United States
Environmental Protection
Agency
Office of.
Emergency and
Remedial Response
E PA/ROD/R02-89/098
September 1989
oEPA
Superfund
Record of
Chemical Insecticide, NJ
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT Ma
EPA/ROD/R02-89/098
3. Recipient1 • Accession No.
4. TOe and Subtitle
SUPERFUND RECORD OF DECISION
Chemical Insecticide,. NJ
First Remedial Action
5. Report D«te
09/29/89
7. Author(a)
8. Performing Organization Rept No.
9. Perfoiming Organization Nune and Address
10. Pro|ect/Taak/Work Unit No.
11. Contnct(C) or Grsnt(G) No.
(C)
(G)
12. Sponsoring Organization Name snd Address
U.S. Environmental Protection Agency
401 M Street', S.W.
Washington, D.C. 20460
13. Type of Report ft Period Covered
800/000
14.
IS. Supplementary Notes
16. Abstract (Limit: 200 words)
The Chemical Insecticide site is part of a 94-acre industrial development in Edison,
Middlesex County, New Jersey. From 1958 to 1970 Chemical Insecticide Corporation (CIC)
produced and stored pesticide formulations at the property resulting in soil, surface
water, and ground water contamination. The site is currently vacant and consists of the
remaining building foundations, asphalt roadways, a one-acre wetlands area, and a surface
water drainage ditch bordering the site to the east, which ultimately drains into the
Raritan River. Between 1966 and 1969 CIC was ordered by the city to close onsite
lagoons, dispose of leaking drums, and stop wastewater discharge. Subsequent RI/FS
investigations revealed the extreme complexity of the site due to the number and variety
of contaminants (herbicides, pesticides, and metals) and the physical characteristics of
the site. EPA performed two response actions to address concerns over high levels of
contamination in the drainage ditch. First, in February 1988, EPA installed a fence to
limit access to the ditch. The second action occurred in March 1989 when the ditch
overflowed and EPA responded by removing contaminated surface water run-off that had
collected in a parking lot onsite, and repairing the ditch to prevent future overflow
incidents. This operable unit represents an interim remedial action to address
contaminated surface water run-off from the site until the source of contamination, the
soil, is remediated. Future operable units will address contaminated soil and ground
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision - Chemical Insecticide, NJ
First Remedial Action
Contaminated Media: sw
Key Contaminants: organics (pesticides), metals (arsenic)
b. Identifiers/Open-Ended Terms
c. COSATI Held/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
76
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
Or IIUNAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R02-89/098
Chemical Insecticide, NJ
First Remedial Action
16. Abstract (continued)
water. The primary contaminants of concern in the soil which may affect the surface
water are organics including pesticides, and metals including arsenic.
The selected remedial action for this site includes clearing and grading the site;
covering the entire site with an impermeable surficial cap; constructing a surface water
run-off diversion system; controlling the release of collected, uncontaminated surface
water run-off from the site; and surface water monitoring. The estimated present worth
cost for this remedial action is $1,420,211, which includes annual O&M costs of $37,184.
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^
I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION a
^L^otf JACOB K. JAVfTS FEDERAL BUlDINa
NEW YORK. NEW YORK 10276
Declaration for the Record of Decision
chemical Insecticide Corporation Site
Edison Township. Middlesex Count,yf New Jersey
Statement of Basis and Purpose
This decision document presents the selected interim remedial
action for the Chemical Insecticide Corporation site, in Edison
Township, Middlesex County, New Jersey, which was chosen in
accordance with the requirements of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended by the Super fund Amendments and Reauthorization Act of 1986
(SARA) and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). This
decision document explains the factual and legal basis for
selecting the remedy for this site.
The New Jersey Department of Environmental Protection concurs
with the selected remedy. The information supporting this remedial
action decision is contained in the administrative record for' this
site.
Assessment of the Site
Actual or threatened releases of hazardous substances from
this site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an imminent
and substantial endangerment to public health, welfare, or the
environment.
Description of the Selected Remedy
This ROD addresses the first operable unit for the site. This
operable unit is limited to addressing the problem of contaminated
surface water run-off which drains from the site following heavy
precipitation events. Other problems at the site, including
contaminated soil and groundwater, will be addressed by one or more
future operable units following the performance of planned
treatability studies. The selected remedy is considered to be an
interim remedy because the planned future remediation of the
contaminated soil at the site would remedy the surface run-off
contamination problem by addressing the soil which is the source
of the surface water contamination.
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The major components of the selected remedy include the following:
- Site Grading
Surficial Capping
Controlled Release of Uncontaminated Run-off
Additional details and discussion of the selected remedy are
found in the Decision Summary for this Record of Decision.
Declaration of Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This interim remedy utilizes
permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable for this
operable unit. This interim remedy does not satisfy the statutory
preference for treatment as a principal element. Remedial
alternatives which utilize treatment technologies to control the
surface run-off from the site were determined to be less protective
than the selected remedy and, therefore, were not selected.
This remedy will result in hazardous substances remaining on
the site above health-based levels. A future ROD is planned for
a subsequent operable unit to address those remaining hazardous
substances. The need for five-year reviews to ensure that the
remedy remains adequately protective of human health and the
environment, as required by Section 121 (c) of CERCLA, will be
dependent on the levels of hazardous substances which will remain
at the site following the implementation of that future ROD.
William J/Murfzyttftci Date
Acting Regional Administrator
U.S. Environmental Protection Agency
Region IX
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Decision Summary for the Record of Decision
1. gite Name. Location, and Description
Chemical Insecticide Corporation (CIC) owned and operated the
property located at 30 Whitman Avenue in Edison, New Jersey from
1958 to 1970, manufacturing and formulating a variety of pesticide
products. The CZC property (i.e. the property formerly owned and
operated by CIC) is bordered on the north by Route 287 and on the
east, west and south by industrial properties. As used in this
Record of Decision (ROD), the "Chemical Insecticide Corporation
Site", the "CIC Site" or "the site" means the CIC property as well
as the power line easement area located along the eastern boundary
of the CIC property. The site is shown in Exhibits 1 and 2. (These
exhibits and all other exhibits are presented at the end of this
ROD Decision Summary.)
The CIC property is currently vacant, but does contain remnant
structures (e.g. building foundations and asphalt roadways) from
the pesticides manufacturing facility which once stood there.
Wetlands constitute approximately one acre of the CIC property,
which contains vegetation such as switchgrass, rushes and reeds.
A strip of property which is approximately 20 feet wide and is
located east of the CIC property contains Public Service Electric
and Gas (PSE&G) electric power lines. Metroplex Corporation has
granted an easement to PSE&G for the maintenance of the power
lines. Both the CIC property and the easement area are fenced to
restrict access.
The site is located in a 94 acre industrial development, however,
there are residential developments to the north and west of the
site. Approximately 2,870 residents live within a one-half mile
radius of the site. Within one, two and three miles of the site,
there are approximately 10,640, 37,720 and 76,700 residents,
respectively.
There are no permanent surface water bodies on the CIC Site. After
heavy precipitation, the surface water run-off drains toward the
east to the drainage ditch located on the power line easement. The
drainage ditch empties into an underground conduit which flows into
an unnamed tributary of Mill Brook. Mill Brook, in turn, flows
into the Raritan River (refer to Exhibit 2 for a map showing the
drainage from the site) approximately four miles downstream of the
site. None of these water bodies are used as a drinking water
source downstream of the site.
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The shallow groundwater in the vicinity of the site generally flows
toward the east. Groundwater is not used as a drinking water
supply in the immediate vicinity of the site. The nearest drinking
water well is a private well which is located some 3,200 feet
northwest of the site.
2. Site History and Enforcement Activities
Over the period that Chemical Insecticide Corporation occupied the
property at 30 Whitman Avenue in Edison, NJ (1958-1970), various
pesticide formulations were produced and stored on the property.
Over the period of CIC operations, the Edison Department of Health
and Human Resources (EDHHR) became concerned with activities on the
site due to numerous neighborhood complaints of site odors,
documented off-site discharges and releases, and the frequency of
on-site fires. EDHHR ordered cessation of discharges of wastewater
(1966 and 1969), oversaw the disposal of leaking drums to eliminate
an odor problem (1966), and required the closing of on-site lagoons
(1966). CIC declared bankruptcy in 1970. The property was
purchased in anticipation of future development by Piscataway
Associates, which demolished the production facilities on the site
(1975), leaving the concrete building foundations and asphalt
roadways.
Triggered primarily by the potential for the presence of dioxin (a
contami-nant generated in the production of 2,4,5-
trichlorophenoxyacetic acid, an herbicide which was handled on the
premises), both NJDEP and EPA performed on-site and off-site field
investigations at the CIC site, testing soils and surface water for
dioxin (1983). In 1984, NJDEP further sampled on-site soils for
the presence of other pollutants.
Based upon the analytical results from these investigations, EPA
Region II authorized a remedial investigation and feasibility study
(RI/FS) for the site. On-site and off-site RI field investigations
were performed over the period July 1987 through March 1988.
Concurrent with the RI/FS work, EPA conducted two response actions
at the site. In February of 1988 after discovering high levels of
contamination in the drainage ditch located in the power line
easement area east of the CIC property, EPA installed a fence to
limit access to the drainage ditch. (The CIC property was already
surrounded by a fence at that time.) In March of 1989 the drainage
ditch overflowed into the parking lot of the Metroplex property.
EPA responded by improving the drainage ditch to prevent overflows
and by removing the contaminated surface water run-off from the
parking lot.
Since the Chemical Insecticide Corporation is no .longer in
existence, EPA has not been able to take enforcement action against
CIC for the problems caused by the company. However, EPA has
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notified Mr. Arnold. M. Livingston, who vac the president of CIC,
of his potential liability with respect to the site.
3 . Highlights of Cofffflunity Participation
The RI/FS Report and the Proposed Plan for the CZC site were
released to the public for comment on August 3, 1989. These two
documents were made available to the public in the administrative
record repositories maintained at the EPA Region XI office located
at 26 Federal Plaza, New York, Mew York and at the Edison Township
Municipal Complex. A notice of availability for these two
documents was published in the New Brunswick Home News on August
3, 1989. A public comment period on the documents was held from
August 3 to September 8, 1989. In addition, a public meeting was
held on August 10, 1989. At this meeting, representatives of EPA
and of EPA's contractor, Ebasco Services, answered questions about
problems at the site and the remedial alternatives under
consideration. A response to the comments received during this
period is included in the Responsiveness Summary, which is part of
this ROD.
4. Scope and Role of this Operable Unit
The CIC site, as characterized by the RI field investigations, is
extremely complex, due to the number and variety of contaminants
present, the concentrations of contaminants documented, and the
physical and geological characteristics of the site. The specific
combination of chemical contaminants at the CIC site (herbicides,
pesticides and metals) will require performance of treatability
tests prior to identification of alternatives to remedy the entire
site. Preparation of an FS report which addresses all aspects of
the CIC site requires performance of the proposed treatability
tests and assessment of the results. Such treatability tests are
in the planning stage.
EPA has already taken two limited response actions related to the
surface water run-off problem at the site. The first action in
February of 1988 was to install a fence to prevent access to the
contaminated liquids and sediments in the drainage ditch east of
the CIC property. The second action in March of 1989 was to clean
up the overflow from the drainage ditch to the Metroplex parking
lot and to improve the ditch to reduce the likelihood of future
overflows. The surface water run-off during this overflow incident
had a yellow color that is characteristic of standing water at the
southern end of the CIC property. This yellow color is attributed
to dinoseb, an herbicide which has been found in samples of
standing water from the southern end of the site and in water
samples from the drainage ditch and parking lot during the overflow
incident. Dinoseb is known to produce a yellow color when
dissolved in water.
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These limited response actions have only partially addressed the
surface water run-off problem in that the surface water run-off
would continue to migrate to downstream waterways (i.e. the unnamed
tributary, Mill Brook and the Raritan River), with potential for
harm to the environment and for human exposure.
In this ROD, EPA is selecting an interim remedial action to control
contaminated surface water run-off from the CZC site until the time
that the FS addressing all aspects of the CZC site is finalized and
the resulting ROD is implemented. This action will be the first
operable unit (i.e., the first cleanup phase) of the remediation
of the entire site. EPA has elected to address the surface water
run-off problem as the first operable unit because of the threat
posed by the surface water run-off (see Section 2, above) and
because sufficient information is available to select an
appropriate remedy for this problem. This action will focus on one
of the principal threats presented by the site, that of the
contaminated surface water run-off.
One or more future RODs will address the remaining problems
presented by the site, including the contamination of soil and
groundwater. It should be noted that once the contaminated soil
at the site has been effectively remediated, the surface water run-
off from the site would no longer become contaminated by contact
with the soil. As a result, the remedy selected in this ROD would
no longer be needed after the contaminated soil is cleaned up.
Therefore, the remedy selected in this ROD is considered to be an
interim remedy which can be discontinued once a remedy for the soil
contamination has been implemented. EPA expects to be in a
position to select a remedy for the soil contamination after
treatability studies for the contaminated soils are conducted and
after the results . of the studies have been analyzed and
incorporated in a FS.
5. Summary of Site Characteristics and Site Risk
Based on results of the analysis of surface water samples collected
at and near the site, it was determined that surface water run-off
from the CIC site is contaminated with various pesticides (DDT,
DDE, dieldrin and lindane), herbicides (including dinoseb) and
metals (particularly arsenic). DDT/DDD/DDE, the hexachloro-
cyclohexane isomers (BHCs, e.g., lindane) and arsenic are all
considered potential human carcinogens. Dioxin was not found in
any of the surface water samples. The results of the analyses of
surface water samples collected during the RI are presented in
Exhibit 3. Results of the analyses of surface water run-off
samples collected during the March 1989 overflow incident are
presented in Exhibit 4.
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Chronic exposure to these pesticides (DDT and its metabolites, DDE
and ODD, and the BHCs) has been associated with a number of adverse
systemic effects, including liver and central nervous system
disorders. Arsenic is also considered a human carcinogen with
evidence most compelling for inhalation exposures. The chlorinated
herbicides and dinoseb, though not known to be carcinogenic to
humans, have been associated with adverse reproductive effects in
both humans and laboratory animals.
In addition to the adverse toxicological characteristics discussed
above, CIC-related contaminants also have physical/chemical
characteristics which warrant concern from an environmental
standpoint. For example, the chlorinated pesticides (DDT/DDD/DDE,
chlordane and dieldrin) are persistent in the environment and
absorb strongly to silts, sediment* and organic matter. These
compounds also exhibit significant bioaccumulation and are all
highly resistant to biodegradation and/or biotransformation
processes. Arsenic, one of the major contaminants detected at the
CIC site, is typically persistent in the environment.
Human exposure to the contaminants in the surface water run-off
from the site could result from wading or swimming in waterways
downstream of the drainage ditch or from ingestion of fish from
these waterways. Zn the event of another overflow of the drainage
ditch to the Metroplex parking lot, there would be an additional
opportunity for human exposure.
Samples of site soils, residual structures and groundwater also
showed contamination with pesticides, herbicides and metals.
Although dioxin was found in some samples of soil and residual
structures, because of its relatively low concentration, the risks
presented by dioxin are small when compared to the risks presented
by arsenic and pesticides. While the contamination of these media
does present potential risks, the fencing around the site and the
fact that the groundwater near the site is not used for drinking
water reduces the likelihood of human exposure to the contaminants
in these media, the cleanup of which will be addressed by one or
more future operable units.
•
6. Description of Alternatives
The alternatives analyzed for the interim action to control surface
water run-off from the CIC site are presented below. These are
numbered to correspond with the numbers in the focused RZ/FS report
which is available in the CZC site administrative record
repositories. The alternatives for run-off control are summarized
below:
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Alternative 1: No Action
Alternative 2: Site Grading/Surficial Cap
Installation/Controlled Release of
Uncontaminated Run-off
Alternative 3: Site Grading/Run-off Collection/On-site
Treatment/Discharge of Treated Water
Alternative 4: Site Grading/Run-Off Collection/
Transportation of Run-off to Off-site
Treatment Facility
COMMON ELEMENTS: With the exception of the No Action alternative,
the alternatives considered for the control of surface water run-
off include a number of common components including: site
preparation and grading for control of run-on to and run-off from
the site. The extent of the site preparation work for capping
(Alternative 2) is slightly greater than for either the on-site or
off-site treatment alternatives (Alternatives 3 and 4) in order to
assure a surface which will not adversely impact the cap during
installation. Alternatives 2 through 4 include site grading to
divert surface water run-on around the site and to enhance flow to
effectively collect site run-off. Treatment options in
Alternatives 3 and 4 differ primarily in the location of the
treatment units, on-site and off-site, respectively.
Alternative it MO ACTION
The NCP requires that the No Action alternative be evaluated at
every site to establish a baseline for comparison. Under this
alternative, EPA would take no further action at the site to
prevent exposure to surface water run-off from the site but would
continue to maintain existing controls in at the site. Existing
controls include the fences restricting access to both the CIC
property and the contaminated drainage ditch which is located in
the power line easement area, and warnings posted on the fence.
The No Action alternative also includes periodic monitoring of on-
site and off-site surface water and public information meetings to
warn area residents and workers of the hazards associated with the
site.
The estimated costs and time for design and construction of this
alternative are listed below:
Capital Cost: $0
Annual O&M Costs: $20,790
Present Worth (PW): $134,366
Months to Design and Construct: 0
8
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2t 8ITB QRADZMa/SUBTZCZAL
CAPPING/CONTROLLED RELEASE OF
UNCONTAMINATED RUM-OTF
Major features of this alternative include: clearing and grading
the site; covering the site (including the contaminated drainage
ditch and the portions of the easement area that are vest of the
drainage ditch) with a surficial cap; construction of a surface
water run-on diversion system; and controlled release of collected,
uncontaminated surface water run-off from the site. Because the
cap would include a liner material (e.g., high density
polyethylene) that would be nearly impermeable to water, this
alternative would effectively eliminate contact of precipitation
with the contaminated soils on the site.
The run-on diversion system would utilize berms, ditches, sheet
piling and/or other barriers to divert surface water from running
onto the site. The surficial cap would involve an impermeable
liner and is also likely to include one or more layers of material
such as a geotextile fabric to protect the impermeable liner.
Materials such as concrete or clay, which are sometimes used for
surficial caps, would not be utilized for Alternative 2. Concrete
is relatively permanent and could interfere with the future cleanup
of the contaminated soils below the cap. Clay caps must be thick
to be effective. The future removal of a clay cap to clean up the
underlying soil would generate a large amount of potentially
contaminated material. The run-off from the cap would be collected
in a storage area which would be created by the site grading and/or
by run-off control barriers. The uncontaminated run-off from the
cap would be released to the underground conduit in a controlled
manner to prevent downstream flooding. Zn addition, regular
inspections and maintenance would be performed to ensure the
continued effectiveness of the selected remedy. The details of the
surficial cap and other portions of this alternative would be
determined during the remedial design.
The estimated costs and time for design and construction of this
alternative are listed below:
Capital cost: - $1,179,891
Annual O&M Costs: $37,184
Present North (PW): $1,420,211
Months to Design and Construct: 10
An example of Alternative 2 is shown in Exhibit 6. This
representative example has been used for illustrative purposes and
for estimating the cost of this alternative. However, other
designs that are consistent with the above discussion of this
alternative may be found to be more effective during the remedial
design process and are not being ruled out.
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Alternative 3( 8ZTI ORADXKQ/RUH-OFr
COLLBCTZON/ON-8ZTB TREATMENT/
DISCHARGE OT TREATED WATER
Major features of this alternative include: construction of a
surface water run-on diversion systea; on-site collection and
treatment of contaminated surface water; and discharge of the
treated water. On-site collection would involve run-off control
barriers, a surface water collection sump and storage tanks to
which the contaminated surface water would be pumped. On-site
treatment would include process options to meet the cleanup
standards for discharge of surface water run-off listed in Exhibit
5. Process options considered include (but are not limited to):
activated carbon adsorption and ion exchange to treat the major
contaminants of concern in the surface water run-off (pesticides,
herbicides and metals). Options for discharge of treated run-off
water include either the unnamed creek which flows into the Mill
Brook or a permitted POTW (publicly-owned treatment works). The
details of the surface water treatment system and other portions
of this alternative would be determined during the remedial design.
The estimated costs and time for design and construction of this
alternative are listed below:
Capital Cost: $3,138,443
Annual O&M Costs: $212,007
Present Worth (PW): $4,508,644
Months to Design and Construct: 24
An example of Alternative 3 is shown in Exhibit 7. This
representative example has been used for illustrative purposes and
for estimating the cost of this alternative. However, other
designs that are consistent with the above discussion of this
alternative may be found to be more effective during the remedial
design process and are not being ruled out.
Alternative 4s BITE ORADZMO/RUH-OFP
COLLBCTIOM/OTF-SITB TRANSPORT AND
TREATMENT
Major features of this alternative include: construction of a
surface water run-on diversion system; temporary on-site collection
and storage of contaminated surface water; and trucking of
contaminated surface water to a licensed treatment facility. The
surface water collection and storage system would be similar to
that described for Alternative 3. The details of the surface water
storage system and other portions of this alternative would be
determined during the remedial design.
10 • i
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The estimated costs and time for design and construction of this
alternative are listed below:
Capital Cost:
Annual O&M Costs:
Present Worth (PW):
Months to Design and Construct:
$2,393,066
$2,551,300
$18,882,118
18
An example of Alternative 3 is shown in Exhibit 7. This
representative example has been used for illustrative purposes and
for estimating the cost of this alternative. However, other
designs that are consistent with the above discussion of this
alternative may be found to be more effective during the remedial
design process and are not being ruled out.
CLEANUP STANDARDS: Exhibit 5 lists the Applicable or Relevant and
Appropriate Requirement (ARARs) and To Be Considered standards
(TBCs) that pertain to one or more of the remedial alternatives.
For each cleanup standard (i.e., for each ARAR or TBC), the
alternatives to which that standard pertains are identified.
It should be noted that Federal and State requirements for capping
hazardous waste landfills and solid waste landfills have not been
selected as ARARs for Alternative 2, even though that alternative
involves capping the site. Those capping requirements were
intended to result in permanent caps, which would not be
appropriate for this interim action. A permanent cap would
obstruct future actions to cleanup the site soils and would result
in a large volume of potentially contaminated waste material when
the cap is removed to remedy the underlying soil.
Because wetlands on the site may be impacted by the proposed
remedial alternatives, Executive Order 11990, relating to the
protection of wetlands, is pertinent to this operable unit.
Section 1 of the Executive Order requires each Federal agency to
take action to minimize the destruction, loss or degradation of
wetlands when undertaking construction projects. Sections 2 of the
Executive Order requires each agency to avoid undertaking
construction in wetlands unless the agency finds that (1) there is
no practicable alternative to such construction, and (2) the
proposed action includes all practicable measures to minimize harm
to wetlands. Section 2 also identifies prevention of "risk to
health or safety" as a purpose of the Order, while Section 5(a)
specifies that "public health, safety, and welfare, including water
supply, quality, recharge and discharge? pollution; flood and storm
hazards; and sediment and erosion" are factors to be considered in
evaluating an action's impact on wetlands.
The on-site wetlands presently have a low functional value due to
their limited areal extent, low species diversity, isolation from
other wildlife habitats, and due to the high levels of
contamination with pesticides, herbicides and metals. Any
11
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significant protection of on-site wetlands is_not possible without
remediation of the contaminated on-site soils, which will be
addressed by a subsequent operable unit.
Alternatives 2, 3 and 4 each would result in some impact on the on-
site wetlands, with Alternative 2 causing the greatest impact
because this alternative would involve the stripping of all
vegetation from the site and the covering of the site with a cap.
Although this alternative would have the greatest impact on
wetlands, it will be found that Alternative 2 would also provide
greater protection of human health and the environment than the
other alternatives (see Section 7, below). Thus, there is no means
of achieving the objectives of this remedial measure (protecting
human health and the environment from the contaminated surface
water run-off from the site) that is more practicable for achieving
those objectives than Alternative 2. In view of the Executive
Order's language concerning public health and safety, the
implementation of Alternative 2 will meet the requirements of the
Executive Order.
The FS for the operable unit addressing the remediation of site
soils will evaluate methods to restore these wetlands and/ or to
mitigate any unavoidable adverse impacts on these wetlands.
Appropriate measures for wetlands protection will be selected in
a ROD based on that FS. EPA intends to provide substantive
protection of wetlands in this manner.
OFF-SITE WASTE MANAGEMENT: For all of the remedial alternatives,
any and all off -site shipment of hazardous substances to a
treatment, storage or disposal facility would be subject to EPA's
policy for off -site management of Superfund wastes (i.e., Revised
Procedures for Planning and Implementing Of f -site Response Actions,
November 13, 1987, as updated). This would be especially relevant
to Alternative 4, which involves off-site shipment of the collected
surface water run-off.
7. SvTOmarv of Comarative Analsis of Alternatives
A summary of the comparative analysis of alternatives using the
nine criteria established by EPA for evaluating alternatives is
presented below:
Overall Protection of Human Health and the Environment
Alternative 1 would continue to limit exposure to surface water
contaminants by restricting access to the site and by warning local
workers and residents of the risks they face by contacting the run-
off. However, contaminated run-off would continue to migrate out
of the restricted area to the unnamed creek, Mill Brook and the
Raritan River. Once implemented, Alternatives 2 through 4 would
protect both human and environmental receptors from contact with
12 •••'••••'
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contaminants in the site run-off by eliminating or removing
contaminants from the surface water run-off. Primarily because
Alternative 2 can be implemented in a shorter time than Alternative
3 or Alternative 4, it would provide greater overall protection of
human health and the environment over the intended duration of this
interim action, when compared to any of the other alternatives.
Compliance with ARARs
Alternative 1 would not directly address contaminated surface water
migrating from the site and, thus, would not attain the cleanup
standards for discharge of surface run-off identified in Exhibit
5. Once implemented, each of Alternatives 2, 3, and 4 would fully
address the contaminated surface water problem at the site either
by eliminating the contamination of the surface water by precluding
contact with contaminated site soils (Alternative 2) or by treating
contaminated surface water (Alternatives 3 and 4). Each of the
three alternative would attain all ARARs and TBCs which pertain to
it.
Long-Tenn Effectiveness
Alternative 1 is not effective in the long-term or short-term.
Alternative 2, 3 and 4 would each be effective, once implemented.
Because this is an interim remedial action, the long-term
effectiveness criteria was applied by evaluating the ability of
each alternative to be effective for the maximum expected duration
of the interim action (eight years). Each of these alternatives
can, with appropriate operation and maintenance, maintain its
effectiveness for the expected duration of the interim remedial
action.
Reduction of Toxicitv. Mobility or YftlMB?
None of the alternatives evaluated for the interim remedy would
utilize treatment to provide significant reductions in the
toxicity, mobility or volume of on-site contaminants. Although
Alternative 3 and 4 do involve the treatment of contaminants, the
reductions would not be significant in terms of the overall site
remediation. Measures to permanently reduce the quantities and
threats associated with the contaminants will be evaluated in a
subsequent FS which addresses the entire CIC site. Alternatives
2 through 4 would reduce the toxicity and volume of contaminants
in the surface water run-off to satisfy the goals of the interim
remedial action. Alternative 2 would also reduce the mobility of
contaminants by abating the mobilization of contaminants by
precipitation.
Short-Term Effectiveness
Alternative 1 presents the least short-term risks to on-site
workers since construction is not a task required for implementing
13
-------
the No Action alternative. However, it will not reduce the
existing risks. Alternatives 2, 3 and 4 each will require the
execution of health and safety protection measures, including
appropriate protective clothing and respiratory protection, during
the remedial construction to adequately protect workers. Health
and safety measures to protect the community, such as dust
suppression, will also be required. However, none of the
alternatives present implementation problems which cannot be
successfully addressed by available construction methods.
The estimated time periods for design of the systems and periods
for the construction are as follows: Alternative 2, 6 months for
design and 4 months to construct; Alternative 3, 12 months for
design and 12 months to construct; and Alternative 4, 9 months to
design and 9 months to construct. Therefore, Alternative 2 will
remediate the run-off problem and abate the associated risks most
quickly, followed by Alternatives 3 and 4, in that order.
Implementability
The No Action alternative is the simplest alternative to implement
from a technical viewpoint since it only involves actions to
periodically inspect and sample the site, ensure restricted access
to the site and continue to provide information about the site to
the surrounding communities.
The operations associated with Alternatives 2, 3 and 4 (e.g.,
clearing, grading, lining, excavation, surface water diversion and
detention techniques, pipe construction, treatment plant
construction) employ readily available and reliable operations and
are thus technically feasible. Alternative 2 requires greater site
preparation for protection of the impermeable liner. Alternative
3 and 4 require coordination with several vendors to implement the
associated collection, storage, transport and treatment tasks.
Alternative 3 would require the greatest technical effort.
Administrative efforts for the capping and treatment alternatives
involve obtaining access to the easement adjacent to the eastern
site boundary, possible relocation of utility lines, obtaining
regulatory agency approvals, development of a traffic control plan,
and inspection and maintenance of all site controls and systems.
Additionally, Alternative 4, would require a manifesting system to
track disposal of each tanker which transports the liquid waste.
Each of the tasks listed above is implementable from both an
administrative and a technical perspective.
cost
Alternative 1, No Action, has an estimated present worth cost of
$134,366. The primary constituents of this cost are inspection,
sampling, chemical analysis and public awareness programs* Present
worth costs for Alternatives 2, 3 and 4 are: $1,420,211;
$4,508,644; and $18,882,118; respectively. The major cost item for
14
-------
the capping system is the work associated with site preparation.
The other two alternative share the same costs for site
preparation. However, they differ significantly on the costs for
treatment. Treatment costs for Alternative 4 are higher because
of the off-site transport and treatment of the volumes of
contaminated surface water that are expected to be generated.
i
state Acceptance
The State of New Jersey Department of Environmental Protection
concurred with the selected remedy described in this Record of
Decision (Alternative 2). The State has not endorsed any of the
other remedial alternatives.
Community Acceptance
Members of the community who spoke at the August 10, 1989 public
meeting asked many questions to obtain information regarding the
RI/FS findings, the details of EPA's Proposed Plan and EPA's
rationale for the preferred alternative. One chief concern of the
speakers was how and when the entire site cleanup would be
accomplished. These speakers expressed a clear preference for a
complete cleanup of the site. However, they did not express a
clear position for or against any of the interim action
alternatives as the first step in a complete site cleanup. EPA
received one letter dated August 28, 1989 which contained written
comments on EPA's Proposed Plan. This letter was signed by about
twenty members of the community. The letter expressed opposition
to Alternative 2, as well as to the other alternatives developed
by EPA, on the grounds that none of these alternatives address the
cleanup of the entire site. This letter also expressed concerns
about possible air impacts resulting from earth moving activities
during the preparation of the site for capping, and presented a
number of other comments and questions. EPA has responded to these
comments by stressing the interim nature of the selected remedy and
by stating that EPA will proceed to develop and implement a
complete site cleanup plan as soon as it is possible. While
agreeing that this interim action is not a complete remedy, EPA's
response notes that this interim action will adequately deal with
the one route of exposure to contaminants from the site that
currently presents* the greatest risk (i.e., the contaminated
surface water run-off). The EPA response also provides assurance
that the remedial work will be performed in a manner that will not
cause adverse air quality impacts. In addition, EPA will be
available to meet with interested members of the community in the
future to discuss any remaining concerns about the site. (Refer to
the attached Responsiveness Summary for further details.)
8. Selected Remedy ,
EPA has determined that Alternative 2 is the remedial alternative
15
-------
that best satisfies EPA's evaluation criteria. Once implemented,
Alternative 2 is more protective than Alternative 1 and at least
as protective as Alternative 3 or Alternative 4. Because
Alternative 2 can be implemented more expeditiously than
Alternatives 3 or 4, it would attain overall protection of human
health and the environment more quickly than these alternatives.
Primarily for this reason, it provides greater overall protection
and greater short-term effectiveness than the other alternatives.
It is also less costly than Alternative 3 or Alternative 4. With
respect to the criterion of reduction of toxicity, nobility or
volume, Alternative 2 is only marginally less effective than
Alternatives 3 and 4. The State has concurred with the selection
of Alternative 2, but has not endorsed any .of the other
alternatives. Although some members of the community have
expressed their disagreement with the selected remedy, EPA's
responsiveness summary addresses those comments and concerns
expressed during the public comment period. With respect to all
remaining evaluation criteria, Alternative 2 equals or ranks higher
than any of the other alternatives. In addition, it should be
noted that Alternative 2 has less potential than Alternatives 3 or
4 to interfere with future remediation of the soils at the site.
The concrete foundations of the tanks that would be needed for
Alternatives 3 and 4 could interfere with the remediation of the
underlying soil, while the surficial cap for Alternative 2 could
be removed relatively easily.
Based on the above considerations, Alternative 2 is selected as the
remedy for the first operable unit.
9. Statutory Determinations
Protection of Human Health and the Environment
The selected remedy will adequately protect human health and the
environment from the contaminated surface water run-off leaving the
site. The cap which will be installed will be effective in
preventing contact between the water on the site surface and the
contaminated soils and debris beneath the cap. As a result the
water running off the cap will not contain significant
contamination or present significant risk. The selected remedy
will not pose unacceptable short-term risks during implementation.
While improving surface water quality, this alternative will not
adversely affect other media. In fact, the cap will have an added
benefit of reducing the migration of contaminants from the site to
the groundwater since the cap will prevent rainwater from
mobilizing site contaminants and carrying them deeper into the
ground. It will also eliminate the potential for direct contact
with the contaminants on the surface ot the site.
16
-------
Compliance with Applicable or Relevant and Appropriate Requirements
The selected remedy will comply with all Applicable or Relevant and
Appropriate Requirements (ARARs) and To Be Considered standards
(TBCs) that pertain to it. These ARARs and TBCs are identified in
Exhibit 5.
Cost-Ef fectiveness
The selected remedy is a cost-effective remedy and is the most
cost-effective of the alternatives which would adequately protect
human health and the environment from the surface water run-off
from the site.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
The selected remedy does not use permanent solutions and
alternative treatment technologies. However, it is not practicable
to use permanent solutions given the interim nature of this
operable unit and the fact that treatability studies are needed
before a permanent solution can be reliably selected. Those
alternatives which use treatment technologies for the surface water
run-off were evaluated and were found to be less protective of
human health and the environment than the selected remedy.
Section 121(b) of CERCLA requires that a selected remedial
alternative utilize permanent solutions and alternative treatment
technologies to the maximum extent practicable. However, Section
121(b) was not intended to make the use of permanent solutions and
alternative treatment technologies an end in itself, but was
intended to use such solutions and technologies to the extent
practicable, as a means of ensuring the protection of human health
and the environment. Since, for this operable unit, the remedial
alternatives which would make greater use of permanent solutions
or alternative treatment technologies are less protective than the
selected remedy, the seleced remedy utilizes permanent solutions
and alternative treatment technologies to the maximum extent
practicable, considering CERCLA's primary goal of protecting human
health and the environment.
» •
Preference for Treatment as a Principal Element
The selected remedy does not utilize treatment. As stated above,
it is not practicable to utilize a remedy which utilizes treatment
as the interim remedy for surface water run-off because such
remedies would be less protective of human health and the
environment than the selected remedy. Remedies utilizing treatment
as a principal element are being evaluated as part of the FS work
for the contaminated soils and groundwater at the site..
17
-------
Section 121(b) of .CERCIA creates a preference for remedies which
utilize treatment by requiring that the long-term disadvantages of
remedial alternatives are taken into account in the remedy
selection process. Since treatment alternatives tend to minimize
long-term disadvantages of remedies, remedies relying on treatment
are favored by taking long-term disadvantages into account.
However, Section 121(b) also takes short-term risks into account
in the remedy selection process. Section 121(b) was not intended
to establish treatment as an end in itself, but was intended to
create a preference for treatment as a means for ensuring the
protection of human health and the environment. Since, for this
operable unit, the remedial alternatives which have a greater
reliance on treatment are less protective than the selected remedy,
CERCIA's preference for remedies that rely on treatment as a
principal element has not been satisfied.
10. Documentation of Significant Chances
There have been no significant changes in the selected remedy from
the preferred remedy described in the Proposed Plan.
18
-------
EXHIBITS
-------
MULLER
MACNMERT
ALLIED CHEMICAL
EXHIBIT 1
DETAILED SITE LOCATION MAP
CHEMICAL INSECTICIDE CORP.. EDISON. N.J.
-------
-1300
1300
US. OWRONMENTAL PRO1ECHON AttWCY
OMPOftAllON
EXHIBIT 2
MILL BROOK WATERSHED
-------
EXHIBIT 3 (Sheet 1 of 2)
CHEMICAL INSECTICIDE CORPORATION
CHEMICALS DETECTED IN OM-SITE SURFACE MATER
UNITS: UG/L
COMPOUND
Al rili HI IT
M^rwW'vvl^
ALDR1M
OlELDRIN
4-4-OOC
4-4400
4-4-OOT
suvEx
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
0ERYUIUN
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAOCSIUN
NICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
VANADIUM
ZINC
COUNT OF
VALID
ANALYSIS
3
3
MINIMUM MAXIMUM MEAN
COUNT OF COUNT OF DETECTED DETECTED DETECTED
OCCURRENCES UNDETECTED* CONCENTRATION CONCENTRATION CONCENTRATION
COUNT OF COUNT OF
ESTIMATED REJECTED
VALUES VALUES
10
11
II
II
9
11
11
a
11
3
3
II
1
3
11
11
8
11
11
7
11
S
11
1
0
9
I
7
0
9
1
2
11
1
3
11
9
7
3
2
7
8
S
2
2
2
2
2
2
2
2
0
10
3
0
10
4
0
2
2
1
0
0
0
0
2
1
8
9
0
3
0
1.8
0.5
1.2
0.6
0.3
0.3
0.6
2.5
0.3
111.
55.
13.
28.
1.
4.
32700.
12.
15.
9.
227.
6.
6750.
22.
II.
2800.
3.
8.
6200.
9.5
49.0
1.8
0.5
1.2
0.6
0.3
0.3
0.6
2.5
0.3
3508,
55
1680,
217,
I,
10,
70208,
31,
15
19,
8750
6
427,
46
7540
3,
21,
22800.
93
287
1.8
0.5
I.
0.
0.
0.
0.
2.5
0.3
744.
55.
456.
84.
1.
6.
42S37.
16.
15.
14.
3772.
6.
8706.
176.
19.
4694.
3.
14.
12367.1
24.1
140.8
0
0
0
0
1
1
1
0
0
0
1
0
2
1
0
0
2
2
S
0
0
1
0
2
10
-------
EXHIBIT 3 (Sheet 2 of 2)
CHCHICAl INSECTICIDE CORPORATION
CHEMICALS DETECTED IN ON-SITE SURFACE MATER
UNITS: UG/L (EXCEPT PCOO/Ft s NG/L)
COMPQUMP
COUNT OF HINIMUN HAXINUM MEAN
VALID COUNT OF COUNT OF DETECTED DETECTED DETECTED
ANALYSIS OCCURRENCES UNDETECTED* CONCENTRATION CONCENTRATION CONCENTRATION
COUNT OF COUNT OF
ESTIMATED REJECTED
VALUES VALUES
DltMMS/TIMAMS (*f/1]
2378-TCOF
TETRA [TOTAL]
OCTA
8 1
10 - 1
. 10 1
7
9
9
0.2
0.2
0.7
0.2
0.2
0.7
0.2
0.2
0.7
1
0
0
0
0
0
1.2-OICHLOMKNZCNE
11
10
2.0
2.0
2.0
CHLOROFORM
4.4
4.400
4.4
-------
EXHIBIT 4
EPA REMOVAL ACTION WATER SAMPLE RESULTS
Two water samples were taken on March 7, 1989 by region II TAT.
These samples were collected in the drainage ditch on the east*
side of the CIC site and in the parking lot of Metroplez where
run-off had occurred. Samples were analyzed for priority
pollutant metals, volatile organics +15, PCB/Pesticides along
with a computer aided library search of 33,000 compounds.
Results are tabulated as follows:
MARCH 7, 1989 Water Suiple Results (PPB)
Compound Run-off Drainage Pit-rh
Aluminum 6,319.0 9,086.0
Arsenic 87.6 86.6
Barium 198.0 169.0
Cadmium 4.5 3.3
Calcium 25,684.0 14,866.0
Chromium 12.0 20.5
Cobalt 19.2 4.9
Copper 18.8 35.6
Iron 4,378.0 6,042.0
Lead 96.0 82.5
Magnesium 1,910.0 1,910.0
Mercury .49 .95
Nickel 27.5 19.2
Potassium 218,806.0 2,973.0
Di-n-butylphthalate 2.8
2(1-methyl-propyl-
4,6-dinitrophenol (Dinoseb) 225.0 181.0
bis (1,1-dimethylethyl)
phenol -— 12.0
0927K
-------
EXHIBIT 5 (Page 1 of 2)
SUMMARY OF ARARs AND TBCs AND THE
ALTERNATIVES TO WHICH THEY PERTAIN
FOR THE CHEMICAL INSECTICIDE CORPORATION SITE
ARAR OR TBC CRITERIA
ALTERNATIVES
NJPDES Water Quality Toxic
Effluent Limits
NJPDES Additional Requirements
Applicable to Discharges to
Surface Water
NJPDES Additional Requirements
for Users of Domestic
Treatment Works
Federal Pretreatment
Requirements for Existing
and New Sources of Pollution
Federal and New Jersey
Hazardous Waste TSD
Facility Requirements
New Jersey Soil Erosion and
Sediment Control Requirements
New Jersey Surface Water
Quality Standards
Federal Executive Order
Concerning Protection of
Wetlands
CITATION
NJAC 7:14-A,
Appendix F
NJAC 7:14A-3
NJAC 7:14A-13
40 CFR Part 403
40 CFR Part 264
and NJAC 7:26
NJAC 2:90-1.3
NJAC 7:9-4
Executive
Order 11990
PERTINENT
1, 2 and 3
1, 2 and 3
3 and 4
2, 3 and 4
1, 2 and 3
1, 2, 3
and 4
-------
EXHIBIT 5 (Page 2 of 2)
SUMMARY OF ARARs AND TBCs AND THE
ALTERNATIVES TO WHICH THEY PERTAIN
FOR THE CHEMICAL INSECTICIDE CORPORATION SITE
ARAR OR TBC CRITERIA
ALTERNATIVES
Health Advisory from the
Office of Drinking Water
for Dinoseb, EPA, August 1988
CITATION
PERTINENT
1, 2 and 3
CLEANUP STANDARDS FOR DISCHARGE OF SURFACE WATER RUNOFF
The following cleanup standards for the discharge of the surface
water run-off to a waterway have been selected for this remedial
action:
Contaminant
4,4 - DDT
4,4 - ODD
Dieldrin
Gamma BHC (lindane)
Dinoseb
Arsenic
Standard (uq/1)
0.001
0.001
0.0019
0.08
35.0
50.0
Except for dinoseb and arsenic, the standards are based on New
Jersey Pollutant Discharge Elimination System Toxic Effluent
Limits. The standard for arsenic is based on New Jersey Surface
Water Quality Standards. The Standard for dinoseb is based on a
Federal Drinking Water Health Advisory.
The above cleanup standards pertain to Alternatives 1, 2 and 3
(all alternatives involving a discharge of surface run-off to a
waterway at or near the site).
-------
EXISTING FENCE (METROPLEX)
RELOCATED
FENCE
15" DIA. CONC.
PIPE TO
EXISTING
STHRM
SEVER
EXISTNGRAD
UTILITY
PDI-E
-------
EXISTING
FENCE
UTILITY
LINE
PROPOSED
FENCE
RELOCATION
EXISTING
GRAVEL
ROAD
LINER
ANCHOR
TRENCH
EXISTING
FENCE
(TO BE REMOVED)
GEOTEXTILE
HDPE LINER
SECT A-A
PEA GRAVEL
GEOTEXTILE _
HDPE L
EXISTING
FENCE
LINER
ANCHOR
TRENCH
6" ASPHALT
CURB
EXISTING
BITUMINOUS
PAVEMENT
SECT B-B
UTILITY
LINE
EXISTING
FENCE
CHEMICAL INSECTICIDE CDRPDRATIDN
EXHIBIT 6
CROSS-SECTIONS
SHEET g OT 3
rBAsnn SFRVICFS
-------
UTILITY
LINE
PROPOSED
FENCE
RELOCATION
EXISTING
GRAVEL
ROAD
i
EXISTING
FENCE
(TO BE REMOVED I
RELOCATED)
SECT C-C
N.T.S.
PEA GRAVEL
GEOTEXTILE
HDPE LINER
CHEMICAL INSECTICIDE CORPORATION
EXHIBIT 6
CROSS-SECTIONS
siccr 3 or 3
EBASfO SFRVICES INCORPO
-------
EXISTING
FENCE
^~X
-------
UTILITY
LINE
EXISTING
FENCE
EXISTING
FENCE
6" ASPHALT
CURB
BITUMINOUS
PAVEMENT
SECT A-A
N.T.S.
UTILITY
LINE
EXISTING
FENCE
SECT B-B
N.T.S.
EXISTING
-- FENCE
EXISTING
FENCE
EXISTING
BITUMINOUS
ROAD
PROPOSED
DITCH
SECT C-C
N.T.S.
CHEMICAL INSECTICIDE CDRPDRATIDN
EXHIBIT 7
CROSS-SECTIONS
sett e or e
-------
_J* -— .*--
UTILITY
POLE
(TYP)
EXISTING
BITUMINOUS
ROAD
EXISTING
CURB
-100.
•~1
EXISTING
FENCE
(METRUPLEX)
PROPOSED
SHEET
L PILING
EXISTING
BITUMINOUS
ROAD
(IMPROVED)
PROPOSED
6" ASPHALT
CURB
SCALE
0.
100.
CHEMICAL INSECTICIDE CDRPDRATION
EXHIBIT 8
SITE LAYOUT FOR ALTERNATIVE 4
SNCCT i or e
FIBASCH SFRV1CFS INCORPORATION
-------
EXISTING
FENCE
UTILITY
LINE
6" ASPHALT
CURB
BITUMINOUS
PAVEMENT
(IMPROVED)
SECT A-A
N.T.S.
EXISTING
FENCE
EXISTING
FENCE
EXISTING
FENCE
UTILITY
LINE
SECT B-B
N.T.S.
EXISTING
FENCE
EXISTING
BITUMINOUS
ROAD
PROPOSED
DITCH
SECT C-C
N.T.S,
CHEMICAL INSECTICIDE CORPORATION
EXHIBIT 8
CROSS-SECTIONS
:HCCT * or e
FBASm SERVICES INCHRPriRA
-------
RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
CHEMICAL INSECTICIDE CORPORATION SITE
EDISON, NEW JERSEY
I. RESPONSIVENESS SUMMARY OVERVIEW
The U.S. Environmental Protection Agency (EPA) held a public
comment period from August 3, 1989 through September 8, 1989 for
interested parties to comment on the Focused Remedial
Investigation/Feasibility Study (RI/FS) report for Surface Water
Run-off Control and the Proposed Remedial Action Plan (PRAP) for
the Chemical Insecticide Corporation (CIC) Site in Edison, New
Jersey.
The PRAP, which has been provided as Appendix A of this document,
provides a summary of the background information leading up to
the public comment period. Specifically, the PRAP includes
information pertaining to the history of the CIC Site, the scope
of the proposed cleanup action and its role in the overall Site
cleanup, the risles presented by the Site, the descriptions of the
remedial alternatives evaluated by EPA, the identification of
EPA's preferred alternative, the rationale for EPA's preferred
alternative, and the community's role in the remedy selection
process.
EPA held a public meeting at 7:00 p.m. on August 10, 1989 at the
Edison Municipal Complex in Edison, New Jersey to outline the
interim remedial alternatives described in the focused RI/FS and
to present EPA's proposed remedial alternative for controlling
the surface water run-off from the CIC Site.
The responsiveness summary, required by the Superfund Law,
provides a summary of citizens' comments and concerns identified
and received during the public comment period, and EPA's
responses to those comments and concerns. All comments received
by EPA during the public comment period will be considered in
EPA's final decision for selecting the remedial alternative for
addressing surface water run-off from the CIC Site.
•
This responsiveness summary is organized into sections and
appendices as described below:
I. RESPONSIVENESS SUMMARY OVERVIEW. This section outlines
the purposes of the Public Comment period and the
Responsiveness Summary. It also references the
appended background information leading up to the
Public Comment period.
-------
II. BACKGROUND OH COMMUNITY INVOLVEMENT AMD CONCERNS. This
section provides a brief history of community concerns
and interests regarding the Chemical Insecticide
Corporation Site.
III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING
THE PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THESE
COMMENTS. This section summarizes the oral comments
received by EPA at the August 10, 1989 public meeting,
and provides EPA's responses to these comments.
IV. WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES TO THESE COMMENTS. This
section contains the one letter received by EPA
containing written comments, as well as EPA's written
response to that letter.
Appendix A: The Proposed Remedial Action Plan (PRAP)
which was distributed to the public during the public
meeting on August 10, 1989.
Appendix B: Sign-in sheets from the Public
Meeting held on August 10, 1989 in The Edison Municipal
Complex, Edison, New Jersey.
Appendix C: Names, addresses and phone numbers of the
information repositories designated for the CIC Site.
Appendix D: A list of the laboratories used to
analyze samples from the CIC Site.
-------
IX. BACKGROUND OH COMMUNITY mVOLVBCEMT AMD CONCERNS
Township records show that community concern regarding the CIC
Site, existed as early as 1966, when residents living near the
Site complained of odors emanating from the CZC Site. The Edison
Township Department of Health and Human Resources and the New
Jersey Department of Health (NJDOH) continued to receive
complaints from residents and business operators about odors and
air pollution from 1966 through 1970.
Community interest increased in June 1983 when the New Jersey
Department of Environmental Protection (NJDEP) and EPA began
collecting soil samples for a State-wide dioxin-screening
program. Residents were concerned about the potential for off-
site migration of dioxin into surrounding residential areas. EPA
held a public meeting on June 20, 1983 to address community
concerns. Several hundred residents attended the meeting and
extensive media coverage continued for weeks.
Residents, local officials and business owners were interviewed
in 1987 during the development of the Community Relations Plan
for the Site. Their concerns are summarized below:
• Residents would like to be better informed of all EPA
activities at the CIC Site.
• Residents were concerned about the potential exposure to
dioxin during EPA activities.
• Local officials and residents were concerned that local
property values could be adversely affected by the EPA
activities at the CIC Site.
• Residents and business owners were concerned regarding
the extent and potential of contamination at the Site and
of the surrounding business and residential properties.
As part of EPA1 s responsibility and commitment to the Superfund
Program, the community has been kept informed of ongoing
activities conducted at the CIC Site. EPA has established
information repositories where relevant site documents may be
reviewed. Documents stored at the repositories include:
• The focused RI/FS Report for surface run-off
control.
• The Proposed Remedial Action Plan (PRAP).
• Fact sheets, summarizing the technical studies
conducted at the Site.
• Public Meeting Transcript.
3
-------
EPA's selection of a remedy to control surface water run-off at
the Site will be presented in a document known as a Record of
Decision (ROD). The ROD and the documents containing information
that EPA used in making its decision (except for documents that
are published and generally available) will also be placed in the
information repositories, as will this responsiveness summary.
III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE
PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THESE COMMENTS
Oral comments raised during the public comment period for the CIC
Site interim remediation have been summarized below together with
EPA's response to these comments.
COMMENT: One resident wanted to know why it was necessary to
select an interim remediation alternative if a final remedy would
be the most protective of human health and the environment.
RESPONSE: A final remedy which would, among other things, clean
up the contaminated soil at the Site, cannot be selected at the
present time. EPA has determined that treatability studies are
needed to find the most effective technology or combination of
technologies for treating the Site soils. The particular mixture
of pollutants in the Site soils (arsenic and pesticides, in
particular) is potentially difficult to treat. This is because
the most proven technology for organic pesticides, thermal
treatment (e.g. incineration), may not be effective in treating
arsenic. In fact, the arsenic emissions from an incinerator
treating Site soils might present an air pollution hazard, unless
treatability studies can show that air pollution controls are
capable of reducing arsenic emissions to safe levels. Therefore,
EPA is currently planning to test thermal treatment and other
technologies such as soil extraction and soil fixation on soil
samples from the Site.
Depending on the final remedy eventually selected, it could take
up to eight years to perform treatability studies, select the
remedy, design the remedy and implement the remedy. Unless an
interim remedy is implemented first, the surface water run-off
from the Site would present continued risks until the remedy for
Site soils has been implemented.
EPA believes that the surface water run-off problem should be
addressed first, since EPA is now in a position to address the
hazards presented by the surface water run-off from the Site.
While the interim remedy is proceeding, EPA would not slacken its
efforts to achieve a final remedy. Once the final remedy for
site soil has been implemented, surface run-off from the Site
would no longer be contaminated by contact with Site soils.
Therefore, the surface water remedy is considered to be* an
interim measure which would no longer be needed once the Site
soils have been cleaned up.
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COMMENT: One resident asked what type of capping system would be
used and how effective would it be.
RESPONSE: If an impermeable surficial capping systea was
implemented, it would probably consist of a multi-layer cap with
a synthetic membrane or a sprayed-on lining, together with
protective layers, such as textile fabrics. Standard landfill
caps are intended to be effective for thirty years or more.
However, the capping system recommended by EPA for the CZC Site
would only be needed for the duration of the interim remedy
(probably less than eight years). This capping system would have
fewer layers than the standard landfill caps. Therefore, the
capping system would allow easier access to collect any soil
samples required for a treatability study, and would be easier to
remove once the final remediation plan was implemented.
COMMENT: A resident inquired whether capping systems have been
used on other sites and, if so, how effective they were.
RESPONSE: Surf icial caps have been employed at a number of sites
such as hazardous waste landfills and municipal landfills. This
technology has proven quite effective over time periods similar
to that contemplated for this interim action in preventing the
migration of contamination in the past.
COMMENT: One resident noted that there would be a large quantity
of run-off if a surf icial cap were installed on CZC's six acre
lot. The resident wanted to know what type of storage capacity
EPA has planned to accommodate the large volume of accumulated
run-off.
RESPONSE: A detention structure would be constructed in the
northeast corner of the Site to regulate the flow of discharge so
that the remedy would not cause any adverse flooding impact. As
part of the remedial design for Alternative 2, a drainage
analysis would be performed. The size of the detention structure
and the details of any other measures needed to avoid flooding
impact (e.g., improvements in area storm drains), would be based
on that drainage analysis. The detention structure for
Alternative 2 would not necessarily be designed to detain the
precipitation from a once in twenty-five year storm event.
COMMENT: A resident asked if Alternative 2 was selected, when
would EPA expect the surficial cap to be installed.
RESPONSE: Work could begin on capping the Site approximately six
months following finalization of the ROD for this interim action.
The remedial design would be performed during those six months.
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COMMENT: Several residents wanted to know if EPA had tested the
vegetation at the Site for contamination, and if EPA plans to
remove the vegetation in the near future in order to avoid
migration of the contaminants in wind-blown vegatative matter.
RESPONSE: Vegetation on the Site has not been tested for
contamination. However, based on the off-site soil sampling, it
does not appear that there has been any significant migration of
contaminants by wind-blown vegatative matter. The vegetation on
the Site serves to prevent erosion of the highly contaminated
soil. Therefore, EPA does not plan to remove the vegetation
until the grading is done at the Site.
COMMENT: One resident asked how EPA plans to reduce the amount
of soil and dust disturbance at the Site when grading is
performed.
RESPONSE: Soil and dust migration would probably be minimized by
wetting the Site. EPA has considered using a surfactant solution
to wet the Site. In addition, a wind fence could be installed to
avoid excess soil disturbance by wind. This problem has been
addressed at previous sites and air emissions have been kept
under control.
COMMENT: The same resident asked if air emissions would be
monitored while the cap is being constructed.
RESPONSE: There would be air monitoring during construction at
the Site. Methods for controlling air emissions will be
developed in detail during the Remedial Design.
COMMENT: One resident asked whether air sampling results showed
any detectible levels of contaminants.
RESPONSE: The test results indicated that the air contained low
concentrations of contaminants. These concentrations were
significantly below the permissible exposure limits (PELs) and
threshold limit values (TLVs) established by the Occupational
Safety and Health Administration (OSHA) and the American
Conference of Governmental Industrial Hygienists (ACGIH),
respectively.
COMMENT: One resident wanted to know what laboratory facilities
EPA used to analyze samples collected during the focused RZ/FS.
RESPONSE: Analyses were performed through EPA's Contract
Laboratory Program (CLP). Numerous laboratories participate in
the program. Approximately 65 laboratories were involved in
analyzing the samples from the CIC Site. (A list of the
laboratories that analyzed the samples is provided in
Appendix D.)
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COMMENT: A resident asked if EPA had conducted tests on the
neighboring residential areas.
RESPONSE: Residential areas were tested extensively for dioxin
from 1983 through 1985. No levels of dioxins above EPA's action
level (1 ppb) were found outside of the CZC property. There have
been no tests conducted on residential properties during the
recent RI for the CIC Site. However, tests performed on adjacent
industrial properties during the RI indicated that site-related
contamination of residential properties is highly unlikely.
COMMENT: Several residents asked if EPA planned to conduct
health studies and environmental tests in the neighboring
residential areas to the CZC Site.
RESPONSE: At this time, no health studies or environmental tests
in residential areas are planned. As part of Superfund
procedure, the Agency for Toxic Substances and Disease Registry
(ATSDR) has been consulted regarding the CZC Site, and has not
recommended health studies. ATSDR is in the process of reviewing
the RZ results, and may recommend health studies in the future.
COMMENT: One resident asked EPA to define ARARs and to briefly
explain how they were derived. Several residents wanted to know
how ARARS applied to the CZC Site.
RESPONSE: "ARARs" stands for applicable or relevant and
appropriate requirements of State and Federal environmental laws
(other than the Superfund Law). Section 121 of the Comprehensive
Environmental Response, Compensation, and Liability Act, as
amended (the Superfund Law) requires that, with limited
exceptions, a remedy selected under the Superfund Law attain all
ARARs that pertain to that remedy. Zn the case of the CZC Site,
ARARs that pertain to the interim action to control surface water
run-off, include the following concentration limits for the run-
off leaving the Site:
Contaminant XRAR fua/11
4,4 - DDT 0.001
4,4 - DDD 0.001
Dieldrin 0.0019
Gamma BHC (lindane) 0.08
Arsenic 50.0
Other ARARs for the interim action have also been identified in
the focused RZ/PS report.
Soil and groundwater ARARs exist for some of the contaminants
detected at CZC. Arsenic, pesticides and herbicides, found in
surface soil, soil boring, and groundwater samples significantly
exceeded the available ARARs. However, attainment of the ARARs
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for soil and groundwater is outside the scope of this interim
action, but will be addressed by future cleanup decisions and
actions.
COMMENT: Have air samples indicated that air pollution from the
Site nay be a threat to the community?
i
RESPONSE: OSHA guidelines provide a context for evaluating
concentrations of contaminants detected in air filter samples
from the air monitoring program. OSHA has established
permissible exposure limits (PELs) which define allowable
exposure levels for specific occupational settings. A PEL is
available is arsenic (0.5 mg/m ). The site-related contaminants
for the threshold limit values (TLVsK generated by ACGIH, are
DDT (1.0 mg/ar) and arsenic (0.2 mg/m3). In comparison with
these criteria, the measured concentrations of arsenic and DDT
found in the samples taken from the CIC Site were five orders of
magnitude below the OSHA and ACGIH standards.
Although the OSHA and ACGIH standards were intended to protect
workers in occupational settings, EPA believes that the fact that
air concentrations were far below these standards indicates that
site-related air pollution is not a significant threat.
COMMENT: A resident noted that OSHA standards apply to
occupational settings; therefore, exposure to contaminants would
therefore be limited to an 8 hour day. The citizen wanted to
know if local residents are in greater danger because they are
exposed to contaminants longer than the 8 hour/day OSHA standard.
RESPONSE: It would usually be inappropriate to apply OSHA
standards to residential areas because residents would be exposed
to contaminants for a longer period of time than workers, and
because certain residents, such as children, may be more
susceptible than most workers. However, EPA believes that OSHA
standards could be of use when evaluating the health risk for
residents because the concentration of contaminants is
significantly reduced as a result of the distance between the CIC
Site and residential areas. Also, see the previous response for
further information.
COMMENT: A resident wanted to know if EPA conducted a risk
assessment during the focused RX.
RESPONSE: A complete RI report, which contains a risk assessment
section, was submitted to EPA as a draft document by EBASCO. EPA
is currently reevaluating the risk assessment calculations and
incorporating more recently developed cancer potency factors not
included in the original assessment. Therefore, EPA has not
8
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released the risk assessment results as yet. Although the risk
assessment has not been finalized, EPA would discourage anyone
from using Mill Brook or the unnamed tributary for recreational
purposes.
COMMENT: A resident asked if there vas a risk of developing
cancer from being exposed to the contaminants near the facility,
or from swimming in Mill Brook or the unnamed stream.
RESPONSE: The RI data indicates that site-related soil
contamination is limited chiefly to the CIC property and the
easement area. Since access to these areas is controlled, there
is currently not a significant risk of human exposure to these
contaminated soils.
Given that arsenic is a human carcinogen and that there are
several potential human carcinogens in the surface water run-off
from the Site, there may be an increased likelihood of developing
cancer associated with wading or swimming in Mill Brook or the
unnamed stream. Preliminary risk calculations indicate that the
likelihood of developing cancer may be increased as.a result of
wading in these streams by a factor between 1 x 10 and
1 x 10~. A 1 x 10 (one in a million) cancer risk factor means
that, if a population of one million people is exposed to a
carcinogen under specified conditions, then it is estimated that
one person would be likely to contract cancer above and beyond
those.who would have contracted cancer due to other causes. A 1
x 10~° cancer risk is often accepted by EPA as a goal for
cleanups to attain.
It should be noted that the preliminary risk calculations
represent the risk of wading 216 times over a lifetime, not the
risk of one wading incident. It should also be noted that the
calculations were based on contaminant concentrations which were
not measured during, or shortly after, the occurrence of run-off
from the CIC Site. Substantially higher concentrations could
occur after a site run-off occurrence.
COMMENT: A resident asked who is going to pay for the cleanup.
RESPONSE: EPA has paid for the RI/FS using Federal Superfund
monies. The Superfund Law makes parties that are responsible for
the contamination liable for the costs of cleaning up Superfund
sites. CIC, which was responsible for the contamination at the
Site, went bankrupt in 1970 and is no longer in existence. EPA
has notified Mr. Arnold M. Livingston, the former president of
CIC, that he may be personally liable. However, EPA does not
believe that Mr. Livingston is financially capable of cleaning up
the Site, which is a multi-million dollar task. Therefore, EPA
believes that the cost of cleanup will be paid chiefly' by the
Federal and State governments, in accordance with the funding
requirements of the Superfund Law.
-------
COMMENT: On* resident wanted to know whether, if a responsible
party was paying for the cleanup, EPA would have chosen a final
remedy instead of proceeding with the interim remediation
alternatives.
RESPONSE: The source of funds for the cleanup work was not a
factor in EPA's decision to select an interim remedy to control
surface water run-off.
COMMENT: One resident asked if the herbicide, Dinoseb, which was
produced at the CIC Site and contaminated the run-off at the
Site, was the same type of herbicide used in Agent Orange.
RESPONSE: The herbicides used in Agent Orange were chlorinated
herbicides. Dinoseb is not a chlorinated herbicide. The two
active ingredients in Agent Orange have been found in samples
taken from the Site. Site files indicate that CZC handled the
chemicals used in Agent Orange at the Site but that CZC did not
manufacture them at the Site.
COMMENT: A resident wanted to know if the CZC Site was located
on wetlands.
RESPONSE: Contrary to an erroneous statement made by an EPA
representative at the public meeting, approximately one acre of
the CZC Site is located on wetlands. These on-site wetlands
would be temporarily impacted during the interim remedial action.
However, EPA will restore the wetlands, or, if that is not
feasible, mitigate the impacts to wetlands when final remediation
of the Site is implemented.
COMMENT: What future plans do the current owners have for the
CZC Site.
RESPONSE: The current owners have been very cooperative with
EPA. The present owners are not likely to make any use of the
Site until the cleanup work makes it safe to do so.
COMMENT: Several residents were concerned that they be kept
adequately informed of future developments, remedial plans, or
tests performed at the Site.
RESPONSE: The informational repositories designated for the CZC
Site contain the focused RI/FS, PRAP, fact sheets and other
documents. The Responsiveness Summary and the ROD will also be
placed in the repositories. There is also a two volume report of
sampling results that is available for review at the
repositories. EPA has also utilized letters to area citizens, a
press release and a public notice in the newspaper to inform the
public about EPA activities concerning the Site.
EPA will continue its efforts to keep the community informed of
developments related to the CZC Site.
10
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COMMENT: Several residents wanted to know if CIC has been placed
on the National Priorities List (NPL) as a Superfund site, or if
it is a proposed Superfund site.
RESPONSE: The CIC Site has not officially been placed on the
NPL. EPA Region II has submitted a proposal to EPA Headquarters
in Washington D.C. to include the Site on the NPL. A Site can
qualify for the NPL if it has a hazard ranking score higher than
27. The CIC Site has a preliminary ranking score of 37. CIC's
score ranks considerably higher than many of the sites presently
listed on the NPL. If the recommendation is accepted, the Site
would be proposed for the NPL in the next Federal Register
announcement concerning NPL listing, which is scheduled for
publication this fall.
Even if the Site has not been placed on the NPL at the time that
the construction of the interim remedy is to begin, funding the
interim remedy with Superfund monies would still be a
possibility. A portion of the Superfund is designated for
cleanup work at non-NPL sites.
11
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.
IV. WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
AND EPA RESPONSES TO THESE COMMENTS.
This section contains the on* latter received by EPA containing
written comments, as well as EPA's written response to that
letter.
12
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August 28* 1969
Jonathan Josephs
Remedial Project Manager
U.S. Environmental Protection Agency
26 Federal Plaza* Room 747
New York, New York 10278
Re: Chemical Insecticide Corp., Edison* New Jersey
%
Dear.Mr. Josephs s
On August 19* 1989 neighbors and concerned citizens met to
discuss the matter of the Chemical Insecticide Corporation
Superfund site* (CZC)* located on Whitman Avenue in Edison New
Jersey. We have the following questions and concerns which we
would like put on public record* addressed in the selection of
the remedial measures to be instituted for the site and answered
by your office.
The following past effects have not been addressed.
How much and what types of contaminants were
onsite and have spread off the site?
What effects did these contaminants have on
the workers of the factory* the community and
the surrounding land and animals?
What are the present problems with the site?
Is the onsite contamination level dangerous to
an unprotected person on the site?
Is there currently an active transport of the
contaminants off the site via air or water?
If so* are the surrounding human and animal
population currently exposed to contamination
from the site?
Do you think we should consult a doctor about possible
adverse effects? If so* what tests should be
performed?
The EPA should perform offsite sampling to determine if there is
offsite contamination and the extent and type of that
contamination. In addition* a study should be- performed
concerning the affects of the (CIC) operation and this superfund
site on the former employees of the Chemical Insecticide
Corporation and the past and current residents of the area*
-------
We feel the airborne sampling during the remedial investigation
(RI) was inadequate for the following reasonss
1. The standards applied to the small amount of
air data collected are work place standards and ,
are not to be used as environmental standards*
2. The airborne samples may have been collected
during optimum dust generation conditions but
the activities onsite during sampling did not
generate a relatively large amount of dust*
The air monitoring data does not even approximate
a worst case analysis as would be evidenced
during the stripping* grading and contouring of
the site.
The EPA's "preferred" alternative (12) is not acceptable to us.
Capping the land will generate high amounts of airborne
contaminants during its installation. The cap will hide the real
problem* it will be costly to install and maintain* and is not
reliable to do the job it is designed for.
The other alternatives that have been proposed do not address the
real problem which is the contamination on the land that is the
Chemical Insecticide Corporation site. Alternatives t 2* 3 and 4
only address the water running off the site* There are no
alternatives that address the actual cleanup of the site.
During the installation of any remedial measures the disturbance
of the site should be kept to a minimum. When the site is
disturbed* standard operating procedures and dust prevention
controls should be implemented to prevent airborne contaminants.
We saw no mention of emergency or contingency plans.
The lack of security at the site is a major concern. At
present* the only signs posted are rusted over so one cannot
even decipher that this is a hazardous area* quite unlike the EPA
slide of the site which was quite clear and unfortunately
misleading. The public should be informed of the potential
risks. You could utilize your mailing list to increase
awareness. Unfortunately most of the residents were unaware of
the EPA public meeting due to untimely and inadequate
announcements with no visible press release. Improvement in your
public relations and education would increase the chances of
selecting an alternative acceptable and understandable to a
majority of the public.
Do you have more information on the responsible parties? Is
there e way for private citizens to take legal action against the
responsible parties to recover the costs of cleanup?
-2-
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We are concerned about the pact, present and future impact of the
•ite on the community, our children, the land, animal* and the
value* of homes. We would like An expeditious response to our
letter* We feel that appropriate vehicles for response would
include written responses to each of us, those on your mailing
list and in your required summary of all public comments
concerning this matter*
We look forward to your timely response and continued
cooperation•
Sincerely
ccs Township of Edison
Borough of Metuchen
-3-
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•ijLf1lM'***Wi
-------
C/0 Matthew Reilly
3 Terrill Road
Edison, Mew Jersey 08817
Fold at line over lop of enveicoe lo the rigM
of lh< rtturn address.
i ' •
Mr* Jonathan Josephs
Remedial Project Manager
U.S. Environmental Protection Agency
26 Federal Place* Room 747
New York, Mew YorX 10278
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
1QQQ
!3W^
REGION •
JACOB K. JAVtfS FEDERAL BUUDING
NEW YORK. NEW YORK 10278
See Address List
Re: Your August 28, 1989 Letter Concerning the
Chemical Insecticide Corporation Site in Edison, New Jersey
Dear :
Thank you for the August 28, 1989 letter which you and other
concerned citizens wrote to express your questions and comments
concerning the Environmental Protection Agency's Proposed Plan
for an interim remedial action at the Chemical Insecticide
Corporation Site. The concerns expressed in your letter have
been reviewed by appropriate Environmental Protection Agency
staff, by Ebasco Services personnel who worked on the Remedial
Investigation and Feasibility Study for the site, and also by an
Agency for Toxic Substances and Disease Registry representative
assigned to the EPA Region II office. A response to the
questions and comments expressed in your letter has been
prepared, incorporating information obtained from the reviewers
mentioned above. A copy of this response is enclosed and is
being be sent to each of the signers of the August 28 letter.
Copies of both the August 28 letter and EPA's response will also
be placed in the information repositories for the Site.
EPA will keep you informed of our progress regarding the Chemical
Insecticide Corporation Site, including the decision regarding
the selection of an interim remedial action. I appreciate your
interest and participation in the Superfund program.
Sincerely yours
Jonathan Josephs
Chemical Engineer
New Jersey Compliance Branch
Emergency and Remedial Response Division
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ADDRESS LIST ,
Matthew A. Reilly and
Maureen Reilly
3 Terrill RD
Edison, NJ 08817
Jeff V. Sheard and
Lynn M. Sheard
2 Terrill Road
Edison, NJ 08817
Carol Herman
271 Newman Street
Metuchen, NJ 08840
C. Damian Spears and
Carol Spears
275 Newman Street
Metuchen, NJ 08840
Donald O'Neill
311 Rose Street
Metuchen, NJ 08840
Pat O'Neill
311 Rose Street
Metuchen, NJ 08840
Gail E. Toth
305 Rose Street
Metuchen, NJ 08840
D. S. Toth
305 Rose Street
Metuchen, NJ 08840
Shirley Stempinski
279 Newman Street
Metuchen, NJ 08840
Stephen Stempinski
279 Newman Street
Metuchen, NJ 08840
Carol Puchalski
265 Rose Street
Metuchen, NJ 08840
Bennett & Rosalie TVbrams
266 Newman Street
Metuchen, NJ 08840
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Elyidio Laguna
283 Newman Street
Metuchen, NJ 08840
Asela R. Laguna
283 Newman Street
Metuchen, NJ 08840
Patricia Frozier
101 Essex Avenue
Metuchen, NJ 08840
W. Zampetti
65 High Street
Metuchen, NJ 08840
Betty Ann Kirtman
14 Poets Lane
Metuchen, NJ 08840
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EPA RESPONSE TO THE AUGUST 28, 1989 WRITTEN COMMENTS REGARDING
THE CHEMICAL INSECTICIDE CORPORATION SITE IN EDISON, NEW JERSEY
The August 28, 1989 written comments regarding the Chemical
Insecticide Corporation Site have been summarized below, together
with and EPA's responses to these comments.
COMMENT: How much and what types of contaminants were on-site
and have spread off-site?
RESPONSE: The types of contaminants linked to the Site were
discussed at the August 10, 1989 public meeting and summaries of
the analytical data were presented. Unfortunately, the slides
that were projected were not very clear. The chief contaminants
are arsenic, pesticides (DDT, lindane, chlordane, dieldrin,
etc.), herbicides (e.g., 2,4,5-T, 2,4-D and dinoseb) and dioxin.
Summaries of this data, which provide concentration values for
the measured contaminants in the different media sampled, can be
found in Exhibits 1-12 through 1-24 of the Focused RI/FS Report.
The results for on-site and off-site samples have been summarized
separately in these exhibits. The complete set of sampling data,
together with maps showing the sampling locations, can be found
in the two-volume document containing the "Remedial Investigation
Field Data: Validated Laboratory Results" (Ebasco, July 1989).
These documents are available in the information repositories for
the Site. Because of the volume of this information, it is not
practicable to present it here.
COMMENT: What effects did these contaminants have on the workers
of the factory, the community and the surrounding land and
animals?
RESPONSE: There is little information currently available to EPA
indicating any effects of the contaminants on the CIC employees,
the area residents and animals. In the 1960's several cattle
were alleged to have died as a result of drinking arsenic
contaminated water downstream of the factory. However, the
levels of arsenic found at the downstream sampling locations
during the Remedial Investigation are much less than those
associated with such acute effects. In all likelihood, the
arsenic concentrations were much higher during the period when
the Chemical Insecticide Corporation was operating and the cattle
deaths occurred.
As noted at the public meeting, sampling results from the
Remedial Investigation and other studies indicates that
contamination of the land around the CIC property by arsenic,
pesticides and herbicides is chiefly limited to the easement area
immediately east of the CIC property. In addition, soil
concentrations of dioxin off of the CIC property have all been
-------
below the one part per billion action level recommended by the
Centers for Disease Control for residential areas.
COMMENT: Is the on-site contamination dangerous to an
unprotected person on the Site?
RESPONSE: Yes, although the degree of danger will depend on the
duration and frequency of on-site exposure and the type of
activities that the person conducts while on-site. Merely
standing or walking on-site for a short period of time would not
present a significant risk. On the other extreme, the long-term
ingestion of groundwater from beneath the site would present
risks far outside of the range of risks generally accepted by
EPA. Also, it should be noted that the reliance on other sources
of drinking water and the current restricted access to the site
prevent such high risk exposures.
COMMENT: Is there currently an active transport of the
contaminants off the Site via air or water? If so, are the
surrounding human and animal populations currently exposed to
contamination from the Site?
RESPONSE: The air monitoring results indicate that air transport
of hazardous substances is not a problem under the present
conditions. Off-site transport by surface water run-off is an
active transport route following heavy precipitation events.
Transport of contaminants by groundwater is also an active route,
but one which is much slower than the surface water route. This
is because of the slower flow of groundwater, compared to surface
water flow, and because many of the contaminants tend to be
adsorbed from the groundwater onto the soil. Humans and animals
are exposed to the surface water transported contaminants since
access to the unnamed stream and Mill Brook is not restricted.
The possibility of another overflow from the drainage ditch onto
the Metroplex property also cannot be ruled out.
COMMENT: Do you think we should consult a doctor about possible
adverse effects? If so, what tests should be performed?
RESPONSE: A doctor should be consulted if one experiences
symptoms of illness and for routine medical examinations. In the
event of illness, it may be useful to inform the doctor about the
patient's potential exposure to the contaminants from the CIC
Site. This information may assist the doctor in determining the
appropriate tests, along with other factors such as the nature of
the illness.
COMMENT: EPA should perform off-site sampling to determine the
extent and nature of the off-site contamination.
RESPONSE: As part of the investigations of the CIC Site and as
part of a separate investigation of the Muller Machinery
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property, extensive sampling of the industrial properties
surrounding the CIC property has been conducted. This sampling
indicates that the CIC related contamination of soils is limited
chiefly to the CIC property and the adjacent easement area.
Contamination has migrated a greater distance in the Mill Brook
sediments, but there are no indications that Site-related
contaminants have migrated from the industrial areas to
residential areas. Therefore, EPA does not plan to perform
additional sampling of off-site industrial or residential areas
at this time.
COMMENT: EPA should perform a study to determine the effects of
the Site on the former Site employees and on the past and current
area residents.
RESPONSE: The Agency for Toxic Substances and Disease Registry
(ATSDR), the Federal agency charged with performing epidemiologic
studies under the Super fund law, has been consulted by EPA
regarding the CIC Site. ATSDR has not recommended a health
effects study for the Site. However, ATSDR is in the process of
reviewing the RI results and may recommend a health effects study
in the future.
COMMENT: The writers feel that the remedial investigation air
sampling was inadequate because 1) the results of the sampling
were compared to workplace standards, which were not intended as
environmental standards, and 2) the results are not comparable to
the air contamination which would occur during the stripping and
grading of the Site during remediation.
RESPONSE: EPA's judgement that air contamination from the Site
is currently not a problem is not due only to the fact that the
measured levels of air pollutants were less than these standards,
but because the levels are more than one-thousand times less and
because the pollutants would be further diluted by the surround-
ing air in migrating off-site.
EPA agrees with the writers that the results are not reflective
of conditions that would occur during Site remediation. EPA's
judgement that stripping and grading of the Site would not cause
adverse air emissions was based on other information, as
described in the response to the following comment.
COMMENT: The writers state that EPA»s preferred remedy is
unacceptable to them because 1) it will generate high amounts of
airborne contaminants during installation, 2) the cap will hide
the real problem, 3) it will be costly to install and maintain,
and 4) it is not reliable to do the job it is designed for.
RESPONSE: 1) EPA does not agree that the installation of the
preferred remedy will generate high amounts of airborne
contaminants. EPA has performed cleanup actions at other sites
-------
.which involved extensive excavation of contaminated soils (for
example, the excavation of contaminated creek sediments at the
Love Canal Site in Niagara Falls, NY and the cleanup of the
Krysowaty Farm site in Hillsborough, NJ). Those actions had much
greater potential to generate airborne contaminants than the
proposed stripping and grading at the CIC Site, which would
involve comparatively little soil disturbance. Yet, those
actions were performed in a manner which protected the public
from air emissions. As further described in later responses
provided below, the grading and stripping would be done using
dust suppression methods. In addition, an air monitoring program
would be in place to identify any adverse air quality impacts and
a contingency plan for responding to air quality problems would
be developed and implemented. 2) EPA believes that the cap would
eliminate one real problem (surface water run-off) while EPA
continues its efforts to develop solutions for the remaining real
problems. As stated at the public meeting, EPA is planning to
perform treatability studies to identify the most appropriate
remedial technologies for cleanup of the Site soils. The soil
contamination problem is considerably more complex and will take
considerably more time to remedy than the surface water run-off
problem. In view of the fact that EPA can take action now to
stop the one threat from the Site which presents the most
immediate risk, EPA has elected to do so, rather than to leave
the storm water run-off problem unabated until a complete Site
cleanup can be performed. 3) While the cap is costly to install
and win have some maintenance costs, it is a cost-effective
remedy by Superfund standards, given the costs and associated
benefits for most remedial actions selected by EPA. 4) EPA
believes that the cap can be designed to do the job for which
this remedy is intended (that is, to reliably control the surface
water run-off problem until a complete remedy of the Site can be
implemented).
COMMENT: The other alternatives that EPA has considered also
fail to address the entire cleanup of the Site, but are limited
to addressing the problem of surface water run-off.
RESPONSE: This comment is accurate. As stated previously above,
future remedial measures are planned to address the remainder of
the Site cleanup. '
COMMENT: During the installation of any remedial measures, the
disturbance of the site should be kept to a minimum. When the
Site is disturbed, dust prevention controls should be
implemented. The writers saw no mention of emergency or
contingency plans.
RESPONSE: EPA intends to minimize the generation of airborne
contaminants during the implementation of the remedial action.
Attempts will be made to minimize Site disturbance to the extent
that this can be done while effectively implementing the remedial
-------
alternative that is selected. Methods to minimize air emissions
(such as soil wetting, wind screens and, if needed, a tent-like
enclosure over the work area) would be utilized to protect air
quality. In addition, air monitoring will be conducted during
the remedial work to confirm that air quality is acceptable, both
for on-site workers and for persons off-site.
Contingency planning is a routine part of any Superfund remedial
action. Typically, contingency planning includes:
- the identification of an emergency response coordinator and
chain of command to ensure that the contingency plan is
carried out
- the identification of the emergency response equipment (e.g.
fire extinguishers, first aid equipment, etc.) which must be
on hand, as well information concerning its use and
maintenance
- the emergency response arrangements with police, fire
department, hospitals and other emergency response
authorities
- the definition of the conditions requiring implementation of
the plan, for example, the criteria for unacceptable air
impacts
The details of the contingency plan, which may be a part of the
Site health and safety plan, may depend on the nature of the
remedy that is selected. Those detailed plans would be developed
during the remedial design of the selected remedy.
COMMENT: The lack of security at the Site is a concern to the
writers, as is the condition of the warning signs which are
rusted and difficult to read.
RESPONSE: EPA will soon add new warning signs and ensure that
they remain readable. With the added signs, EPA believes the
existing fence will provide adequate security.
COMMENT: The public should be kept better informed about the
Site. The public meeting announcements were untimely and
inadequate, and there was no visible press coverage.
RESPONSE: EPA agrees that the public meeting announcement fliers
should have been prepared and distributed earlier. In the
future, EPA will strive to time the distribution of its fliers to
provide sufficient advance notice. However, the distribution of
fliers was only one method used by EPA to notify the public about
the public meeting. A public notice announcing the public
meeting was published by EPA in the New Brunswick Home News on
August 3, 1989. In addition, on July 28, 1989 EPA sent press
releases to the Home News, the Newark Star Ledger, the. Metuchen-
Edison Review and the Woodbridge News Tribune, as well as to
those individuals and organizations on the mailing list for the
-------
Site. EPA is aware that at least one of these papers printed .a.
hews story concerning EPA's proposed plan for the Site and the
scheduled public meeting (an August 9, 1989 article in the New
Brunswick Home News). As a result of the increased community
interest in the Site resulting from EPA's Proposed Plan, the site
mailing list has been enlarged and more people will be informed
of future Site activities. (
COMMENT: Is there more information on the responsible parties?
Is there a way for citizens to take legal action against
responsible parties to recover costs of cleanup?
RESPONSE: The Chemical Insecticide Corporation went bankrupt in
1970. and is no longer in existence. Only one party has been
given written notice of his potential liability with respect to
the CIC Site. That party is Mr. Arnold M. Livingston, 50
Division Avenue, Millington, NJ 07946. Mr. Livingston was
formerly the president of the Chemical Insecticide Corporation.
The Superfund law does not limit any rights that a private party
may have under common law or under other state and Federal
statutes. However, it does not provide an injured party with
rights against a responsible party, unless that injured party is
the object of a Federal enforcement action under the Superfund
law. Citizens may wish to consult an attorney about their rights
under common law, state law and Federal statutes other than the
Superfund law.
COMMENT: The writers feel that EPA should expeditiously prepare
a response to their letter, directing it to each of them and to
those on the Site mailing list. EPA's response should also be
included in the required responsiveness summary.
RESPONSE: EPA intends to send a response to each of the writers
and to include the response in the responsiveness summary. Any
other interested persons may review this material in the Site
information repositories.
-------
APPENDIX A
PROPOSED REMEDIAL ACTION PLAN
-------
Superfund Program
Proposed Plan
Region
Chemical Insecticide Corporation Site
Edison, New Jersey
August 1989
EPA ANNOUNCES PROPOSED PLAN
This Proposed Plan identifies the preferred option
for controlling surface water runoff from the
Chemical Insecticide Corporation (CIO Site in
Edison, New Jersey (Figure 1). In addition, the Plan
includes summaries of other alternatives analysed
for addressing the surface water runoff problem at
this site. This document is issued by the U.S.
Environmental Protection Agency (EPA). EPA, in
consultation with the New Jersey Department of
Environmental Protection (NJDEP), will make a
final decision for the site only after the public
comment period has ended and the information
submitted during this time has been reviewed and
considered.
EPA is issuing this Proposed Plan as part of its
public participation responsibilities under section
117(a) of the Comprehensive Environmental
Response. Compensation and Liability Act
(CERCLA). This document summarizes information
that can be found in the focused Remedial
Investigation and Feasibility Study (RI/FS) report
and other documents contained in the administrative
record file for this site. EPA and the State
encourage the public to review these other
documents in order to gain a more comprehensive
understanding of the site and Superfuna activities
that have been conducted there. The administrative
record file, which contains the information upon
which the selection of the response action will be
based, is available at the following locations:
Edison Township Municipal Complex
100 Municipal Boulevard
Edison, New Jersey 08817
(201)287-0900
Mon-Fri: 9a.m. to 4p.m.
U.S. Environmental Protection Agency
4h^» CM .* V WW
26 Federal Plau
New York, New York 10278
(212)2644676
Moo'Pri: 9a.m. to 4
EPA. in consultation with the NJDEP may
modify the piefened alternative or select
another response action presented in this
Plan baaed on new information or public
comments. Therefore, the public is
encouraged to review and comment on aD of
the alternatives identified here.
DATES TU REMEMBER
MARK YOUR CALENDAR
August 3-24,1989
Public comment period on remedies to
control surface water runoff from the site.
August 10,1MQ at 7 p M.
Public meetinc at Edison Township
Municipal Complex Auditorium
FIGURE 1
CHEMICAL INSECTICIDE CORPORATION PROPERTY AND ENVIRONS.
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SITE BACKGROUND
Over the period that Chemical Insecticide
Corporation occupied the uiuueity at SO Whitman
Avenue in Edison, NJ (1956-1970), various pesticide,
herbicide and insecticide formulations were
produced and stored on the property. Over the
period of CIC operations, the Edison Department of
Health and Human Resouces (EDHHR) became
concerned with activities on the site due to
numerous neighborhood complaints of site odors,
documented offsite discharges and releases, and the
frequency of onsite fires. EDHHR oideied cessation
of discharges of wastewater (1966 and 1969).
oversaw the disposal of leaking drums to eHminate
an odor problem (1966), and required the dosing of
two onsite lagoons (1966). CIC was declared
bankrupt in 1970. The piepeity was purchased in
anticipation of future development by Piacataway
Associates who demolished the production facilities
on the site (1975), leaving only concrete building
foundations and asphalt roadways.
Triggered primarily by the potential for the presence
of cuozin (a contaminant generated in the production
of 2,4,5-trichlorophenoxyacetic add, an herbicide
which was handled on the premises), both NJDEP
and EPA performed onsite and offsite field
investigations at CIC, testing soils and surface water
for diozin (1983). In 1984, NJDEP further sampled
onsite and offsite soils for the presence of other
pollutants.
Based upon the analytical results from
investigations, EPA Region II authorized a remedial
investigation/feasibility study (RI/FS) at the site.
Onsite and offsite RI field investigations were
performed over the period July 1987 through Inarch
1988. Validated data from physical and chemical
samples collected during the field activities and
quantified in analytical laboratories are available in
the CIC Site Repository in the Edison Township
Municipal Complex.
Observations made during the RI field activities and
an EPA removal action required to control site
run-off onto the parking lot of the adjacent
Metroplex property (March 1989) indicate that
surface run-off from the CIC property may occur in
early spring as the result of heavy precipitation
falling on soils which are still frozen, causing offsite
runoff of rainwater and/or melting snow which has
contacted contaminated soils on the site.
Additionally, the potential exists for offsite surface
run-off during either extended or extreme rainfall
events over the remainder of the year.
SCOPE AND ROLE OF ACTION
The CIC site, as characterised in the RI field
investigations, is extremely complex, due to the
number and variety of contaminants present, the
concentrations of contaminants documented, and the
physical and geological characteristics of the site.
The specific combination of chemical nmtanv^fn**
•t the qC dte (herbiddes, peatiddes and metals^
will require performance of treatability tests priori
identification of alternatives to remedy the cot
dte. Preparation of an F8 report which addres
•n aspects of the CIC dto requires performance of
the propoaed treatability tests and assessment of the
EPA is proposing an interim action to control surface
water runoff from the CIC rite until the time the PS
addressing all aspects of the CIC site is finalised and
the *"^»«r lUeordof Dedakn (ROD)
implemented. EPA's Propoaed Plan identifies a
preferred alternative, based on the focused RI/FS,
which evaluated interim actions to control surface
water runoff from the CIC site intended to protect
human health and the environment
AX
Based on results of the analysis of surface water
samples collected and and near the site, it was
determined that surface water run-off from the CIC
site is potentially contaminated with selected
pesticides (DDT. DDE, DieMrin and Undine),
herbiddes (tododinf Diaoseb) and metals
(particularly ersenic). DDT/DDD/DDE, the
hexachlorocydohexane isomers (BBC*. e.g..
Lindane) and arsenic are all considered potential
human carcinogens. Chronic exposure to those
pastiddes (DDT and its metaboUtea, DDE and DDI
and the BHCs) has been associated with a number!
adverse systemic affects, mdnding over and
nervous system disorders* Arsenic is also considered
a human carcinogen with evidence most compelling
for inhalation exposures. The chlorinated herbicides
and Dinoeeb, though not considered carriimsjenlc to
humans, have been assodated with
reproductive effects in both humans and laboratory
In addition to the adverse toxicologieal
characteristics discussed above, CIC-related con-
taminants alt? have physical/chemical
iMictiM •fc«<4« wwv^nt oH^Mrn A
environmental standpoint. For example, the
chlorinated pesticides <5>DT/DDD/DDB, duordane
and dieldrin) are persistent in the environment and
absorb strongly to soils, sediments and organic
matter. These compounds also exhibit significant
bioaccumulation and are aQ highly resistant to
bfodegradation and/or biotranaformation .
Arsenic, one of the major contaminants detected at
CIC, is typically persistent in the environment.
Recommended cleanup objective* for surface runoff
quality selected for thetoteriin action to control
surface water runoff are baaed primarily UJNJU New
Jersey Pollutant Discharge- Elimination System
(NJPDES) regulations. The cleanup objective for
Dinoeeb is baaed upon the Safe Drinkinf Water Act
Health Advisory since no criterion is identified
this contaminant under NJPDES regulations.
• 2
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SUMMARY OF ALTERNATIVES
The alternative* analyzed for the interim action to
control surface water run-off from the CIC rite are
presented below. These are numbered to correspond
with the numbers in the focused RI/FS report which
is available in the CIC site administrative record file
in Edison and New York. The alternatives for
run-off control are summarized below:
o Alternative 1: No Action
o Alternative 2: Site Grading/Surficial Cap
Installation/Controlled Release of Uncontam-
inated Run-off
o Alternative 3: Site Grading/Run-off Collection/
Onrite Treatment/Discharge of Treated Water
o Alternative 4: Site Grading/Run-Off Collection/
Transportation of Run-off to Oflsite Treatment
Facility
COMMON ELEMENTS. With the exception of the
No Action alternative, the alternatives now being
considered for the control of offsite surface water
run-off include a number of common components
including: site preparation and gradingfor control of
run-on to and run-off from the rite. The extent of
rite preparation for capping (Alternative 2) is
slightly greater than either the onrite or offrite
treatment alternatives (Alternatives 3 and 4) in
order to assure a surface which will not adversely
impact the cap during installation. Alternatives 2
through 4 include rite grading to divert surface
water run-on around the site and to enhance flow to
effectively collect rite run-off. Treatment options in
Alternatives 3 and 4 differ chiefly in the location of
the treatment units, onrite and offrite, respectively.
Alternative 1: NO ACTION
Capital Cost: $ 0 ,
Annual Operation and Maintenance
(OAM) Costs: $ 20,790
Present Worth (PW): $134,366
Months to Design and Construct: 0
The Snperfund program requires that the No Action
alternative be evaluated at every rite to establish •
baseline for comparison. Under this alternative,
EPA would take no further action at the rite to
prevent exposure to surface water run-off from the
rite but would continue to maintain t*"**T>g controls
in place at the rite. Exisiting controls include the
fences restricting access to both the CIC property
and the contaminated drainage ditch which lies
between the rite and the Metroplex parking lot and
warnings posted on the fence. Tne No Action
alternative also includes periodic monitoring of
onrite and offrite surface water and public
information meetings to warn residents and workers
of the potential hazards associated with the rite.
Alternative 2: 8TIE GRADING/SURnCIAL
OUTING/CONTROLLED RELEASE OF
UNCONTAMINATED RUN-OFF
Capital Cost: 11,179,891
Annual OfcM Costs: $ 37.184
Present Worth (PW): $1,420,211
Months to Design and Construct: 10
Major features
construction of a
of this alternative
surface water run-on
include:
diversion
system; clearing and grading the rite; lining the
entire rite (including the contaminated drainage
ditch near the eastern boundary of the CIC propaity)
with a surficial cap; and controlled release of
collected, nncontaminated surface water run-off from
the rite. Because the Kmng material («.g., high
density polyethylene) would be nearly impermeable
to water, this alternative effectively eliminates
contact of precipitation with the contaminated soils
on the rite.
s: SITE QRADINQ/RUN-OFF
COLLECTION/ONBTTE TREATMENT/
DISCHARGE OF TREATED WATER
Capital Cost: $3,138,443
Annual OftM Coals: I 212,007
Present Worth (PW): $4,608,644
Months to Design and Construct: 24
of this alternative include:
surface water run-on diversion
•ttainment and treatment of
water; and discharge of the
Major feat
construction of
system; onrite cent
contaminated surface
treated water. Onrite
treatment would include
process options to meet NJFDES criteria for surface
discharge. Piecees options considered include (but
are not limited to): activated carbon adsorption and
ion exchange to treat the major contaminants of
concern in the surface water run-off (pesticides,
herbicides and metals). Options for surface
discharge of treated run-off water include cither the
unnamed creek which flows into the Mill Brook or a
permitted POTW.
4:_STTE GRADING/RUN-OFF
OOLLBCnON/OFFSrrE TRANSPORT AND
$ 2.393,066
$ 2£51,300
$18382,118
18
Capital Cost:
Annual OftM Costs:
Present Worth (PW>
Months to Design and Construct:
Major
features of Una alternative include.
of a fin hi T water diversion system;
onrite storage of contaminated surface
water, and trucking of contaminated surface water
to a licensed treatment facility.
-------
EVALUATION OF ALTERNATIVES
The preferred alternative for controlling surface
water run-off from the CIC site is Alternative 2:
Surface Grading/Surfidal Capping/Controlled
Release of Uncontaminated Run-off. Based on
current information, this alternative would appear to
provide the best balance of trade-ofis among the
alternative, with respect to the criteria that EPA
uses to evaluate alternatives. This section profiles
the performance of the piefened alternative against
these criteria, noting how it compare* to the other
options under consideration. A glossary of the
•Valuation criteria is provided below:
GLOSSARY OF EVALUATION CRITERIA
o Overall Protection of Human Health and
Environment addresses whether or not a
remedy provides adequate protection and
describes how risks posed through each
pathway are eliminated, reduced, or controlled
through treatment engineering controls or
institutional controls.
o Compliance with ARARs addresses whether or
not a remedy will meet all of the applicable or
relevant and appropriate requirements
(ARARs) of Federal and State environmental
statutes (other than CERCLA) and/or provide
grounds for invoking a waiver.
_ and performance
refers to the magnitude of residual risk and the
ability of a remedy to maintain reliable
protection of human health and the
environment over time, once cleanup goals have
been met. Given that this is an interim action,
effectiveness need only be p»««»t*it»H for the
duration of the interim action, which is
expected to be in the range of 3 to 8 years.
A substantial Reduction of Tapcity, Mobility, or
Volume of Contaennante at the site through
treatment is the preferred result of I
that may be employed in the remedy.
refers to the spaed
with which the remedy achieves protection, as
wen as the remedy's potential to create adverse
impacts on human health and the environment
that may result during the construction and
implementation period.
ImpleoMntabffitr is the technical and
istrative feasibility of a remedy, including t
availability of materials and services needed
implement the selected alternative.
the
to
o Goat include* capital and
COStS.
•tifl
and
o State A""Tr**"Mi* indicates whether, based on
its review of the RI/FS and Proposed Flan, the
State concurs with, opposes, or has no comment
on the piefened alternative. This criterion win
be addressed when State comments on the
Proposed Plan are received.
win be assessed in the
Record of'Decision following a review of the
public comments received on the RI/FS report
and the Proposed Plan.
-------
ANALYSIS OF ALTERNATIVES
Overall Protecti
Environment: Alternative 1 would continue to
limit exposure to surface water contaminant* by
restricting access to the site and by warning local
workers and residents of the risks they face by
contacting the run-off. However, contaminated
run-off would continue to migrate out of the
restricted area to the unnamed creek and to Mffl
Brook. Alternatives 2 through 4 would protect
both human and environmental receptors from
contact with contaminants in the site run-off by
eliminating or removing Mft^wfay** from the
surface water run-off.
nli
with
JURa: No Action (Alternative
1) would not directly address contaminated
surface water migrating from the site and, thus,
would not satisfy the recommended clean-up
objectives identified for the interim remedy.
Alternatives 2, 3, and 4 would fully address the
contaminated surface water problems at the site
either by eliminating the contaminantion of the
surface water by precluding contact with
contaminated site soils (Alternative 2) or by
treating contaminated surface water
(Alternatives 3 and 4). Each of the three
alternatives would attain all ARARs which
pertain to the interim action.
EfF*
BOSH: Alternative 1 is not
effective in the long or short-term. Alternatives
2, 3 and 4 are each effective, once implemented,
and each can maintain its effectiveness for the
expected duration of the interim remedial action.
Reduction of ToricitY. Mobility or Volume: None
of the alternatives evaluated for the interim
remedy provide significant reductions in the
toxicity, mobility or volume of onsite
contaminants. Although Alternatives 3 and 4 do
involve the treatment of contaminants, the
reductions would not be significant in terms of
the overall site remediation. Measures to
permanently reduce the quantities and threats
associated with the contaminants will be
evaluated in a subsequent PS which addresses
the entire CIC site. Alternatives 2 through 4
reduce the toxicity and volume of contaminants
in the surface water to satisfy the goals of the
interim remedial action objectives.
fihart^T
arm
s the
Alternative 1
presents the least short-term risks to onsite
workers since construction is not a task required
for implementing the No Action alternative.
However, it will not reduce the existing risks.
Alternatives 2, 8 and 4 each wiD require the
execution of health and safety protection
measures during the remedial construction to
adequately protect workers which include
appropriate protective clothing and respiratory
protection. Health and safety measures to
protect the community, such as dust
suppression, win also be lequiied. However, none
of the alternatives present implementation
problems which cannot be successfully addressed
by available construction methods.
The estimated time periods for design of the
systems and periods for construction are as
follows: Alternative 2, 6 months for design and 4
months to construct; Alternative 3,12 months for
design and 12 months to cumirutt; and
Alternative 4, 9 months to design and 9 months
to construct. Therefore, Alternative 2 wiD
remediate the run-off problem most quickly,
followed by Alternatives 3 and 4, in that order.
The No Action alternative is
Iternative to implement from a
viewpoint since it only involves actions
to periodically inspect and sample the site,
ensure issUktsd access to the site and continue
to provide information about the site to the
The
»tfons
ted with Alternatives 2, 3
grading, lining, excavation,
.—.^..J
ana
and 4 (e.g.,
surface water
techniques, pipe construction, treatment plant
construction) employ readily available and
reliable operations and are thus technically
feasible. Alternative 2 requires extensive site
prapenFettiofi for taM nDponBOexDio oner*
•^•tvt&rEafttiVM 9 Afiw ^f sTBQQla^O GOOe^Cuflav1 (tOO YVXvjSM
several vendors to implement the associated
collection, storage, transport end treatment
tasks. Alternative 3 would require the greatest
technical effort Administrative effort* for the
capping and treatment alternatives involve
obtaining access to the easement adjacent to the
eastern site boundary, potential relocation of
utility Unas, obtaining regulatory agency
approvals, development of a traffic control plan,
and inspection and maintenance of aD site
controls and systems. Additionally, Alternative
4, would require a mantfestinc system to track
disposal of each tanker which transports the
Bquid waste. Bach of the tasks listed above is
miplementable from both an administrative and
rtchnical perspective.
Coat: Alternative 1, No Action, has an estimated
present worth cost of $134,366. The primary
constituents of this cost are inspection, sampling,
«*«ii«fa«l analysis and public awareness
programs. Present worth costs for Alternatives
5, 3 and 4 are: $1,420,211; $4*08,644; and
118382,118; respectively. The major cost item
for the capping system is the work associated
with site preparation. The other two
alternatives have the same jaosU for site
preparation. However, they differ significantly
on the costs for treatment Treatment costs for
Alternative 4 are higher because of the ofixtte
transport and treatment of the large volumes of
contaminated surface water that are expected to
be generated.
-------
SUMMARY OP THE PREFERRED ALTERNATIVE
In summary. Alternative 2 would achieve substantial
risk reduction by minimizing surface water run-off
and eliminating contact of surface water run-off with
contaminated soils at the CIC site. Alternative 2
achieves this risk reduction more quickly and at
substantially less cost than any of the other options.
Additionally, the alternative does not conflict with
future remedies which may be selected to address
the entire site. Therefore, Alternative 2 is believed
to provide the best balance of trade-offs among
alternatives with respect to the evaluation criteria
and is proposed by EPA as the piefened alternative.
Figure 2 provides an illustrative example of this
alternative as it could be implemented. Detailed
discussion of the prefen'ed alternative is found in the
focused RI/FS for the surface water interim action
which is part of the administrative record for the
CIC Site (in the Edison Township Municipal
aplez).
THE COMMUNITY'S ROLE IN THE SELECTION
PROCESS
EPA solicits input from the community on the
cleanup methods proposed for each Superfund
response action. EPA has set a public comment
period from August 3 through August 24, 1989 to
encourage public participation in the selection
process. The comment period includes a public
meeting at which EPA will present the RI/FS Report
and Proposed Plan, answer questions, and accept
both oral and written comments.
The public meeting for the Chemical Insecticide
Corporation Site is scheduled for 7 p.m., August 10,
1989 and will be held in the auditorium of the
Edison Township Municipal Complex, 100 Municipal
Boulevard, in Edison, NJ.
Comments will be summarised and responses
provided in the Responsiveness Summary section of
the Record of Decision (ROD). The ROD is the
document that presents EPA's final selection for
cleanup. Written commenta should be sent to:
THE WORD NOTEBOOK
Specialised terms used elsewhere in this'
Piupueed Plan are defined below.
A wastewater
treatment technology in which wastewater is
contacted with activated carbon (a material
similar to charcoal). Certain contaminants,
such as most pesticides, win tend to adhere to
the carbon, purifying the water.
A wastewater treatment
technology in which harmful ions (electrically
charged particles) in the wastewater are
replaced by relatively harmless ion*. For
example, arsenic ions in wastewater, passing
through an appropriate ion exchange column,
may be replaced by sodium ions, trapping the
areenie on the column and purifying the water.
A Pubhcly-Owoed Treatment Works.
Although some POTWs treat only domestic
sewage, some are also permitted to treat
industrial wastewaters ana other wastewaters
containing hazardous substances.
Water Run-oft The temporary flow of
water along the surface of the ground after a
precipitation event (e.g., a rainstorm). Run-off
flows follow the path of least resistance,
moving uvUi higher ground to lower ground,
carrying materials nicked up from soils
itacted.
si Gap: A cover placed over the
surface. Common capping materials :
day and plastics. Pui poses of a cap may be to
contain waste below the cap and to keep
precipitation from contacting the waste and
spreading it.
Jonathan Josephs
Remedial Project Manager
U.S. Environmental Protection Agency
26 Federal Plaza, Room 747
New York, New York 10278
6
-------
FIGURE 2
CHEMICAL INSECTICIDE CORPORATION
PREFERRED ALTERNATIVE: ILLUSTRATIVE EXAMPLE OF SITE PLAN
EXISTING
CURB
EXISTING
BITUMINOUS
ROAD
13" CONCRETE
PIPE TO .
EXISTING
STORM
SEVER
rtj
PROPOSED
«" ASPHALT
CURB
CROSS SECTIONS A.B.C.
VTUTT
SCCT B-B
UIUTY
teer c-c
N.TX
HDPE
LINER
/ EARTHX
OWE /
EXISTING
FENCE
OCTROPLEX)
RELOCATED
FENCE
-------
APPENDIX B
BION-IM SHEETS
Ths following sign-in shoots aro from tho Public Information hold
August 10, 1989 at 7:00 pa. ia tho Edison Municipal Coaploz
Edison, V«v J«rs«y
-------
(VI
Q."
UNITED STATES PROTECTION AGENCY
REGIONII
PUBLIC MEETIBG
FOR
CHEMICAL INSECTICIDE CORPORATION 9Uir£kftliilD SITK
Kugust 10, 1989
ATTENDEES
(Please Print)
STRZET
ZIP
MAILING
LIST
-------
UNITED STATES PROTECTIOK AGENCY
REGION II
PUBLIC MEETING
FOR
CHEMICAL INSECTICIDE CORPORATION SUPERTUND SITE
Aujuat10, 198S
A'f PMUI lfc»^t
I Please Print)
KMLIH:
-------
APPENDIX C
INFORMATION REPOSITORIES
-------
REPOSITORIES TOR THE CHEMICAL INSECTICIDE CORPORATION SITE
Edison Township Municipal complex
100 Municipal Boulevard .
Edison, New Jersey 08817
(201) 287-0900
Mon-Fri: 9 a.m. to 4 p.m.
U.S. Environmental Protection Agency
26 Federal Plaza
New York, New York 10278
(212)264-8676
Mon-Fri: 9 a.m. to 4 p.m.
The Edison Library
340 Plainfield Avenue
Edison, New Jersey 08817
(201) 287-2298
Mon-Fri: 9 a.m. to 9 p.m.
Sat: 9 a.m. to 5 p.m.
The Metuchen Library
480 Middlesex Avenue
Metuchen, New Jersey 08840
(201) 632-8526
Hon., Tues., and Thurs: 10 a.m. to 9 p.m.
Weds., Fri., and Sat: 10 a.m. to 5 p.m.
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APPENDIX D
LIST OF LABORATORIES USED TO ANALYZE SAMPLES 7ROM THE CZC 8ZTE
-------
Page No.
08/22/89
LABORATORY
NAME
CHEMICAL INSECTICIDE CORPORATION
RI/FS FIELD INVESTIGATION
ANALYTICAL LABORATORIES USED
CITY
STATE ZIP CODE
*
*
*
*
*
*
*
*
*
*
*
Accu-Labs Research
Acurex Corporation
Alliance Technologies
Amer. Analy. & Tech
Analytical Resources
Aquatech, Inc.
Associated Labs Inc
CSMRI Analytical Inc.
California Water Labs
Cambridge Analytical
Centec Analytical
Century Laboratories
Century Refining Co.
Century Testing Labs
ChemTech Consulting
Clayton Env. Consultant
CompuChem Laboratories
EA Engineering Sci&Tech
EMS Laboratories
ENESCO/Cal. Analytical
ENSECO/Rocky Mountain
ETC/Toxicon Inc.
Eagle Picher
Ecology & Environment
Env. Control Technology
Env. Industrial Rsrch.
Env. Monitoring 6 Serv.
Env. Protection Systems
Env. Science & Engnring
Env. Testing & Cert.
Galson Technical Serv.
GeoChea Research Inc.
Gulf South Rsrch Inst.
Hazelton Lab Inc.
Hittman-Ebasco Assoc.
IT Analytical Services
IT Corporation
JTC Env. Consultants
Kansas city Scientific
Kemron
Laucks Testing Labs Inc
Mack Laboratories
Martin Marietta
MetaTrace Inc.
Northern Labs 6 Engring
Pacific Analytical Inc.
Post Buckley S & J
RF Weston Inc.
Wheat Ridge CO 80033
Mountain View CA 94042
Bedford MA 01730
Tulsa OK 74146
Seattle WA 98109
So. Burlington VT 05403
Orange CA 92668
Golden CO 80403
Madesto CA 95351
Boston MA 02215
Salem VA 24153
Thorofare NJ 08086
Brighton CO 80601
Bend OR 97709
New York NY 10014
Novi MI 48050
RTP NC 27709
Sparks MD 21152
Lakevood NJ 08701
W. Sacramento CA 95691
Arvada CO 80002
Baton Rouge LA 70814
Miami OK 74354
Buffalo NY 14225
Ann Arbor MI 48108
St. Rose LA 70087
Camarillo CA 93010
Pensacola PL 32506
Gainesville FL 32602
Edison NJ 08818
East Syracuse NY 13057
Houston TX 77084
New Orleans LA 70126
Madison WI 53707
Columbia MD 21045
Export PA 15632
Cerritos CA 90701
ROCkville MD 20850
Kansas city MO 64110
Baton Rouge LA 70810
Seattle WA 98108
Pittsburgh PA 15210
Columbia MD 21045
Earth City MO 63045
Valparaiso "IN 46383
Carlsbad CA 92008
Orlando FL 32805
Lionsville PA 19380
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Page No.
08/22/89
LABORATORY
NAME
CHEMICAL INSECTICIDE CORPORATION
RI/FS FIELD INVESTIGATION
ANALYTICAL LABORATORIES USED
CITY
STATE ZIP CODE
*
*
*
*
*
*
*
*
RF Weston Inc.
Radian Corporation
Resource Analysts Inc.
S-Cubed
SPL Inc.
Science Appl. Int'l.
Southwest Labs of OK.
Southwest Research Inst
Spectrix-Div. of K.E.R.
TMA/NORCAL
TMS Analytical Services
Thermo Analytical Inc.
Triangle Laboratories
US Testing Co. Inc.
University of Iowa
Versar Inc.
West Coast Analytical
Western Research Inst.
Weyerhauser Company
Wilson Laboratories
York Laboratories
Stockton
Sacramento
Hampton Falls
San Diego
Houston
La Jolla
Tulsa
San Antonio
Houston
Richmond
Indianapolis
Ann Arbor
RTP
Hobolcen
Iowa City
Springfield
Santa Fe Spring
Laramie
Tacoma
Salina
Monroe
CA
CA
NH
CA
TX
CA
OK
TX
TX
CA
IN
MI
NC
NJ
IA
VA
CA
WY
WA
KS
CT
95210
95827
03842
92121
77054
92038
74146
78284
77063
94804
46268
48104
27709
07030
52242
22151
90670
82071
98477
67402
06468
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