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

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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

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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

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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

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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

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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

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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


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                                               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

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                                                  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

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                          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

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                    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

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                     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).

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                            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

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                                     	 _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

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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.

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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.

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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

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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.

-------
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.

-------
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.)

-------
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

-------
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*

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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


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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

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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

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.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

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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

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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.

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         APPENDIX A
PROPOSED REMEDIAL ACTION PLAN

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  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.

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                                 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

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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.

-------
                          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

-------