound.  Furthermore, flood control
and slope stabilization measures would not be as protective
as those planned in Alternative SC-2/3.  The cost of Alternative
SC-4 is estimated at $3,463,000.

Alternative SC - 5 - Excavation/Offsite Disposal

This alternative would provide for source removal which includes
the excavation of 90,000 cubic yards' of asbestos waste using
control measures such as silt fences, wetting,  and berms to
minimize erosion and potential airborne releases of asbestos
during excavation.  The excavated asbestos would be container-
ized in bulk and transported to an off-site disposal facility
in accordance with NESHAPs and other Federal and State require-
ments.  Clean soil would be used for regrading, followed by
the vegetation of all disturbed areas.  Air, soil and groundwater
sampling would be conducted to verify the effectiveness of
the remedial action.  This alternative would require 150-200
working days for excavating and containerizing the asbestos
in bulk.  The estimated cost for alternative SC-5 remedy is
$22,172,000.

Groundwater Alternatives;

As documented in the Summary of Site Risks section of this
document, the groundwater contamination at the Site does not
pose a significant risk to public health and environment.
Therefore,  groundwater alternatives will not be addressed in
this document.

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                             -16-
                           TABLE - 7
                   ALTERNATIVE COST COMPARISON
Alternative

SC-1   No Action

SC-2/3 Completion of
       Soil Cover/Site
       Security/Slope
       Protection/
       Erosion & Sedi-
       ment Control/
       Monitoring/Treat-
       ability Studies

SC-4   Surface        2345
       Regrading/
       Cover

SC-5   Excavation/   21726
      'Off-site
       Disposal
Capital
Cost
($1,000)
0
679-966
Annual
O&M
($1,000)
171
56-161
Present Worth
@ 8% Discount
Rate ($l,OOOs)
30 years
1925
1145
Total
Costs
($1,000)
1925
1824-2111
53-161
45-81
1118
 446
 3463
22172

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                               -17-


       SUMMARY QF COMPARATIVE ANALYSIS OF ALTERNATIVES


The alternatives were evaluated based on the following nine
criteria:

     - Overall protection of human health and the environment;

     - Compliance with federal and state Applicable or Relevant
       and Appropriate Requirements (ARARs);

     - Reduction of toxicity, mobility or volume;

     - Short-term effectiveness;

     - Long-term'effectiveness;

     - Implementability;

     - Cost;

     - Community Acceptance; and

     .- 'State Acceptance.

Table 8 presents a matrix in which all nine criteria can be
compared for each alternative.  Table 8 also highlights the
advantages and disadvantages of each alternative with respect to
the evaluation criteria, thereby providing the rationale for the
selected remedy.

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                                        SUGARY OF DETAILED
                                           8
                                          iTIQN OF ALTERNATIVES
                                                  SOURCE CONTROL ALTERNATIVES
Assessment Factors
Overall protection of
Human Health &
Environment
SC-1 No Action
Does not minimize potential for future release
of asbestos into the environment. -Does not
limit site access and potential direct contact
threat.
Compliance with ARARs   Does not comply with ARARs.
Long-Term
Effectiveness and
Permanence
Short-Term
Effectiveness
Reduction of Toxicity
Mobility/Volume
Implementability
Cost
State Acceptance

Community Acceptance
No direct engineering controls to prevent future
release.  Residual contamination and source of
asbestos remains.
ND reduction in the potential for airborne and
surface water release or direct contact.
No reduction of mobility, toxicity, or volume
since no treatment employed.
ND technical restraints to implementation.
Capital Cost
Annual O&M
Present Worth O&M
Total Cost

Not acceptable

Not acceptable
         0
$  171,000
$1,925,000
$1,925,000
                                SC-2/3 Completion of Soil Cover/Eros ion/Site
                                Security/Slope Protection/& Sediment Control/
                                Monitoring/Treatability Studies	

                                Mitigate risks associated with exposure to
                                contaminated soils and airborne asbestos.
                                Prevents migration of asbestos to surface
                                water.

                                Compliance with all ARARs.

                                Provides for increased structural stability of
                                asbestos mound and long-term protection against
                                flooding.  Technologies are proven with long-term
                                reliability.   Although residuals remain on-site,
                                the potential for exposure ana migration is
                                limited.  Treatability studies to ensure that
                                permanent solutions employed to maximum extent
                                practicable.
                                                                                                                             00
                                Reduces potential  for direct  contact  within
                                several weeks of implementation.   Prevents
                                migration to surface water and airborne
                                transport of asbestos within  several  weeks ot
                                implementation.

                                Reduces mobility of  asbestos  through  air  and
                                surface water especially during  flood events.
                                No reduction of  toxicity or volume.
Services and materials available, some specialists
required for construction and startup.  Oofrer
dam may be needed to divert stream during
construction.  Technical requirements lor stream
encroachment or relocation permits need to be met.

Capital Cost        $  679,000 - 966,000
Annual O&M          §   56,000 to $161,000
Present Worth O&M - $1,145,000
Total Cost          $1,824,000 - 2,111,000

State has concurred with remedy

Comnunity agrees with remedy

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Assessment Factors
Overall protection of
Human Health and
Environment
Compliance with ARARs
Short-Term
Effectiveness
Long-Term
Effectiveness and
Permanence
Reduction of Toxicity
Mobility/Volume
Implementability
Cost
                                     TAHLb 8 (continued)
                SIM1ARY OF DETAII£D EVALUATIONLp
                          SOURCELCCOTI»L~ ALTERNATIVES "
SC-4 Surface Regarding/Cover/Slte" Security7
Morutpring  "                                   SC-5 Excavation/Off-Site pisposal
State

Oomnunity Acceptance
Mitigates risks associated with exposure to
contaminated soils and airborne asbestos.
Controls migration of asbestos to surface
water by reduction of slope angle.

Air, surface water standards may be exceeded
in short-term but should be met in the long-
term.
Implementation time less than complete
excavation and off-site removal.  Movement
of asbestos during construction and regrading
operation increases the potential for airborne
asbestos.
Reduces existing slope angle and minimizes
long-term erosion and transport of asbestos
to air and surface water.  Requires greater
O & M to maintain integrity of slope.  Does
not provide maximum level of protection
against flood damage.

Cover will reduce mobility of asbestos to air
and soil contaminants to groundwater.  No
reduction in toxicity or volume.

Surface regrading is easily implemented.
May require on-site or off-site disposal
of excavated materials to maintain proper
slope.  Mitigative measures required to
reduce potential for release of asbestos
during contruction.
Capital Cost      - $2,345,000
Annual O&M        - §   53,000 to $161,000
Present Worth O&M - $1,118,000
Total Cost        - $3,463,000

State acceptance unlikely
   r     /
Community acceptance unlikely
Removal will eliminate long-term erosion
and transport of asbestos to surface water ana
provide protection tor public health and environment
in the long-term.

Air, surface water standards may be exceeded in
short-term but should be met in the long-term.
Excavation and transportation of such a large
volume of asbestos waste involves a significant
threat of release during construction even with
mitigative measures designed to reduce the like-
lihood of such exposures.  Requires 150-200
working says for excavation and bulk container-
ization of 90,000 cubic yards ot asbestos.

Removes source and eliminates associated long-
term risks.
No reduction in toxicity and volume of waste.
Of t-site disposal without treatment is generally
the least preferred alternative.

Implementation requires costly mitigative measures
such as silt fences, wetting and berms to min-
imize erosion and airborne release of asbestos
during excavation.  Implementation time is variable
depending on removal metholodology and availability
off-site disposal location.

Capital Cost      - $21,726,000
Annual O&M        - $    45,000 to $81,000
Present V\orth O&M - $   446,000
Total Cost        - $22,172,000
State acceptance unlikely

Oomnunity acceptance unlikely  *"

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                               -20-
SELECTED REMEDY

After a complete review and evaluation of the remedial alterna-
tives, EPA has selected Alternative SC-2/3 as the remedy for the
Millington Site.  This alternative will protect public health and
the environment by containing asbestos, which is the major contami-
nant of concern, and provide for long-term monitoring of other
contaminants detected in the asbestos mound.

          The preferred remedy is comprised of:

          0 installation of a two-foot soil cover
            on areas of exposed or minimally covered
            asbestos;

          0 installation of a chain-link security
            fence to restrict access to the asbestos mound;

          0 construction .of slope protection/stabilization
            measures along the asbestos mound embankment;

          0 construction of surface run-off diversion
            channels on top of the asbestos mound;

          8 operation and maintenance; •

          0 long-term monitoring;

          0 institutional controls to restrict on-site
            groundwater usage and limit development on
            the asbestos fill areas; and

          0 treatability studies of technologies for permanent
            destruction or immobilization of asbestos.

In accordance with NESHAPs, which apply to inactive asbestos
waste disposal sites, a minimum of 2 feet vof soil cover will
be placed on areas of exposed or minimally covered asbestos.
Since the existing soil cover is an acceptable cover material
for asbestos, it needs only to be supplemented in areas where
asbestos is exposed or where soil cover is less than two-feet.
Excavation and replacement of the existing soil cover would
create significant short-term risks without any benefit to human
health and the environment.  A chain-link security fence, complete
with warning signs will be installed to restrict access to the
asbestos mound.

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                               -21-


The slope protection/stabilization measures to be built at the
base of the mound along the Passaic River will protect the mound
from flooding and possible failure, which would result in the
release of asbestos to the Passaic River and the air.  The types
of slope protection/stabilization measures which may be utilized
include a retaining wall, a pre-cast concrete mat .or an equivalent
system.  The specific measures will be refined during the remedial
design phase.

Surface run-off diversion channels will be constructed at the
top of the asbestos mound.  These channels will divert surface
runoff to the Passaic River, as opposed to over the mound, which
could lead to further erosion and release of asbestos into the
Passaic River.

To ensure that the remedy maintains its integrity and the site
does not present any future threat to the public health and/or
the environment, a long-term maintenance and monitoring program
will be implemented at the site for a minimum of 30 years.
Institutional controls will be utilized to restrict future on-
'site groundwater usage and limit development on the asbestos fill
area.  The long term monitoring program would include off-site
groundwater monitoring wells to ensure protection of public
health should there be future use of off-site groundwater within
the influence of the site.  The Town of Millington and the
surrounding townships are served by public water supply systems.

EPA remains concerned about the extremely persistent nature of
asbestos.  Therefore, the selected remedy will include a program
providing for treatability studies to evaluate innovative treatment
technologies that may be effective in permanently remediating
asbestos.  Upon completion of the treatability studies EPA will
evaluate their applicability to the site and may select such a
technology in a future Record of Decision.


STATUTORY DETERMINATIONS

Protection of Human Health and the Environment

The selected remedy is protective of human health and the
environment.  By covering and maintaining areas having less than
two feet of soil cover, the risk of asbestos fibers becoming
airborne will be eliminated.  The slope protection measures to be
implemented will stabilize and contain the asbestos mound and
mitigate the risks of surface water transport of asbestos.  No
groundwater threat is posed by the site, as the community is
served by a public water supply and the low level contamination
detected within the asbestos mound should meet health based
levels beyond the site boundary.  As an added precaution,
potential risks related to future off-site use of groundwater
will be further mitigated by the implementation of an off-site
groundwater monitoring program.

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                               -22-
Consistency With Other Laws

During development of the feasibility study, potentially Applicable
or Relevant and Appropriate Requirements (ARARs) were established
based on current EPA guidance.

There are several types of ARARs that Superfund actions may need
to comply with.  The classifications of ARARs are presented below:

Chemical-specific requirements are health or risk based concentra-
tion limits or ranges in various environmental media for specific
hazardous substances, pollutants or contaminants.  The chemcial-
specific requirements for the site are summarized in Tables 4 and 6.
The remedy, through containment of asbestos waste, is expected to
comply with Federal and State chemical-specific ARARs.

Location-specific requirements are restrictions on activities
occurring on site or in the immediate vicinity of the site.
Location-specific ARARs pertinent to the Asbestos Dump - Millington
site include the National Historic Preservation Act,  the Wild and
Scenic Rivers Act and Executive Order 11988 and 11990.  The sub-
stantive requirements of location-specific ARARs will be met
during the remedial design phase.  Accordingly, implementation of
selected remedy will be in compliance with the above-referenced
ARARs.

Action-specific requirements set controls or restrictions on
particular kinds of activities related to management of hazardous
substances, pollutants or contaminants.  Action-specific require-
ments pursuant to the following Federal and State regulations
governing air emissions "will be met during the remedial design
phase.

   - 40 CFR Part 50: National Ambient Air Quality Standards

   - NJAC 7:27-13: New Jersey Ambient Air Standards

   - 40 CFR Part 61: National Emission Standards for
        Hazardous Air Pollutants

The remedy complies with the technical requirements of the National
Emission Standards for Hazardous Air Pollutants (NESHAPs) for
inactive asbestos waste disposal sites.  Areas of asbestos waste
disposal will be covered with a minimum of two feet of compacted
nonasbestos-containing material (i.e., soil), and maintained to
prevent exposure of the asbestos waste.  In addition, the area of
the asbestos mound will be fenced and posted with warning signs-

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                               -23-
Cost Effectiveness

The EPA feels that the selected remedy is cost effective when
compared with the other currently feasible alternatives.  The No
Action alternative (SC-1) does not mitigate the release .of hazardous
substances from the site, yet its total cost is similar to the
selected alternative (SC 2/3).  This is due to the comprehensive
nature of the long term monitoring program associated with the No
Action alternative.  In comparison to alternative-SC 2/3,  alternative
SC-4 is more costly and less protective in terms of the slope
protection/stabilization measures to be implemented.  Finally,
alternative SC-5 is far more costly than the selected alternative
and is not as protective due to the significant short term risks
involved in implementing the remedy.

Utilization of Permanent Solution to Maximum Extent
PractTcable               ~                   ~~

The Agency believes that Alternative  SC-2/3 is the most appropriate
remedy to be implemented at this site.  The No-Action alternative
(SC-1) was rejected "because it does not reduce or mitigate the
potential for future release of asbestos at the site.  Alternative
SC-4 and SC-5 were not selected primarily because the potential
for a significant release of asbestos to the air and surface
water during implementation.  The selected alternative is cost-
effective and protective of human health and the environment without'
involving the implementation risks of Alternatives SC-4 and SC-5.
Treatment based remedies, although desirable,  were not selected
at this time because current treatment technologies were not
shown to be feasible for a project of this scale.  However,
treatability studies to determine the feasibility of a more
permanent asbestos remedy will ensure permanent solutions are
utilized to the maximum extent practicable.

Preference for Treatment

Treatment of the principal threat from the site was not found to
be practicable at the present time.  Accordingly, the remedy does
not satisfy the statutory preference for treatment as a principle
element of the remedy.  However, the remedy does provide for
treatability studies to determine the future applicability of
technologies that would satisfy the statutory preference for
treatment.

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                 ASBESTOS DDMP-MILLINGTON SITE
                           MILLINGTON
                   MORRIS COUNTY, MEW JERSEY

                        RESPONSIVENESS  SUMMARY


The U.S. Environmental Protection Agency (EPA) held a public
comment period  from August 19, 1988 through September 9, 1988
for interested  parties to comment on the draft Remedial
Investigation/Feasibility Study  (RI/FS) and Proposed Remedial
Action Plan  (PRAP) for the Asbestos Dump-Millington Superfund
site in Millington, Morris County, New Jersey.  The Asbestos
Dump-Millington site RI/FS encompasses only one of several areas
of the Asbestos Dump site.  Three "satellite sites" will require
additional investigatory work to fully evaluate effective
remedial options and impacts on natural resources.

EPA held a public meeting on August 29, 1988 at the Passaic
Township Hall,  Millington, New Jersey to describe the remedial
alternatives and present EPA's preferred remedial alternative
for the Asbestos Dump-Millington site.

A responsiveness summary is required for the purpose of
providing EPA and the public* with a summary of citizens'
comments and concerns about the site, as raised during the
public comment  period, and EPA's responses to those concerns.
All comments summarized in this document will be factored into
EPA's final decision for selection of the remedial alternative
for cleanup of  the Asbestos Dump-Millington site.

I.   BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS.  This
section provides a brief history of community interest and
concerns regarding the Asbestos Dump-Millington site.

II. SUMMARY OF  MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE
PUBLIC COMMENT  PERIOD AND EPA RESPONSES TO THESE COMMENTS.  This
section summarizes comments submitted to EPA at the public
meeting and during the public comment period, and provides EPA's
responses to these comments.

I.  BACKGROUND  ON COMMUNITY INVOLVEMENT AND CONCERNS

The Asbestos Dump-Millington site has not generated a high level
of community interest throughout the RI/FS process.  The site
first received  public attention in 1980 when a former asbestos
plant employee  identified three off-site areas where asbestos
waste material  had been dumped.  This was followed by a report
from a state-wide public interest group on potential asbestos
pollution problems caused by the four dump sites.  Also, a
regional coalition to protect the Passaic River expressed
concern that asbestos waste material from the Asbestos Dump-
Millington site was washing into the Passaic River during flood
conditions.  An additional concern expressed by members of the

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community was the potential threat to public health that could
occur from the inhalation of airborne asbestos particles.

II.  SUMMARY OP MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE
PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THESE
Comments raised during the public comment period for the
Asbestos Dump-Millington site are summarized below.  The public
comment period was held from August 19, 1988 through September
9, 1988 to receive comments from the public on the draft RI/FS
reports and the PRAP.  Comments received during the public
comment period are summarized below and organized into the
following categories:

A.  Site contamination,

B.  Responsibility for site remediation,

C.  Other remedial alternatives, and

D.  Miscellaneous.

Written comments submitted to EPA during the public comment
period, along with EPA's responses to those comments are
attached as Appendix A.

A.  SITE CONTAMINATION
                                                *

1.  Comment:  A citizen noted that the Passaic River is a
    drinking water source, and asked if any volatile organic
    compounds (VOCs) had been detected during the RI sampling of
    the river.

    EPA Response:  Low levels of VOCs were detected in the
    asbestos fill area, however, even though groundwater in the
    fill area flows toward the river, the RI sampling did not
    reveal the presence of site-related VOCs in the Passaic
    River.

2.  Comment:  A citizen asked whether EPA would continue to
    monitor the Passaic River for site-related contaminants.

    EPA Response:  Continued sampling of the site and related
    areas is part of the long-term monitoring program that EPA
    has included as a component of the proposed remedial action.
    EPA plans to install additional groundwater monitoring wells
    and will continue surface water sampling of the Passaic
    River.

3.  Comment:  A citizen asked for further information on what
    levels, if any, of PMA and mercury were detected in the
    asbestos mound.

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    EPA Response:  EPA received reports from former employees of
    past owners of the site that sludge containing PMA was
    disposed in pits in the asbestos mound area.  EPA targeted
    the RZ to try and locate the pits, however, it appears that
    the PMA disposal was not of the magnitude that would allow
    for accurate definition of the pits.  Low levels of mercury
    were detected throughout the asbestos fill area.  Although
    mercury was detected in groundwater samples, there is no
    evidence of mercury migrating into the Passaic River.  The
    groundwater in the area is not utilized as a public drinking
    water supply and, at this time, EPA is not proposing any
    groundwater remediation.

4.  Comment:  A resident asked how frequently EPA would conduct
    groundwater sampling during the proposed monitoring program.

    EPA Response:  EPA is planning on conducting quarterly tests
    for the first five years.  The test results will determine
    the frequency of the sampling program after that point.

5.  Comment:  Several residents asked who would actually be
    conducting the future site monitoring.  They expressed
    concerns over the ability of the -potentially responsible
    parties (PRPs) to conduct as thorough a monitoring program
    as EPA or an independent party.

    EPA Response:  EPA has maintained oversight and control on
    the site investigation and will continue to maintain
    stringent oversight guidelines regarding remedial actions at
    the site if the PRPs conduct the remediation.  EPA and the
    PRPs would continue to split any samples taken and have the
    samples analyzed by separate laboratories to ensure the
    consistency of results.

B.  RESPONSIBILITY FOR SITE REMEDIATION

1.  Comment:  A resident wanted to know which company was
    considered the responsible party for the Asbestos Dump-
    Millington site.

    EPA Response:  At this point in time, National Gypsum
    Company has been identified as a viable responsible party
    and has accepted EPA's offer to conduct the RI/FS at the
    site.

2.  Comment:  A resident asked what steps EPA would be taking to
    establish who would assume responsibility for the legal and
    financial components of the upcoming remedial activities.

    EPA Response:  After EPA signs a Record of Decision (ROD)
    selecting a remedial alternative for the site, the agency
    will negotiate with National Gypsum Company to provide them

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    the opportunity, in accordance with the law, to implement
    the selected remedy.  If National Gypsum Company accepts
    responsibility for site remediation, they may either pay for
    the remedial activities or conduct the work themselves with
    EPA oversight.  If the company declines responsibility for
    site remediation, EPA will implement the remedy with
    Superfund monies and seek to recoup the expenses from the
    responsible parties through legal channels.

C.  OTHER REMEDIAL ALTERNATIVES

1.  Comment:  A resident asked why EPA preferred the soil cover
    alternative over the asbestos removal alternative for site
    remediation.

    EPA Response:  Excavation and removal of the asbestos could
    create a potential public health threat by exposing the
    asbestos particles to the atmosphere.  The soil cover
    alternative reduces the potential for future airborne
    release of asbestos particles.  It also allows EPA to
    explore permanent treatment options that may be developed
    with innovative technologies.

2.  Comment:  A resident requested information on a remedial
    technology called vitrification.

    EPA Response:  Vitrification is a process in which the
    asbestos would be heated with electrodes to a temperature
    between 2,000 and 3,000 degrees Celsius which virtually
    melts the asbestos until it forms into a non-toxic glass-
    like substance.  Vitrification has been used successfully on
    some hazardous materials, but has not yet been used on
    asbestos.  Consequently, there is not enough data at this
    time to recommend vitrification as a viable remedial
    alternative.

O.  MISCELLANEOUS

1.  Comment:  A local official asked for clarification on the
    status of the three satellite sites that are a part of the
    overall Asbestos Dump site.

    EPA Response:  The RI results for the three satellite sites
    have been forwarded to the U.S. Department of the Interior
    for review and comment.  They will assist EPA in determining
    what additional field work is needed to assess any damage to
    natural wildlife or natural resources in the vicinity of the
    satellite sites.

2.  Comment:  A local official asked whether EPA would have a
    public meeting concerning the remedial alternatives for the
    satellite sites.

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EPA Response:  EPA will have a public meeting  for the
satellite sites during which EPA will present  the proposed
remedial alternatives and EPA's preferred alternative?
There will also be a public comment period to  give 'the
public an opportunity to discuss and comment on the
alternatives prior to signing of a ROD.

Comment:  A resident noted that the U.S. Army  Corps of
Engineers recently approved a flood plain program for the
Passaic River Basin and the program includes the
construction of a dam approximately 1,000 feet upstream of
the site.  The resident questioned whether the risks
involved with a potential dam break had been factored into
EPA's preferred alternative of soil cover, slope protection
and erosion and sediment control.                          '

EPA Response:  EPA intends to exceed the design
specifications for slope protection as much as possible.
Accordingly, EPA will contact the Corps of Engineers during
the design phase to determine the exact nature of their
flood control program,  to determine if the selected remedy
will maintain its desired level of protection.

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APPENDIX A

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