United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R02-91/139
June 1991
SEPA Superfund
Record of Decision
A.O. Polymer, NJ
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50272-101
REPORT DOCUMENTATION i. REPORT NO. 2.
PAGE EPA/ROD/R02-91/139
4. TMctndSdMHto
SUPERFUND RECORD OF DECISION
A.O. Polymer, NJ
First Remedial Action - Final
7. Authors)
9. Performing Oratmbrton Nsfne snd Address
12. Sponsoring OrgsntzstionNsme snd Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. RsdptenTs Accession No.
5. Report Dste
06/28/91
6.
8. Performing Orgsnlzrfon Rept No.
10. ProJectfTuk/WorkUnitNo.
11. ConlrscqC) or Grsnt(G) No.
(C)
(G)
IX Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Umft: 200 words)
The 4-acre A.O. Polymer site is an active resin manufacturer in Sparta, Sussex
County, New Jersey. Land use in the area is semi-rural, and the facility is
surrounded by wetlands. The A.O. Polymer site is one-half mile from Sparta High
School which has an onsite well, and 500 feet southeast of the Wallkill River, a
ground water discharge area. The ground water in the area is a current or potential
source of drinking water. From the early 1960's to 1978, Mohawk Industries operated
as a resin production facility and also reclaimed electronic component cleaning
fluids. In 1978, the A.O. Polymer Corporation purchased the site, and onsite resin
manufacturing operations continued to utilize the same storage vessels and
laboratories previously owned by Mohawk Industries. State investigations in 1978
identified VOC-contamination in local drinking water, and in 1979 the affected
residences were connected to the public water supply. Further State investigations
in 1978 identified improper waste handling and storage practices including disposal
of liquid wastes into unlined lagoons; improper storage of over 800 deteriorating
drums; and buried, crushed, and open drums containing VOCs and organic compounds. In
1980 and 1981, the State excavated and removed 120 cubic yards of crushed drums and
(See Attached Page)
NJ
17. Document Analysis a. Descriptors
Record of Decision - A.O. Polymer,
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, TCE, toluene, xylenes), other organics
. .._„_., _._.,. pesticides and phenols)
b, MenfiOers/Open Ended Ti"-~ ^ c
(PAHS, PCBS,
c. COSATI Held/Group
18. AnOabOty Statement
19. Security Class (This Report)
None
20. Security Class (TW» Psge)
None
21. No. of Pages
74
22. Price
(See ANS-Z39.18)
See Instructions en flewerae
OPTIONAL FORM 272 (4-77)
(Formerly NT1S-35)
ucpw liiitnt of Commerce
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EPA/ROD/R02-91/139
A.O. Polymer, NJ
First Remedial Action - Final
Abstract (Continued)
debris, 1,700 cubic yards of associated contaminated soil, and 1,150 surface drums. In
1982, State investigations confirmed that these disposal practices had resulted in the
contamination of potable ground water. This Record of Decision (ROD) addresses soil
contamination in the former waste lagoon area and the contaminated ground water plume,
and provides a final remedy for the site. The primary contaminants of concern
affecting the soil and ground water are VOCs including benzene, TCE, toluene, and
xylenes; and other organics including PAHs, PCBs, pesticides, and phenols.
The selected remedial action for this site includes treating contaminated soil onsite
using vapor extraction, with control of off-gas emissions using activated carbon;
treating minimal amounts of liquid condensate with an onsite ground water treatment
unit, or disposing of liquid condensate offsite along with the spent carbon; onsite
pumping and treatment of ground water using activated sludge in conjunction with a
powdered activated carbon treatment, followed by filtration and a carbon polishing
treatment; reinjecting the treated ground water onsite with a contingency for onsite
discharge to surface water, if necessary; and disposing of residual sludge offsite. An
ARAR waiver may be necessary if onsite discharge standards to surface water cannot be
met. The estimated present worth cost for this remedial action is $4,577,000, which
includes an annual O&M cost of $218,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Soil clean-up levels are based on State soil action
levels including total VOCs 1 mg/kg and total organics 10 mg/kg. Ground water will be
remediated to meet the more restrictive of State or Federal MCLs.
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ROD FACT SHEET
SITE
Name:
Location/State:
EPA Region:
HRS Score (date)
NPL Rank (date):
ROD
Date Signed:
Selected Remedy
Soils:
Groundwater:
Capital Cost:
O & M:
Present Worth:
LEAD
A.O. Polymer
Sparta, Sussex County, New Jersey
II
28.91 (2/91)
1039 (2/91)
June 28, 1991
Soil Vapor Extraction
Pump and Treat with a Powdered Activated
Carbon Treatment System
$ 2,186,000
$ 218,000
$ 4,577,000
Enforcement, EPA
Primary Contact (phone): Rich Puvogel (212-264-9836)
Secondary Contact (phone): Kim O'Connell (212-264-8027)
WASTE
Type:
Medium:
Origin:
Soil - toluene, trichloroethene,napthalene,
2-methy1naphtha1ene
Groundwater - trichloroethene,carbon
tetrachloride, chlorobenzene, methylene
chloride, 1,1,1-trichloroethane
Soil, groundwater
Pollution originated as a result of improper
disposal of hazardous wastes at this
location. Drums and liquid wastes were
dumped into unlined lagoons.
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DECLARATION STATEMENT
RECORD OF DECISION
A.O. POLYMER
FACILITY NAME AND LOCATION
A.O. Polymer
44 Station Road
Sparta,-Sussex County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the A.O. Polymer Superfund site. The remedial action was chosen
in accordance with the requirements of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980,
as amended by the Superfund Amendments and Reauthorization Act of
1986, and to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan. This decision
document explains the factual and legal basis for selecting the
remedy for this site.
The United States Environmental Protection Agency and the New
Jersey Department of Environmental Protection concur with the
selected remedy. Information which supports the remedy can be
found within the administrative record for the site.
ASSESSMENT OF THE SITE
Releases of hazardous substances from this site, if not addressed
by implementing the response action selected in this Record of
Decision, may present a current or potential threat to public
health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
The selected remedial action described in this document addresses
the principal threats posed by the A.O. Polymer site. It
addresses the remediation of contaminated soil and groundwater.
No further remedial actions are planned for the site.
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-2-
The selected remedy for the site includes the following
components:
- Vapor extraction of organic compounds in soils;
- Pumping and treatment of contaminated groundwater
utilizing a powdered activated carbon filtration system/-
and
- Implementation of an appropriate monitoring program to
ensure the effectiveness of the remedy.
STATUTORY DETERMINATIONS
f
The selected remedy is protective of human health arid 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 remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable, and
satisfies the statutory preference for remedies that employ
treatment that reduce toxicity, mobility, or volume as their
principal element.
Because the remedy will not result in hazardous substances
remaining on the site above health-based levels, the five year
review will not apply to this remedial action.
Constantine Sidamon-Eristoff
Regional Administrator
U.S. EPA Region II
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DECISION SUMMARY
A.O. POLYMER
Sparta, New Jersey
SITE DESCRIPTION
The A.O. Polymer site is an active facility, located at 44
Station Road in the Township of Sparta, Sussex County, New
Jersey. " The site occupies four acres near the Sparta Rail Road
Station along the New York, Susquehanna and Western (NYS&W)
Railway. Structures present at the site include office and
laboratory facilities, a main reactor building, assorted storage
buildings, and a non-contact water cooling water pond. The
office, reactor building, and laboratory are currently used by
A.O. Polymer in its present manufacturing processes. The cooling
water pond, which is located in the southeast quadrant, has no
surface outlet, and is lined with concrete. It is used for the
recirculation of non-contact cooling water and is periodically
replenished with water from an on-site production well.
The site is situated in a semi-rural, area near the Wallkill
River, about one-quarter mile from the commercial district of
Sparta and one-half mile from the Sparta High School. The site
is bounded to the north and east by Station Park, a municipal
recreation area, to the southeast by Station Road, and to the
south and west by the NYS&W Railway. Several small businesses
and three homes are located near the site on Station Road. The
Sparta High School lies one-half mile to the north-northeast and
a private gun club is located 500 feet northwest of the site.
The Wallkill River flows in a northerly direction and is located
500 feet to the southeast of the site (See Map, Attachment I).
SITE HISTORY
Mohawk Industries began operations at the site in the early
1960's. Mohawk was involved in the production of resins using
polymerization processes. Mohawk also engaged in the reclamation
of electronic component cleaning fluids containing freon
compounds in alcohol.
In 1978, the facility was purchased by A.O.. Polymer Corporation.
Along with the property, A.O. Polymer purchased the rights to
manufacture resin products previously produced by Mohawk. A.O.
Polymer continues to utilize the same processing machinery,
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storage vessels and laboratories used by Mohawk.
ENFORCEMENT
Complaints of odors emanating from well water and air near the
site were first registered by citizens living or working near the
site in 1973. Complaints of odors and bad smelling well water
intensified in 1978, touching off formal investigations by the
Sparta Health Department and the New Jersey Department of
Environmental Protection (NJDEP). In December 1978, NJDEP
inspectors and Sparta Health Department officials collected
samples from potable wells surrounding the site. Analysis of
these samples revealed the existence of volatile organic
contamination in three domestic wells located along Station Road.
In June.1979, the owners of the three affected wells filed damage
claims with the New Jersey Hazardous Spill Fund, and in January
of the following year, these homes were connected to the District
No.l water line which continues to provide the homes' with.
municipal water.
In 1978, NJDEP began investigating reports of drum stockpiling at
the site. These investigations identified on-site waste disposal
and storage practices as the source of groundwater contamination
in residential wells. Waste handling practices included disposal
of liquid chemical waste into unlined lagoons, improper storage
of over 800 deteriorating drums, and burial of crushed and open
drums containing waste materials including volatile and semi-
volatile organic compounds.
In 1980 and 1981, surficial cleanup at the site was initiated by
NJDEP, including the removal of surface drums and the excavation
and removal of contaminated soil located in the unlined lagoon
area. The area was excavated to a depth of approximately 10 feet
and backfilled with clean soil. This cleanup resulted in the
removal of 1,150 drums, 1,700 cubic yards of contaminated soil,
a/iu 120 cubic yards of crushed drums and debris.
Concern regarding the extent of groundwater contamination
resulted in additional investigations by NJDEP. In January 1982,
NJDEP's Division of Water Resources installed 11 monitoring wells
on and adjacent to the site to determine the extent of
groundwater contamination. Sampling confirmed that contamination
had reached the Allentown formation, which is a source of potable
water in the area. Sampling also revealed that groundwater
contamination had migrated to Station Park, 300 yards northeast
of the site.
The site was placed on the National Priorities List (NPL) on
September 1, 1983. In 1984, further investigation of the site
was performed by the NJDEP's Division of Hazardous Site
Mitigation. A Remedial Investigation and Feasibility Study
(RI/FS) was performed by ICF Technology funded by the U.S.
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Environmental Protection Agency (EPA) through a Cooperative
Agreement with NJDEP.
Complaints of odors emanating from the site have continued
throughout the 1980s and still continue. In response to repeated
complaints from residents in the area, NJDEP Division of
Environmental Quality has cited and fined the A.O. Polymer
facility for air emission violations. NJDEP is continuing to
investigate complaints concerning air emissions from the active
facility.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
On April 25, 1991, NJDEP presented the Proposed Plan for site
remediation, the RI/FS Reports, and other documents which
comprise the administrative record for this final remedy for the
site to the public for comment. These documents were made
available to the public at the EPA Administrative Re'cord File
Room, Room, 26 Federal Plaza, New York, New York; at the Sparta
Township Library, 22 Woodport Road, Sparta, New Jersey; and at
NJDEP, 401 East State Street, Trenton, New Jersey.
On April 25, 1991, NJDEP also issued a notice in the Jersey
Herald newspaper which contained information relevant to the
public comment period for the site, including the duration of the
comment period, the date of the public meeting and availability
of the administrative record. The public comment period began cr,
April 25, 1991 and was to end on May 24, 1991. However, based on
a request for an extension, the public comment period was
extended until June 7, 1991. A public meeting was held on May 9,
1991 at the Sparta Municipal Building located at 65 Main Street,
Sparta, New Jersey. At that time, the public was given an
opportunity to have questions and concerns about the site
addressed by NJDEP. In addition, written comments were accepted
during the public comment period. Responses to the significant
comments received during the public comment period are included
in the Responsiveness Summary (Attachment 4), which is part of
this Record of Decision (ROD).
SCOPE AND ROLE OF RESPONSE ACTION
The remedial action described herein addresses the principal
threats associated with the A.O. Polymer site. The remedial
action has been divided into two parts, one which addresses soil
contamination in the former waste lagoon area, and the other
which addresses groundwater contamination. The soil
contamination is believed to be the source of the groundwater
contaminant plume and is addressed under a source control
alternative. Groundwater contamination is addressed under a
management of migration alternative.
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The response action described in this ROD addresses all known
soil and groundwater contamination at the site and is the final
action contemplated for the A.O. Polymer site.
SUMMARY OF SITE CHARACTERISTICS
GEOLOGY
The region surrounding Sparta, New Jersey is underlain by many
rock types. Pre-Cambrian rocks form the hills to the west and
Sparta Mountains to the east of the town. The Wallkill River
Valley is underlain by a combination of Cambrian Hardystone and
Cambro-Ordovician Kittatinny Limestone of which the Allentown
Formation is of most importance. The Allentown Formation is a
thick, "rhythmically bedded, impure dolomite that locally contains
significant amounts of groundwater.
Sussex County is located in the New Jersey Highland''Physiographic
Province. This area is characterized by linear valleys and
ridges, predominantly trending northeast and southwest. This
linearity is the result of two major tectonic upheavals which
severely deformed the entire region. As a result, bedrock is
highly deformed by both folding and faulting.
The A.O. Polymer site is situated atop a small hill in the center
of the valley, possibly a remnant of a stratified drift deposited
by glacial meltwater. Water level measurements indicate that the
top of the water table is approximately 20 and 30 feet below
grade beneath the A.O. Polymer property. Depth to the top of the
water table decreases to the north and east until, in Station
Park next to the Wallkill River, it is only 2.6 feet below the
ground surface. Glacial deposits consisting of silts, sands,
gravel and boulders comprise the water table aquifer. The water
table aquifer extends down to the top of the bedrock at a depth
ranging from 17 to 123 feet. In addition to being highly
fractured and weathered, the bedrock also has locally significant
solution cavities. This bedrock, also known as the Allentown
Formation, is a source of potable water in the Wallkill Valley.
SOILS
As mentioned above, surface soils from the former waste lagoons
were remediated by NJDEP in 1980 and 1981. During this removal
action, the top 10 feet of the contaminated soils in the lagoon
area were excavated and disposed of off-site. The excavated area
was then backfilled with clean fill, leaving behind unsaturated
residual soil contamination between a depth of approximately 10
to 25 feet.
Residual soil contamination from the "former lagoon disposal area
is the major source of the groundwater contamination emanating
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from the site. The source area is located approximately 10 feet
below the ground surface down to the water table at a depth of 25
feet. The estimated volume of contaminated soil is approximately
7,500 cubic yarQs. Subsurface soil analysis indicates that
organic chemicals seeped from the lagoons into the unsaturated
soil zone, also known as the vadose zone, and are now located
within the pore spaces of the soil. The organic compounds
retained in the soil pores are relatively mobile. These
compounds desorb upon contact with infiltrated groundwater
providing a relatively constant release of contamination to
groundwater for as long as immersible liquids remain. As a
result, the contaminated vadose zone soils are likely to
constitute a prolonged and significant source of groundwater
contamination.
On-site soil samples taken from 17 borings revealed the presence
of various organic compounds significantly above background
levels. Metals were detected at levels similar to background
levels. The Volatile Organic Compounds (VOCs) detected most
frequently and in highest concentrations include toluene at 61
parts per million (ppm), and trichloroethene at 27 ppm. Semi-
volatiles compounds, including napthalene at 16 ppm, 4-
methylphenol at 14 ppm, and 2-methlylnaphtalene at 9.6 ppm were
also detected. These and other volatile and semi-volatile
compounds were found between 10 and 25 feet below the ground
surface underlying the former lagoon area. The compounds and
detected ranges, as well as soil cleanup goals are listed in
(Table 1A). These levels are above the New Jersey Soil Action
Levels of 1 ppm for total VOCs and 10 ppm for total semi-VOCs.
Contaminants in subsurface soils, the source of groundwater
contamination, are not readily accessible for human contact and,
therefore do not pose a direct contact hazard. However,
contaminants from this soil continue to be released into
groundwater.
GROUNDWATER
The water table beneath the A.O. Polymer property is between 20
to 30 feet below grade. Depth to the water table decreases to
the north and east of the property, until it is only 2.6 feet
below the surface in Station Park next to the Wallkill River. RI
data show that both the water table and bedrock aquifers are
hydraulically interconnected and that groundwater contamination
from the site has moved downward through the glacial overburden,
and migrated from the site through the shallow portions of the
Allentown formation. Groundwater contamination in the water
table aquifer consists primarily of volatile organic compounds
including carbon tetrachloride,. chlorobenzene, methylene
chloride, 1,1,1-trichloroethane. The compounds were detected at
levels above the Federal and New Jersey Maximum Contaminant
Levels (MCLs) for these compounds. A list of groundwater
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contaminants for both the water table and bedrock aquifer is
presented in Table IB.
The RI data has defined the latitudinal (east - west) and
longitudinal (north - south) extent of the groundwater
contaminant plume. The northernmost boundary of the plume is 400
feet north of the site, and the southernmost boundary of the
plume does not appear to extend past the southern boundary of the
site, refer to map, Attachment 2. Latitudinally, the plume
appears to have stabilized. The plume emanates from the former
disposal lagoon area and extends to the Wallkill River in the
east/northeasterly direction. The plume is confined to
relatively shallow portions of the groundwater flow system and is
discharged to the river along with the normal groundwater flow.
The dowhgradient extent of the plume from the former lagoon area
is limited by the Wallkill River. Transport past the river is
not indicated by the data and appears to be unlikely given
present hydrologic conditions. The Wallkill River ifs a
groundwater discharge area, a fact that is corroborated by the
apparent convergence of piezometric contours at the river and the
upward gradients observed along both sides of the river.
Furthermore, contamination in the deep wells on the east side of
the river (opposite the site) has not been detected, suggesting
that the plume is confined to relatively shallow portions of the
flow system and is thus discharged to the river along with the
groundwater.
In summary, as a result of the present extent of contamination
and the assessment of contaminant fate and transport, it appears
that present opportunities for exposures to site contaminants in
groundwater are limited. Currently, groundwater contamination
from the A.O. Polymer site is unlikely to present a direct threat
to existing potable water supplies. All affected existing wells
along Station Road, with the sole exception of the A.O. Polymer
well used for production processes, have been replaced with
municipal water supplies. Contaminant transport from the former
lagoon area is believed to be approaching an almost steady state
condition,.and the plume may not continue to spread. Groundwater
concentrations near the contaminant source have decreased since
1985 but have remained relatively stable for the last two
monitoring episodes. This suggests a nearly constant input from
residual contamination at the source. Downgradient from the
source, near the center of the plume, a slow but gradual increase
in concentration of contaminants was observed until 1987. The
latest data indicates a decrease in groundwater contamination
suggesting a levelling off trend. Such behavior is typical for a
constant source and steady state conditions. Continued migration
of the plume beyond its present boundaries" is unlikely.
Therefore, all known existing water supply wells, including the
Sparta High School well, are currently at minimal risk of
becoming contaminated. ' .
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Although there is minimal risk currently posed by contaminated
groundwater at the site, potential risk would exist if a well is
placed in the contaminated groundwater plume sometime in the
future. The Allentown formation and the water table aquifer in
the study area are important sources of water in the valley and
it is possible that a potable well could be installed within or
near enough to the plume to be affected. The ingestion of
contaminated groundwater would cause unacceptable risks to human
health.
SURFACE WATER
Surface water bodies in the vicinity of the site include the
Wallkill River, a small wetland area located downstream of the
site, and an unnamed tributary to the Wallkill River which is
located approximately 500 feet to the north of the site. The
A.O. Polymer facility lies on the surface water divide between
the Wallkill River and the unnamed tributary, which'joins the
Wallkill River about one mile northeast of the site.
The main source of surface water contamination at the site is
contaminated subsurface soils and groundwater. As residual
subsurface soil contaminants enter the groundwater they
eventually discharge to the wetland area and the Wallkill River.
The groundwater contaminant plume is presently discharging to the
wetland area located on the west side of the river as well as the
river itself, as evidenced by detections of 1,1-dichloroethene
(1,1-DCE) and 1,2-dichloroehtene (1,2-DCE) in surface water
samples from the wetland and river. Eight surface water samples
were taken from four points in the river and wetland. Samples
taken upstream from the contaminant discharge plume are
consistent with background levels. The only organic contaminants
detected upstream of the groundwater plume discharge area were
methylene chloride and acetone. It is believed that most
volatile organic compounds entering the Wallkill River from the
contaminated groundwater are quickly attenuated by dilution,
volatilization and degradation as reflected by the low levels
detected in the downstream samples (see Table 1C). Direct
contact with water in the Wallkill River and the wetland provide
minor opportunity for exposure.
The wetland area is located 1,600 feet northeast of the site and
extends along the side of the river approximately 1,200 feet.
Surface water samples from the wetland area have higher
contaminant concentrations than the surface water samples
collected from the Wallkill River. Concentrations of volatile
organic compounds, including 1,2-DCE, dichloroehtane, vinyl
chloride, and trichloroethan0. in surface water samples collected
from the wetland are presented'in Table ID.
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SEDIMENTS
Four sediment samples from the Wallkill River indicate the
presence of one volatile organic compound, toluene, and one semi-
volatile compound, di-n-butylpthalate, at levels above background
(Table IE). Background levels were determined by sampling
sediments upstream of where the contaminated groundwater plume
discharges to the Wallkill River.
AIR
Sources of air contamination include contaminated subsurface
soils, groundwater, surface water and ongoing operations at the
A.O. Polymer facility. No air sampling was performed on the site
during the RI. Air emissions from volatilization of contaminants
from subsurface soils, groundwater, and surface waters were
modeled. Due to the current operations at the facility, and
other sources, it would be difficult to collect air •'samples that
are representative of any contribution from VOCs detected in site
soils, groundwater, surface water, or sediment. In addition, air
emissions from the operations at the A.O. Polymer plant have in
the past and continue to be investigated by NJDEP.
Volatile contaminants in subsurface soils, groundwater, or
surface water can be transferred to air at rates dependent on
atmospheric and chemical specific properties. Volatile organic
contamination is present in on-site subsurface soils in high
concentrations, but is present 10 feet or more below the soil
surface. Some emissions of volatile organic vapors may occur,
however, subsurface contamination is well below the surface and
is localized in the former lagoon area at A.O. Polymer, a remote
area, which is not frequented by people.
Volatile organic contamination in soils not only spreads to the
groundwater, but volatile vapors from subsurface soils can also
diffuse through the soil pore spaces in the vadose zone and be
released into the atmosphere. Similarly, some volatilization
from groundwater in the water table aquifer will occur for those
contaminants that are volatile. Transfer of contaminants to the
atmosphere from groundwater is most likely to occur in areas of
Station Park where depth to the water table is shallow. Also, as
contaminated groundwater discharges to the Wallkill River, some
volatilization will occur there. It is expected that these
volatile organic emmissions will be dispersed by air currents
within a short distance, resulting in bulk air concentrations
that are extremely low.
SUMMARY OF SITE RISKS
EPA conducted a baseline Risx Assessment (RA) of the ."No Action"
alternative to evaluate the potential risks to human health and
the environment associated with the A.O. Polymer site in its
8
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current state. The RA focused on contaminants in the
groundwater, surface water and air which are likely to pose
significant risks to human health and the environment.
contaminants of concern were identified for the site. The
summary of the contaminants of concern in sampled matrices is
listed in Table 1.
EPA's RA identified several potential exposure pathways by which
the public may be exposed to contaminant releases at the site
under current and future land-use conditions. A total of six
exposure pathways were evaluated under present and future land
uses (Table 2).
Under current EPA guidelines, the .likelihood of carcinogenic
(cancer-causing) and noncarcinogenic effects due to exposure to
site chemicals are considered separately. Toxic effects of the
site-related chemicals are additive. Thus, carcinogenic and non-
carcinogenic risks associated with exposures to individual
compounds of concern were summed to indicate the potential risks
associated with mixtures of potential carcinogens and non-
carcinogens, respectively.
Noncarcinogenic risks were assessed using a hazard index (HI)
approach, based on a comparison of expected contaminant intakes
and safe levels of intake (Reference Doses). Reference doses
(RfDs) have been developed by EPA for indicating the potential
for adverse health effects. RfDs, are expressed in units of
milligrams per kilogram per day (mg/kg/day) which are thought to
be safe over a lifetime of exposure (including sensitive
individuals). Estimated intakes of chemicals from environmental
media (e.g., the amount of a chemical ingested from contaminated
drinking water) are compared with the RfD to derive the hazard
quotient for the contaminant in the. particular media. The HI is
obtained by adding the hazard quotients for all compounds across
all media.
A HI greater thar 1 indicates that the potential exists for non-
carcinogenic health effects to occur as a result of site-related
exposures. The HI provides a useful reference point for gauging
the potential significance of multiple contaminant exposures
within a single medium or across media. The reference doses for
noncarcinogenic compounds of concern at the A.O. Polymer site are
presented in Table 3. A summary of the noncarcinogenic risks
associated with these chemicals across various exposure pathways
is found in Table 4.
Since the HI is less than 1 for the current land use scenarios,
non-carcinogenic adverse health effects are unlikely for the
contaminants quantitatively assessed.
For a future groundwater ingestion scenario however, the
potential hazard index under both the average and reasonable
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maximum exposure (RME) cases exceeds one, due primarily to the
liver toxicants carbon tetrachloride, 1,2-dichloroethene, and
trichloroethene.
Potential carcinogenic risks were evaluated using the cancer
potency factors developed by EPA for the carcinogenic compounds
of concern. Cancer slope factors (SFs) have been developed by
EPA's Carcinogenic Risk Assessment Verification Endeavor for
estimating excess lifetime cancer risks associated with exposure
to potentially carcinogenic chemicals. SFs, which are expressed
in units of (mg/kg/day)"1, are multiplied by the estimated intake
of a potential carcinogen, in mg/kg/day, to generate an upper-
bound estimate of the excess lifetime cancer risk associated with
exposure to the compound at that intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated
from the SF. Use of this approach makes the underestimation of
the risk highly unlikely. The SF's for the chemicals assessed
are presented in Table 5. , '
For known or suspected carcinogens, EPA considers exces's
upperbound individual lifetime cancer risks of between 10** to 10"6
to be acceptable. This level indicates that an individual has no
greater than one in ten thousand to one in a million chance of
developing cancer as a result of site-related exposure to a
carcinogen over a 70-year period under specific exposure
conditions at the site.
The cumulative upper bound risk from all evaluated exposure
pathways at the A.O. Polymer site is 4.7 x 10"*. The breakdown of
risk for each exposure pathway analyzed appears on Table 6. The
risks for carcinogens at the site are at the high end of the
acceptable risk range. Because of the presence of sensitive
populations (i.e. children) that can potnetially be exposed, the
point of departure for cancer risks was considered to be
1 X 10"6. Residents ingesting contaminated groundwater within the
groundwater plume emanating from the A.O. Polymer site would have
a lifetime upper bound excess cancer risk of 2 X 10"1 under the
average case, and 4 X 10"4 under the Reasonable Maximum Exposure
(RME) case, primarily due to the compound 1,1-dichloroethene.
These risks exceed EPA's Superfund risk range of 10"4 to 10"6.
For local residents breathing the ambient air, the lifetime upper
bound excess lifetime cancer risk is 8 X 10"6 under the average
case and 6 X 10"5 under the RME case. For recreational users of
Station Park breathing the ambient air, the upper bound excess
lifetime cancer risk is 9 X 10'7 under the average case and
6 X 10"6 under the RME case. These risks associated with
inhalation of volatile chemicals in the air are notably less than
the acceptable risk range.
A qualititative risk assessment evaluated the risks to residents
exposed via other pathways to the chemicals in groundwater during
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home use of groundwater. Most of the organic chemicals in
groundwater are volatile and residents could be exposed via
inhalation of chemicals that have volatilized during activities
such as showering, cooking and washing clothes. Dermal
absorption could result during bathing or washing. Exposure via
these pathways would add to overall exposure and risk. The
scientific literature on this subject indicates that the risk
associated with these sources may be similar in magnitude to that
associated with ingestion thus, for all practical purposes, the
risks calculated for ingestion may be doubled to estimate the
importance of this effect.
The upperbound excess lifetime cancer risk for children wading in
the wetland area is 1 X 10"6, due solely to vinyl chloride (Table
6). A qualitative risk assessment was also performed on the
potential inhalation exposures and risks to children playing in
the wetland area located on the west bank of the Wallkill River.
These exposures and risks were evaluated by comparing them to
those for recreational users of Station Park. The surface water
concentrations of the volatile chemicals in the wetland area are
similar to or lower than the RME concentrations for volatile
chemicals in shallow groundwater which were used to estimate
ambient air concentrations in the park. Also, children would be
exposed less frequently and for fewer years than the park users.
Therefore, inhalation risks to children playing in the wetland
are probably less than those estimated for park recreational
users.
UNCERTAINTIES
The procedures and inputs used to assess risks in this
evaluation, as in all such assessments, are subject to a wide
variety of uncertainties. In general, the main sources of
uncertainty include:
- environmental chemistry sampling and analysis
- environmental parameter measurement
- fate and transport modeling
- exposure parameter estimation
- toxicological data
Uncertainty in environmental sampling arises in part from the
potentially uneven distribution of chemicals in the media
sampled. Consequently, there is uncertainty as to the actual
levels present.
Uncertainties in the exposure assessment are related to estimates
of how often an individual would actually come in contact with
the chemicals of concern, the period of time over which such
exposure would occur, and in the models used to estimate the
concentrations of the chemicals of concern at the point of
exposure.
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Uncertainties in toxicological data occur in extrapolating both
from animals to humans and from high to low doses of exposure, as
well as from the difficulties in assessing the toxicity of a
mixture of chemicals. These uncertainties are addressed by
caking conservative assumptions concerning risk and exposure
parameters throughout the assessment. As a result, the RA
provides upper bound estimates of the risks to populations near
the A.O. Polymer site, and is highly unlikely to underestimate
the actual risks related to the site.
More specific information concerning public health risks,
including quantitative evaluation of the degree of risk
associated with various exposure pathways, is presented in the RI
report.
Actual or threatened releases of hazardous substances from this
site, if not addressed by the preferred alternative pr one of the
other active remedial measures considered, present a potential
threat to the public health, welfare, and the environment through
the continued release of contaminants from the subsurface soil
into the groundwater.
ECOLOGICAL ASSESSMENT
The ecological assessment performed at the A.O. Polymer site was
limited to a qualitative evaluation of potential impacts
associated with chemicals in surface water. The potential
impacts associated with contamination in subsurface soil and
groundwater were not evaluated because no pathways currently
exist by which receptors can be exposed to chemicals in these
media. The potential impacts associated with chemicals in air
were not evaluated. The assessment was further limited to an
evaluation of potential impacts in aquatic receptors, such as
copepods, water fleas, crayfish, other decapods, and a variety of
insects as well as several amphibian species, which inhabit the
wetland area, because exposures and risks are potentially
greatest in these receptors. This is based on the fact that
surface water chemical concentrations are highest in the wetland
area and that aquatic receptors could be continuously exposed to
surface water contaminants for all or part of their lifetime.
Environmental impacts of the groundwater discharge to the
Wallkill River were measured by sampling the water quality of the
stream. It was found that when compared to toxicity data,
chemicals in the river are below concentrations associated with
toxic effects. Surface water exposures in exclusively
terrestrial species would be less because these species would
only occasionally be exposed to chemicals in surface water. None
of the wetland chemicals of concern are expected to bioaccumulate
extensively, therefore, significant exposures in terrestrial
wildlife, such as rabbits, mice', and deer, from occasional use of
surface water is unlikely.
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DESCRIPTION OF ALTERNATIVES
The remedial alternatives for the A.O. Polymer site can be
divided into two groups of alternatives: source control (SC)
alternatives to address soil contamination, and migration
management (MM) alternatives to address groundwater -
contamination. In order to formulate a complete site remediation
alternative, the selected source control and the selected
management of migration alternative must be combined. Six source
control and four management of migration alternatives can be
combined to form a total of 19 potential site remediation
alternatives.
The time to implement provided for each of the following
alternatives represents actual construction and treatment time,
where applicable, and does not include the time required to
perform remedial design activities prior to construction.
Alternative SC-1: No Action
Capital Cost: $ 0
Annual Operation and
Maintenance (0 & M) Costs : $ 19,400
Present Worth: $319,000
Time to Implement: 0 months
The NCP requires that the No Action alternative be evaluated at
every site to establish a baseline for comparison of other
alternatives. Under the No Action alternative, no action would"
be taken at the site to control migration of contaminants from
soils to groundwater and the Wallkill River. Under this
alternative existing and potential health and environmental risks
would remain. The No Action alternative would include periodic
monitoring of groundwater and soils.
Alternative SC-2; Capping
Capital Cost: $ 81,000
Annual 0 & M Cost: $ 6,100
Present Worth: $135,000
Time to Implement: 8 months
Capping represents a containment alternative that does not
utilize treatment. The proposed conceptual cap design includes
(from bottom to top) a 6 inch layer of sand, a 60 millimeter high
density polyethelene (HDPE) liner, synthetic flow net for
drainage, a layer of filter fabric for separation, a 12 inch
layer of sand and gravel, and a 2.5 inch layer of asphalt
covering the former lagoon disposal area. The total thickness of
the entire cap system would be approximately 21 inches. The
dimensions of the cap would be approximately 70 feet by 185 feet,
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or an area of approximately 13,000 square feet. The capping
alternative would include periodic monitoring of groundwater.
Alternative SC-3; Soil Flushing
Capital Costs: $158,000
Annual O & M Costs: $ 21,300
Present Worth: $499,000
Time to Implement: 3 years
Soil flushing enhances the natural flushing and attenuation of
contaminants by recharging the area with water. Water soluble
contaminants, which are most prone to leaching, would be flushed
from the soil by recharge into the groundwater. Since soil
flushing further mobilizes the contaminants in soil, this
alternative would be implemented in conjunction with a
groundwater extraction and treatment alternative. Soil flushing
would be implemented by constructing a subsurface re'charge basin,
or leach field. The subsurface recharge basin consists of a
network of polyvinyl chloride (PVC) pipe laid in a 12 to 16 inch
thick gravel bed. The gravel bed would have a 2 to 3 foot thick
layer of gravel and soil over it to prevent freezing. Filter
fabric would be used to separate the gravel layer from the
surrounding soil. The recharge basin would be located above the
soil contamination zone (the "east recharge basin") which is
located near a local groundwater divide (see map, Attachment 3).
The recharge basin would create a groundwater mounding effect,
which would cause water from the recharge basin to flow in a
westerly direction, and into a different drainage basin. To
compensate for this, a second recharge basin would be placed
outside of the contaminated zone on the west side of the
groundwater divide (the "west recharge basin") to control the
direction of flow from the east recharge basin. The flow rate to
the west recharge basin would be larger than the flow rate to the
east recharge basin, thus creating a larger groundwater mounding
effect, forcing the water from the east recharge basin to flow in
an easterly direction.
Periodic subsurface soil sampling and analysis would be required
to monitor the progress of the soil flushing.
Alternative SC-4; Soil Vapor Extraction
Capital Cost: $491,000
Annual O & M Cost: $ 19,000
Present Worth: $810,000
Time to Implement: 1 year
Soil vapor extraction would involve the installation of vents in
the contaminated vadose zone. A vacuum is then applied through
these venting wells to volatilize volatile organic compounds and,
to a certain degree, semi-volatile compounds from the soil. As
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air is circulated through the soil, biodegradation and some
volatilization of semi-volatiles would take place. The vapors
would then be drawn into a collection system where they would
subsequently be removed with an activated carbon off-gas
treatment system. Treatment residuals from the soil vapor
extraction process, including liquid condensate and spent carbon,
may be considered hazardous waste and would be regulated,
transported, and disposed under Resource Conservation and
Recovery Act (RCRA).
A small amount of condensate liquid would be generated during the
vapor extraction process. Condensate production volumes are
estimated to be 10 to 15 gallons per day for the first two weeks
of operation due to the reduction of the saturated soil's
capillary fringe. Little to no condensate would be produced
thereafter. With an on-site groundwater treatment alternative
operating in conjunction with groundwater extraction and
treatment, the condensate may be.treated on-site at-ininimal
additional cost. Off-site disposal of condensate would be
necessary if this alternative is implemented before a water
treatment system is built. An additional study on SVE would
performed during the remedial design phase.
Subsurface soil sampling would be required to monitor the
progress of the soil vapor extraction process.
Alternative SC-5: Soil Vapor Extraction and Soil Flushing
Capital Cost: $ 685,000
Annual 0 & M Costs: $ 21,300
Present Worth: $1,016,000
Time to Implement: 4 years
This alternative combines the two alternatives described above.
The soil flushing technology will remove most volatile and semi-
volatile compounds relatively well, but may not be as effective
in removing a group of volatile compounds known as monocyclic
aromatic hydrocarbons. Vapor extraction, on the other hand, will
perform well in removing monocyclic and aliphatic hydrocarbons,
but will not be as effective for semi-volatile compounds which
are present in soils only slightly above soil cleanup goals.
Soil vapor extraction would be performed first on the soil to
remove volatile compounds. A soil sampling and analysis program
would then be implemented to assess the success of the soil vapor
extraction. Soil flushing, used to flush any remaining water
soluble contaminants from the soil, would be implemented after
soil vapor extraction, if necessary, to achieve soil cleanup
levels.
Periodic subsurface soil sampling and analysis would be required
to monitor the progress of the soil vapor extraction process, and
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the soil flushing process.
Alternative SC-6; Excavation and Low Temperature Thermal
Desorption
Capital Cost: $4,496,800
Annual O & M Cost: $ 0
Present Worth: $4,518,000
Time to Implement: 12-18 months
Low temperature thermal desorption is a mass transfer process in
which excavated soils are passed through a thermal rotary dryer
where volatile contaminants in soils are transferred to the gas
phase. .The off-gas is then passed through a carbon adsorption
treatment system.
This alternative would involve excavation of contaminated soil
and on-site treatment using low temperature thermal desorption.
After the soil contaminants are removed to below action' levels
for soil, the treated soil would be used to backfill the
excavation.
The low temperature thermal desorption system would consist of
two main elements: an indirectly fired rotary dryer and an off-
gas treatment system. Waste is fed into the rotary dryer where
it is heated to a temperature of 450 to 850 degrees Fahrenheit.
The thermal energy vaporizes the volatile and semi-volatile
organic compounds from the soil. The off gas passes through a
treatment system consisting of a liquid scrubber, a condenser, a
particulate filter, and a carbon adsorption unit to ensure that
emissions are within acceptable levels. Off-gas treatment
products would be tested prior to disposal and may be considered
hazardous waste and therefore, would be regulated, transported,
and disposed under the Resource Conservation and Recovery Act
(RCRA).
COMMON MAJOR ELEMENTS OF GROUNDWATER ALTERNATIVES
The remedial components described below are common to the
majority of the groundwater remedial alternatives evaluated.
Therefore, these components are described once and then
referenced in the subsequent alternative descriptions.
Groundwater Extraction and Reinfection
Groundwater extraction and reinjection systems are being proposed
fcr the handling of groundwater at the A.O. Polymer site, and can
be combined with a groundwater treatment system.
The extraction system employed would use a row of pumping wells,
positioned perpendicular to the direction of plume movement. The
location of the extraction system would be such as to minimize
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negative effects to wetlands adjacent to the Wallkill River and
to athletic fields located in Station Park. The extraction
system will be designed to reduce the contaminant plume area to
cleanup level goals over the largest area practicable. Solute
transport modeling indicates that the time required to achieve a
cleanup within the active restoration area under the extraction.
system would .be approximately 7 to 9 years.
The maximum drawdown anticipated from implementing a pumping
system is about 17 feet. This level approaches the practical
limit for an aquifer approximately the thickness of the water
table aquifer. Since the capture zone for the extraction system
would be close to the Wallkill River, drawdowns may be moderated
by induced recharge from the River, however, this could affect
the performance of the pumping system and require much higher
pumping rates to affect the desired capture zone. The exact
number of wells, their placement, and pumping rates will be
addressed in the design phase of the project.
Groundwater Treatment
Each of the remedial alternatives which involves groundwater
extraction and reinjection also includes groundwater treatment.
While the specific method of treatment considered for inclusion
in each alternative is described in the individual alternative
descriptions, other considerations are common to all groundwater
treatment alternatives. These include the inorganics and
potential impacts to the proposed treatment system. In
particular, high levels of iron and calcium which are naturally
present in groundwater in the area. The presence of these
inorganics in the groundwater could potentially foul the proposed
treatment processes without some method of pretreatment.
Therefore, prior to the final design of the groundwater treatment
system, the impact of inorganics on the treatment system must be
defined and, if impacts are significant, pretreatment may be
required.
Alternative MM-1; No Action
Capital Cost: $ 32,200
Annual O & M Cost: $ 17,000
Present Worth: $385,000
Time to Implement: 0 months
Under this alternative, no remedial action would be implemented.
This alternative represents a natural attenuation remedy that
includes institutional controls and monitoring. This alternative
would also include restrictions on future groundwater use and
public awareness and education programs.
Periodic groundwater sampling and analysis would be required to
monitor the progress of natural attenuation.
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Alternative MM-2; Extraction and Treatment:: Bioloaical/Air
Stripping/Carbon Adsorption
Capital Cost: $1,223,100
Annual O & M Cost: $ 6.10,800
Present Worth: . $7,122,000
Time to Implement: 7-9 years
This treatment alternative utilizes aerobic biological treatment
as a first step to remove biodegradable compounds in groundwater.
In this aerobic biological process, micro-organisms are used to
degrade organic compounds in the presence of oxygen. This
biological process would be followed by air stripping to remove
any remaining volatile organic compounds. Air stripping is a
mass transfer process in which volatile contaminants in water are
transferred to the gaseous phase. This process works best on
contaminants with high volatility and low solubility. Air
stripping would be followed by activated carbon adsorption as a
polishing step to remove any remaining organic compounds. Carbon
adsorption removes organic compounds from waste water via surface
attachment of organic solutes onto the activated carbon. The
remedy involves recharge of treated water to the groundwater.
Recharge would be implemented through the use of recharge basins
or groundwater reinjection wells. A portion of the treated water
may be discharged into the Wallkill River if recharge of all
treated groundwater is not technically feasible. The exact
amount of discharge to each would be determined during the
remedial design. Treatment residuals, estimated to be 451 pounds
a day, include sludge from biological treatment, spent carbon
from air stripping off-gas treatment and spent carbon from
liquid-phase carbon polishing. These treatment residuals may be
considered hazardous waste and would be regulated, transported,
and disposed of under RCRA.
Alternative MM-3; Extraction and Treatment; Powdered Activated
Carbon Treatment (PACT)
Capital Cost: $1,695,000
Annual O & M Cost: $ 199,000
Present Worth: $3,767,000
Time to Implement: 7-9 years
Powdered activated carbon treatment (PACT) is a biological
approach, utilizing activated sludge in conjunction with powdered
activated carbon. Powdered activated carbon is added to the
aerator of the activated sludge system. The combined biological
and activated carbon treatment is synergistic; the carbon
enhances the biological treatment, by adsorbing biodegradable
compounds. Many compounds'.are adsorbed on the carbon which is
removed and recycled along with, the biomass in a clarifier. When
compounds are adsorbed to the recycled activated carbon and
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biomass they have a much longer system retention time, allowing a
greater degree of biological degradation. The presence of carbon
in the aeration basin also acts as a buffer to protect the
biological process against shock loading caused by sudden changes
in influent concentration. Approximately 180 pounds of sludge a
day, consisting of biomass, removed contaminants, and spent
carbon will require dewatering and off-site disposal. Sludge
from the PACT process may be considered a hazardous waste and
would be regulated, transported and disposed under RCRA.
Batch PACT plants are single tank systems, and consist of an
aeration tank containing micro-organisms and nutrients for
biological treatment, and powdered activated carbon. An effluent
stream would be continuously withdrawn from the reactor and
pumped to a clarifier. The treated water from the top of the
clarifier would require filtration or a carbon polishing step
prior to reinjection into the groundwater and, as a contingency,
some treated water may be discharged into the Wallkill River.
The exact quantity of discharge to each would be determined in
the remedial design.
Periodic groundwater sampling and analysis would be required to
monitor the progress of this treatment alternative.
Alternative MM-4: Extraction and Treatment: UV Oxidation
Capital Cost: $1,787,900
Annual O & M Cost: $ 670,400
Present Worth: $8,241,000
Time to Implement: 7-9 years
Ultraviolet (UV) Oxidation is an emerging technology for cleanup
and destruction of organic compounds in groundwater. Commercial
applications using hydrogen peroxide and ozone as the oxidant
have been developed. In this process, ultraviolet light reacts
with hydrogen peroxide and/or ozone molecules to form hydroxyl
radicals. These very powerful chemical oxidants then react with
the organic contaminants in water. This alternative would
actively remove contaminants from the aquifer, and would
gradually reduce the toxicity and volume of groundwater
contaminants over the extraction and treatment period. If
carried to completion, the end products of the oxidation process
are carbon dioxide, water, and any other oxidized substances
associated with the original organic wastes.
SUMMARY OP COMPARATIVE ANALYSIS OF ALTERNATIVES
The alternatives identified above were initially evaluated on the
basis of technical effectiveness and feasibility, public health
and environmental effects, institutional issues, and costs, as
presented in the Feasibility Study. Subsequently, these
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alternatives were also evaluated using criteria derived from the
NCP and CERCLA, as amended by SARA, as presented in the Proposed
Plan.
Overall Protection of Human Health and the Environment draws on
the assessments conducted under other evaluation criteria and
considers how the alternative addresses site risks through
treatment, engineering, or institutional controls.
Compliance with ARARs evaluates the ability of an alternative to
meet applicable or relevant and appropriate requirements (ARARs)
established through Federal and State statutes and/or provides
the basis for invoking a waiver.
Long-term Effectiveness and Permanence evaluates the ability of
an alternative to provide long-term protection of human health
and the environment and the magnitude of residual risk posed by
untreated wastes or treatment residuals. /
Reduction of Toxicitv, Mobility or Volume Through Treatment
evaluates the degree to which an alternative reduces risks
through the use of treatment technologies.
Short-term Effectiveness addresses the cleanup time frame and any
adverse impacts posed by the alternative during the construction
and implementation phase, until cleanup goals are achieved.
Implementability is an evaluation of the technical feasibility,
administrative feasibility, and availability of services and
materials required to implement the alternative.
Cost includes an evaluation of capital costs, annual operation
and maintenance costs, and net present worth costs.
State Acceptance indicates the State's response to the
alternatives in terms of technical and administrative issues and
concerns.
Community Acceptance evaluates the issues and concerns that the
public may have regarding the alternatives.
A comparative discussion of the seven alternatives on the basis
of the evaluation criteria presented above follows.
Overall Protection of Human Health and the Environment: SC-1,
the no action alternative, does not provide protection of human
health or the environment because contaminants will continue to
leach to groundwater; it has been estimated that leaching will
result in groundwater concentrations that exceed MGLs for 60
years or more. Therefore, the no action source control
alternative is not protective of human health, since it provides
no control of the source of the groundwater plume and no
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reduction in risks to human health posed by the potential future
ingestion of contaminated groundwater. Because soil contaminants
will continue to leach into the groundwater over a long period of
time, cleaning up the groundwater will take longer to implement
with the no action alternative. SC-2, the capping alternative,
provides limited protection of human health by minimizing
infiltration and reducing leachate generation. Since soil
contaminants will remain at present concentrations for an
indefinite period of time, contaminants will continue to reach
the groundwater through fluctuation of the groundwater table.
SC-3, the soil flushing alternative, SC-4, the soil vapor
extraction alternative, SC-5, soil flushing and soil vapor
extraction and SC-6, low temperature thermal desorption, reduce
potential human health risks by utilizing treatment to remove
contaminants from the soil.
MM-1, the no action alternative for groundwater, provides no
immediate reduction in potential human health risks.' This
alternative relies heavily upon institutional controls to ensure
its effectiveness. The time period for natural attenuation to
occur has been estimated to be approximately 27 years, assuming
that a source control alternative is implemented, and
approximately 87 years without a source control alternative.
The level of protectiveness provided by extraction and treatment
alternatives MM-2, MM-3, and MM-4 is primarily a function of the
extraction system. All three treatment systems will treat
groundwater to acceptable levels.
Compliance with ARARs; There are several types of ARARs: action-
specific, chemical-specific, and location-specific (Table 9).
Action-specific ARARs are technology or activity-specific
requirements or limitations. Chemical-specific ARARs establish
the amount or concentrations of a chemical that may be found in,
or discharged to, the environment. Location-specific ARARs are
restrictions placed on concentrations of hazardous substances
found in specific locations, or the conduct of activities solely
because they occur in a specific location.
No chemical-specific ARARs for soils have been identified. The
action levels (1 ppm for volatiles and 10 ppm for semi-volatiles)
are based on groundwater protection and are the New Jersey Soil
Action Levels which are considered cleanup goals. Action-
specific ARARs associated with soil treatment will be met for
source control and management of migration alternatives.
Each management of migration alternative that includes extraction
and treatment alternatives (MM-2 through MM-4) will treat
extracted groundwater to MCLs. MCLs are ARARs for groundwater.
Active restoration to below MCLs in areas within the capture
zones of the extraction systems will be achieved in approximately
9 years.
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Residual contamination that is not actively removed from the
groundwater will be flushed naturally to the Wallkill River. To
achieve total cleanup with the active restoration alternatives,
the travel time required for non-extracted contaminated
groundwater to discharge to the Wallkill River must also be
considered. Travel time calculations indicate that this time is
estimated to be 4 years. Therefore, the time needed to achieve
total cleanup of the aquifer with active restoration is estimated
to be 13 years. In MM-1, MCLs may be exceeded until natural
restoration proceeds to completion, which is estimated to require
approximately 27 years when used in conjunction with a source
control alternative.
Both Alternatives MM-3 and MM-4 will be required to comply with
ARARs dealing with the transport and disposal of hazardous waste
with respect to residuals management and ARARs concerning
effluent discharge to surface water. MM-2 will be required to
comply with these ARARs in addition to ARARs regulating air
emissions. Each treatment system can be designed t«5 comply with
the substantive requirements of the ARARs. In the event that
groundwater reinjection is difficult to implement for all treated
groundwater, discharge to surface water may be utilized and
appropriate ARARS will be met.
Most location-specific ARARs regulate the extent of activity in
wetlands, recreational lands or historic sites. Location
specific ARARs also provide that where an action is taken because
no other alternative is feasible, established procedures for
mitigating or repairing any resulting damage must be employed.
Informal consultation with the U.S. Fish and Wildlife Service has
determined that the immediate site area does not contain critical
habitats of rare or endangered species.
Long-term Effectiveness and Permanence; SC-1, no action,
results in groundwater contamination that exceeds MCLs for the
groundwater contaminants for approximately 87 years. The long-
term effectiveness of the capping alternative, SC-2, is severely
limited as the risk to groundwater continues to result from
contaminants being left in place untreated at present
concentrations for an indefinite period of time. Diligent
maintenance of the cap and long-term monitoring are required.
The goal of Alternatives SC-3, SC-4, and SC-5 is to reduce
contaminants and subsequent migration into the groundwater by
treatment to below remediation goals or NJDEP action levels.
Long-term soil and groundwater monitoring would be required to
ensure that any residual soil contaminants do not pose a
groundwater threat. Therefore, Alternatives SC-3, SC-4, and SC-5
afford greater degrees of long-term effectiveness and permanence
than SC-1 or SC-2. Alternative SC-6 offers the highest degree of
long-term effectiveness and permanence since the potential for
residuals to be above remedial goals is less than for
Alternatives SC-3, SC-4, and SC-5.
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Alternative MM-1 relies heavily on institutional controls to be
effective in the long-term. Since human health risks are
identified based on potential future use, restrictions on future
groundwater use could be used to manage long-term risks
associated with ingestion of contaminated groundwater under the
no action, MM-1, alternative. Groundwater use restrictions would
be implemented at the site for approximately 27 years, if soil
source control is implemented, or 87 years, if no soil source
control is implemented.
Alternatives MM-2, MM-3, and MM-4 provide for active extraction
systems which will remove the most contaminated part of the
plume. These active treatment and extraction alternatives reduce
the potential risk posed by the site by achieving groundwater
cleanup goals. In conjunction with a source control alternative,
these extraction and treatment alternatives will significantly
expedite the restoration of a once potable aquifer f,or future
use.
Short-term Effectiveness; Alternatives SC-3, SC-4, and SC-5
involve activities such as drilling and excavation, however, the
major components in each alternative would not disturb the
contaminated subsurface soils to any significant degree.
Potential risks to workers could be managed easily by procedures
outlined in site-specific health and safety plans. Few short-
term impacts to human health or the environment are anticipated
for these alternatives.
Alternative SC-6 involves the excavation of approximately 7,500
cubic yards of contaminated subsurface soils and will take 12 to
18 months to implement. Diligent control of fugitive dust and
storm water would be required to prevent the spread of
contamination from exposed contaminated soils to currently
uncontaminated areas. Controls would be implemented to minimize
volatilization from these soils and short-term impacts.
Potential risks to human health during implementation are higher
for SC-6 than for other source control alternatives.
It is estimated that over 60 years would be required to achieve
soil cleanup goals for the SC-1 alternative. Of the source
control alternatives, SC-2 through SC-5, Alternative SC-4, soil
vapor extraction, takes the least amount of time to achieve
cleanup goals (approximately 1 year). It has been estimated that
source control Alternatives SC-3 and SC-5 can achieve remediation
objectives within 18 months and 4 years, respectively. Due to
the complex hydrogeological and chemical processes employed in
SC-3 and SC-5, however, this time period is difficult to estimate
precisely.
All extraction and treatment alternatives for groundwater involve
little disturbance to contaminated subsurface areas, therefore
the potential risks to site workers during cleanup activities
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would be minor and could be easily managed. The potential short-
term risks to human health and the environment are anticipated to
be low for each of these management of migration alternatives.
Implementability: All of the source control alternatives would
be implementable. All source control alternatives use standard
construction techniques and materials. Alternatives SC-1 and SC-
2 would be the easiest to implement. The potential impacts that
SC-3 and SC-5 may have on groundwater flow regimes make these
alternatives more complex and difficult to implement than SC-4.
The soil flushing alternatives, SC-3 and SC-5, require the
coordination of recharge between two separate recharge basins
separated by a groundwater mound. No groundwater reinjection
would be used in SC-4, thus making this alternative less complex
and eas-ier to manage than Alternatives SC-3 and SC-5. SC-6 is
the most difficult to implement because site space constraints
pose safety concerns for site workers. The engineering controls
that will be needed to manage fugitive dust or storm water runoff
also make this alternative the most difficult to implement.
The treatment components of MM-2 and MM-3 are proven effective
for contaminants of concern and should be the easiest to
implement because they rely on well understood and readily
available commercial components. Alternative MM-4 relies on an
innovative technology for treatment and, therefore, would be more
difficult to implement. Treatability studies would be required
to determine the level of effectiveness that can be provided by
MM-2, MM-3, and MM-4. More extensive testing, requiring more
costs and time, would be involved with Alternative MM-4 since it
is an innovative technology.
Reduction of Toxicitv. Mobility or Volume: Alternatives SC-1 and
SC-2 do not utilize treatment to reduce the toxicity, mobility or
volume of contaminants. SC-3 and SC-5 remove contaminants from
the soil by actually increasing their mobility, and must be
implemented in conjunction with a groundwater extraction and
treatment alternative.
Alternatives SC-4 and SC-5 remove and concentrate contaminants
from on-site soils for later disposal or toxicity reduction. SC-
6 provides the highest efficiency of removal of contaminants from
the soil.
MM-l would not actively reduce the toxicity, mobility or volume
of the groundwater contaminants. MM-2 through MM-4 would
actively remove contaminants from the aquifer, and would
gradually reduce the toxicity and volume of groundwater
contaminants over the extraction and treatment period.
Cost; Six source control and four management of migration
alternatives can be combined to. form a total of 19 potential site
remedial alternatives. The cost of a complete site remedial
24
-------
alternative is the sum of the costs of the selected source
control and management of migration alternatives. The least
expensive remedial alternative combination of soil capping and no
action for the management of migration is approximately $520,000
(present worth cost). The no action alternative for soils, SC-1,
would be more expensive than capping due to the more intensive
and longer term monitoing involved with the no action
alternative. The most expensive remedial alternative combination
is the excavation/thermal treatment of the contaminated soil
combined with UV oxidation of groundwater, which costs
approximately $12,759,000. See Table 10 for comparison of all
source control and management of migration alternatives. Besides
the no action alternative for groundwater, MM-3 is the least
expensive. MM-4 costs approximately twice as much as MM-3. For
source control involving treatment, SC-4, soil vapor extraction,
is the second least expensive alternative compared to all other
source control alternatives.
/
State Acceptance; NJDEP has concurred with the selected remedy.
Community Acceptance: Based upon public comments addressed in
the responsiveness summary (Attachment 4), the community concurs
with the selected remedy.
SELECTED REMEDY
Based on the results of the RI/FS, and after careful
consideration of all reasonable alternatives, EPA and NJDEP
presented SC-4, Soil Vapor Extraction (SVE), and MM-3, Powdered
Activated Carbon Treatment (PACT) as the preferred remedy for
addressing site contamination at the May 9, 1991 public meeting.
After considering public comments, the selected remedy is
implementation of the combination of Alternatives SC-4 (SVE) and
MM-3 (PACT).
The selected remedy is the combination of Alternatives SC-4 and
MM-3: soil vapor extraction, and powdered activated carbon
treatment. This combination of alternatives represents the best
balance with respect to the evaluation criteria and it meets the
statutory requirements of CERCLA Section 121(b), which are: to
protect human health and the environment, to comply with ARARs,
and to be cost effective. The selected remedy utilizes permanent
solutions and alternative technologies to the maximum extent
practicable and satisfies the statutory preference for treatment
as a principle element.
By reducing the soil contaminants to NJDEP Interim Soil Action
Levels through Soil Vapor Extraction, they will no longer.be a
significant source of groundwater contamination. Soil Vapor
Extraction also reduces the amount of time necessary to perform
groundwater extraction and treatment to reach groundwater levels
that are protective of human health and the environment. Soil
25
-------
Vapor Extraction utilizes treatment to reduce the volume and
mobility of contaminants by removing them from the soil.
Groundwater treatment will be conducted concurrent with soil
treatment. Groundwater will be extracted by groundwater
extraction wells. The groundwater will be processed through a
powdered activated carbon treatment system, utilizing activated
sludge in conjunction with powdered activated carbon. This
alternative offers protectiveness, short-term as well as long-
term effectiveness and reduction of toxicity, mobility, and
volume of contaminants. Both groundwater and soil treatment
systems, including the emissions control units, will be designed
to meet the substantive requirements of New Jersey air pollution
control regulations.
Once treated, the water extracted from the aquifer will be
reinjected into the groundwater through injection wells or
recharge basins. To meet cleanup standards, it was ^estimated
that extraction of groundwater will be required for'a period of
nine years. As a contingency, if it is not possible to return
all the treated groundwater to the aquifer some treated water
would be discharged to the Wallkill River.
A cost estimate for Alternative SC-4, soil vapor extraction, is
presented in Table 7. A cost estimate for Alternative MM-3,
Powdered Activated Carbon Treatment, is presented in Table 8.
These cost estimates are based on a preliminary design of the
remedial systems.
STATUTORY DETERMINATIONS
Under Section 121 of CERCLA and Section 300.430(f) of the NCP,
selected remedies must meet certain statutory and regulatory
requirements. These requirements and a description of how the
selected remedy satisfies each requirement are presented below.
Protection of Human Health and the Environment
The selected alternative will fully protect human health and the
environment through treatment of each contaminated media while
also meeting ARARs and minimizing short-term risks. Contaminated
soils will be treated using soil vapor extraction, resulting in
minor short-term risks, but no long-term risks associated with
on-site treatment residuals. Groundwater treatment through the
PACT system will similarly remediate contaminants to acceptable
levels in the groundwater with little or 'no associated short-term
risks.
Compliance with ARARs
The proposed remedy has been developed to meet Federal and State
ARARs for drinking water. Pursuant to the New Jersey Ground
26
-------
Water Quality standards, N.J.A.C. 7:9-6 et seq., the groundwater
at the A.O. Polymer site is classified as GW-2, which means it is
a current or potential source of drinking water. Groundwater
cleanup criteria have been developed for the A.O. Polymer site
pursuant to N.J.A.C. 7:9-6 et seq. and N.J.A.C. 7:14A-1 et seq.
and are listed in Table 9 under Chemical-Specific ARARs. The
more restrictive of Federal or New Jersey MCLs will be used as
the cleanup levels for groundwater. As a contingency, if all the
water is not able to be reinjected to the aquifer, surface water
discharge to the Wallkill River will meet all ARARs listed in
Table 9. If it is determined that the selected groundwater
treatment system is unable to meet the surface water discharge
ARARs, despite design modifications and/or additional polishing
steps, the Agency may propose a waiver of these requirements.
The waiver process would include appropriate public participation
requirements pursuant to CERCLA. Because no chemical-specific
ARARs applicable to soil contamination were identified, soil
cleanup levels for volatile and semi-volatile organic compounds
are based on NJDEP Soil Action Levels, which are not ARARs, but
are To Be Considered (TBC) criteria. These TBCs for soil are 10
ppm for total semi-volatiles and 1 ppm for total volatile organic
compounds.
Cost-Effectiveness
The selected remedy provides effective treatment of contaminated
soil and groundwater and is cost-effective compared to other
alternatives. The combination provides the best balance among
the nine evaluation criteria utilized by EPA. The treatment
methods included in the alternative have been proven effective in
the treatment of similar contaminated materials and are expected
to attain ARARs at the A.O. Polymer site.
Utilization of Permanent Solutions and Alternative Treatment
Technologies
EPA and NJDEP have determined that the selected remedy utilizes
permanent solutions and treatment technologies to the maximum
extent practicable. This determination was made based on the
comparative evaluation of alternatives with respect to long-term
effectiveness and permanence, reduction of toxicity, mobility or
volume through treatment, short-term effectiveness,
implementability, and cost, as well as the statutory preference
for treatment as a principal element, and State and community
acceptance.
A high degree of success is anticipated using the selected soil
remedy, SC-4 (Soil Vapor Extraction). Similar projects have
shown the soil vapor extraction technique to be highly successful
in removing volatile organics from soils, particularly in sandy
soil matrices such as those found at the A.O. Polymer site. Soil
concentrations of semi-volatiles are slightly above New Jersey
27
-------
Soil Action Levels. It is anticipated that SVE will volatilize
and enhance biodegredation of semi-volatiles thus reducing their
concentrations below action levels. Alternative MM-3, Powdered
Activated Carbon Treatment system, is capable of treating
contaminated groundwater at the site to meet MCLs.
State and Community Acceptance
The State of New Jersey and community concur with the selected
remedy for the A.O. Polymer site.
Preference for Treatment as a Principal Element
The principal threats at the A.O. Polymer site include the
presence of organic compounds in the soil and groundwater. The
selected remedy satisfies the statutory preference for treatment
as a principal element in addressing the human health and
environmental threats posed .by contamination in both soil and
groundwater.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the A.O. Polymer site was released for
public comment on April 25, 1991. The Proposed Plan identified
Alternative SC-4 and MM-3 (soil vapor extraction and Powdered
Activated Carbon Treatment) as the preferred response action.
All written and verbal comments submitted during the public
comment period were reviewed by EPA. Upon review of these
comments, it was determined that no significant changes to the
remedy, as it was originally identified in the Proposed Plan,
were necessary.
28
-------
TASLE 1
SJWA2T OF CM£*;C1LS Cf PCTcXTIAL O
PCS 7H£ A.C. PC.T«a SITS
ir-?act Sett
Be:a-3KC
8-tyl ieriy '. sh t.'.a late
C:-n-butyl;y.:.-.ala:a
2,«-2 in; :rst:l-jer»
e-^ise^eAt"1^1*
C.-3U-CS.
Aceta
aipf.a
be:i-
Cjrbej
«:tr
r»
•SXC
5KC
^"^7*. ,i j: •
Surfac» Water
WaUtiU Bfver:
Wetland
Acatan*
r» Csta!)
PAX* (.
V-ryl »ci:a:«
Scil
3uty •„ Sariy i ^ tr.a •. a : a
•v i __•
:r».-3 -'. 2-I: s.~. i s.-s«t.*:
'.i-Z-iaBt.ivi — exl
2 • -.-.- ixry isr t.-a I a :t
iet.*ac*isra*t.l*.er>
ttrtcr. tit.-
1 , 2-0 i cs I srK«ri«ra
l.l-rieJiisrs* :.-.««•
1,1-5it':ler9«:.-.en«
1,2-2:sslars«t.'.«r* Crta
Cet.^y'.era sr.lsr-ic*
»or»
d'sulfic*
Carbon t»tr*c>. icr;
Chlorsfsrrf
1,1-OicMor:»t-har»
Metftylen* ehtsrib*
7«trach I srcxtr-.ei-a
ToL'
Viryt e.-.isris»
Xyi er» <:stal)
Caelin? ?=rs!:
(t=:»;)
(tstai)
POOR QUALITY
ORIGINAL
-------
TABLE 1A
Organic Cheoieal Sunmary For Surface and Subsurface Soil Sanptes
A.O. Polymer Site Remedial Investigation
CJI
V
V
V
V
V
V
V
V
V
V
>SS TARGE7 COMPOUND
7E7RACHLCRCE7HE.VE
1.1.1-7RICHLGRCE7HAKE
TRICHLGRCETHENE
72AVS-1 2-DICHL3R3E7HENE
1 , 1 ,2-7R:CHLG30£7XAKE
7R!CHLGRCrLUCROHE7HAKS
--MOHGCYCLJC AROKA7IC HYORCCARSCNS---------
TGL'JENE
XYLEXES (7G7AL)
E7HYL3EK2ENE
CHLSRC3E.W2ENE
....... irrTni: s:.. .......-...--. .--.-.-.--•
HininjB
Detected
Value
Cus/k3>
2.6
7.5
14
2.7
SCO
530CO
2
. 51
35
570
Kaxinun
Detected
Value
— ------ ••——-»•..•«.«•-
•95
66
64
37
130
TS
46
57
64
64
110
100
150
120
120
75
38
77
96
' 150
1700
760
1900
46
1100
300
64
1.2
1300
44
58
... — .......
5300
96CO
560
42CO
740
160CO
2600
960
833
830
590
520
290
260
41000
260
290
14000
•2600
4600
120
NG7ES:
V = Volatile orsanic eampound
A = Acid extractasle ccnpound
B - Base/Nuetral Cccpound
P = PCs/Pesticides
POOR QUALITY
ORIGINAL
-------
TABLE IB
SUMMARY OF CHEMICALS DETECTED IN
GROLWDUATER AT THE A.O. POLYMER SITE (a)
(Concentration in ug/L)
Range of Detected
Chemical (b) Concentrations HCL
Acetone
alpha-3HC
beta-3HC
Benzene
Benzoi c acid
BisC2-ethylhexyl)ph thai ate
2-Butanone
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chloroform
Di-n-butylphthalate
1 , 2-D i eh 1 orobenzene
1 , 1 -D i ch I oroethane
1 , 1 -Dich loroethene
1,2-Dichloroethene (total)
1 , 2-D i ch I oropropane
Ethylbenzene
2-Hexanone
3-Methyl-2-pentanone
Methylene chloride
4-Methytphenol
PAHs (noncarcinogenic)
2- Methyl naphthalene
Phenol
Tetrach loroethene
Toluene
1 ,1,1- Trich I oroethane
1 ,1,2-Trichloroethane
Trichloroethene
Trichlorof luoromethane
Xylenes (total)
5.0 - 4900
0.1
1.1
3.3 - 14
14
97
5.0 - 9200
3.8
19-23
2.3 - 82
2.3 - 320
5.8
2.2
2.5 - 600
2.3 - 310
1.8 - 4000
6.3
4.5 - 130
4.5 - 12
4.0 - 1800
2.0 - 800
5.4 - 11
3.0
3.0
5.1 - 200
1.8 - 400
1.8 - 780
1.8 - 2400
2.0
2.0 - 2600
3.7
2.0 - 350
—
-
-
1
-
.
-
.
2
4
-
-
600
-
2
10
-
-
-
-
2
-
'
-
-
1
-
26
-
1
.
44
(a) Includes all samples collected from water table and bedrock groundwater we1. Is.
(b) Only organic chemicals are
listed. Inorganic
chemicals detected in groundwater are i
concnerrations within the range of background concentrations and are not believed to be site related
All listed chemicals are selected as chemicals of potential concern.
-------
TABLE 1C
SUMMARY OF CHEMICALS DETECTED IK WALLKILL RIVER SURFACE WATER
AT THE A.O. POLMER SITE
(Concentrations in ug/L)
Chemical (a)
Acetone
1,1-Dichloroethane
1,2-Dichloroethene (total)
Hethylene" chloride
Vinyl chloride
Range of Det<
Stations
2 & 3
20
NDC5)
ND(5)
2
NO (5)
scted Concentrati
Stations
445
18 - 29
1 - 2
5.2 - 6
2.8 - 3
1
ons
Background
(Station 1)
18
ND (5)
NO (5)
2.8
ND (5)
ND = Not detected. Detection limit shown in parentheses.
-------
TABLE 1D
Organic Chemical Surmary For Surface Water Sanpl.es in the Wetland Area
A.O. Polymer Remedial Invesigation
(Concentrations in ug/L)
1,2-DICHLOROETHENE(Total)
1,1-DICHLOROETHANE
VINYL CHLORIDE
TRICHLOROETHENE
1,1,1-TRICHLOROETHANE
CHLOROFORM
TETRACHLOROETHENE
1,1-DICHLOROETHENE
1,1,2-TRICHLOROETHANE
.CARBON TETRACHLORIDE
XYLEME
BENZENE
TOLUENE
CHLOROBENZENE
ETHYLBENZENE
ACETONE
2-BUTANONE
METHYLENE CHLORIDE
CARBON DISULFIDE
Max i nun
Detected
Value
850
260
280
22
130
15
6
14
1
20
18
5
22
9
3
32
10
13
1
HCL
10
-
2
1
26
-
1
-
-
2
44
1
-
4
-
-
-
2
-
-------
TAS;.= IE
Organic CJieaicats In Benthie Sediment Samclss
A.O. Pslyncr Site Remedial Irsvesisa:-on
sr. t rat ions in as/'.)
7ARQE7 C3*?O:«
AW7HilAC£>iE
6s5iI3(A;A>i7>:RA:=ii =
oE-vrccAjPTREVs
SsJirscsjr-.'jc^tsT:-:;*:
5£.s'::«;rLJC^^'.-:£s£
c:-:srs=.»i=
D:-K-5C7rL?H->-A.A-£
F'.L!GRA>i7HsVi =
rHEVIAKTrSES'E
PvRH>i =
5:scz-£7HT.-£xvL)?:-:-:-:A.i-£
BACS35XK3
NO
5=
120
^ C^
32C
3ZC
210
NO
320
250
260
310
«:«i«.'M
D£7£"s2
VAi.'.'£
3
56
51
72
1-0
uo
51
5 /
1iO
£3
leC
13C
MAX; nun
DE7HC7H3
VAL'JH
3
56
120
150
320
320
210
57
320
250
2£0
310
AV=SAGH
VALJE
3.00
56.00
130.25
124.50
212.50
212.5-0
U2.75
57.00
20/.50
150.73
240.00
122.50
POOR QUALITY
ORIGINAL
-------
TABLE 2
EXPCSURE PATHWA7S SELECTED FOR EVALUATION
AT THE A.O. PCLrMER SITE
Ezpcsurs M
Pate.-.rial'.y
Exposes Peculation
Exposure Retire
Craunewatsr
Air
aci Water
Residents
Residents
Residarts, resrearicr.at
Residents
Future irgestion
Future cersal e=rtac: euri--
in-horae use ef or: "
Cyrre.^: ir.nalarior of c.ies:sat
users ef SraTion P3r-i t^a.
votiliss frsrt S-»«:-8t'e.-"t.-.r».-r
soil ic srcient air ''
C^rr-.-t irhatatior, of =.ier:;c3is
tr.ar'vsiatfl ire during
in-home use of gpourewa:-.-
C_-rner.t i;r.halat-or. ef che—cals
fran tr.e ic: i- rh-
werLanc area
£J»CS:i£ rATH.ATS SELICTiD fM SVAL-ATISX AT THE A.3. PCLTXE3 Si'r
Potentially
E*pcsu.-e ««i!Xi Eipcse-i Pspulati:
E.tscs-rs Sctr;
Type cf rval
Xis::e.-.ts l.-gest io.-. Cuant i :a:i ve
Aesieents Cerrji c:-:acr curir.; in- =ualira::ve
hone use of s.-suncwarsr
Sesiberts, recrestioral Inhatatier. ef cheaicaii Cuar.titativw
i=er» el Station ?arr t.-.at velatilin fr=a
Sr=u-«rwa:ir t.'trsuch »e:l
to accier.t air
Air
Seaider.ts
Surface Vater O. Her en playing in 'nr.alaTion o* eheaical* Qualitative
:se wetland t.^.a: vcia;:' :;e frsa ir-.a
Inhalation sf c.u.eaica;i Oualitative
t.'-.at velat:li:e du.-ir?
fn-r.orae use of.jr:
"e wetland .
lerral esrract
Cuartirative
POOR QUALITY
ORIGINAL
-------
lARIf J
ORAL
INHALATION
Chfiical (•)
S * i f t y
(K'.or (b)
Itrotl Organ (cl
• rrlw-t
oenlfot
Sflmc tcid
ill** I»C
t»ti-r>«C
»iiphihal«it
M.iterw..
Cartxn diml fide
Cafl**> ttlrichlorlcl*
cMoictxiiitn*
Chloroform
1,1 OlcMortxtht'*
l' 1-OirMorwlhet.e
1 2-picMorocthfr*
cii-
in-vi-
1 , 3 • 0 i f h I orcfr pfwte
Oi r, l._,irlr*
"rlhylrre chlorittt
t Htihrirhe.,))
r«K, |fm.t>00
100
i.ooo
10.0OO
100
1.000
HO
I. O™)
I.UOO
1.000
I, (TO
100
liver
frlm
liver
liver, kirtxy
llvtr
liver
llvtr
llvtr
Stood
MortalIty
livtr, t irtv>y
livtr, kirtxy
liver
gnrtf weight, CHS
(yel, inl
DID
5«ircf Idl
HIS
HIS
HIS
IBIS
HIS
HIS
HIS
HIS
HF»S1
HIS
HA
HIS
BMSI
HIJ
HIS
HIS
HIS
HIS
(n)
Rrtl/rnn
I .lll-.tl leltnrliloride
<:lllr.|rlw,,fri,r;
(llln,,,l,.,m
1.1 Mi, I, I,,, or-1 Mr.,,,.
1.1 I'i.lllnm'-llien..
d^lliyl MI* rlilnriilr.
It.lti.-i,..
1,1, I Irirlilni.i-llirme
1, l,?-ll irliliunelhnne
Xyleimc (tnlnl)
Tin rune
HflrrriM-f
Tin'.* (Dill)
(N>>|/ky liny)
If-01
9F-OI (I)
fsr-o? (t)
3r-oi
Safely
rnt:lni (t
larqtt Oiqnn (c)
tv.lr viom
livtr
OS
I Iver
Clinical chrmiMry
I iv.r
Mortal Ity
C»S, body utioM,
norlali ty
or gtMit Olhtr
HIS
HIS
HIS
HIS
HI'.
H1ASI
HIS
(i) loxicity crittria aft prtientfi only lor thoit chewlcali for vMch chronic and tipoturtt art being evaluate*) quantitativtly.
Ho oral loiicily crllirii art tvtilablt for 2-hnaoor>t.
(b) Saftiy la^lc-M mtd to develop rtltrttxrt doati art Iht p»t>r>«:ti of uxitrtainty arid iwdilying farton. Uiveri»in(y
lactort crv^\iit of njlliplti of 10, with tach factor rtprt\mting • specific arta of uictrtainty in tht dita availnhlt.
lh* starvjard trtctrtainty factor! IncluV:
tv*»?t*rf of tht hifiwi population;
data lo th« caie of
or lo account for tht variation In aaotltlvity twrmg the
or to accotit for tht mctrtalnty In tvtrapol at ing ani*^
or lo icccunt for tht uxtrltinty In rilmrnliiling frevt le'i. If an BID »M Ivjaxi on • llurty In tthich I targtt organ ua> ml identified, the organ litlrH M cwie t
allrrird by <>" particular ch«lcal of conrtrn.
(rl) HIS • Ihr clie-iiml lilta of IP«'» lnl»gr«le.| »ilk ll.lr-.m«l irxi Sy Irrtn r.l
tiiKlitwli. rUlr.1 Jut «. I0*™.
the t^r<
v>w«> to I
••.•.e-.-.me..l
. Hutu. K«n.
08
oo
in.ooo
1,000
till)
100
t.onn
in,ooo
lou
liver, kidney
liver
CMS
I Ivor
Klilne.y. ltff|t|
CH^. rr^piratory
11 .ic t
Sourc«(rl)
IIFASI
IIFASI
llfASI
IRIS
Hf«SI
HtASI
SUBCHIONIC ORAL ICftltEKCE DCStS in K SUISCI Of CHEMICALS Of fOlfNIIAI CCNCCIN
Al IK? A.O. rOLIMEl Silt
's
Chemicrtt (8)
Arrlro*
2-ftulanm«
Cnrt>on tetrachlor Id*
Chlrtrrbenf trvi
Chlnroforia
,1-OlchlnrcHitliaiH
, 1-Dlrhlnrnethei»«
,?-Plf hloi orthriM
• thyleivi chlnrld*
etrirliloroelheite
oluerwi
,1,1- Ir IchlortMithwf*
, 1 ,?• Ir IchloroethaiM
(ylritt
(a) SUKhronlc RfOi art p
lurfara uattr. for J>
havt Iwen developed 1
«IOl ulll Nl mrd to
Silxh'rmlc
lelrienra
Ooia
(•10)
• 1E<00
H 01
7E-OI
if 01
1E-0?
It -00
>T -0!
?( -01
tl-Ol
If 01
00
rtltnted only
Ich ii
-------
TABLE 4
NONCANCER RISK ESTIMATES
Furture land-Use
I. Exposure to Groundwater
Ingest ion of Chemicals in Groundwater
Dermal contact during in-home use of
groundwater.
Hazard Index for
Noncareinogenie Effects
2
NA
Reasonable
Maximum Case
Exposure
5
NA
Current Land-Use
II.
Exposure to Air
Inhalation Exposure of
Volatile Chemicals in
Ambient Air for Local Residence
Recreational Users
Inhalations Exposure of
Volatile Chemicals in
Ambient Air
Exposure to Surface Uater
Direct Contact with wetland
Surface Water for Children
Inhalation of chemicals from
the wetland area that volatilize
from the wetland.
.008
.002
NA
NA
.04
.009
.04
NA
NA: exposure pathway not quantitatively assessed
-------
ORAL
Tnblo 5
o
Slop*
Factor (SF)
Chemical (a) (maAg-day)- 1
•n
\j
30
C
1
-H
-<
Acetoo*
Benien*
Benioic acid
atpha-BHC
beta-BHC
Bis(2-ethylhfxyl)phthalat>
2 -But anon*
Carbon diiul fide
Carbon let rachlorid*
Chlorobenien*
Chlorofom
1 , 2 • D i ch 1 orobeni en«
1, 1-Dichloroeih»ne
1 , 1 -Oichlorotthene
1,2-0ichloroethen«
cis-
trans-
1 , 2 • 0 i ch 1 oropropane
Oi-n-butylptithalate
E thylbeniene
4 • Me t hy I • 2 • pen t anon«
Methylene chloride
r inn r
. f I: illll c
i.«e-ttt HZ
D
.1.3F-01 a?
0
5.7r-oa c
I.7F-OZ n^
n
"
• (<•) Sourer (d)
IRIS
IRIS
IRIS
IRIS
IRIS
HrASI
llfASI
XyUnrs (lol.it)
(a) loxicity crilerU are presented only lor thote chemical! for utiich chronic »nd exposures are being evaluated quantitatively.
Ho or»l toxicity criteria are availabl* for 2-heK«oon«.
(e) EPA wnqht of evidence classification schrnte for carcinogen*:
A = Hinvin Carcinogen, sufficient evidence from hL»m»n epict^niologirnl stiflie*;
B1 = Prohflbte Himnn Carcinogen, Hailed evidence from rpiil«inio|rv|iral l«il>le Himnn Core iixxjen, iivxtrxjunte rvitJenr.e frun r|m|piniigirnl studies and mtrifinte evidence from animal
studies;
C ~ Possible Hiftvin Carcinogen, limited evidence in nnimnls in the nb'.nice of hitnnn data; and
0 = Mot rlnssi f ied.
(') Value listed is for naphthalene.
= Criterion has not been develoj>ed for this chenical.
-------
TABLE 6
CANCER RISK ESTIMATES
Future Land-Use
Exposure te Greundwater
Ingest ion of Chemicals
in Groundwater
Dermal contact during in-home use
of groundwater
Upper Bound Excess Lifetime
Cancer Risk
Average
Reasonable
Case
Exposure
2E-04
NA
4E-04
NA
Current Land-Use
II.
Exposure to Air
Inhalation Exposure of
Volatile Chemicals in
Ambient Air for Local Residences
Recreational Users
Inhalation Exposure of
Volatile Chemicals in Ambient Air
Exposure to Surface Water
Direct Contact with East
Seep Surface Water for Children
Inhalation of chemicals from the
wetland area that volatilize from
the yet land
8E-06
9E-07
NA
NA
6E-05
6E-06
1E-06
NA
NA: exposure pathway not quantitatively assessed
-------
TABLE 7
COST ESTIMATE &MMA8T
ALTERNATIVE SC-4
SOIL VAPOR EXTRACTION
A. 0. POLYNEK FEASIBILITY STLOT
css=s^sss=ss==xa
ITEH
ssu VAPOR EXTRACT: c« TREATMENT (nooo CD
Capital Casts:
1. System Instal lation/Mobil isation
2. Off-gas treatment (activated carbon)
3. Liquid Condensate Treatment
4. Soil Sampling Program
Subtotal:
Quantity
Lure Sam
Lire SLID
150 gallons
30 sables
Capital
Cast
$153,000
S 79, 200
$3,300
$32,500
Annual
0 £ M
S3CS,OCO
S3
-— ==- --------- =-======s
Present Uorth of
Annual CSH Costs
Rate = SS ga:e s 1C
===================== =======
»
iO
I!. LC*G TEX* HOKITCSZHG I REVIEW (30 TEARS)
1. S-jbs-rface Soil Sa-npiing t Analysis
2. 5-Year Reviews
Subtotal:
CtXSTSUCTIC* SUBTOTAL
ANNUAL 0 S H
S233.3CO
SO $15,SCO
=====s======:r=ss=============
5332,000
515.500
$259,100 S'57,7:2
$259,100 $1:7,7C3
Health and Safety
Bid Contingency
Scope Cor.ti regency
UITICii TOTAL
Capital 0 ( M
5S
20S
20S
55
5S
c*
$15
561
561
,
•
iOO
6CO
600
sss==s=
$2
$775
$775
,325
$11(
sn,
S-,
900
900
7CO
5
57
$7
•£<
:
7*-»
3:3
9CO
519,^00
5313,600
Pemittins t Le^al
Services During Construction
"TAi. IMrLHMEJiTATIC* C3ST
Er>jine-erir>s I Design
TCTAl CAPITAL CCSTS
TC'AL PSESEKT U05TH
5S
522,330
522,330
Si91,300
so
Sir1,300
SS'.C,COO
• Half of the cost of each 5-year review (57500) is included in SC Alternatives.
Reviews at t » 5 yr, 10 yr, 15 yr, 20 yr, 25 yr, and 30 yr.
** Ensineering «nd design included in item I. (1) System installation/mobiliiation
POOR QUALITY
ORIGINAL
-------
TABLE 8
COST ESTIMATE SUMMARY
ALTERNATIVE HH-4 (Bl
EXTRACTION AMD TREATMENT
POWERED ACTIVATED CARBON TREATMENT (PACT)
A. 0. POLYMER FEASIBILITT STUDY
I.
I!.
in.
IV.
V.
VI.
C3WST
I TEX
EXTRACTION/DISCHARGE SYSTEM
1. Hew Extraction Wells
2. Submersible Punpc
3. Collection/Discharge Piping
t>. Electrical Connections/Electric Power
5. System Controls
Subtotal:
SITE PREPARATION/TREATMENT BUILDING
1. Construct Treatment Building
2. Building Lighting/Heating
3. Construct Parking/Staging Area
Subtotal:
WATER TREATMENT SYSTEM
1. Mooel BUO (Batch) Pact System
and Auxiliary Ec^jipment/Oel ivery/Set-up
2. Multi-Media Post-Filtration Unit
3. Filter Press (sludge dewatering)
4. 0 1 M Costs:
a. Electricity
b. Carbon Usage
c. Sludge Disposal
c. Polymer
5. Full -Time Systere Operator
Subtotal
TREATED WATER DISCHARGE
1. N?D£S Penr.it
2. Weekly Effluent Sampling
Subtotal:
INSTITUTIONAL ACTIONS
1. P-Jlic A.areness/coucation Program I
Croundwater Use Restrictions
Subtotal:
LONG TERM MONITORING t REVIEW (30 YEARS)
1. Install additional nonitoring well
2. Seni-annual Grounduater Monitoring
3. Five-Year Review*
Subtotal:
| Quantity Capital
Cost
7 Uells $46,700
7 Puips $2,900
1C50 LF $18,840
Lutp Sua $14,475
Lump Sun $13,405
$96,320
5000 SF $300,000
lutnp Sun
Lump Sum $8,000
$308,000
$600,000
$50,000
$20,000
$67C,000
$7,500
•
$7,500
Annual
0 I M
$1,400
Si, 570
$5,570
$3,600
$3,600
$25,550
$5i,750
$22, 5 CO
$9CO
$50, 020
-S-E3.7CO
$19,500
$19,500
$25 , 000
$25,000
$3,000
•*
**V
$3,000
RUCT:C* SUBTOTAL ' $1.109,800
$17,000
$17,000
========r=========-___...=_______
Present Worth of
Annual 04* Costs
5S Discount 1C! Discount
$10.000
$32,500
$42,500
$25,600
$25,600
$181,600
$329,200
$159,900
$6,4CO
$355,400
$1,092,500
$133,600
$133,600
$a,ioo
S2i,»03
534,400
$20,700
$20,700
$147, ic:
s3-;5,3:
$:2?,5:
ss,::
S2CC ZZ
jc_cc -5n^
$112,300
$112,300
$0
$261,300
$20,800
$282,100
$199,800 $1,581,300
$0
$16C, 300
$ '.1,6:0
$171,900
S1,i2i,5C:
-table continued on next page-
" POOR QUALITY
ORIGINAL
-------
TABLE 8
Capital DIM
Health and Safety.
Bid Contingency
Scope Contingency
1X 1S
15S 15S
15X 15S
$11.098
$166.470
$166.470
$15,813
$237;195
$237,195
$12.2i5
$183,675
$123,£75
CONSTRUCTION TOTAL
Permitting I Legal
Services During Construction
3S
6X
$1,453.800
$43,614
$87,228
$2,071,500
$1.604,ICO
TOTAL IKPLEXEHTATIC* COST
Engineering I Design
X = = SS=2SS;£S==wS«£=a = £==ZS=
TOTAL CAPITAL C3STS
TOTAL PRESENT UCRTH
$1,584,600
$110,922
=33==S======
$1,695,500
$3,767,CCO
NOTE: Cost estimate assures a 9-year period of operation for the extraction and treatment system.
• Weekly effluent sampling for 9 years.
Analysis performed is for VOCs.
•• Monitoring Period of 30 Tears:
10 nooitcrins wells samples semi-annual ly.
Analysis performed is for VOCs.
•"• Half of the cost of each 5-year review (S75CC) is included in each MM Alternative.
Reviews S t = 5 yr, 10 yr, 15 yr, 20 yr, 25 yr, are 3C yr.
-------
Inlilc V
PIMCHIIAI ACIIWI-SPrciriC AIIAIIS AMD TBCS
A.O. 1'lll.YHI.H ItASIIIIUir SIUDK
IrllorU ur llnil Ullun
UlAllon
l)(;si;r||il lull
oo
>
C'
—I
m.llA r.rltnrU fur
ClAVilfltAlltiii nf Solid
ll|j|n>s«l r«ullllloj mill
Crtullucs.
MIMA llA/Ardons U,nti>
Haiiayciiicnl Systems (JOIHTA!
RCflA Slfimtarih Appllr.Alilp In
liom:i Morj u( ll.iiai il
nc.MA SI/iniMrtls A|i|il Ic.ililr lu
lrjiits|iurlcrs of
UAstc
Rr.nA SltndnriN of DXHCI-I nnil
()|irr«lnrt of lln/nnluin V/isln
liTAlniciil, Slnr,ii|n. anil
Illsjioul lAol
Besiiurcr Consnrvnl Ion
m*l Recovery Act (ln.'RA)
-MiscrlInncuus UnlIt
•111 C..I .11
I'Al't r.,1
r,ul
ID r.r.ii
r«ri ?(rlji fur usn
In (li'liMiiiliiliii) M)I|I;|I no) Id
w.isln illsiiuinl Uclllllm mid
|M /id Ici'fi punp A rc.iniii.ilil n
IH nli.ilil 1 1 ly n( ,idvnrsi> nffncls
on ln'nllh ur llii! nnvl ruiuiiuiil
nnil I|HM rliy consl Illilc
prulillil lud u|ii!ii Uuni|is.
l.tliilil Islins pnicndiirns .ind
crl li.'rl,i (ur n«nll ( leal Ion up
I I'VIIC.lt Illll llf All/ |ll llvl jldll III
10 I.I .II. I'Afl Z60-Z61.
-;|.IMI|,H (h (or
(if ll,\/Allll)US WJjtf!.
I slali
Illllll'l
I sl.\lil Islins r,l Aiid.inli wlildt
apiily tu piirsiiiis Ir.insporl Iny
ll.lNll llliun HilSll! Hi (Illll lllR
U.S. If Die I r.inspiirlal Ion
i i:(|iihi!i A linn lies I undue 10
t.l .II Par I 21)2
I si «lil I shcs niliilminn nfllloii.il
slAiulAiih Mlilclixili>f Inc I Me
iii:ci>pl.ililc Muii,ii|riinMil (if
li,i;,n dciiis MAsIn lor oHiiers ami
iipi<|-Al(irs nl I .n:l Illli-s Mlilcll
lrfi.it . slciri', ur dlspusc of
Kr.lnlil lsliB«i nnvlromionlnl |«Tfnriiwnc«
r-liiivlaril-i o( (m:llUlns Ilint Irrnl.
r-liiro, nr dis|»>!:B i>( linJiirilons Mnslo
in misrrl InncmK null1;.
KLIIA Unil
4(1 C.I Ml.
I'.ul Jlill
I. sliilil I shpd .1 Ilinnloltln for
i i'5l i III Ion n( liiirl.il of
'Mil ullllir
-------
Tnhlc 9 (Ton! lnii»il)
Potential Action-Specific All All.*, and IBCS
Paye ?
Standard, lloip'l min'iit,
Criteria or Limitation
tit itlon
Description
O
oo
OD
Clean Water Act
[ffluent Limitations
Water Quality Related
Effluent Limitations
Toxic and Pre,trcatnx>nt
tffluent Standards
33 II.S.C.
I2M 40
C.F.R.
Section 301
Section 30?
Section 307
Restriction and maintenance of
tin; chemical, physical and
biological Integrity of the
nation's water
Technology-based discharge
limitations for point sources
of conventlonal,
nonconventlonal and toxic
pollulanls.
Protection of Intended uses of
receiving waters (e.g., public
water supply, recreational
uses).
Establishes list of toxic
pollutants and promulgates
prulrciitmcnl standards for
discharge Into I'OIUs.
National Pollutant
Discharge [IImlnation
System (Hl'l)tS)
Suction 40?
Issues permits for discharge
Into navigable waters.
Safe Hi Inking.Vater_Ayl
Underground Injocllnn
•in c.r.n.
H-l-14/
I'rovliln ri!<|uln.'in
-------
Tnbte 9 (CuntInuml)
Putentlal Action-Specific ARAR$ and tecs
Paye 3
Standard, Iteqiilrnnnnl,
Criteria or Limitation
Citation
Description
TJ
08
OO
Oilier
Occupational Safely and
Health Act
H.UArdous Materials
transportation Act
Clean Air Act
National Ambient Air
quality Standard
29 U.S.C. ss
f.51-6/0 29
C.P.H. 1910,
1926, 1904
19 C.F.II.
Parts 11)0-1/7
10 C.r.H. 50
R
-------
Table 9 (fnnl Innnil)
Potential Act Ion-Sped f Ic AIIARs nnd TBCS
Page 4
Standard, Requirement,
Idler)a or Llinl Ullon
Cl lot Ion
Description
-o
O
00
33:13
Air Pollution Controls
Permit Conditions
Air Pollullon Control
Air Stripping Guidelines
N.J. Air Pollution
controls llt!ijiil«l Ions
letter to Robert
I'alnslls.
( I Iraljclhlown
Uati!r Company
from HI I Inn
Pot*kov\r, on «lr
stripping of
cunt null nitcil
water. 12/fl/OZ.
Hnno from
Asslslflnt Cuim.
lyler
HIIIHI fiinii
Wllllnm
(I'Siil llvflii.
Amondcd pRrmlt condition) with
rcsprcl to total flow ifllc,
emissions rales anil testing.
Controls and prohibits air
pollution, particle mission!
and VU emissions.
Criteria for air pollution
conlrnl requlreniunls and
exempt Ions.
Information required for air
pollution control pennlts must
lip sulxiil Iti-d for review;
approved eqiil|nncnt must lie
used In hfl/ardous waste site
cleanups.
Air Pollution Control
Guidelines fur Rnsoun.n
Recovery I ai;l lilies and
Incinerators
Addendum
J/l/fM
Specifies maximum air
conlflmlnant emissions rates,
testing rciiulrc'iiH'iits, and
inlnlimini duslijn standards.
-------
Tnble 7 (Continued)
Potential Ac I lull-Spec I Tic Alt/Mis and 1IICS
Page rj
Standard, Requirement,
Criteria or Limitation
Citation
Description
3
OO
go pa
OO
Incinerator Pcnnlt
Conditions
Pnimll /inil
Croundwjtcr Controls,
(iroundvialer Qu«l lly
Criteria
No. 60.12(1.
llol I Ins
r.iwlrnnniuntal
Services
IIJAC /:1-r.
IIJAC /:I4A-C.H
Specifies requirements for
opcr«llni|, ^nalytlcsl and
reporting, and waste analysis
lialogcn limit on waste feeds,
stank emission testing,
performance standards and
monitoring and Inspection
requirements.
Protection and enhancement of
yroundwatcr resources.
Di?(|iil rciiwnls fur
Gtuundxater Hunllorlny
IIJAC 7:ZG-9
Oroiindwa ler mon 1 1 or I ny . sys tcin
requirements.
Plsclurgcs to Surface Walcr
New Jersey Pollutant Discharge
elimination System (NJPUtS)
Uater Quality Standards
Policy/Procedures for
Discharge to Surface U.ilers
(IISW) fru-n Supcrfiind Sites
(lii'ckllsl for Dpvcloi'iii'nl (if
Host I'lulur.sluiiiil Judgement
I'oiuil Is
NJAC 7:14A Issue NJPOES permits for
discharge to suYface water and
groiindwdlur.
NJAC 7:9-4.1 Protection and enhancement of
ct.scg, surface water resources.
HPU«) from Id Information required for a
Post, II/I/II3 Sufinrfund Site USU pormll.
Mrnii ficini III Cunsldcr.il Ion used In
I'nsl, .1/1/11.1 piuparliHj HJI'DIS-USH Permit.
-------
Table 9 . (Continued)
Cut pill Id I Action-Specific All Alls "nd THCS
I'ltyi! 6
Slumlord, Itcqill rrnmnt,
Crlterla or Limitation
Citation
Description
Vaslewater Discharge
Requirements
NJAC 7:9-5,1
Minimum treatment requirements
and effluent standards for
discharge to surface water.
-o
O
OO
go 33
OO
Hew Jersey Safe
Drinking Valor Act
NJAC 7:10
Other
emergency Response
Notice of Release of Hazardous
Substance to Atmosphere
Water Pollution Control
H.ISA ?6:2C-I9
H.IAC 7:2I(E)
Sets standards for drinking
Mater Including HCI.S,
disinfection requirements,
secondary drinking water
regulations and monI lor Ing
requirements.
Control exposure to air
pollution by tinned! ate
notification to the department
hotline of any air release
Incident.
Imncdlale notification of any
spill of haiardous substances.
Air Pollution Control
Node Control Act
Noise Pollution
HJAC 7:27
N.ISA 13:10-1
ct.scu.
HJAC 7:29-1
Lists •qulrements for control
of al>
Prohibits and restricts noise
which unnecessarily degrades
the quality of life.
Sets maximum limits of sound
from any Industrial ,
cniuimrcliil , public service or
cuiinunlly service fad Illy.
-------
Tnble 9 (Continued)
Potential Action-Specific All Alls and TBCS
Page /
Standard, Requirement,
trllerla or Limitation
ClUtlon
Description
08
QO
Veil Drilling, and Seal I mi Qiul PICIIP Install alloii
General Requirements for
I'ennllllng Veils
Seal Ing of Aliandooml
Veils
Well Drillers and I'unp
Installers Act
HJAC 7:9-;
NJAi:
N.ISA r.o:4A-!>
Re<|ulatcs permit procedures,
(MMiiM'fll m«|iili tiimnls for
dillllnij nnd Inst/il lallon uf
Wt'l IS, I ICI'llSllM) III HI!) I
drllli'r anil pump Instnlln,
const rucllun spec I f lea I Ions,
and will 1 casing.
(p<'imr.vl rrt|iili ciK'nls for
SIM 1 1 MI| of all wells (e.(|.,
slnillc cased; multiple cased,
hand dui). test wo I Is,
boreholes and monitoring
we) Is, abandoned wells).
Well drillers llcensliu),
supervision, Inspection and
s Amp 1 1 nij.
Soil Decontamination
Permit Re(pjlreiiicnls
Pre-applleal Ion
Itinf. lerra-Vai:
Ioi p. (nuiiiu (ruin
Jut'I I eon,
12/Z/U6)
Proposed permit requirements
for portalile sol I
decontamination operations.
-------
Tnlile 9
POH.IIIIAI riirmiAi-si'icinc AIIAIIS *ND TBCS
A. I). I'll) YHIII II ASIIIII.IIY SIIIIIY
Standard, Hei|iil rrtnrnl.
Criteria or Limitation
Citation
Description
-o
o
oo
OO
Resource Conservation
ami Recovery Act (lll'.HA)
- Identification and
I Is) Iny of MatAnluus
Waste
Safe Drinking Voter Act
National Primary Water
Standards
SOUA Haxltnin'
Contaminant Level
(riLGs)
Goal
Clean Water Act Water
duality Criteria
40 C.I .11.
Part ZG1. 1
40 C.F.n.
Pnrt 141
40 C.F.S.,
141.11 -
141,10
40 C.r.R..
Part Ul
llnflnci Iliii-in solid HA sins which
arn siilijncl In riM|iilalloiis as
Im/nrdmis Hflitps unilci' 40 C.K.K.
I.AI-IS ?(,2-?M and Parts 124.
2/0. m.
Cilfllil lilins heal Ih-hasml
fur public water
fstahllslms drinking water
ipiallty goals set at levels of
anticipated adverse health
effects, with an adequate nianjln
of safely.
Sets criteria for water (|iiallly
hasod on tuxlclly to n(|iMtlc
organisms and hiiiimii liniillh.
-------
Table 9
(font Iniieil)
Potential Chemical-Spec I Me All Alls and IBC i
Standard, Requirement,
Criteria or Limitation
Citation
Description
08
230
00
SQLIDi
Sludrjo quality Criteria
Hnw Jersey Department
of Environment
Groundwater Standards
5U2CMOA1U1
Surface Water Criteria
NJAC 7:14 -
4 |)i;ndlx
II- 1
June I, 1900
Diicnniunl
A-?HO
Safe Drinking U/ilcr Act
Maximum Contaminant
Levels
Groundwater Protection H.II'DCS
Hew Jersey U/itnr Pollution
(imlrol Act l^inlflinlnnnl
Indicators.
Cleanup lifljed on hackgroimd
levels for Inorganics, and risk
assessment for organic!
Including total volatile
nr(/anlr:s, total semi-volatile
organlcs (liase neutral (a) , and
total petroleum hydrocarbons
Stale criteria for drinking
water
Standards when written Into
IIJDIPS permits
H.JAC 7:9-6 Hew Jersey Water Pollution
II. I AC 7:11 A- Control Act standards for
6:1!)
NJAC 7:9-4
Criteria for surface water
classes; St. (sal Inn
(.•sluarUn) , SC (sal Inn coastal),
and I WZ (ijeneral 1 1 esliwjlcr) .
-------
fnhle 9
roiniHAi. i.ncAiinii-spr.r.inr. AIIAIIS
A.O. I'dl.YHIIt IIASIIIII.IIY SIIIIIY
AND TBCS
Standard, Requirement,
Criteria or limitation
Citation
Description
Clean Water Act
National Historic
Preservation Act
txccutIva Ordnr
I'rolcclliuj Wetlands
Sent Inn 404
10 C.l.ll
no, ?.M
16 ll.S.C.
s 4/0
40 C.l .11.
s 6:301 (It)
.If. C.I .H
I'arl 1100
Fxer.ut I vu
Order lln.
II'J'MI
I'roMlilla discharge nf dredijcd
nr (III material Into wetlands
without permit, ('reserves anil
enhances wet lands.
llerpilrcs federal agencies In
taki; Into account llm effect
of any federally-asslsled
umli:rlaklni| or licensing on
any district, site, liulldlnq,
striir.tnre, or object that Is
Included In nr Is elli|llile fur
Inclusion In the National
Itcijlslcr of Historic I'Uces.
lleqnlres federal agencies to
inlnlmlre llm diistrur.tInn,
loss, nr degradation nf
wetldiids on li.'deral properly.
Fish and Wildlife
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Tnble 9
Potential Local-Spec I DCS ARAHs and T8CS
Page 2
Standard, Requirement,
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Men .lersny's Threatened
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threatened habitats where they
occur.
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1
ATTACHMENT 4
RESPONSIVENESS SUMMARY
A.O. POLYMER SUPERFUND SITE
SPARTA, NEW JERSEY
INTRODUCTION
This Responsiveness Summary provides a summary of the public's
comments and concerns regarding the Proposed Plan for the A.O.
Polymer" site and New Jersey Department of Environmental
Protection's (NJDEP's) and the U.S. Environmental Protection
Agency's (EPA's) responses to those comments. At the time of the
public comment period, NJDEP and EPA had selected a preferred
alternative for controlling soil and groundwater contamination at
the site.
NJDEP held a public comment period from April 25, 1991 through May
24, 1991 to provide interested parties the opportunity to comment
on the Proposed Plan for the A.O. Polymer site. A request for an
extension of the public comment period was granted and the public
comment period was extended to June 7, 1991.
NJDEP held a public meeting to present the preferred remedial
alternative for controlling soil and groundwater contamination at
the A.O. Polymer site. The meeting was held at the Sparta
Municipal Building, 65 Main Street, Sparta, New Jersey on May 9,
1991 at 7:00 pm.
Judging from the comments received during the public comment
period, the residents and the town council of Sparta were
responsive to t-.he Proposed Plan and it appears they support the
preferred alternative for controlling soil and groundwater
contamination. No objections to the Proposed Plan or preferred
alternatives were raised at the public meeting.
This Responsiveness Summary is divided into the following sections:
I. RESPONSIVENESS SUMMARY OVERVIEW: This section briefly
describes the site background and preferred remedial
alternative for controlling soil and groundwater
contamination.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS: This
section provides the history of community concerns and
interests regarding the A.O. Polymer site.
III. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS, CONCERNS
AND RESPONSES: This section summarizes the oral comments
received by NJDEP at the public meeting, and NJDEP's responses
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as well as responses to written comments received during the
public comment period.
I. OVERVIEW
The A.O. Polymer Superfund site, which is located at 44 Station
Road in the Township of Sparta, New Jersey, occupies approximately
four acres near Sparta Station along the New York, Susguehanna and
Western (NYS&W) Railway. It is bounded to the north and east by
Station Park, a municipal recreation area, to the southeast by
Station. Road, and to the south and west by the NYS&W Railway.
Several small businesses and three homes are located near the site
on Station Road. The Sparta High School is approximately one-half
mile to the north-northeast and a private gun club is located 500
feet northwest of the site. The Wallkill River flows 500 feet to
the southeast of the site.
The A.O. Polymer complex has been operating as a specialty polymer
and resin manufacturing facility for approximately 30 years.
Mohawk Industries began operations at the site in the early 1960s
and was involved in the production of various resins using
polymerization processes. Mohawk also engaged in the reclamation
of electronic component cleaning fluids containing various freon
compounds in alcohol.
In December 1978, NJDEP inspectors and Sparta Health Department
officials began collecting water samples from potable wells
surrounding the site. Analysis of these samples revealed the
presence of volatile organic comtaminants in three private domestic
wells located along Station Road. In June 1979, the owners of the
three affected wells filed damage claims with the New Jersey Spill
Fund, and in January of the following year, these homes were
connected to the public water line.
In 1980, NJDEP began investigating reports of drum stockpiling at
the site. These investigations identified on-site waste disposal
and storage practices as the source of the groundwater
contamination. Waste handling practices included disposal of
liquid chemical waste into unlined lagoons, improper storage of
over 800 deteriorating drums, and the burial of crushed and open
drums containing waste materials.
Between 1980 and 1981, a surface cleanup of the site was initiated
by NJDEP, including the removal of suriace drums and the excavation
and removal of contaminated soil in the lagoon area to a depth of
approximately 10 feet. After excavation of this lagoon area, the
area was backfilled with, cleein soil. This cleanup resulted in the
removal of 1,150 drums, 1,700 cubic yards of contaminated soils and
120 cubic yards of crushed drums and debris.
Concern regarding groundwater contamination at the site resulted in
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additional investigations by NJDEP. In January 1982, NJDEP's
Division of Water Resources installed 11 monitoring wells on and
adjacent to the site to determine the extent of groundwater
contamination. Sampling confirmed that groundwater contamination
had reached the Allentown Formation, which is a source of potable
water. Sampling also revealed that contamination had migrated
under Station Park, approximately 300 yards northeast of the site.
The site was placed on the National Priorities List on September 1,
1983. In 1984, an investigation of the site was initiated by the
NJDEP's Division of Hazardous Site Mitigation. In December 1986,
a contract to conduct a Remedial Investigation and Feasibility
Study (RI/FS) at the site was awarded to ICF Technology
Incorporated.
The RI included sampling of groundwater, soils, surface waters, and
sediment at the site; the FS presented a detailed review of the
alternatives considered in remediation of the site. The RI/FS was
completed in April 1991. On April 25, 1991 the public comment
period commenced with NJDEP's release of the RI/FS findings and the
Proposed Plan. NJDEP identified its preferred remedial alternative
in a public notice which appeared in the New Jersey Herald and in
a mailing to NJDEP contacts for the site. A public meeting to
present the Proposed Plan to the public was held on May 9, 1991.
The selected remedy specified in the Record of Decision (ROD)
involves remediation of soils using soil vapor extraction.
Groundwater is to be remedied by pumping and and then treatment by
use of Powdered Activated Carbon Treatment followed by reinjection
of treated water to the groundwater by use of recharge basins.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
Community concerns have centered around odor complaints, the threat
of contamination of the high school drinking well, the park playing
fields, and surface water pollution of the Wallkill River.
Although the threat of contamination to the high school drinking
well, contamination of the park playing fields, and pollution of
the Wallkill River are being addressed by the Superfund response
action outlined in the Proposed Plan, the air emissions from the
continued operation of the A.O. Polymer plant are being addressed
by NJDEP's Division of Environmental Quality (DEQ). DEQ has been
responsive to community complaints concerning emissions from the
active facility.
Additional community concerns regarding site clean-up activities
were raised during the May 9 public meeting and are summarized in
Section III below.
III. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS. COMMENTS. CONCERNS.
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AND RESPONSES
This section summarizes comments received from the public during
the public comment period, and NJDEP's responses.
A. SUMMARY OP QUESTIONS AND NJDEP's RESPONSES FROM THE PUBLIC
MEETING CONCERNING THE A.O. POLYMER SITE - MAY 9, 1991
A public meeting was held May 9, 1991 at 7:00 p.m. at the Town
Hall, 65 Main Street, Sparta, New Jersey. Following a brief
presentation of the RI/FS findings, NJDEP's Remedial Project
Manager, Zoe Kelman, presented the Proposed Plan and preferred
alternative for the A.O. Polymer site. Comments raised by the
public following Ms. Kelman's presentation are categorized by
relevant topics and presented as follows:
1. Impact of Remediation on the Wallkill River, Franklin
Pond, and the Surrounding Community
2. Air Concerns
3. Groundwater Concerns
4. Health Concerns
5. Hazardous Materials at the Site
6. Length of Time Involved in Studying and Cleaning the Site
7. Current Plant Operations and Emissions
8. Cost and Liabilities
1. Impact of Remediation on Wallkill River, Franklin Pond, and the
Surrounding Community
Comment: As part of the preferred alternative, contaminated
groundwater would be pumped from the ground, treated, and
reinjected. Several questions were posed with regard to the
handling of treated groundwater including: where the discharge of
the treated water would be going; where, how, and how often the
treated discharge water would be sampled and tested; if the
discharged groundwater would in any way negatively impact the
Wallkill River or Franklin Reservoir.
Response: Most of the treated groundwater will be placed in
recharge basins to be constructed on-site, and filter back into the
ground. In the event that the recharge basins are not able to
handle the volume of treated water, some amount of treated water
may be discharged to the Wallkill River. The details of how and
how often the treated discharge water would be tested will be
worked out during the design stage; testing of treated water would
occur before any treated water is released into the groundwater or
the Wallkill River. Any discharge of treated water to the Wallkill
River will have no significant negative impact to the river or to
Franklin Resevoir, located downstream. The treated water which
will be reinjected will be treated to levels lower than Maximum
Contaminant Levels (MCLs) which are limits established for drinking
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water.
Comment: Is there a potential for disruption of local activities
by the remediation of the site? Also, what effect will increased
traffic from the site remediation have on local businesses? Will
the positioning of groundwater extraction wells in Station Park
interfere with park activities?
Response: Increased traffic due to the remediation of the site is
not anticipated to have an impact on commerce in the surrounding
area. Traffic to and from the site would be scheduled to minimize
any disruption to the surrounding community and commerce in the
area. This concern will be considered in greater detail during the
design stage. The conceptual design presented at the public
meeting showed that the location of the pumping wells was located
on the soccer fields. The design presented is preliminary and
another more detailed phase of the design process would have to be
performed before it is known for certain where the exact location
of the extraction wells will be. Although there are engineering
considerations that must be weighed to determine where extraction
wells must be placed to be most effective, efforts will be made to
minimize, to every extent possible, the disturbance to the park
activities.
2. Air Concerns
Comment: Since no air sampling has been conducted at the site how
can a risk assessment be considered complete?
Response: The air exposure pathway evaluated in the risk
assessment examined the evaporation of volatile organics from the
groundwater and migration of volatile organics from the groundwater
through the soil into the air, as well as their impact on the
health of residents and people using the park. Due to the
difficulty and inaccuracies encountered with air sampling, the
exposure pathway of air contaminants from these media was evaluated
using a mathematical model. The evaluation indicated that air
contamination resulting from the groundwater and soil contamination
at the A.O. Polymer site poses no significant risk to residents or
park users.
During the Remedial Investigation (RI), while installing monitoring
wells and collecting sub-surface soil samples, air monitoring was
conducted on-site. The readings from this monitoring indicated no
significant risks existed.
Air emissions from the A.O. Polymer active facility are regulated
by the NJDEP's Division of Environmental Quality.
,-
Comment: Earlier in the public meeting a statement was made that
there is no risk to residents posed by the air from the A.O.
Polymer Superfund site but there exists considerable concern about
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6
emissions coining from the A.O. Polymer active facility.
Response: The role of the public meeting was to address concerns
about the Superfund aspect of the site i.e. the site cleanup with
regard to the contaminated soil and groundwater. Air emissions
from the active facility are not related to the Superfund cleanup
process of the contaminated soil and groundwater. Air emissions,
as they are related to the groundwater and soil contamination at
the site pose acceptable levels of risk to human health or the
environment.
Although the air concerns regarding the current operating facility
were not addressed in the Proposed Plan to remediate the
contaminated groundwater and soils, by no means was this area of
concern overlooked. Current air emissions from the A.O. Polymer
plant are being addressed separately by NJDEP's Division of
Environmental Quality (DEQ). Jeff Meyer, a representative from
DEQ, was present at this public meeting to provide information
about air emissions from the A.O. Polymer active facility.
Jeff Meyer stated that A.O. Polymer is subject to provisions of the
New Jersey Air Pollution Control Act of 1968 and has been cited and
fined for violations of air emissions standards. The company has
requested a hearing with NJDEP regarding these violations and the
action is under review.
NJDEP will continue to inspect and take appropriate enforcement
actions at the site to ensure compliance with all applicable laws.
Comment: Would the emissions from the Soil Vapor Extraction (SVE)
treatment system, proposed as part of the preferred alternative,
contribute to the air pollution of the area and what method would
be used to test air emissons from the SVE process?
Response: The SVE treatment system would not contribute to air
pollution in the area. The emissions from the SVE treatment system
are subject to regulations which must meet both Federal and State
air quality standards before the system could run continuously.
Sampling and analysis would be conducted prior to full-time
operation to ensure that emissions do not exceed permissible
levels.
The actual method for sampling the SVE treatment system would be
consistent with the current requirements of the New Jersey
Department of Environmental Protection's Division of Environmental
Quality.
3. Groundwater Concerns
Comment: Does the groundwater contamination relate to the septic
system of the facility?
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Response: No link between the septic system and the groundwater
plume has been identified. Although the septic tank is no longer
being used by the facility, there may be a problem with
contaminants in it. The septic tank will be either cleaned out or
removed.
Comment: What would be the potential health risk to people of the
community if the Eagle's Nest Municipal Well Facility is activated?
Response: The well in question is being installed on the opposite
side of the Wallkill River in relation to the site. The river acts
as a boundary preventing the contaminated groundwater plume from
moving to the opposite side of the River where the municipal well
was installed. Initial tests performed on the municipal well
showed that it had no effect on the wells installed at the A.O.
Polymer site. It is anticipated that pumping from this well will
not affect the contaminated groundwater plume which discharges to
the Wallkill River.
4. Health Concerns
Comment: A comment was made concerning an apparent discrepancy
between a Health Assessment Report written for the federal Agency
for Toxic Substance and Disease Registry (ATSDR) by the New Jersey
Department of Health (DOH), and the Risk Assessment of the Remedial
Investigation. The commenter was concerned that the Health
Assessment concluded that the A.O. Polymer site should be
considered a public health concern, while the Risk Assessment part
of the Remedial Investigation Report concluded that there is an
acceptable level of risk posed by the site.
Response: The Health Assessment report the commenter was refering
to is a report which based its recommendations on preliminary data
and does not include the findings of the completed RI/FS.
Extensive data was collected and compiled after the ATSDR report
was issued. This data shows that with the exception of ingesting
the contaminated groundwater, the current risks associated with the
Superfund site are within EPA acceptable limits. In addition, the
NMJDOH will be re-evaluating and amending the health assessment
based on the complete findings of the RI/FS.
Comment.: Has there been a thorough risk assessment performed for
the site with regard to air exposures, and the cumulative and
synergistic effects of chemicals?
Response: A thorough risk assessment was performed for the A.O.
Polymer site in which the synergistic and cumulative effects of
chemicals were taken into account when calcultaing risks to the
people who use the park, as well as residents of the area. This
risk assessment was based on data from the subsurface soil and
groundwater investigation and considered potential air emissions
from these sources.
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8
5. Hazardous Materials at the Site
/
Comment: Concerns were raised regarding drums on site: are drums
still present from the 1981 cleanup, if not, what was the fate of
those drums, also, how are the drums on the site labeled, and are
drums on the property still being dumped into the lagoon area?
Response: No drums from the 1981 cleanup are present on the site.
These drums were shipped off-site for disposal. There are drums on
site, which are lawfully present, containing raw materials to be
used for processing at the active plant. Other drums on-site
contain.the remanants of protective clothing worn by technicians
who conducted the remedial investigation or contain water and soil
generated when soil samples were collected and monitoring wells
were drilled, developed, and sampled during RI activities. NJDEP
has issued a contract, which will go into effect within the next
six to eight months, that provides for the removal of all drums
associated with the remedial investigation of the site.
All the drums on the site relating to the Remedial Investigation
are labeled "Sample," and are numbered.
The lagoon area, which was remediated by NJDEP in 1980, has not
been used as a disposal area after the 1981 clean-up.
Comment: What are volatile organic compounds, and how long does it
take for them to breakdown?
Response: Volatile organic compounds that were found at the A.O.
Polymer site are common industrial solvents used in industries
across the country. They include trichloroethene, which is used
for degreasing and cleaning. Other volatile organic compounds
found at the site are typical gasoline components such as toluene
and xylenes. The amount of time it takes for these chemicals to
break down is site specific. For the A.O. Polymer site, it is
estimated that the contaminants found in the soil could leach into
the groundwater and discharge into the Wallkill River for up to 90
years if no remediation is conducted.
6. Length of Time Involved in Studying and Cleaning the Site
Comment: Several commenters expressed frustration over the amount
of time involved with studying and planning remediation at the
site.
Response: The process of cleaning up hazardous waste sites does
take a long time because cleanup of these sites often become
encumbered by very complex technical, administrative, and financial
issues. Also, the length of time taken to study the site ensures
that the extent of contamination is accurately known and that the
chosen treatment technology will be the most effective remedy
available. However, immediate hazards to the public or environment
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are addressed early on in the Superfund process. In this case, the
1981 cleanup and hookup of affected properties to a public water
supply addressed immediate health threats posed by contaminated
groundwater.
7. Current Plant Operations and Emissions
Comment: Concerns were raised regarding the current operating
facility. Specifically, concerns pertaining to the plant's
possible adverse impact on the health of residents and workers of
the surrounding area as well as recreational users of the park who
are subjected to the plant's air emissions.
Response: The cleanup of soils and groundwater at the site is
being addressed under the authority of the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA)
otherwise known as Superfund. Superfund addresses the threat to
human health and environment posed by the contaminated groundwater
and soils at the A.O. Polymer site.
As described above, NJDEP has and will continue to take enforcement
action against A.O.Polymer to ensure compliance with the Air
Pollution Control Act.
Comment: One commenter reported that she had witnessed a discharge
from the A.O. Polymer facility to the Wallkill River. This person
raised the concern over the handling of materials, including waste
material, at the site.
Response: The A.O. Polymer facility has been issued a restraining
order to stop any discharge into the groundwater and, in the
future, if any person believes that this restraining order is not
being complied with, they sould report it to the NJDEP hotline,
which is available 24 hours a day, at (609) 292-7172.
8. Cost and Liabilities
Comment: There were concerns about who would be liable for
additional expenses associated with capping of wells, installation
of water meters, and the cost of using municipal water incurred by
businesses in the area.
Response: The Spill Compensation and Control Act (NJSA Title
58:10-23.11) provides a mechanism for filing damage claims through
the New Jersey Environmental Claims Administration located at 506
East State Street, Trenton, New Jersey 08625, (609) 633-2947.
Comment: What funding for business and residential relocation is
available during the remediation process?
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10
Response: Based on anticipated activities, there would be no need
to relocate anyone during the remediation of the site. Air
emissions from treatment facilites would be monitored and are not
expected to exceed maximum allowable limits.
B. WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
Comments and concerns which were not addressed at the public
meeting were accepted in writing during the public comment period
and are answered in the following part of the Responsiveness
Summary.. These written comments are categorized by relevant topics
and presented as follows:
1. Alternative SC-6, Excavation and Low Temperature Thermal
Desorption
2. Alternative MM-2, Extraction and Treatment: Biological/Air
Stripping/Carbon Adsorption
3. SC-4, Soil Vapor Extraction
4. Health Concerns
5. Location of Remedial Structures and Wells
6. Current Plant Operations and Related Environmental Problems
7. Findings of the RI Report
1. Alternative SC-6/ Excavation and Low Temperature Thermal
Desorption
Comment: The Proposed Plan does not address potential difficulties
associated wth excavation of soil as related to Alternative SC-6,
Excavation and Low Temperature Thermal Desorption.
Response: The Proposed Plan does consider the difficulties in
executing such excavation activities and states this in the
"Analysis of Criteria" section of the Proposed Plan under the
Implementability subsection. Further detail regarding problems
associated with implementing SC-6 may be found in the FS report.
The Feasibility Study is available to the public in the public
repositories located at the following locations:
Sparta Township Library
22 Woodport Road
Sparta, New Jersey 07871,
(201) 792-3101
NJDEP
401 East State Street
Trenton, New Jersey 08625
(609) 984-2902
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11
U.S. EPA - Region II
26 Federal Plaza
Room 13100
New York, New York 10278
(212)264-9836
Comment: As part of the excavation alternative, would saturated
material also be excavated if the heavier phases of the
contaminants are dispersed in the soil layer containing
groundwater? Feeding saturated materials into a thermal treatment
unit may present capacity problems. No data is presented in the
Proposed Plan to indicate that thermal desorption would reduce the
component concentrations to below the required treatment levels.
Response: Saturated soil would not be excavated and fed into the
thermal treatment unit; excavation of contaminated soil would cease
once the area of saturated soil layer is reached. No data is
presented about the reduction capacity of the thermal treatment
unit in the Proposed Plan. The effectiveness of the thermal
desorption treatment process is discussed in section 4.2.6 of the
Feasibility Study. More exact figures regarding the effectiveness
of the thermal desorption treatment process would have been
discussed in the design phase, if this alternative was chosen.
2. Alternative MM-2, Extraction and Treatment: Biological/Air
Stripping/Carbon Adsorption
Comment: Alternative MM-2 does not describe the proposed
biological treatment system in enough detail to determine whether
the release of volatiles to the atmosphere would present a problem.
Response: It is anticipated that release of volatiles to the
atmosphere would not be a problem with regard to alternative MM-2.
Air stripping-emissions would be regulated under the Federal Clean
Air Act. The State of New Jersey also regulates particle and
volatile organic emissions from air strippers. Air pollution
control permits are requirements met for all air strippers in the
State of New Jersey.
Comment: Would the vent gas from the biological reactor pass to
the air stripper and on through the carbon treatment system or
would the biological reactor be vented through a separate vent
treatment system?
Response: It is anticipated that the gas from the biological
reactor would pass to the air stripper and then through the carbon
treatment system.
3. SC-4, Soil Vapor Extraction
Comment: The description of SC-4, the Soil Vapor Extraction
system, does not explain whether extraction will be by vertical
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12
wells or from horizontal (lateral) collection headers.
Response: Since the contaminated soils lie between approximately
10 feet and 25 feet below the soil surface, it is anticipated that
a vertical extraction well system will be implemented to extract
volatile organic compounds from unsaturated soils. Specific
details will be determined during the design phase of the project.
Comment: The vapor extraction and groundwater pump and treat
methods both suffer from the same physical problems in that
movement of contaminants is retarded by the soil structure thus
making the removal of contaminants increasingly difficult as the
distance increases from the collection point. Installation details
of a vapor extraction system along with a better characterization
of the soil geology would aid in understanding how effective vapor
extraction is going to be.
Resonse: The lowlands in Station Park, on either side of the
Wallkill River, are mapped as alluvial land. This is a land type
typified by flat, poorly drained soils. Parent material, soil
texture, and other properties vary significantly over short
distances and they are prone to frequent flooding. About 15 to 20
percent of the study area is in this land type. About 15 to 20
percent of the soils in the Station Park are classified as
Riverhead sandy loam. These are deep, well drained soils with a
sandy loam surface layer generally underlain by glacilal-fluvial
deposits of sand and gravel. The permeability of the soil is
moderately rapid. Riverhead sandy loam occurs in the northern
regions of Station Park on slopes varying from 3 to 8 percent.
From 20 to 40 percent of Station Park, and part of the A.O. Polymer
site are underlain by Palmyra gravelly fine sandy loam. This is
composed of deep, well to excessively well drained upland soils
formed on glacial outwash deposits. The Palmyra series has a
moderate to rapid permeability. The remaining portion of Station
Park and most of A.O. Polymer are underlain by the Otisville
gravelly, loamy sand series. The texture, parent material and
permeability of this series are similar to the Palmyra series.
However, the Otisville soils are not as well developed with lower
fertility, cation exchange capacity and pH. The Otisville series
occupies upland areas in Station Park adjacent to A.O. Polymer.
Overall, the soil at the A.O. Polymer site has relatively high
permeability and thus is expected to lend itself to the selected
soil vapor extraction and groundwater pumping systems. Highly
permeable soils will have high diffusion rates to allow large
quantities of air and water to be passed through the soil matrix.
Specific details of how far apart and where wells will be placed
will be determined after a treatability study is performed during
the design phase of the project.
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13
4. Health Concerns
Comment: Two recent newspaper articles were cited as saying no
health risks exist to the people on the Station Park ball field.
Who was verifying this information?
Response: The risk assessment in the RI, which evaluated risks
solely associated with the Superfund site, found current health
risks to people using the park to be at acceptable levels. This
risk assessment was then reviewed by NJDEP's Bureau of
Environmental Evaluation and Risk Assessment as well as risk
assessment specialists at USEPA. Both agencies found the risk
assessment to be correct in stating that current health risks to
people using the park are within acceptable limits.
Comment: An Agency for Toxic Substance and Disease Registry
(ATSDR) report was cited which recommended that soil and air
sampling be performed, the report also stated that the community is
probably being exposed. Why were no soil and air samples taken?
Response: Extensive soil sampling was performed on the A.O.
Polymer property to determine the extent of the source of
groundwater contamination. The data from these samples indicated
that the area of soil contamination responsible for groundwater
contamination was limited to the A.O. Polymer property. Station
Park soils were sampled in Phase I of the RI. Although groundwater
contamination is present beneath Station Park, results of the
inhalation exposure scenario from the risk assessment conducted
during the RI showed an acceptable level of risk to recreational
users of the park.
The air exposure pathway evaluated in the risk assessment examined
the evaporation of volatile organics from the groundwater and
migration of volatile organics from the groundwater into the air,
as well as their impact on the health of residents and people using
the park. The exposure pathway of air contaminants from these
media was evaluated using a mathematical model provided by EPA.
The evaluation indicated that air emissions from the volatilization
of organic compounds in the groundwater are currently well within
the EPA acceptable risk range to both residents and recreational
park users.
5. Location of Remedial Structures and Wells
Comment: The proposed placement of wells on soccer fields in
Station Park, as depicted in the Feasibility Study, shows one of
the wells to be in the same location as a municipal maintenance
building.
Response: The location of wells depicted in the Feasibility Study
is not anticipated to be the final location of the wells. The
Feasibility Study presented a conceptual design of the groundwater
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14
extraction system and the exact location of the well system was not
chosen at that time. The final location of wells and treatment
units will be determined in the design phase of the project. Every
effort will be made to minimize the interference of park activities
by the location of the wells and treatment systems.
6. Current Plant Operations and Related Environmental Problems
Comment: The Remedial Investigation and Feasibility Study Report
did not adequately address the current use of the A.O. Polymer site
and did not include any proposed action to correct the continuing
source of environmental problems caused by its operation,
particularly with regard to air pollution and improper discharge to
the septic system.
Response: Cleanup of soils and groundwater at the site is being
addressed under the authority of the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) otherwise known
as Superfund.
Although the air concerns regarding the current facility were not
addressed in the Proposed Plan, by no means has this area of
concern been overlooked. Air emissions from the A.O. Polymer plant
are being addressed by NJDEP's Division of Environmental Quality.
There has been no link found between the septic system and the
contaminated groundwater plume. Discharges to the septic system
have been haulted by a court order and the septic system may be
cleaned, but not as component of the selected remedy.
Comment: Would there be significant exposure to park users
resulting from excavation of soils for the development of a
maintenance building in an area where transfer of gases from the
groundwater to iir was characterized as high.
Response: Transfer of contaminants to the atmosphere from
groundwater is likely to be most significant in areas of Station
Park where groundwater contaminant concentrations are high and the
depth to water is shallow. The air emissions exposure pathway was
evaluated as part of the Superfund risk assessment using a
mathematical model. The risk assessment indicated air emissions
related to the Superfund site are curently well within the EPA
acceptable risk range.
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7. Findings of the RI Report.
Comment: The conclusion that the plume has reached a steady state
condition is not completely substantiated. The recommendation that
additional wells, and a wetland study be conducted suggests that
future investigative work is necessary. These recommendations, as
well as the lack of soil gas data as it relates to the design of
the soil vapor extraction system, leads one to believe the
investigation is incomplete.
Response: Data obtained during the RI was adequate to characterize
the site and perform detailed evaluations of alternatives in the
feasibility study. Results of a soil gas study performed at the
site indicated that little additional benefit would be gained by
further soil gas investigation. Therefore, plans to expand the
soil gas study were dispensed with. Future data gathering, as it
relates to the design phase of the project, is necessary and will
be performed as appropriate in the design phase of the project.
Comment: The RI report does not adequately identify the source of
the groundwater mound beneath the site.
Response: The data in the RI report indicate that a zone of
perched water is responsible for the groundwater mound beneath a
portion of the A.O. Polymer site. The area of perched water is
caused by a localized silt and clay layer. This is stated in the
RI report in Section 3.7.1.
Comment: The RI report notes that groundwater flows to the
Wallkill River, although it appears that some groundwater adjacent
to the former waste lagoons flows to the north. Would this
northward flow of groundwater affect groundwater remediation?
Response: While there is a northward flow component of
groundwater, this will not affect the remediation of the
contaminated groundwater since the contaminated groundwater plume
is moving in a northwestly direction toward the Wallkill River.
Comment: Secondary sources of contamination such as the railroad
tracks, septic tanks and cooling ponds have generally been
discounted in the RI report. Discounting these sources makes it
difficult to determine their contribution to the total contaminant
load.
Response: The most significant source of contamination on the A.O.
Polymer site is the former lagoon disposal area. The secondary
sources have been discounted because it is believed that they do
not significantly contribute to the contaminant load.
Comment: The RI has not fully documented the activities of Mohawk
Industries.
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Response: Mohawk Industries was involved in the production of
resins using polymerization processes. Mohawk also engaged in the
reclamation of electronic component cleaning fluids containing
freon compounds in alcohol. EPA is currently conducting further
investigations to obtain additional information regarding the
activities of Mohawk Industries.
Comment: Will subsurface structural pathways modify the projected
capture zones presented in the feasibility study? Aquifer
performance testing (i.e., pump testing) was not performed for the
evaluation of hydraulic conductivity. Is slug testing to be the
only tool used for the evaluation of hydraulic conductivity when
considering the design of the remediation systems?
Response: Structural pathways as well as other factors may modify
the projected groundwater capture zones. These considerations will
be evaluated in detail during the design phase of the project. It
is anticipated that pump testing will take place during the
remedial design stage.
Comment: The groundwater remediation goal of 50 parts per billion
(ppb) established for the combined levels of various chemicals
found at the site as well as remedial soil action levels for
volatile and semi-volatiles are established in the absence of risk
assessment based action levels.
Response: In situations where a promulgated standard is not
available the NJDEP has the regulatory authority to determine an
appropriate standard of cleanup based on the health effects of the
compound. These recommended levels are standards considered
protective of human health and are: 50 ppb for combined levels of
various chemicals found in groundwater, and 1 parts per million
(ppm) for total volatile organics in soil and 10 ppm for total
semi-volatile... organic compounds in soil.
Comment: Pre-design bench scale and field pilot tests have not
been completed as part of the FS which may cause data gaps for
screening remedies and for determining realistic estimates of cost
and time to cleanup.
Response: Pre-design bench scale tests can be performed as part of
the design phase of the project. Pilot scale tests are usually
done on a remedy once it has been selected in order to obtain data
on the performance of the remedy. A treatability study is usually
considered appropriate for screening data on various remedial
alternatives. However, in this case, a literature search was
conducted on the remedial alternatives and data retrieved from this
search was considered adequate to perform the screening of remedial
alternatives.
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