United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R02-93/203
September 1993
&EPA Superfund
Record of Decision:
American Cyanamid, NJ
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-93/203
3. Recipient's Accession No.
Title and Subtitle
SUPERFUND RECORD OF DECISION
American Cyanamid, NJ
First Remedial Action
5. Report Date
09/28/93
6.
7. Author(s)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10 Project Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/800
14.
15. Supplementary Notes
PB94-963832
16. Abstract (Limit: 200 words)
The 575-acre American Cyanamid site is a manufacturing facility located in the
southwestern section of Bridgewater Township, Somerset County, New Jersey. Land use in
the area is predominantly residential, commercial, and industrial. The entire site
lies on the Raritan River, about 20 miles upstream from where the river discharges into
the Atlantic Ocean. The estimated 30,000 people who reside within the 33-square miles .
of the township use the Elizabethtown Water Company's two water intakes, located
approximately 1,800 feet upriver from the site, to obtain their drinking water supply.
Beginning in 1918, American Cyanamid has used the facility to produce rubber chemicals,
Pharmaceuticals, dyes, pigments, chemical intermediates, and petroleum-based products.
In 1981, American Cyanamid conducted preliminary onsite studies which determined that
contamination sources were confined to the main plant production area and around 27
onsite impoundments in the main plant area. As a result of reported spills and leakage
of various plant wastes, a number of onsite investigations were conducted by the PRP
and the State, which revealed PCB- and PAH-contaminated soil that could potentially
affect ground water in the area. In 1988, 16 of the 27 onsite impoundments were
determined to be potentially contributing to ground water contamination due to waste
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - American Cyanamid, NJ
First Remedial Action
Contaminated Media: soil, sludge, debris
Key Contaminants: VOCs (toluene, xylenes), metals (arsenic, chromium, lead)
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
72
22. Price
(See ANSI-239.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R02-93/203
American Cyanamid, NJ
First Remedial Action
Abstract (Continued)
leakage; and RCRA closure procedures were implemented for four impoundments. These 16
impoundments, being addressed under the Superfund cleanup program, were taken out of
service before the RCRA regulations were promulgated. Beginning in 1989, American
Cyanamid implemented several remedial actions at the site, including the removal of
pumpable tars for use as an offsite fuel, and a berm stability evaluation program. In
1992, eight surface soil areas requiring removal action were identified under the 1992
Surface Soils Remedial/Removal Action (SSR/RA) Program, and included the excavation and
offsite disposal of PCB-contaminated soil; excavation and disposal of PAH-contaminated
soil in the onsite RCRA permitted disposal facility; capping of another PAH-contaminated
area; and the placement of a geotextile, soil, and vegetative cover over a
chromium-contaminated area. In addition, tars from impoundments 4 and 5 are being removed
and blended in an onsite RCRA permitted hazardous waste fuel blending facility and four
onsite impoundments have been closed, to be replaced by the new RCRA permitted Impoundment
8 facility. This ROD addresses the contamination in Group 1 Impoundments, consisting of
four onsite surface impoundments, as OU1. The sludge contained in the Group 1
Impoundments is believed to have originated from onsite wastewater treatment operations,
and it originally was deposited into another impoundment before being dredged and/or
pumped into these Impoundments. Future RODs will address other impoundment areas and
onsite ground water. The primary contaminants of concern affecting the soil, sludge, and
debris are VOCs, including toluene and xylenes; and metals, including arsenic, chromium,
and lead.
The selected remedial action for this site includes excavating and treating 176,500 yd^ of
soil, sludge, and debris from the Group 1 Impoundments onsite using cement-based
solidification; consolidating the solidified material into the onsite RCRA permitted
facility; collecting volatile emissions using a blower and treating them with a carbon
ads_orber, as needed; monitoring the ground water; and revegetating the impoundment .area.
The estimated present worth cost for this remedial action is $12,500,000.
PERFORMANCE STANDARDS OR GOALS:
Soil cleanup goals are based on health-based risk criteria and will not exceed the State
health level of 10~6. Chemical-specific goals were not provided.
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NOTICE
THIS DOCUMENT HAS BEEN REPRODUCED
FROM THE BEST COPY FURNISHED NTIS BY
THE SPONSORING AGENCY. ALTHOUGH ITS
RECOGNIZED THAT CERTAIN PORTIONS ARE
ILLEGIBLE, IT IS BEING RELEASED IN THE
INTEREST OF MAKING AVAILABLE AS MUCH
INFORMATION AS POSSIBLE.
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ROD FACT SHEET
SITE
Name
Location/State
EPA Region
American Cyanamid
Bound Brook/New Jersey
2
HRS Score (date): 50.28 (Sept. 1983)
ROD
Date Signed: September 24, 1993
Remedy: Solidification
Operable Unit Number: OU-1
Capital cost: $12,500,000 (in 1993 dollars)
Construction Completion: to be determined during RD
O & M in 1993: Not Applicable (N/A), None required
1994:
1995:
1996:
Present worth: N/A
LEAD
Remdial/Enforcement:
EPA/State/PRP:
Primary contact:
Secondary contact:
Main PRP(s):
PRP Contact:
Enforcement
State of New Jersey
Haiyesh Shah, NJDEPE, (609) 633-1455
Rocco Grassi, EPA, (212) 264-6314
American Cyanamid
Joel Jerome, (908) 862-6000
WASTE
Type: Volatile and semivolatile organics, heavy metals
Medium: Sludge
Origin: Lagoons
Est. quantity: 176,500 cubic yards
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SUPERFUND RECORD OF DECISION
AMERICAN CYANAMID SITE
BRIDGEWATER TOWNSHIP
SOMERSET COUNTY
NEW JERSEY
PREPARED BY:
N.J. DEPARTMENT OF ENVIRONMENTAL PROTECTION AND ENEBG*
SITE REMEDIATION PROGRAM
BUREAU OF FEDERAL CASE MANAGEMENT
SEPTEMBER 1993
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AMERICAN CYANAMID SITE
RECORD OF DECISION
TABLE OF CONTENTS
DECLARATION STATEMENT 1
DECISION SUMMARY 3
GLOSSARY 22
ADMINISTRATIVE RECORD INDEX 24
RESPONSIVENESS SUMMARY 26
ATTACHMENT 1 - FIGURES
ATTACHMENT 2 - TABLES
ATTACHMENT 3 - RESPONSIVENESS SUMMARY ATTACHMENTS
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DECLARATION STATEMENT
RECORD OF DECISION
AMERICAN CYANAMID SITE
SITE NAME AHD LOCATION
American Cyanamid Site
Bridgewater Township, Somerset County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document, prepared by the New Jersey Department of
Environmental Protection and Energy (NJDEPE) as lead agency, presents the
selected remedy for the American Cyanamid Site. The selected remedy was
chosen in accordance with the requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA),
as amended by the Superfund Amendments and Re-authorization Act of 1986
(SARA) and the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP). This decision document explains the factual and legal basis for
selecting the remedy for this site. This decision is based on the
administrative record for this site. The attached index identifies the items
that comprise the administrative record.
The United States Environmental Protection Agency (USEPA), support agency
for this site, concurs with the selected remedy and has provided a
concurrence letter to that effect which is attached to the responsiveness
summary section of this document.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in this Record of
Decision (ROD), may present an imminent and substantial endangerment to
human health, welfare, or the environment.
DESCRIPTION of THE SELECTED REMEDY
This ROD addresses only one operable unit (Group I Impoundments) consisting
of four on-site surface impoundments 11. 13, 19 and 24. The selected
remedy is "Solidification with Consolidation into the on-site Resource
Conservation and Recovery Act (RCRA) Permitted Impoundment 8 Facility".
The major components of the selected remedy include:
• Excavation of the waste material from Group I Impoundments (11, 13,
19 & 24)
• On-site solidification of excavated material by using cement-like material
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• Consolidation of the solidified material into the on-site RCRA Permitted
Impoundment 8 facility
Ground water monitoring will be performed to assess potential influences from
Impoundments 19 and 24 on water quality of the Raritan River. The NJDEPE
and USEPA may consider the results of pilot studies for in-situ solidification
treatment for Impoundment 24.
DECLARATION OF STATUTORY DETERMINATIONS
The Solidification with Consolidation into the on-site RCRA Permitted
Impoundment 8 Facility has been selected based on the results of the
Impoundments Characterization Program, Baseline Endangerment Assessment
and Corrective Measure Study/Feasibility Study (CMS/FS) for Group I
Impoundments, which have shown the remedy to be protective of human
health and the environment. The selected remedy is protective of human
health and the environment, complies with State and Federal 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 for this site.
Because this remedy will result in hazardous substances remaining on the site.
a review will be conducted pursuant to CERCLA every five (5) years after the
commencement of the remedial action to ensure that the remedy continues to
provide adequate protection of human health and the environment.
Final site-wide remediation including all impoundments, soils and ground water
will comply with the applicable or relevant and appropriate requirements
(ARARs).
The State of New Jersey general guidelines on contaminant cleanup levels as
found in the formerly proposed "Cleanup Standards for Contaminated Sites"
were published in the February 3, 1992 New Jersey Register. These
guidelines are protective to 10"* risk level. Final site-wide remediation will
insure that there is no current or future unacceptable risk to human health
and the environment including compliance with the State of New Jersey 10*
risk level.
Signature Datti
Lance R. Miller, Assistant Commissioner
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, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
; PR°lt JACOB K. JAVITS FEDERAL BUILDING
NEW YORK. NEW YORK 1O278-OO12
2 7 SEP 1993
Jeanne Fox, Acting Commissioner
State of New Jersey
Department of Environmental
Protection and Energy
401 East State Street, CN 402
Trenton, New Jersey 08625-0402
Re: Record of Decision
American Cyanamid Superfund Site
Bridgewater Township, Somerset County, New Jersey
Dear Commissioner Fox:
The United States Environmental Protection Agency (EPA),
Region II, has reviewed the draft Record of Decision (ROD) dated
August 1993 for the American Cyanamid Superfund Site (Site), which
is located in Bridgewater Township, Somerset County, New Jersey.
EPA concurs with the selected remedy, which includes the
excavation and on-site solidification of the waste material from
the Group I Impoundments (11, 13, 19 and 24) and has determined
that the draft ROD is consistent with Section 121 of the
Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) based on the administrative record for the Site. This
finding shall not affect EPA's right to conduct five-year reviews
of the Site or to take or require appropriate action pursuant to
such review, in accordance with Section 121(c) of CERCLA. EPA
further reserves the right to take response and enforcement actions
pursuant to Sections 104, 106 and 107 of CERCLA with respect to the
remedy and any additional future work at the Site.
William-a. Mus^ynski, P.E.
Acting Regional Administrator
PRINTED ON RECYCLED PAPER
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DECISION SUMMARY
1. SITE DESCRIPTION
The American Cyanamid Company site (facility, site or Cyanamid) is located
in north-central New Jersey in the southwestern section of Bridgewater
Township, Somerset County. The facility encompasses approximately 575
acres and is bounded by Route 28 to the north, the Raritan River to the
south. Interstate 287 and the Somerset Tire Service property to the east,
and Foothill Road and the Raritan River to the west. The southern perimeter
of the property follows the north bank of the Raritan River for nearly 1.5
miles, approximately 20 miles upstream from the river's discharge into the
Atlantic Ocean. The general location of the site is shown on Figure 1 .
The Raritan River provides recreational value (fishing and boating) along its
course through Somerset County. The river is also used as a primary supply
of residential water by the Elizabethtown Water Company, which operates
two water intakes upriver (approximately 1,800 feet upriver) of the site.
Ground water in the general vicinity of the site is not used as a potable
water supply. Potable water is supplied primarily by the Elizabethtown Water
Company. A search of available well records indicate that there are no
public community water supply wells or zones of contribution for such wells
in the general area of the site.
The Township of Bridgewater encompasses an area of approximately 33
square miles, with a population of about 30,000 (Census data, 1990). The
boroughs of Bound Brook, South Bound Brook, Manville, and Somerville are
in close proximity. The Township of Bridgewater is well-developed, providing
areas zoned for residential, commercial business, and manufacturing uses.
The northern three-quarters of the township are primarily zoned for
commercial business, manufacturing, office/rental, high density residential (R-
10 and R-20), and multifamily residential use. The land use/zoning
classification for the entire Bound Brook facility is manufacturing "M-1A" and
"M-1B" (Township of Bridgewater 1991).
Areas in the southern section of the township along the Raritan River, and
areas adjoining the river in the surrounding townships and boroughs, are
zoned primarily for industrial and manufacturing uses.
2. SITE HISTORY
Throughout its 75-year manufacturing history, numerous organic and inorganic
chemical raw materials were used at the Cyanamid facility to produce
products such as rubber chemicals, Pharmaceuticals, dyes, pigments, chemical
intermediates, and petroleum-based products. Currently, only Pharmaceuticals
are being manufactured at the facility. There are 27 on-site surface
impoundments at the facility, some of which were used for the storage or
disposal of industrial wastes.
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Preliminary . investigations conducted by . Cyanamid in 1981 verified that
approximately one-half of the site never supported manufacturing, waste
storage, or waste disposal activities, and that contamination sources are
confined primarily to the main plant area (including the production area and
West Yard) and the on-site waste storage impoundments. Most of the
wastes generated from past manufacturing operations were stored in the on-
site surface impoundments, while general plant wastes, debris, and other
materials were primarily disposed on the ground at various locations in the
West Yard.
Figure 2 shows location and important features of the site.
Cyanamid and the NJDEPE entered into an Administrative Consent order
(ACO) in May 1988 to address 16 of the 27 on-site impoundments, site-wide
contaminated soils, and ground water. In addition, a New Jersey Pollutant
Discharge Elimination System (NJPDES) permit had been issued in 1987.
This permit requires that Cyanamid conduct extensive ground-water monitoring
on a quarterly basis and continue pumping three bedrock production wells,
at a minimum rate of 650,000 gallons per day, to contain ground-water
contamination within the production area and West Yard.
The USEPA issued a Hazardous and Solid Waste Amendments (HSWA) permit
in November 1988 which, in conjunction with the operating permit issued by
NJDEPE, constitutes the Resource Conservation and Recovery Act (RCRA)
permit for the Cyanamid facility. The HSWA permit requirements are
consistent with the ACO and the NJPDES permit.
While a total of 27 impoundments exist at the Cyanamid facility, 16 of these
were determined through investigative efforts to be potentially contributing
to ground-water contamination and are covered by the Superfund cleanup
program. These 16 impoundments include impoundments 1, 2, 3, 4, 5, 11,
13, 14, 15, 16, 17, 18, 19, 20, 24 & 26. The other 11 impoundments (Im-
poundments 6, 7, 8, 9, 9A, 10, 12, 21, 22, 23 & 25) were either never
used (Impoundments 9, 10, and 12), contain only river silt from the facility's
former river water treatment plant (Impoundments 22 and 23), contain emer-
gency fire water (Impoundment 21), have been closed with NJDEPE approval
(Impoundment 25, 1988) or are being closed in accordance with approved
RCRA closure plans (Impoundments 6, 7, 8 and 9A). Impoundments 6, 7,
8 and 9A are being closed under RCRA because they were classified as
RCRA Treatment/Storage/Disposal (TSD) facilities.
RCRA closure procedures were implemented for Impoundments 6, 7, 8 and
9A after the use of Impoundments 6 and 7 was discontinued and interim
TSD status expired. Impoundment 9A has been closed in-place. The 16
Impoundments being addressed under this Superfund cleanup program were
taken out of service before the RCRA regulations were promulgated and,
therefore, were never given interim status as TSD facilities under RCRA.
The same 16 impoundments, potentially contributing to ground water contami-
nation, were used for storing by-products of rubber chemical production, dye
production, and coal tar distillation, as well as for disposal of general plant
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waste and demolition debris. A total of approximately 877,000 tons of
waste material are contained in these 16 Impoundments.
American Cyanamid Company is the sole responsible party for contamination
at this site.
3. ONGOING oft COMPLETED REMEDIAL PROGRAMS
Cyanamid has implemented, or is currently conducting, several remedial
programs at the site. Completed programs include removal of pumpable tars
(3.1 million gallons) from Impoundment 2 for off-site use as a supplemental
fuel (1986-1987), removal of pumpable tars from Impoundment 1 (1960s),
and a berm stability evaluation program (1989).
Surface Soils Remedial/Removal Action Program
The 1992 Surface Soils Remedial/Removal Action (SSR/RA) Program was
developed to address areas of surface soil contamination that pose a
potential risk to worker health and safety, as determined by the risk
evaluation presented in the Baseline Endangerment Assessment Report. The
program had identified eight surface soil areas requiring removal action. The
removal action program included excavation and off-site disposal of
Polychlorinated Biphenyl (PCB) contaminated soils, excavation and disposal
of Polyaromatic Hydrocarbon (PAH) contaminated soil in the on-site RCRA
permitted Impoundment 8 facility, and capping of another PAH contaminated
area, as well as placement of a geotextile, soil and vegetative cover over
a chromium contaminated area. These areas, except for one PAH Area (Area
11), will be revisited as part of the site-wide soil remediation program. PAH
Area 1 1 was determined to be clean based on post excavation sampling
results which indicated no surface contamination and based on the Soil
Remedial Investigation data which indicated no sub surface contamination
above the applicable State Cleanup Criteria. The SSR/RA was completed in
December 1992.
Impoundments 4 & 5 Fuel Blending Program
Under the Impoundments 4 & 5 fuel blending program, tars from these
impoundments are being removed and blended in an on-site RCRA permitted
hazardous waste fuel blending facility. The blended material is then being
sent off-site for use as a supplemental fuel in cement kiln'operations.
Impoundment 8 Program
The Impoundment 8 program involves closure of four (4) on-site
impoundments (Impoundments 6, 7, 8 & 9A) and the construction of a RCRA
permitted facility (New Impoundment 8 facility). Half of the state-of-the-art
RCRA permitted Impoundment 8 facility has been constructed (western half)
which includes a triple liner, leachate detection and collection system and
ground water monitoring system. Half of the waste from the old
Impoundment 8 has been dewatered, solidified and consolidated into the
western half of the RCRA permitted Impoundment 8 facility. Waste from
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Impoundments 6 and 7 as well as half of the waste from the old Impound-
ment 8 are to be dewatereo. solidified and consolidated into the eastern half
of the RCRA permitted Impoundment 8 facility. The construction of this
eastern half of Impoundment 8 will also include a triple liner, leachate
detection and collection system and ground water monitoring system. This
activity is expected to be completed in early 1994. The NJPDES permit
issued under the authority of RCRA allows the Impoundment 8 facility to
receive other on-site solidified/stabilized waste materials. Impoundment 9A
has been closed in-place by installing a double synthetic liner capping system
(60-mil High Density Poly Ethylene).
Bedrock Ground-Water Pumping/Control System Program
For the past 60 years, Cyanamid has withdrawn water from on-site bedrock
production wells for use as non-contact cooling water in production opera-
tions. Cyanamid's present average withdrawal of over 650,000 gallons per
day results in ground water flow inward from the perimeter of the site
towards the pumping wells. This system effectively contains the majority
of the ground water contamination within the production area and west yard
area on the site. Recovered ground water is treated on-site before discharge
to the adjacent Somerset-Raritan Valley Sewerage Authority (SRVSA) waste
water facility for further treatment. Any ground water not captured by the
NJPDES pumping system flows to the Raritan River. A previous study
(Lawler, Matuskey, & Skelley. 1983) concluded that the Cyanamid facility did
not have a significant impact on water quality in the Raritan River. Further
study of the Raritan River water quality to determine the potential impact
from the Cyanamid facility will be conducted as part of the site-wide remedi-
ation program. Cyanamid is in the process of relocating the production wells
to an area within the manufacturing portion ,of the facility to more
effectively contain contaminated ground water to areas beneath the
production area and the West Yard, where most of the sources of
contamination still exist.
4. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The following documents were made available to the public for review:
Impoundment Characterization Program Final Report (ICPFR);
Technology Evaluation Work Plan for Group I Impoundments;
Baseline Site-Wide Endangerment Assessment Report;
Group I Impoundments CMS/FS Report;
Proposed Plan for the Group I Impoundments; and
Draft Modified HSWA Permit and supporting documentation.
These documents are part of the administrative record and are located in an
information repository maintained at the NJDEPE Docket Room in Trenton,
New Jersey, at the Somerset County Public Library and at the Bridgewater
Township Municipal Complex. The notice of availability for these documents
was published in the Courier News on June 29, 1993. A public comment
period on the documents was held from June 30, 1993 to September 12,
1993. In addition, a briefing with the mayor of Bridgewater Township and
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a public meeting were held on August 5, 1993. At this meeting,
representatives from NJDEPE answered questions about the results of
investigations and the remedial alternatives under consideration for Group I
Impoundments at the site. A follow-up meeting was held on August 24,
1993 with Bridgewater Township officials and representatives of CRISIS
(citizens group which was recipient of the USEPA Technical Assistance Grant
from the Superfund) to discuss the comments received during the August 5,
1993 public meeting in detail. NJDEPE provided detailed responses to the
Township and CRISIS prior to the meeting in the letter dated August 20,
1993. The responses were acceptable to the attendees of the August 24,
1993 meeting with additional comments. NJDEPE provided detailed responses
to additional comments received during August 24, 1993 meeting to the
Township and CRISIS in the letter dated August 30, 1993. A response to
the comments received during the public comment period and the public
meeting (including the follow-up responses mentioned above) is included in
the Responsiveness Summary, which is attached to the ROD. A complete
background on community involvement throughout the remedial process is
included in the Responsiveness Summary. Comments received on the Draft
Modified HSWA permit will be addressed in the Final Modified HSWA permit.
5. SCOPE AND ROLE OF OPERABLE UNIT OK RESPONSE ACTION WITHIN SITE
STRATEGY
Due to practical limitations, all 16 of the CMS impoundments cannot be
remediated concurrently. The impoundments have been grouped into three
impoundment groups according to waste type, nature of contaminants, and
geographical location on the site. This concept allows this complex site to
be subdivided into discrete, more manageable units.
The impoundments groups are as follows:
Group I - Impoundments 11, 13, 19 & 24
Group II - Impoundments 1, 2, 15, 16, 17 & 18
Group III - Impoundments 3, 4, 5, 14 & 26
Impoundment 20 was initially included in Group I Impoundments. However,
because of the similar concentration of contaminants, an appropriate remedy
for Impoundment 20 will be evaluated along with either Group II or Group
III Impoundments.
This ROD addresses the remediation of Group I Impoundments only.
Remediation of the remaining impoundment groups will be addressed in
separate CMS/FS reports completed in accordance with the schedules set
forth in the May 1988 AGO and the November 1988 HSWA Permit The
CMS/FS report for the Group II Impoundments will be completed in November
1993 and the CMS/FS report for the Group III Impoundments will be
completed in May 1995. A Remedial Investigation of the site-wide soils was
completed in 1992. A feasibility study addressing the site-wide soils
remediation will be initiated after completion of the remediation of 16 on site
impoundments. Final remediation for site-wide ground water contamination
will be addressed after completion of the remediation of site-wide soils.
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Final site-wide remediation will insure that there is no current or future
unacceptable risk to human health and the environment.
6. GROUP I IMPOUNDMENT CHARACTERIZATION
The Group I Impoundments were characterized as reported in the January
1990 Impoundment Characterization Program Final Report (ICPFR). The
locations of the impoundments are indicated on Figure 2. The sludges
contained in the Group I Impoundments (Impoundments 11, 13, 19 & 24) are
believed to have originated from on-site waste water treatment operations
and were originally deposited into Impoundment 6 before being dredged
and/or pumped from Impoundment 6 into the Group I Impoundments. Similar
chemical constituents are present in all of the Group I Impoundments. The
existing data from analysis of the contents of each of the Group I
Impoundments were used to estimate the average concentrations of total
organic, total inorganic, total non-carcinogenic and total potentially
carcinogenic contaminants in the Group I Impoundments. The ratio of
inorganic to organic contaminants in the Group I Impoundments is as follows:
12 to 1 for Impoundment 11, 30 to 1 for Impoundment 13, 11 to 1 for
Impoundment 19, and 15 to 1 for Impoundment 24. These estimates demon-
strate that the contaminants present in the Group I Impoundments are
predominantly inorganics. Concentrations and ratios of contaminants detected
in the Group I Impoundments are listed in Table 1 and 2 respectively. An
overview of the characterization of the Group I Impoundments follows:
Impoundment 11
Impoundment 1 1 has a surface area of approximately 2.6 acres, is covered
with a thin layer of soil with sparse vegetation, and is relatively flat. The
contents of the impoundment consist of sludge, filling soil and clay. Total
volume of material in this impoundment is approximately 25,500 cubic yards.
The predominant volatile organic contaminants of concern detected in Im-
poundment 11 have a range of average concentrations from 1 to 40 parts
per million (ppm) and include: Acetone, Ethylbenzene, Chlorobenzene, Methy-
lene Chloride, Toluene, and total Xylenes. The detected predominant
semivolatile organic contaminants of concern have a range of average
concentrations from 100 to 7,000 ppm and include: Acenaphthalene,
Benzo(a)Anthracene, Fluorene, 2-Methylnaphthalene, and Naphthalene. The
detected predominant inorganic contaminants of concern have a range of
average concentrations from 15 to 3,000 ppm and include: Chromium,
Copper, Lead, Mercury, Nickel, and Zinc.
Impoundment 13
Impoundment 13 has a surface area of approximately 3.9 acres, is covered
by soil with dense vegetative growth, and is graded. The contents of the
impoundment consist of sludge, silt, clay, lime, debris and filling soil. Total
volume of material in this impoundment is approximately 67,500 cubic y«rd*.
The detected predominant volatile contaminants of concern have a range of
average concentration from 1 to 20 ppm and include: Benzene.
Ethylbenzene, Chlorobenzene, Toluene, and total Xylenes. The detected
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predominant semivolatile organic contaminants of concern have a range of
average concentration from 20 to 2,000 ppm and include: Acenaphthalene,
Fluorene, 2-Methylnaphthalene, Naphthalene, and 1,2,4-Trichlorobenzene. The
detected predominant inorganic contaminants of concern have a range of
average concentrations from 7 to 1,500 ppm and include: Arsenic, Cadmium,
Chromium, Copper, Lead, Mercury, Nickel, and Zinc.
Impoundment 19
Impoundment 19 has a surface area of approximately 2.3 acres. Its surface
is partially covered with topsoil and vegetation, and is sloped toward the
center of the impoundment. The contents of the impoundment consist of
sludge, fill debris, tar, lime and filling soil. Total volume of material in this
impoundment is approximately 12,000 cubic yards. The detected predominant
volatile organic contaminants of concern have a range of average
concentrations from 30 to 1,200 ppm and include: Benzene, Ethylbenzene,
Chlorobenzene, Methylene Chloride, Toluene, and total Xylenes. The detected
predominant semivolatile organic contaminants of concern have a range of
average concentrations from 200 to 10,000 ppm and include: 1,2-Dichlo-
robenzene, 2-Methylnaphthalene, Naphthalene, and 1,2,4-Trichlorobenzene.
The detected predominant inorganic contaminants of concern have a range
of average concentrations from 3 to 120,000 ppm and include: Arsenic,
Calcium, Chromium, Copper, Iron, Lead, Magnesium and Nickel.
Impoundment 24
Impoundment 24 has a surface area of approximately 3.2 acres, is covered
by soil and lime, and is graded to the top of the surrounding berm. Almost
no vegetation exists on this impoundment because of high concentration of
lime at its surface. The contents of this impoundment consist of silty clay,
lime, debris, sludge and filling soil. Total volume of material in this
impoundment is approximately 71,500 cubic yards. The detected predominant
volatile organic contaminants of concern have a range of average
concentrations from 5 to 130 ppm and include: Acetone, Chlorobenzene,
Methylene Chloride, Toluene, and total Xylenes. The detected predominant
semivolatile organic contaminants of concern have a range of average
concentrations from 95 to 2,600 ppm and include: Dibenzofuran, 1,2-Dichlo-
robenzene, 2-Methylnaphthalene, and Naphthalene. The detected predominant
inorganic contaminants of concern have a range of average concentrations
from 1 to 126,000 ppm and include: Arsenic, Chromium, Copper, Iron, Lead
and Nickel.
7. SUMMARY OF EXISTING Sire RISK
Based upon the results of the ICPFR, a Baseline EA was conducted to
estimate the risks associated with current site conditions. The Baseline EA
estimates the human health and ecological risk presented by the contamina-
tion at the site prior to implementation of remedial action. The results of
the Baseline EA were reported in the January 1990 (Amended March 1992)
Baseline Site-Wide EA report.
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Human Health Risk Assessment
A four-step process is utilized for assessing site-related human health risks
for a reasonable maximum exposure scenario: Hazard Identification—identities
the contaminants of concern at the site based on several factors such as
toxicity, frequency of occurrence, and concentration. Exposure Assessment--
estimates the magnitude of actual and/or potential human exposures, the
frequency and duration of these exposures, and the pathways (e.g., ingesting
contaminated well-water) by which humans are potentially exposed. Toxicity
Assessment—determines the types of adverse health effects associated with
chemical exposures, and the relationship between magnitude of exposure
(dose) and severity of adverse effects (response). Risk Characterization--
summarizes and combines outputs of the exposure and toxicity assessments
to provide a quantitative (e.g., one-in-a-million excess cancer risk)
assessment of site-related risks.
As a first step of the Baseline EA, contaminants of concern were selected
which would be representative of site risks. The contaminant selection
criteria was based primarily on frequency of detection, the availability of
toxicity criteria, and numerical threshold criteria. The Baseline EA identified
a •>.- al of 55 contaminants of concern for the Cyanamid site. Of these 55
cor minants, those that were detected most frequently or in the highest
con -ntrations within the Group I Impoundments are Acetone, Benzene,
Ethyibenzene, Toluene, Chlorobenzene, Methylene Chloride, total Xylenes, 1,2-
Dichlorobenzene, 2-Methylnaphthalene, Naphthalene, 1,2,4-Trichlorobenzene,
Arsenic, Cadmium, Chromium, Copper, Lead, Mercury, and Zinc. Of these
contaminants of concern, only Benzene, Arsenic, Cadmium, Chromium, and
Lead are known or suspected carcinogens according to the USEPA Carcinogen
Assessment Group (CAG) classification system.
Using the evaluation of the Baseline EA of potential exposure pathways for
on-site and off-site human receptors, a number of potentially significant
exposure pathways were identified and evaluated quantitatively to determine
the risk levels presented by existing site conditions.
Exposure to contaminated ground water was not identified as a significant
exposure pathway at the present time because American Cyanamid pumps
650,000 gallons per day of contaminated ground water from NJPDES
permitted production wells, which contains ground water contamination on
the production area and west yard area of the site. Any ground water not
being captured by NJPDES permitted pumping flows to the Raritan River at
a point that is not being used as drinking water source.
Summary of Human Health Risks
Through an assessment of exposure pathways for the 55 contaminants of
concern, specific health risk levels were calculated for each potentially
significant exposure pathway to enable a quantitative evaluation of potential,
site-wide health risks for human receptors.
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Current federal guidelines for acceptable exposures are individual lifetime
excess carcinogenic risk in the approximate range of 1 x 10'4 to 1 x 10"8.
This can be interpreted to mean that an individual may have a one in ten
thousand to a one in a million increased chance of developing cancer as a
result of a site-related exposure to a carcinogen under specific exposure
conditions. Current federal guidelines for acceptable exposures for non-
carcinogenic risk are maximum Health Hazard Index of 1.0. A Hazard Index
greater than 1 .0 indicates that the exposure level exceeds the protective
level for that particular chemical.
A quantitative analysis of the risks associated with the Group I
Impoundments was not conducted because there are no current, complete
exposure pathways. Direct contact with the wastes of Group I
Impoundments is restricted due to site security and the impoundments'
covers. Potential for inhalation of air contaminants from the Group I
Impoundments is absent because dust suppression measures as well as water
and vegetative covers are in place.
However, there is a potential future risk to human health and the environ-
ment if the Group I Impoundments are not remediated. The Group I
Impoundments are a continuous source of ground water contamination, which
eventually discharges into the Raritan River. In addition, the ground water
in the vicinity of the site is classified as a source of drinking water,
although it is not used as drinking water. Although there is a pumping
program to control the migration of contaminated ground water by recovering
650,000 gallons of contaminated ground water per day, the population
around the site could be potentially exposed to contaminated ground water
under a future use scenario. For these reasons, remediation of the Group
I Impoundments is warranted.
Final site-wide remediation will insure that there is no current or future
unacceptable risk to human health and environment including compliance with
the State of New Jersey 10*e risk level.
Qualitative Ecological Risk Assessment
In the Ecological Assessment, a reasonable maximum environmental exposure
is evaluated utilizing a four step process for assessing site-related ecological
risks. These steps are: Problem Formulation - development of the objectives
and scope of the ecological assessment; description of the site and
ecosystems that may be impacted; identification of contaminants of concern.
Exposure Assessment • identification of potential ecological receptors and
exposure pathways; quantitative evaluation of exposure pathways; fate and
transport mechanisms for contaminants. Ecological Effects Assessment -
literature reviews, field studies, and toxicity tests, linking contaminant
concentrations to effects on ecological receptors. Risk Characterization -
measurement or estimation of both current and future adverse effects.
The results of a site-wide habitat survey and direct field observations were
compared to the Natural Heritage Data Base [NJDEPE, 1991 (a)] to confirm
that the on-site habitat does not support threatened or endangered species.
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Undeveloped areas with valuable wildlife habitat exist south of the Raritan
River, which are effectively isolated from the Cyanamid facility by the River
and the on-site berm.
There will be no wetland impacts associated with this proposed remedial
action because no wetland areas exist within the Group 1 Impoundments.
A site-wide natural resources assessment, consisting of a Wetlands
Assessment (using federal and state guidance), a Cultural Resources Survey
and a Flood Plain Assessment is presently being conducted, to ensure that
these resources are evaluated prior to implementation of future remedial
actions at the site. A Cultural Resources Assessment (Stage 1A) completed
in July 1993 determined that the remediation of Group I Impoundments is
not of concern due to absence of significant cultural resources. The
information gathered in the site-wide Natural Resources Assessment, expected
to be completed by December 1993, will help define the resources in terms
of their functional value and historical or cultural significance, and will help
to develop any appropriate mitigation of impacts as a result of any future
proposed remedial actions at the site. In disturbed areas of the Cyanamid
facility (due to historic and ongoing activities) and in areas of continued
construction and demolition, the potential for wildlife habitat values are
greatly reduced. In sufficiently undisturbed areas, conditions exist to
support wildlife. These undisturbed areas are far enough removed or
physically separated enough from the site wastes to restrict significant
exposure to wildlife.
Risks to off-site environmental receptors through contact with Raritan River
water that may have received discharges of contaminated ground water from
the Cyanamid facility are likely to be insignificant because of the dilution in
the river and the relatively small quantities of site-related contaminants
detected in the ground water. A previous study (Lawler, Matusky & Skelly,
1983) concluded that the Cyanamid facility did not have a significant impact
on water quality in the Raritan river. However, as previously stated, further
study of the Raritan River water quality to determine the potential impacts
from the Cyanamid facility will be conducted as part of the site-wide
remediation program. A work plan is being finalized to collect surface water
and sediment samples from the Raritan River to determine any potential
impacts on the Raritan River from the Cyanamid site.
8. REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human health and the
environment; they take into account the contaminant(s) of concern, the
exposure route(s), receptor(s), and acceptable contaminant level(s) for each
exposure route. These objectives are based on available information and
standards such as applicable or relevant and appropriate requirements
(ARARs).
The remedial action objectives for the Group 1 Impoundments are as follows:
1. Eliminate source of contamination;
2. Contribute to compliance with ground water ARARs.
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9. SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA requires that each selected site remedy be protective of human
health and the environment; be cost-effective; comply with other statutory
laws; and utilize permanent solutions, alternative treatment technologies, and
resource recovery alternatives to the maximum extent practicable. In
addition, the statute includes a preference for the use of treatment as a
principal element for the reduction of toxicity, mobility, or volume of the
hazardous substances.
The CMS/FS report includes a preliminary screening of all potentially
applicable technologies, followed by elimination of inappropriate or infeasible
alternatives and identification of applicable technologies based solely on
technical feasibility. The resulting number of technologies are then
developed into remedial alternatives. The CMS/FS report evaluates in detail
the following five remedial alternatives for addressing the contamination
associated with the Group I Impoundments.
These alternatives are:
1 . No-action
2. In-Place Containment
3. Solidification
4. Biological Treatment
5. Moderate Temperature Thermal Treatment
A brief description of each of the remedial alternatives is provided below:
(Note: The Superfund program requires that the "no-action" alternative be
considered as a baseline for comparison with other alternatives.)
Since the contents in the Impoundments of Group 1 are not identical, the
remedial alternatives identified below are not universally applicable to all
Impoundments. Some of the remedial alternatives were not evaluated in
detail for all of the impoundments. Biological treatment was evaluated for
Impoundments 11, 13, and 19 only, because treatability testing indicated
that the high.degree of heterogeneity of waste in Impoundment 24 would
render biological treatment impractical for this impoundment due to an
inordinate amount of equalization/dilution required to initiate biotreatment.
Alternative 1 - No-Action (or Limited Action)
The no-action alternative would involve simply leaving the impoundments in
their current condition. A slight modification of the no-action alternative is
the limited action alternative that may include the establishment of institu-
tional controls as well as improvements in physical site access controls that
could be achieved at minimal cost. This alternative was evaluated for all
Group 1 Impoundments.
Total Cost: $ 100,000
Time to Implement: 1 Year
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Alternative 2 - In-place Containment
The in-place containment alternative would consist of clearing vegetation
(where necessary), consolidating and/or compacting materials, construction
of a cap, and/or installation of a ground water monitoring system. This
alternative was evaluated for all Group I Impoundments.
Total Cost: $ 5,900,000
Time to Implement: 1 Year
Alternative 3 - Solidification
The solidification alternative would consist of excavating the contents of the
impoundments, treating the waste materials via solidification, and
consolidating the treated waste into the on-site RCRA-permitted Impoundment
8 facility. This facility is triple lined and has leachate detection and
collection system as well as ground water monitoring system. Measures
would be taken subsequent to excavation to promote natural re-vegetation
of each impoundment area. Volatile emissions from the solidification treat-
ment unit will be collected with a blower and treated in a carbon absorber,
if necessary. This alternative was evaluated for all Group I Impoundments.
Total Cost: $ 12,500.000
Time to Implement: 1.5 Years
Alternative 4 - Biological Treatment
The biological treatment alternative would consist of excavation of the
contents of the impoundment, process-related dilution of the contents, and
then biological treatment. Biological treatment would occur in a slurry-phase
reactor from which residual biomass would be solidified and consolidated into
the on-site RCRA-permitted Impoundment 8 facility. Measures would be
taken subsequent to excavation to promote natural re-vegetation of each
impoundment area. The Biological Treatment alternative was evaluated for
Impoundments 11, 13, and 19. Impoundment 24 would require Solidification
or Thermal Treatment.
Total Cost: $ 37,700,000
Biotreatment cost for Impoundments 11, 13 and 19:
$ 33,400,000
Solidification cost for Impoundment 24: $ 4,300,000
OR
Total Cost: $ 51,500,000
Biotreatment cost for Impoundments 11, 13 and 19:
$ 33,400,000
Thermal Treatment cost for Impoundment 24: $ 18,100,000
Time to Implement: 6 Years
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Alternative 5 - Moderate Temperature Thermal Treatment
The moderate temperature thermal treatment alternative would involve
excavation of the waste materials, followed by indirect application of heat
to promote volatilization of volatile and semivolatile organic compounds.
Thermal treatment residuals would be solidified and consolidated into the on-
site RCRA permitted Impoundment 8 facility. Measures would be taken
subsequent to excavation to promote natural re-vegetation of each impound-
ment area. This alternative was evaluated for all Group I Impoundments.
Total Cost: $ 51,500,000
Time to Implement: 3.5 Years
10. Evaluation of Remedial Alternatives
During the detailed evaluation of remedial alternatives, each alternative was
assessed against the nine CERCLA evaluation criteria, as described below:
o Overall protection of human health and the environment: addresses
whether or not a remedy provides adequate protection and describes
how risks posed through each pathway are eliminated, reduced, or
controlled through treatment, engineering controls, or institutional con-
trols.
Alternative 1 would not be protective of human health and the
environment since it offers no control of potential releases of
contaminants to shallow ground water. Alternative 2 would offer
protection of human health and the environment by reducing the
potential for direct contact with contaminants and by minimizing future
release of contaminants to the ground water and by isolating the
contaminants from all potential receptors. Alternatives 3, 4, and 5
would achieve greater overall protection of human health and the
environment than Alternatives 1 and 2 by eliminating exposure pathways
through removal, treatment and consolidation of the contaminated source
material.
o Compliance with applicable or relevant and appropriate requirements
(ARARs): addresses whether or not a remedy will meet all of the
applicable or relevant and appropriate requirements of federal and state
environmental statutes and other requirements or provides grounds for
invoking a waiver.
Alternative 1 would not contribute to achieving site-wide ground water
ARARs. Alternatives 2, 3, 4, and 5 would contribute in achieving site-
wide ground water ARARs. Contribution to compliance with the ARARs
will be achieved by containing the contaminated source in case of Alter-
native 2 and by removal, treatment and consolidation of the contami-
nated source material in case of Alternatives 3, 4 and 5. Land Disposal
Restrictions (LDRs) are not ARARs for Impoundments 11, 13, 19 and 24
because they are designated as contiguous areas of contamination along
with Impoundments 6, 7, and 8.
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Wetlands Assessment, Cultural Resources Assessment and Flood Plain
assessment, are presently being conducted. This site-wide assessment,
expected to be completed in December 1993, will determine the
compliance of the site-wide remediation program with location specific
ARARs, i.e.. Wetlands, Cultural Resources and Flood Plains. A Cultural
Resources Assessment (Stage 1A) completed in July 1993 determined
that the remediation of Group I Impoundments is not of concern due to
absence of significant cultural resources. Table 3 lists ARARs and To
be Considered Criteria (TBCs).
o Long-term effectiveness and permanence: refers to the ability of a
remedy to maintain reliable protection of human health and the
environment over time, once cleanup goals have been met.
Alternative 1 would not achieve the long-term effectiveness criterion
since future risks will increase if contamination migrates from the
impoundments. Alternative 2 would depend on the long-term mainte-
nance and ground water monitoring program to ensure long-term
effectiveness. Alternatives 3, 4. and 5 will provide for long-term
effectiveness by eliminating the potential for migration of contaminants.
Alternative 3 would immobilize the inorganic contaminants, bind up the
organic contaminants in the solidified mass and would provide maximum
risk reduction through consolidation into the RCRA-permitted Impound-
ment 8 facility. Alternative 4 would degrade organic contaminants into
non-toxic compounds. Some organic compounds would not be biode-
graded as determined by a treatability study. The biomass and inorganic
residual would then require solidification and consolidation into the
Impoundment 8 facility. Alternative 5 would destroy or remove all
organic contaminants. This alternative would then require solidification
and consolidation into the Impoundment 8 facility to address the
majority of the contaminants, inorganics. Alternative 3 would provide
long term effectiveness for inorganic contaminants by solidification
treatment while Alternatives 4 and 5 would provide greater long term
effectiveness for organic contaminants by degrading and destroying
them, respectively. Alternatives 4 and 5 would also provide long-term
effectiveness for inorganic contaminants by solidification treatment.
o Reduction of toxicity. mobility, or volume: through treatment is the
anticipated performance of the treatment technologies a remedy may
employ.
Alternative 1 does not achieve any reduction in toxicity, mobility, or
volume. Alternative 2 reduces only the mobility of contaminants by
reducing infiltration of rain water. Alternative 3 would decrease the
mobility of both organic and inorganic contaminants by binding them in
a solidified matrix while slightly increasing the volume of waste
material. The risk posed by the material's toxicity would be reduced
because of the reduction in the mobility. Consolidating the solidified
material into the Impoundment 8 facility would provide an added reduc-
tion in mobility of the organic and inorganic contaminants. Alternative
4 would reduce toxicity and mobility by degrading some of the organics,
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but residual organics and inorganics would remain requiring a second
step of either consolidation into Impoundment 8. The mobility of the
residual organic and inorganic contaminants would be reduced through
solidification. Alternative 5 would reduce toxicity, mobility and volume
of organics by destroying or removing them. Alternative 5 will not
reduce toxicity or volume of the inorganics requiring a second step of
consolidation into the Impoundment 8 facility. The mobility of the
inorganic contaminants would be reduced through solidification. Alterna-
tive 3 would provide a reduction of toxicity and mobility for both
organic and inorganic contaminants. Alternatives 4 and 5 would provide
a greater reduction of toxicity, mobility and volume for organic contami-
nants and would also provide a reduction of toxicity and mobility of the
inorganic contaminants by solidification treatment.
o Short-term effectiveness: addresses the period of time needed to achieve
protection from any adverse impacts on human health and the
environment that may be posed during the construction and imple-
mentation period until cleanup goals are achieved.
Alternative 1 will not have any short-term adverse impacts because no
construction or treatment is required. Alternative 2 achieves a degree
of protection in a relatively short period of time and would result in
minimal short-term impacts associated with its implementation. While
Alternatives 3, 4, and 5 would exhibit comparable short-term impacts
to human health and the environment, Alternative 3 could be
implemented in a substantially shorter time period than Alternatives 4
and 5, further reducing short-term adverse impacts on human health and
the environment and providing short-term effectiveness.
o Implementability: is the technical and administrative feasibility of a
remedy, including the availability of materials and services needed to
implement a particular option.
Alternative 1 is the simplest alternative to implement from a technical
standpoint because it involves no construction or operation. The
operations associated with Alternatives 2, 3, 4, and 5 employ well
established, readily available construction methods and are all considered
technically and administratively feasible. Alternatives 1 and 2 could be
implemented in a short period of time. Alternative 3 would require 1.5
years to implement due to design and construction of a solidification
treatment unit and contracting out to vendors. Alternative 4 would
require approximately 6 years to implement due to the necessity for
technicians specifically trained in the operation of this technology and
treatment unit, slow rate of contaminants degradation, and time for
designing and constructing the treatment unit. Alternative 5 would
require 3.5 years to implement due to design, construction and opera-
tion of the treatment unit. Alternatives 4 and 5 would require additional
time for addressing residual material either by consolidating into
Impoundment 8. Alternative 3 provides a somewhat greater degree of
implementability than Alternatives 4 and 5 because the time to
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implement is shorter and construction and treatment components are
readily available.
o Cost: includes estimated capital and operation and maintenance costs,
and net present worth costs.
Total cost for Alternative 1 is $ 100,000. Total cost for Alternative 2
is $ 5,900,000. Alternative 3 provides remediation for all Group 1
Impoundments at a total cost of $ 12,500,000. Alternative 4 provides
remediation of Impoundments 11, 13, and 19 by using Biotreatment at
a total cost of $ 33,400,000. Impoundment 24 would require additional
cost of approximately $ 4,300,000 for Solidification Treatment or
$ 18,100,000 for Thermal Treatment under Alternative 4. The total cost
then for Alternative 4 for all Group I Impoundments would be
$ 37,700,000 by using Biotreatment for Impoundments 11, 13, and 19
and Solidification Treatment for Impoundment 24 or $ 51,500,000 by
using Biotreatment for Impoundments 11, 13, and 19 and Thermal Treat-
ment for Impoundment 24. Alternative 5 provides remediation of Group
I Impoundments at a total cost of $ 51,500,000. The cost differences
between Alternatives 3 and 4 as well as Alternatives 3 and 5 are
$ 25,200,000 or $ 39,000,000, and $ 39,000,000, respectively.
Alternative 3 is significantly less costly than Alternatives 4 and 5.
Detailed costs of solidification, bioremediation, and thermal treatments
for the Group I Impoundments are included in Table 4.
o USEPA concurrence: indicates whether, the federal regulatory agency
concur, oppose, or have no comment on the selected remedy.
USEPA concurs with the selected remedy described in this ROD.
o Community acceptance: assessment of the public comments received on
the ICPFR, Baseline EA report, CMS/FS report. Proposed Plan and the
draft modified HSWA permit.
Community concerns/Comments received during the public comment
period and the public meeting are included in the responsiveness
summary, together with NJDEPE responses, which is part of this ROD.
77. SELECTED REMEDY (REMEDIAL ALTERNATIVE)
Based upon an evaluation of the various alternatives and after consideration
of public comments, NJDEPE and USEPA has selected Alternative 3
(Solidification with consolidation into the on-site RCRA facility) as the
remedy for the Group I Impoundments (11, 13, 19 and 24) because it best
satisfies the requirements of CERCLA and the NCR's nine evaluation criteria
for remedial alternatives. Impoundment 8 Facility is triple lined with
leachate detection and collection systems as well as ground water monitoring
system. Leachate is being monitored on a monthly basis while ground water
is being monitored on a quarterly basis at the Impoundment 8 Facility.
Figure 3 describes the cross section of Impoundment 8 facility with triple
liner and leachate detection as well as leachate collection systems. Detailed
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schedule for implementation will be developed as part of design for the
selected remedy.
Solidification of the sludges from the Group I Impoundments would involve
excavating the sludge from the impoundments, mixing with cement like
materials (most likely in a mixing unit), and consolidating the solidified
sludge in the on-site RCRA facility. The NJDEPE and USEPA may consider the
results of pilot studies for in-situ solidification treatment for Impoundment
24. Additionally, two ground water monitoring wells would be installed
hydrologically downgradient of Impoundments 19 and 24 to assess potential
influences on surface water quality of the Raritan River and associated
ecosystems. Ground water monitoring would be performed for contaminants
of concern (as determined by prior chemical analyses) associated with
Impoundments 19 and 24. The wells would be installed in the shallow
overburden aquifer at locations in close proximity to the Raritan River which
best represent potential exposure pathways to potential environmental and
human receptors.
This alternative satisfies the remedial action objectives and the requirements
of CERCLA, as amended by SARA, the National Contingency Plan, RCRA, as
amended by HSWA, and the AGO including the NJDEPE Ground Water Quality
Standards. Because this remedy will result in hazardous substances
remaining on the site, a review will be conducted every five (5) years after
commencement of the remedial action to ensure that the remedy continues
to provide adequate protection of human health and the environment.
Final site-wide remediation will insure that there is no current or future
unacceptable risk to human health and environment including compliance with
the State of New Jersey 10"6 risk level.
12. STATUTORY DETERMINATIONS
Under their legal authorities, NJOEPE's and USEPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve adequate
protection of human health and the environment. In addition, section 121
of CERCLA establishes several other statutory requirements and preferences.
These specify that when complete, the selected remedial action for this site
must comply with applicable or relevant and appropriate environmental
standards established under State and Federal environmental laws unless a
statutory waiver is justified. The selected remedy also must be cost-
effective and utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent
practicable. Finally, the statute includes a preference for remedies that
employ treatment that permanently and significantly reduce the volume,
toxicity, or mobility of hazardous wastes as their principal element.
The selected remedy is protective of human health and the environment,
complies with State and Federal 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 for this site. Because this remedy will
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result in hazardous substances remaining on the site, a review will be
conducted every five (5) years after commencement of the remedial action
to ensure that the remedy continues to provide adequate protection of human
health and the environment.
Since the majority of the contaminants in the Group I wastes are inorganic,
thermal and biological treatment offer little advantage over solidification
alone in the effective long-term treatment of these wastes.
The solidification alternative will be used to chemically bind the inorganic
contaminants into a matrix, preventing migration of contaminants and thus
indirectly reducing the potential toxicity of the sludge. Solidification and
consolidation into the RCRA-permitted Impoundment 8 facility will also reduce
the mobility of any residual organic contaminants by decreasing the
permeability of the sludge and consequently the potential for infiltration of
water and generation of leachate. The other treatment options (thermal or
biological) provide an insignificant incremental protection of human health
and the environment when compared to solidification, but are significantly
more costly and more difficult to implement. The total cost for Alternatives
3, 4, and 5 for all Group 1 Impoundments are $ 12,500,000, $ 37,700,000
or $ 51,500,000, and $ 51,500,000, respectively. Spending well over
$ 25,200,000 or $ 39,000,000 and $ 39,000,000 under Alternatives 4 and
5, respectively, compared to Solidification under Alternative 3 is not justifi-
able because Solidification provides similar protection of public health and
the environment in a shorter time frame at significantly less cost.
While biological and thermal treatment degrade, destroy, and/or otherwise
remove contaminants, a secondary step, solidification, is required to ensure
immobilization of the contaminants remaining in the treatment residuals.
Solidification with consolidation of the solidified waste into the RCRA-
permitted Impoundment 8 facility achieves the overall remedial objectives and
satisfies the nine CERCLA criteria. The RCRA-permitted Impoundment 8
facility is triple lined and has a leachate detection and collection system as
well as a ground water monitoring system which will provide adequate
protection of public health and the environment. The wastes in the Group
I Impoundments are compatible with the Impoundment 8 facility liner. While
the volume of waste is increased slightly with solidification, the mobility of
the waste materials, specifically the inorganic contaminants will be
substantially reduced. Adequate capacity for the solidified waste materials
is available in the on-site RCRA-permitted Impoundment 8 facility.
Solidification is a conventional, proven technology that is readily
implementable in the shortest time frame of all the treatment alternatives
evaluated.
The selected alternative will contribute to achieving the ARARs more quickly,
or as quickly, and at significantly less cost than the other options. The
selected alternative will provide the best balance of trade-offs among
alternatives with respect to the CERCLA nine evaluation criteria. NJDEPE
and USEPA have selected solidification as the remedial alternative because
it will be protective of human health and the environment, will comply with
ARARs, will utilize permanent solutions and alternative treatment technologies
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or resource recovery technologies to the maximum extent practicable and will
be cost effective. The selected remedy also will meet the statutory prefer-
ence for the use of treatment as a principal element to the maximum extent
practicable.
13. DOCUMENTATION OF SIGNIFICANT CHANGES
There is no change from the Preferred Remedy described in the Proposed
Plan and the Selected Remedy described in this ROD.
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GLOSSARY
Of Terms Used In the Record of Decision
This glossary defines the technical terms used in this Proposed Plan. The
terms and abbreviations contained in this glossary are often defined in the
context of hazardous waste management, and apply specifically to work per-
formed under the Superfund program. Therefore, these terms may have other
meanings when used in a different context.
Administrative Consent Order: A legal and enforceable agreement between
NJDEPE and the potentially responsible parties (PRPs). Under the terms of
the Order, the PRPs agree to perform or pay for site studies or cleanup
work. It may also describe the oversight rules, responsibilities, and enforce-
ment options that the government may exercise in the event of non-
compliance by the PRPs. This Order is signed by the PRPs and the state
government; it does not require approval by a judge.
ARAR: Applicable or r- evant, and appropriate requirements.
Berm: A ledge, wall, or a mound of earth used to prevent the migration of
contaminants.
Cap: A layer of material, such as clay or a synthetic material, used to
prevent rainwater from penetrating wastes and spreading contaminated
materials. The surface of the cap is generally mounded or sloped so water
will drain off.
CERCLA: Comprehensive Environmental, Response, Compensation, and
Liability Act of 1980, 42 U.S.C. § 9601 et.seq., as amended, commonly
known as Superfund.
Closure: The process by which a landfill stops accepting wastes and is shut
down under federal and state guidelines that provide protection for public
health and the environment.
Distillation: A process of first heating a mixture to separate the more
volatile from the less volatile parts, and then cooling and condensing the
resulting vapor so as to produce a more nearly pure or refined substance.
HSWA: Hazardous and Solid Waste Amendments.
NJDEPE: New Jersey Department of Environmental Protection and Energy.
NCP: National Contingency Plan, 40 CFR part 300.
PPM: Parts per million.
RCRA: Resource Conservation and Recovery Act of 1976 as amended.
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SARA: Superfund Amendments and Reau.thorization Act.
USEPA: United States Environmental Protection Agency.
Volatile Organic Compounds (VOCs): VOCs are produced as secondary
petrochemicals. They include light alcohols, acetone, trichloroethylene,
perchloroethylene, dichloroethylene, benzene, vinyl chloride, toluene, and
methylene chloride. These potentially toxic chemicals are used as solvents,
degreasers, paints, thinners, and fuels. Because of their volatile nature,
they readily evaporate into the air, increasing the potential exposure to
humans. Due to their low water solubility, environmental persistence, and
wide-spread industrial use, they are commonly found in soil and ground
water.
Wetland: An area that is regularly saturated by surface or ground water and,
under normal circumstances, capable of supporting vegetation typically
adapted for life in saturated soil conditions.
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ADMINISTRATIVE RECORD INDEX
AMERICAN CYANAMID COMPANY
BRIDGEWATER TOWNSHIP, SOMERSET COUNTY
1. Lagoon 1 & 2 Characterization Report, O'Brine & Gere, October 1982.
2. Phase IV Report Source Assessment and Remedy Program, O'Brine &
Gere, February 1983.
3. Monitoring Groundwater Impact on the Raritan River Report, Lawler,
Matusky, & Skelly (LMS), October 1983.
4. Source Assessment and Remedy Program Final Report, O'Brine & Gere,
December 1984.
5. Sludge Solidification Report for Lagoon 20, IT Corporation, November
1986.
6. Final Report on Continuous Monitoring Assessment Program for Lagoons
6,7,13,19, and 24, Camp Dresser & Mckee (CDM), March 1983.
7. Ground water investigation and site-wide ground water model results,
CDM 1985.
8. Continued assessment of ground water at Impoundments 17 and 18,
CDM 1986.
9. New Jersey Pollutant Discharge Elimination System-Discharge to Ground
Water (NJPDES/DGW) permit # NJ0002313, effective October 30, 1987.
10. Modification to the existing NJPDES/DGW permit # NJ0002313 issued
on November 07, 1987 for the closure of Impoundment 8 facility
(Impoundments 6,7,8 and 9A) under the authority of RCRA delegated to
the NJDEPE from USEPA.
11. Continued assessment of ground water at Impoundments 6,7,13,19 and
24, CDM 1988.
12. New Jersey Department of Environmental Protection and Energy (NJDEPE)
Approval Letter for "No Action" Closure of lagoon 23, May 1988.
13. Administrative Consent Order (ACO) Signed by Cyanamid and NJDEPE,
May 1988.
14. Quality Assurance/Quality Control (QA/QC) Plan Submitted for
Impoundment Characterization Program by Cyanamid, Blasland, Bouck &
Lee (BB&L), September 1988.
15. Hazardous and Solid Waste Amendments (HSWA) permit I.D. #
NJD0002173276 issued by USEPA on November 8, 1988.
16. Impoundment Characterization Program Sampling and Analysis Work Plan,
BB&L, November 1988.
17. NJDEPE Approval Letter for QA/QC Program for Impoundment
Characterization, December 1988.
18. Berm Failure Prevention Plan, BB&L, February 1989.
19. Impoundments 11,20, and 26 Resource Conservation and Recovery Act
(RCRA) Facility Investigation Work Plan, BB&L, February 1989.
20. NJDEPE Community Relations Plan, February 1989.
21. NJDEPE Approval Letter for Berm Failure Prevention Plan, March 1989.
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22. NJDEPE Approval Letter for Impoundments 11,20, and 26 RCRA Facility
Investigation Work Plan, August 1989.
23. Impoundment Characterization Program Final Report, BB&L, January
1990.
24. NJDEPE Approval Letter for Implementation of Fuel Blending Program as
Interim Remedial Action For Lagoons 4 and 5, August 1990.
25. NJDEPE Approval Letter for Impoundment Characterization Program Final
Report, October 1990.
26. Impoundment Corrective Measure Study/Feasibility Study (CMS/FS) Work
Plan, (BB&L), October 1990.
27. NJDEPE Air Permit for Lagoon 4 & 5 Fuel Blending Program, October
1990.
28. NJDEPE Stream Encroachment Permit for Lagoon 4 & 5, March 1991.
29. NJDEPE RCRA Permit Application Approval For Lagoons 4 & 5, June
1991.
30. Technology Evaluation Work Plan (TEWP) for Group I Impoundments,
BB&L, July 1991 .
31. NJDEPE/USEPA Review and Concurrence Letter for TEWP-I, September
1991 .
32. TEWP for Group II Impoundments, BB&L, December 1991.
33. NJDEPE/USEPA Review and Concurrence Letter for TEWP-II, January
1992.
34. Amended Baseline Site-Wide Endangerment Assessment Report (Including
Hill °roperty), BB&L, March 1992.
35. NJD£PE/USEPA Approval Letter for Baseline Site-Wide Endangerment
Assessment Report, April 1992.
36. Amended Hill Property Remedial Investigation Report (Rl), BB&L, March
1992.
37. NJDEPE/USEPA Approval for Hill Property Rl, April 1992.
38. Amended Soils RI/FS Work Plan, BB&L, May 1992.
39. Surface Soils Remedial/Removal Action (SSR/RA) Plan, BB&L, July 21,
1992.
40. A Work Plan for Coal Pile Removal to Impoundment 8 Facility,
Cyanamid, August 13, 1992.
41. Hazardous Waste Site Safety and Health Program, Cyanamid, August 31,
1992 (prepared on 07/20/88).
42. CMS/FS report for Group 1 Impoundments, BB&L, October 1992.
43. NJDEPE/USEPA approval letter for Group 1 Impoundments CMS/FS report,
October 29, 1992.
44. Surface Soil Removal/Remedial Action Final Report, BB&L, March 5,
1993.
45. Superfund Proposed Plan for Group I Impoundments, June 30, 1993.
46. Draft Modified HSWA permit I.D # NJD002173276, June 30, 1993.
47. Transcript for August 5, 1993 Public Meeting/Hearing for the Group I
Impoundments (11, 13, 19 & 24) Proposed Plan and Draft Modified
HSWA Permit.
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RESPONSIVENESS SUMMARY
RECORD OF DECISION
AMERICAN CYANAMID SITE
GROUP I IMPOUNDMENTS (11, 13, 19 & 24)
INTRODUCTION:
A responsiveness summary is required by New Jersey Department of
Environmental Protection and Energy (NJDEPE) and Superfund policies. It
provides a summary of citizen's comments and concerns received during the
public comment period and the public meeting, and the NJDEPE's and United
State Environmental Protection Agency's (USEPA's) responses to those
comments and concerns. All comments summarized in this document have
been considered in NJDEPE's and USEPA's final decision for the selection of
a remedial alternative for the American Cyanamid Site.
OUTLINE:
This Responsiveness Summary is divided into the following sections:
A. Overview
B. Background on Community Involvement and Concerns
C. Summary of Comments Received During the Public Meeting and Comment
Period and Agency Responses
D. Community Relations Activities at the American Cyanamid Company Site
A. OVERVIEW
This is a summary of the public's comments and concerns regarding the
Proposed Plan for Remediation of the Group I Impoundments at the American
Cyanamid Company Superfund Site and the New Jersey Department of
Environmental Protection and Energy's (NJDEPE) responses to those
comments. The comments which were received in writing are attached to
this section.
The public comment period originally extended from June 30, 1993 through
August 13, 1993 to provide interested parties the opportunity to comment
on the Proposed Plan, Technology Evaluation Work Plan,- Impoundment
Characterization Program Final Report (ICPFR), Baseline Site-Wide
Endangerment Assessment Report (Baseline EA), and the Corrective Measures
Study/Feasibility Study (CMS/FS) for the American Cyanamid Company Site.
During the comment period, the NJDEPE and USEPA held a public
meeting/public hearing on August 5, 1993 at 7:00 PM at the Bridgewater
Township Municipal Court to discuss the results of the ICPFR, Baseline EA
and CMS/FS and to present the preferred remedy. This public comment
period and meeting also met the public participation requirements for the
modification of the Hazardous and Solid Waste Amendments (HSWA) Permit
for the American Cyanamid Site. The Draft Modified HSWA Permit was made
available for public review at the same repositories as the other documents
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listed above. In response to requests from a citizen group at the August
5, 1993 meeting, NJDEPE and USEPA agreed to extend the public comment
period through September 12, 1993.
On the basis of the information contained in the above referenced
documents, NJDEPE has selected the following remedy for the Group I
Impoundments (11, 13, 19 and 24) at the American Cyanamid Site:
Solidification with consolidation into the on-site RCRA permitted Impoundment
8 Facility.
B. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
Since 1988 there has been a great deal of concern about a proposal by
American Cyanamid to build a commercial hazardous waste incinerator on the
site. At present, Cyanamid has no plans to pursue the incinerator. The
Somerset-Raritan Valley Sewage Authority already operates a sludge
incinerator on property adjoining the American Cyanamid site. In addition,
the Somerset County Freeholders designated a tract next to the Authority
site for a trash incinerator, while this facility is no longer proposed, a solid
waste transfer station is now in operation at this location.
In January 1989, a briefing for public officials and concerned citizens was
held in Bridgewater to discuss the remedial work under the 1988 ACO and
the initiation of the Remedial Investigation/Feasibility Study (RI/FS). A public
meeting was held on February 21, 1989 in Bridgewater to discuss the RI/FS.
On both occasions citizens and local officials expressed concern and anger
that they were bearing more than their fair share of society's waste cleanup
burden. They made it clear that they did not want the Superfund
remediation process to become a back door for Cyanamid to site a
commercial hazardous waste incinerator.
Attendees at the January and February meetings also were confused about
the remedial process at the site. The main cause of confusion is that some
lagoon closures at the site are being handled under the Resource
Conservation and Recovery Act (RCRA) because the Cyanamid plant is an
operating facility. NJDEPE representatives prepared a response to these
concerns and forwarded it along with the RCRA response document to public
comments received at the June 14, 1988 RCRA public hearing to those
attending the January and February Superfund meetings. The subject of the
June 14, 1988 RCRA hearing was the permitting of a permanent waste
impoundment for storage of treated materials from the closure of other site
impoundments.
NJDEPE held a public meeting in Bridgewater on March 11, 1991 to provide
an update on the progress of the Rl. Residents and officials again expressed
their opposition to any type of incineration at the site. Attendees at the
meeting also raised concerns about the ongoing closure of the RCRA
impoundments and the consolidation of these materials in the new
Impoundment 8 facility. Concerns focused on the location of the new
facility, safety of the liner and air pollution from ongoing site activities.
NJDEPE issued a fact sheet addressing these concerns in June of 1991
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Citizen concerns at the American Cyanamid site have been focused through
two local groups, CRISIS and the Boundbrook Citizens Association. In March
of 1991 representatives of CRISIS expressed concerns regarding a proposed
modification of a Hazardous Waste Facility permit to allow storage and
blending of tars from lagoons 4 and 5. This permit modification was needed
so that materials could be blended and heated for off-site shipment for use
as alternative fuel in cement kilns. During the summer of 1991, Mayor
Dowden of the Township of Bridgewater and other local officials and
residents publicly stated that NJDEPE was working too closely with Cyanamid
and keeping the township in the dark on site activities.
NJDEPE representatives met with Mayor Dowden and other township
representatives in Bridgewater to discuss these concerns and review the
status of remedial activities on November 27, 1991. As a result of the
November meeting, a representative of the Bridgewater Health Department
was invited to attend monthly site remediation progress meetings, NJDEPE
reaffirmed its policy of placing site information in local repositories as soon
as documents were completed and NJDEPE offered to meet with township
and citizen representatives before the start of major site activities.
In 1992 CRISIS received a Technical Assistance Grant (TAG) under the
Superfund program from USEPA and hired a consultant to review and
evaluate documents on the ongoing Superfund remedial program. On August
4, 1992 NJDEPE held a briefing for local officials and representatives of
CRISIS in Bridgewater to discuss the planned Surface Soils Remedial/Removal
Action (SSRRA) at the American Cyanamid Site. Township and CRISIS
representatives were supportive of the surface soil work but asked for
additional information on the health and safety plan for this project which
was provided before commencement of work. During the August 4th meeting
officials expressed concern about possible pollution of Cuckhold's Brook
during the work and stated that the public was still not convinced that
Cyanamid's ground water pumping system was controlling water pollution at
this site. In an August 31, 1992 letter, CRISIS requested additional
information from NJDEPE on other site remediation issues including the
development of the Risk Assessment document, health evaluations,
construction of chemical processing plants as part of the cleanup process,
and proposed ground water cleanup standards. NJDEPE responded in a
September 8, 1992 letter. NJDEPE held a formal public comment period on
the SSRRA from September 17, 1992 through October 16, 1992. no
additional comments on the SSRRA were received during this period.
Representatives of NJDEPE and USEPA visited the site with Congressman
Robert Franks. Township officials and members of CRISIS on April 16, 1993.
In response to concerns raised about remedial activities at the site by CRISIS
representatives during this visit. NJDEPE and USEPA offered, in an April 20,
1993 letter, to meet again with Bridgewater and CRISIS officials to address
these concerns.
C. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND AGENCY RESPONSES
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During the August 5th Public Meeting, representatives of CRISIS expressed
serious concerns that the proposed remedy would not adequately treat
organic contaminants and that as a result these organics would degrade the
Impoundment 8 facility liner releasing contaminants to the environment.
CRISIS also questioned the effectiveness of the ongoing bedrock pumping of
contaminated ground water. NJDEPE prepared an extensive response to these
concerns and met with representatives of CRISIS and Bridgewater Township
in Bridgewater on August 24, 1993 for further discussion. Most of the
items at issue were resolved at the August 24th meeting. Concerns raised
during the American Cyanamid Company Superfund Site Public Meeting held
on August 5, 1993, at the August 24, 1993 working meeting, and written
comments received during the comment period which extended from June 30,
1993 through September 12, 1993 are summarized below. Comments
received on the Draft Modified HSWA permit will be addressed in the Final
Modified HSWA permit.
1. Comment: The technical consultant for CRISIS stated that impoundment
19 appears to contain significantly greater levels of organic
contaminants than impoundments 11, 20 and 24 and recommended that
the biological treatment followed by solidification option be chosen for
impoundment 19. He indicated that since the organic containing
material is present in a discrete layer it should be possible to minimize
the amount of material treated.
Response: Chemical analysis of the Impoundment 19 material detected
only two human carcinogenic organic compounds (benzene at 370 parts
per million (ppm)-maximum concentration, and methylene chloride at 51
ppm-maximum concentration). Impoundment 19 has a total organic
contaminants concentration of 18,824 ppm (8.7% of total contaminants)
and a total inorganic contaminants concentration of 198,247 ppm
(91.3% of total contaminants). The ratio of inorganics: organics is
11:1. Detected human carcinogenic organic compounds in Impoundment
19 represent only 0.19% (total concentration 421 ppm) of the total
contaminants (217,071 ppm).
The Impoundment 19 contents consist of sludge, fill, tar, natural soil
and lime. The discussion in site study reports which indicated that the
two types of material were present in discrete layers may have been
misleading. The tar and lime pockets are interspaced throughout the
impoundment and the entire impoundment contents would need to be
treated to remediate the organic portion.
A treatability study for the biotreatment of Impoundment 19 determined
that it was necessary to dilute the material with water. A 30% slurry
(7 parts water to 3 parts Impoundment 19 material) was determined to
be the highest concentration which could be treated. In addition,
nutrients (nitrogen and phosphorus) had to be added to support and
sustain biodegradative activity. Due to the dilution requirement, the
overall volume of the treated materials increased significantly.
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Additional cost for biotreatment of the material in Impoundment 19
would be $ 4,293,000. Base on the points discussed above,
biotreatment for Impoundment 19 is not practical. Spending over
$ 4.3 M in additional cost, for the biotreatment of Impoundment 19,
compared to solidification, is not practical and cost effective.
2. Comment: Various representatives of CRISIS expressed fears that
untreated volatile organics would escape the solidification process, pool
on the bottom of the Impoundment 8 Facility, degrade the liner and
escape into the environment. Speakers felt that rainfall would magnify
these problems.
Response: The solidification technology proposed in the preferred
alternative will bind both inorganic and organic contaminants in a solid
matrix which will minimize leaching of contaminants. A final cap will
be placed over the Impoundment 8 Facility which will prevent formation
of leachate by eliminating rain water percolating through the
Impoundment 8 contents. A temporary fabric covering is placed over
open areas of the impoundment when filling operations are not in
progress to minimize rainfall entering the facility. A six inch layer of
stone is placed over the 80-mil high density polyethylene liner before
any material is placed into the impoundment to prevent fill material from
coming into direct contact with the primary liner. A system of pipes
for the collection and removal of leachate is built into this stone layer.
Chemical compatibility testing for the liner included immersion in
leachate. Should any leachate pass through the primary liner, a
leachate detection system consisting of another series of collection
pipes would capture it before it reaches the final liner system. This
system is being monitored on a monthly basis and repairs would be
initiated if leachate is present. NJDEPE believes that all these
safeguards will insure that the preferred alternative of solidification and
placement in the Impoundment 8 facility will be protective of human
health and the environment.
3. Comment: A speaker at the August 5th meeting suggested that bentonite
blankets be considered for placement under the final storage facility to
give added protection to the liner. The same speaker stated that the
exposed liner would be subject to ultraviolet degradation from sunlight.
Response: The first cell of the Impoundment 8 facility has already been
closed in accordance with the approved RCRA permit, bentonite blankets
will be considered for future units. The six inch stone layer over the
open liner protects it from damage due to sunlight. Once the final cap
is placed there will be no sunlight reaching the liner.
4. Comment: At the August 24th working meeting Council President
D'Ascensio of Bridgewater suggested that the contents of the Group I
Impoundments be treated, through a multi step process including ion
exchange treatment, to recover the metals present for resale. He
suggested that the organics could be treated in a corollary process and
the rest of the treated material could then be utilized as clean fill.
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Response: The total mass of the Group I Impoundments is 94,000 tons.
Total mass of inorganics in the Group I Impoundments is 6,917 tons
while the total mass of carcinogenic inorganics is 127.8 tons. Total
inorganics are 7.4% and total carcinogenic inorganics are 0.14% of the
total mass of the Group I Impoundments. Based on the results of test
pit samples (Impoundment Characterization Report, August 1990), the
greater portion of the material in the Group I Impoundments consists of
lime, silt, clay, native organic soil and debris.
At the suggestion of the Council President, NJDEPE contacted
representatives of companies with experience in ion exchange technology
to discuss the process. Due to the high percentage of solids (about
60%) and low percentage of recoverable materials in the impoundments,
the material would require a two or three step pretreatment process
prior to ion exchange and a significant amount of dilution which would
greatly increase the amount of material to be treated. The entire
volume of the Group I impoundment would have to be treated because
the materials are practically non-separable. The application of ion
exchange or any other chemical treatment would require the processing
of large volumes of waste in order to "treat" a very small mass of
inorganics. Solidification achieves overall protection of human health
and the environment in a shorter time frame and is cost effective.
5. Comment: The Council President expressed concern that the reaction of
lime with the cement like material used in the solidification process
would generate excess heat.
Response: The findings presented in the July 1991 Technology
Evaluation Work Plan indicated that there was essentially no reactivity
remaining in the lime. In order to be conservative, a bench scale
plough mixer will be used to conduct exotherm (heat release)
evaluations with several successful solidification formulations before
field application.
6. Comment: A Bridgewater resident wrote asking where the new
Impoundment 8 will be located and commenting that the last
impoundment created by American Cyanamid is on Polhemus Lane very
close to residences. The writer requested that any new impoundment
be located close to the plant.
Response: The "new" Impoundment 8 discussed in the Proposed Plan is
the one that has already been located. Wastes from the "old"
Impoundment 8, along with Impoundments 6 and 7, are currently being
processed into the new Impoundment 8 according to the terms of the
RCRA permit for this facility. There are no current plans to construct
additional impoundments at this site.
7. Comment: The Township of Bridgewater submitted written comments
requesting that adequate air pollution control measures including the use
of a carbon absorber be implemented during the removal and
solidification processes to insure that activities are in conformance with
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National Air Quality Standards and the Federal Clean Air Act. The
township asked for a review of the facility at least every three years
instead of five and quarterly monitoring of groundwater monitoring
wells around the Impound 8 facility. The township also requested
review of plans involving the Impound 8 facility and that a thicket of
thorny shrubs be maintained along the fence line of this facility to
serve as a natural buffer.
Response: Excavation, solidification and consolidation activities for the
material in the Group I Impoundments will be carried out in compliance
with applicable state and federal regulatory standards. Volatile
emissions from the solidification process will be collected with a blower
and treated in a carbon absorber, if necessary. This requirement will
be evaluated in detail during the Remedial Design which will include a
health and safety plan. NJDEPE will provide Bridgewater Township with
the opportunity to review these plans before implementation.
The five year review process is consistent with the CERCLA/NCP
requirement and applies to the overall remedy selected for the Group I
Impoundments. Leachate control systems and ground water monitoring
wells are currently being monitored on a monthly and quarterly basis
respectively. Site conditions have been and will be monitored on a
regular basis as part of the ongoing design and remediation of this area
and other areas of the site. A thicket of thorny shrubs will be
maintained along the fence line of the Impoundment 8 facility.
8. Comment: Various comments were made on the perceived inadequacy
of flood control measures and flood information on the site. Speakers
stated that they could recall when all the site impoundments were
flooded and expressed concerns that floods could carry river
contaminants upstream in the Raritan River past the Elizabethtown Water
Company intakes.
Response: The area of the Impoundment 8 facility is clearly outside the
500 year flood plain. The Elizabethtown Water Company Intakes are
located approximately 1700 feet upriver and approximately 2,200 feet
upriver of the American Cyanamid site. Based on the regular analysis
performed by the Elizabethtown Water Company, the water intakes are
not contaminated. The entire site will be evaluated for 500-year flood
plain hazards and the impact of the site on the Raritan River as part
of a site-wide natural resources assessment. The work plan for this
study has been forwarded to CRISIS for review. NJDEPE's objective is
to remove the threat of potential contamination to the river from
flooding or ground water impacts by remediating the impoundments that
are the source of potential contaminants beginning with the Group I
Impoundments as addressed in this Record of Decision. A fact sheet
on the Raritan River and Cuckhold's Brook flood plain, including a flood
events history, is attached.
9. Comment: CRISIS representatives noted that the preferred remedy will
not attain ground water quality standards and asked that the Record of
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Decision contain a statement that final site remediation will meet
ARARS.
Response: A statement to this effect appears as the last paragraph of
the Declaration Statement of this Record of Decision (page 2.) The
remediation of the Group I Impoundments represents only the first step
of a many phased cleanup of the American Cyanamid Site. Effective
final remediation of contaminated ground water can only be achieved
after the sources of continuing contamination, in site impoundments and
soils, have been addressed.
10. Comment: A speaker asked who was responsible for quality
assurance/quality control (QA/QC) for remedial work at the American
Cyanamid Site.
Response: QA/QC on all remedial work conducted by American Cyanamid
has been performed by NJDEPE.
Certain other concerns were raised at the August 5th Public Meeting which
do not bear directly on the remediation of the Group I Impoundments. These
concerns included comments that the Somerset Raritan Valley Sewage
Authority (SRVSA) plant was not equipped to treat organic compounds in the
recovered ground water from the American Cyanamid plant and that the
monitoring system and analysis of the bedrock ground water was insufficient.
NJDEPE's responses to these issues are included in the packet of materials
prepared for and revised after the August 24th working meeting. These
materials and all written comments submitted during the public comment
period are attached to this Responsiveness Summary.
D. COMMUNITY RELATIONS ACTIVITIES AT THE AMERICAN CYANAMID
COMPANY SITE
NJDEPE established information repositories at the following locations:
Bridgewater Town Hall
700 Garretson Road
Bridgewater, NJ 08807 Phone # (908) 725-6300
Somerset County/Bridgewater Library
North Bridge Street & Vogt Drive
Bridgewater, NJ 08807 Phone # (908) 526-4016
New Jersey Department of Environmental Protection And Energy
Bureau of Community Relations
401 East State Street, CN 413
Trenton, NJ 08625 Phone # (609) 984-3081
Contact: George Tamaccio
NJDEPE held a briefing for public officials and concerned citizens in
Bridgewater to discuss the corrective action portion of the 1988
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Administrative Consent Order (AGO) and the initiation of the Remedial
Investigation/Feasibility Study (RI/FS) (January 1989),
NJDEPE held a public meeting in Bridgewater to discuss the RI/FS (February
21, 1989).
NJDEPE prepared a Community Relations Plan (February 1989).
NJDEPE forwarded information requested at the February 21, 1989 meeting
to those attending (April 20, 1989).
NJDEPE held a public meeting in Bridgewater to update the RI/FS progress
(March 11, 1991).
NJDEPE issued a Superfund Site Update fact sheet in response to concerns
raised at the March 11, 1991 meeting (June 1991).
NJDEPE met in Bridgewater with township officials to discuss concerns raised
by Bridgewater regarding ongoing site activities (November 27, 1991).
NJDEPE held a briefing in Bridgewater for officials and CRISIS representatives
to discuss initiation of the Surface Soils Remedial/Removal Action (SSRRA)
(August 4, 1992).
NJDEPE held a public comment period on the SSRRA from September 17,
1992 through October 16, 1992.
NJDEPE held a public comment period from June 30, 1993 through
September 12, 1993 and a public meeting in Bridgewater on August 5, 1993
to discuss the Proposed Plan for Remediation of the Group I Impoundments
and Modification of the Hazardous and Solid Waste Amendments Permit.
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SUPERFUND RECORD OF DECISION
AMERICAN CYANAMID SITE
BRIDGEWATER TOWNSHIP
SOMERSET COUNTY
NEW JERSEY
GROUP I IMPOUNDMENTS (11, 13, 19 AND 24}
ATTACHMENT 1 - FIGURES
-------
FIGURE 1
GENERAL AREA MAP
POOR QUALITY
ORIGINAL
-------
IMPOUNDMENT GROUPING LEGEND;
mm GROUP i
•• GROUP 2
•1 GROUP 9
•• RCRA-PERMITTED
DIPOUND1IBNTS
SOMCHSC1 MMTAM
VAUIY SUCH/MX
PLAN
N01 10 SCALE
AMERICAN CYANAMIO
BOUND BROOK PLANT
BRIDGE WATER TOWNSHIP
SOMERSET COUNTY. NEW JERSEY
•IASUMO. MUC«
-------
Impoundment Bottom Triple Liner System
Slr^e Layer Gtotodfe
16" dotage Layei
W Own Store
hknoy 80 ml WFE Untr
l^coodary ft T«wry
6O ml HDFC Urws
6- Mrv Sand toddftg Material
UrrtJ of Excavation
SlnQto layer Geotetfle
Top of
Beating
Matorta)
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SUPERFUND RECORD OF DECISION
AMERICAN CYANAMID SITE
BRIDGEWATER TOWNSHIP
SOMERSET COUNTY
NEW JERSEY
GROUP I IMPOUNDMENTS (11, 13, 19 AND 24)
ATTACHMENT 2 - TABLES
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( fP 3 >
DATABASE SUMMARY FOR CONTAMINAN
AMERICAN CYANAMID. BOUN
TCLORQ*NICS(m9*tf
Paentely Car ciuyertcTCL Votaries
Benzcn*
MBnyMwuioMcie
OmerTCLVotertes
, - • _
1 ,1 ,2,2-TUU HU M USI IH B
4-Metty-2-penanone
Acaone
QferabemnB
QfcJueUBM
Efytenone
TwacrtoroahytenB
Toluene
XytorBs(nuQ
Poerualy Csrcttsgertc TO. BerrtxolaBes
1,4-Otrtorobenzene
Bis(2*€0
-------
•CONCENTRATIONS
BROOK
P»gelo>3
IMPOUNDMENT 19
AVQ
CONC.
BBSS
1264
_
-
60.30
627.96
27.31
183.26
132.34
260
21.76
4389.21
aso
MAX M
CONC CO
370 <
61 <
_
-
100 <
2300 <
68 <
470 <
490 <
N. NO.
NC OF
DETECTS
1 3
1 2
_
-
1 1
1 3
1 2
1 2
1 2
260 260 1
30 17 4
17000 <
1 3
B.30 B.30 1
IMPOUNDMENT 20
AVQ MAX MIN. NO.
CONC. CONC CONC OF
DETECTS
4660 6600 3800 2
135 160 110 2
_ _ — —
_
_
2160 3000 1300 2
490 680 30C 2
_ •••-•».
2160 2900 1400 2
_ • _ _
: : : :
_
_
IMPOUNDMENT 24
AVQ
CONC
1.36
ia90
11
0.07
3787
9666
46
28.16
27.08
119.60
46.66
377.33
9.80
MAX M
CONC. CO
3.30 <
92.00 <
N. NO.
NC OF
DETECTS
1 1
1 6
11 11 1
<1 <
120 <
460 <
1 0
1 3
1 3
46 46 1
120 <
1 6
70 1.60 6
600 11 6
120 4.70 6
1200 94 6
9.80 9.80 1
-------
DATABASE SUMMARY FOR OONTAMi
AMERICAN CYANAMID.B;
OthvTCLSvTtoQiaiBS
1.2,4-TricNaratOTzra
1.2-OtttorobenzenB
2,4.6-TrtcrtorcphBncl
2,4-OtiMI yl< M ul
2-GHuiu itfJl W mere
»«**»*.
2-NtrophenU
AflfllKJW
B.nza(4»lhr*an.
B0nza(b}fluUH U MV
Banza(K)fluu •!)•§•
Buryl benzyl ptinotae
Dkvtuylptthaan
Dkvooylptthalstt
Dtanzoriran
FLnranhn
Fluararv
Inphororv
N*tth*n.
Phwl
Pyrant
TOTAL POTENTIALLY CARaNOGENICTCL ORQANICS
TOTAL TCLOR3ANICS
IMPOUNDMENT 11
AVQ.
OONC
-
50.42
A fn
4.7U
-
1876.40
_
4^tt
-------
VNT CONCENTRATIONS
IND BROOK
IMPOUNDMENT 19
AVQ
CONC.
1003.59
14336
-
-
3309.60
003
36389
-
0.02
-
131.46
4.31
43.60
10917
13
7.60
-
26
346.76
17.06
613.42
-
401^62
2886.69
97.44
2245
4770.63
MAX M
CONC. CO
260 <
-
-
IN. NO.
NC OF
DETECTS
1 2
1 2
-
-
9800 aeo 3
<1 <
1200 <
-
<1 <
-
350 <
aeo <
1 0
1 3
-
1 0
-
1 2
1 1
64 33 2
240 <
1 2
13 13 1
7.60 7.60 1
-
•
26 26 1
740 <
37 <
1200 <
-
1 2
1 2
1 2
•
11000 290 6
8200 <
210 <
41 <
1 2
1 2
1 2
1682366
IMPOUNDMENTS
AVQ MAX MIN. NO.
CONC CONC CONC OF
DETECTS
_
-
_
_ _ _ —
_
_
_
_
_
_
_
_
_
-
_ _ _ —
_
-
_
_
_
_
_ _ — —
_
_
_
4785.00
9576.00
IMPOUNDMENT 24
AVQ
CONC.
81.60
2000.47
33.40
200
634
-
203.60
66
-
7210
76.24
696
19.20
-
-
_
66
-
8646
20
86.60
0.09
2646.67
11086
66.80
-
67265
MAX
CONC
66*
13000
66
200
2900
-
660
66
-
200
200
7.80
33
-
-
_
65
-
440
20
820
*
8600
850
160
-
MIN.
CONC
4.X
aeo
200
11
-
13
66
-
7.40
ft 20
6.10
6.60
-
-
_
65
-
ax
20
16
<1
120
67
14
-
NO.
OF
DETECTS
2
7 .
2
1
6
-
6
1
-
8
6
2
3
-
-
.. .
1
-
7
1
6
0
6
7
6
-
7232,63
-------
rf-
-TADLE 1 (cnntl
DATABASE SUMMARY FOR OONTAMI
AMERICAN CYANAMIO.Bt
3
TAL INORGANICS (mtVTO
Poems* Cmatagnk. TAL Inorgrfcs
AfMrte
Bvyftjn
Crtitm
Qi VfAjn
LMO
NIC**
OOw TAL Inorqvlcs
Akirtrun
Antnory
Bvun
Ctfckjn
Oobtf
Ooppv
CyvttB
Iron
Mapvsun
' lin^v^^
Mtrcuy
fouotifn
SMrtum
8Kw
Sodum
Ttvkjn
Vradun
Zhc
TOTAL POTENTIALLY CARQNOGEN1CTAL INORGANICS
TOTAL TAL INORGANICS
IMPOUNDMENT 11
AVQ
CONC.
8ZS3
-
1ft SB
1B7B
2183
13123
62340
16.31
S2S&70
173680
11.87
2140
23.80
60510
8836
230.79
161.02
626
aae
1.76
46Z10
-
4067
2213.30
4288.74
MAX
CONC
186
-
31.X
2260
3480
284
106000
2070
8920
3830
24.60
3600
88.80
131000
7160
487
284
668
2.40
6.20
1000
-
47.30
6680
MtN.
CONC
3O10
-
eeo
1380
1140
61.80
10600
8.10
271
624
420
1600
12.80
26300
2200
87.8
41.60
402
<1
270
184
-
21.80
821
NO.
Of
DETECTS
10
-
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
8
10
10
-
10
10
141784.02
MPOUNDMENT13
AVQ
CONC
3248
-
1066
68260
3327.60
186.60
7070
18.61
266980
23182
18.82
2074
1222
81780
4733.80
688.20
3838
81020
1.70
-
686.40
-
26.62
129240
4149.83
MAX
CONC
6810
-
24.60
878
13100
303
13300
42,60
6010
34600
272)
8620
26.20
168000
10800
718
64.60
1370
278
-
873
-
46.40
2440
MM.
CONC
1280
-
<1
248
686
117
2660
247
418
3910
1170
1330
4.30
43200
809
466
16.20
624
<1
-
162
-
7.31
121
NO.
OF
DETECT
6
-
3
6
8
6
6
6
6
6
6
6
6
6
6
6
6
6
4
-
6
-
8
6
13894088
NOTES: 1.
2. *MBC Cone.
3.
4.
& "— *lnclc««$tnon
Vw MBdrrmf G
rtrvon of
uj8\^ivaionc
-------
ued)
»NT CONCENTRATIONS
IND BROOK
•3OI3
IMPOUNDMENT 1 9
AVQ
CONC.
26.38
-
1.10
22968
423.86
79.72
7984
iase
261 a 60
116631.80
9.62
74340
242
&AJ/U
29634.20
844.20
2S.02
31 aa
0.72
-
30040
-
2&74
26922
76974
MAX
CONC
9690
_
3
698
864
238
20200
19.70
9120
301000
24.90
2160
4.90
121000
118000
2109
84
627
210
-
401
-
47.70
836
MIN.
CONC
a so
-
<1
<1
10.30
a so
1290
B.10
17
469
2.40
1070
1.20
4450
366
190
<1
237
<1
-
162
-
3.80
43.50
NO.
OF
DETECTS
6
-
1
4
6
6
6
6
6
6
6
6
6
6
6
6
4
6
1
-
6
-
6
6
196246.64
IMPOUNDMENTS
AVQ.
CONC
7.33
1.33
1.77
60300
1720
448
3276
673
39.66
62000
24.65
7806
2.66
49050
4545
387
1.16
1200
1.33
266
10000
2.44
103.60
80900
6247843
MAX
CONC
a 40
1.36
203
68400
1880
462
3420
663
40.60
66900
27.60
8270
272
63600
4840
412
1.18
129
1.36
272
10600
272
107
148000
MIN.
CONC.
6.26
1.X
1.60
42200
1660
434
3130
483
38.60
47100
21.60
7340
260
44600
4260
362
1.11
1170
1.X
260
9200
216
100
13800
NO.
OF
DETECTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
262391.27
IMPOUNDMENT 24
AVQ
CONC
7206
-
-
296.14
677.67
141.66
7050
12X
1133
27277.14
13.87
2293.96
3220
64728.67
37X
13BS
665
1009.86
a 40
-
660.29
223
101.14
637.29
118652
MAX
CONC
169
-
-
671
1270
276
14600
66.60
2060
80000
2260
2920
171
126000
11900
3160
19.X
2070
14
-
1090
6.71
166
1970
MIN.
CONC
£78
-
-
33
33.70
27.X
gPgp
232
261
8640
4.46
37.70
1.20
22500
1250
624
<1
172
<1
-
187
1.16
27.X
76
NO.
OF
DETECTS
7
-
-
7
7
7
7
7
7
7
7
7
7
7
7
7
6
7
3
-
7
7
7
7
11126342
-------
TABLE 1
DATA
RJUUMff FOR COMT AMMAN! CONCENnMnONS
AMERICAN OTANMM). IOUNO BROOK
TO. OflOAWCT (mgftg)
PanMkCmraoncTCLVDMii
taBtm
o^tayZr"0*""1
^"*^^™
Awn
CMnMram
o ««••••
Evylmra
T«nuumHl»«
U lotam
• **nM6n*
Pan* e»UMI»». TO. 8BIMMM
i'«] •»i»ii||iMaj
ONym
ll»«l«ll«»ll»»
N«w»BOtfwvM»
PCS 12*
FOJ-I2M
MTOUNOUCNTII
AVQ
OONC
••3
on
-
a«o
tut
_
AM
_
17.47
aaaa
I6M
26(0
1(06
_
11039
_
-
MAX
OONC
a
240
-
11
•
.
14
_
73
140
34
tl
at
_
in
_
-
MM
OONC
«o a
1.20 •
-------
TABLE 1 (CONTD)
OAIABAIE tUMUAHTfORODNTAUMAMT CONCENTRATIONS
AtKHCAN CVANAMO. IOUNO MOOK
on, TO. to*—
mianaamn
^ _
1.2-OUUIUIBBI)
2.4,1-TimmpBtt
2,4«nMvt*M
*«*•«*»"•
!^^1"^^
inay»^<«^»«
stMVpm
24*<«m»
m^j -u^a
|t t j_i_j
AL»^»«»a»
AfCnara
04raa(iMr*ncm
OtiuiKit* !•••••
^htfomfmim
Clllllli.ll|HlMM
DHvaatfffMMt
• OlmAjtn
Fhotnt
MQpntwW
Nramm
rmmm
PM«I
Ppm
1
ma
awe
•43
470
-
-
—
IBt40
.
_
_
2MB
I4M
MM
ticto
_
_
2114*
MM
2M40
1MM
7»7»11
230
3K77
_
MM
"•*
HPOUNOI
MAX
OONC
IB
4\B
.
-
_
•100
.
.
—
7B
M
2B
220
.
_
ao
IB
MO
3M
41000
300
MO
_
130
KtNMl
MN.
OONC
• 70
"
-
-
^
44
_
.
^
•7
7.10
M
17
_^
_
.
^
140
•B
1
^
B
M
230
770
.
4M
NO 1
OF 1
DETECTS]
•
2
-
-
_
10
_
_
—
•
•
0
10
1
„
—
(
1
10
_
2
•
1
10
_
•
MPOUNDMMII2
AM MAX MN NO.
OONC CQNT flQNC Of
OETECTI
IOIM 210 4M •
4010 M 2B I
1 6 210
_
ISO i
•M <
1 1
-
1 0
.
1 2
1 1
64 31 2
240 .
11 1
1 2
3 |
760 7CO 1
-
26 a i
740 «
37 .
1300 <
-
-
1 2
1 2
1 2
-
-
11000 200 , 6
•200 «
210 •>
-
41 <
1 2
1 2
-
1 2
MPOUNDUENt 24
AVQ
OONC
It 90
200047
2140
200
-
.
2m 60
M
-
7210
7624
t«6
1*20
-
.
_
-
66
-
•646
20
•to
DOS
-
iO4Af7
tlOtb
•to
~
~
67286
723261
UAX
OONC
to
1HOO
•
200
oonn
•0
66
-
200
200
7*0
»
-
_
_
-
66
-
440
20
120
«'
-
•00
no
140
"
"
KIN
OONC
120
4»
•60
200
-
-
11
66
-
740
620
610
660
-
_
_
-
66
-
IX)
20
16
<'
-
120
67
14
"
NO
Of
DETECTS
2
7 |
2
1
>
t
i
-
t
t
2
1
-
_
„
-
1
-
7
1
6
0
-
6
7
6
~
"
-------
OATAI
TABLE 1 (CONTD)
E 6UMUAHT f OH OONTAMMAMT CONCENTIMTIOM
AtrCMCANCTAMAM0.60UN06AOCK
61
TAL MOAOAMC6 mUW
Pan* Cvcraovic TAL moan*
Aim
•M^M
mm^fn
CMI6JH
Oranm
UM
NO*
On TAL manna
AUmn
Aimoy
•mm
CMcun
CBU6
Cnppo
(V«»
•on
MioriMUn
Mmgnm
IMcuy
Puna re
••mm
6M
lOdLfll
Tra6un
vnttm
ac
TOTAL POTENTIALLY CARdNOOENlC TAL MOMMMCS
TOTAL TAL MOMMMC6
Am
OOMC
6269
1666
1676
2161
1*1 21
62340
16*1
•26670
171660
1167
2140
2*60
60610
•06
23076
16102
626
066
176
46210
4067
221 1*0
420674
MAX
OONC
166
KM
(MO
6460
*64
106000
2070
1620
•90
H60
•too
•660
131000
7160
467
264
666
240
620
1000
47 3D
6660
MM
OONC
aaio
660
1160
1140
6160
10600
• 10
271
624
420
1600
1260
26300
2200
•76
4160
402
-------
TABLE 2
Contaminants
Total Organics
Potentially
Carcinogenic Organics
Total Inorganics
Potentially
Carcinogenic Inorganics
i
Contaminant Ratios*
Inorganics :Or ganics
Noncarcinogens:Carcinogens
OUMMAHT W IUIA
Impoundment 11
12,075
176
141,794
4.299
12:1
34:1
LUUNIAMINANTCON
Impoundment 13
4,574
245
138,941
4.150
30:1
33:1
CENTRATONS IN GROUP
Impoundment 19
16,824
4,770
198,247
760
11:1
39:1
1 IMPOUNDMENTS1
Impoundment 24,
7,233
573
111.253
1.187
15:1
67 1
1. All concentrations reported in milligrams per kilogram (mg/kg) dry weight.
2 Contaminant ratios are calculated by dividing one contaminant group by another (e.g. lor Impoundment 11:141.794 + 12.075 =12:1)
-------
TABLE 3
LIST OF ARARs AND TBCs
Chemical-Specific ARARs
a. RCRA Maximum Concentration Limits (MCLs)
b. A-280 Regulations
c. New Jersey Ground-Water Quality Standards
d. Federal Water Pollution Control Act as amended by the Clean Water Act
e. Clean Air Act, as amended
f. New Jersey Air Pollution Control Regulations (NJAC 7:27)
Location-specific ARARs
f
a. Floodplains Standards in 40 CFR 264.18
b. Floodplain Management - Executive Order Number 11988
c. Protection of Wetlands • Executive Order Number 11990
d. Flood Hazard Area Control Regulations
e. New Jersey Freshwater Wetlands Protection Act Rules in N.J.A.C. 7:7A
f. Endangered Species Act in USC Sec. 1531
g. Cultural Resource/Archaeological Resource Protection Requirements
Action-specific ARARs
a. RCRA Hazardous Waste Facility Requirements (40 CFR 260-264)
b. NJOEPE Hazardous Waste Regulations (NJAC 7:26)
c. Land Disposal Restrictions (LORs)
d. Water Quality Permit Requirements
e. Air Quality Permit Requirements
f. New Jersey Soil Erosion and Sediment Control Act Requirements
-------
TABLE 4
AMERICAN CYANAMD COMPANY
BOUND BROOK, NEW JERSEY
PRELIMINARY COST ESTIMATE: SOLIDIFICATION AND CONSOLIDATION IN
ON-SfTE RCRA FACtLJTY flMPOUNDMENTS 11. 13. AND 19)*
Description
Mobilization/Demobilization
Excavation/Transportation
Solidification Installation/Process"'
Consolidation in RCRA Facility9
Restoration"
Site Controls (Air Monitoring)*4
Estimated
Quantity
70.500
70.500
70.500
77,550
8.8
Unit
cu. yd.
cu. yd.
cu. yd.
cu. yd.
acres
lump sum
Unit Price
Material
and Labor
$
3
25
35
15
37.000
20.000
Subtotal
Engineering. Legal. Adm (20%)
Subtotal
Contingencies (15%)
TOTAL
ROUNDED TO
Estimated
Amount
$ 211.500
1.762.500
2.467.500
1.163.250
325.600
20.000
$5.950.350
1.190.070
$7.140.420
1.071.063
$8.211.483
$8.200.000
Notes:
1. Assumes no dewatering required/no water to be added.
2. Assumes 10 percent increase in solids due to bulking and addition of solidification materials.
3. Assumes a six-inch cover of top soil at $1.50 per cu. ft. and seeding at $010 per sq ft.
4.. These costs do not include air permits.
* This cost estimate is considered an order of magnitude estimate with an accuracy oi +50 percent
to -30 percent
t/w
-------
TABLE 4 (CONTD)
AMERICAN CYANAMIO COMPANY
BOUND BROOK, NEW JERSEY
PRELIMINARY COST ESTIMATE: BIOTREATMENT (SLURRY-PHASE)'
IMPOUNDMENTS 11. 13. AND 19
Descfiption
Excavation/Transportation
Slurry-Phase Biotreatment with
Solidification
Analytical
Consolidation in RCRA Facility01
Restoration®
Site Controls (Air Monitoring)"
Estimated
Quantity
70,500
70,500
79.000
87,000
8.8
Unit
cu. yd.
cu. yd.
cu. yd.
cu. yd.
acres
lump sum
Unit Price
Material
and Labor
$ 25
265
30
15
37,000
87.000
Subtotal
Engineering, Legal, Adm. (20%)
Subtotal
Contingencies (15%)
TOTAL
ROUNDED TO
Estimated
Amount
$ 1.762,500
18.330.000
2.370,000
1.305,000
325.600
87.000
$24,180.100
4.836.020
$29.016,120
4.352.418
$33,368.538
$33.400.000
1. Assumes a 10 percent increase in solids due to bulking and addition of solidification material.
2 Assumes a six-inch cover of top soil at $1.50 per cu. ft and seeding at $0.10 per sq. ft.
3. Costs do not include air permits.
* This cost estimate is considered an order of magnitude estimate with an accuracy of +50 percent
to -30 percent. ~*
vanax
-------
TABLE 4 (CONTD)
AMERICAN CYANAMID COMPANY
BOUND BROOK. NEW JERSEY
PRELIMINARY COST ESTIMATE: SOLIDIFICATION AND CONSOLIDATION IN
ON-StTE RCRA FACILfTY (IMPOUNDMENT 24)*
Description
Mobilization/Demobilization
Excavation/Transportation
Solidification Installation/Process1"
Consolidation in RCRA Facility0
Restoration"
Site Controls (Air Monitoring)1*
Estimated
Quantity
37,500
37.500
37,500
41.250
3.2
Unii
cu. yd.
cu. yd.
cu. yd.
cu. yd.
acres
lump sum
Unit Price
Material
and Labor
$
3
25
35
15
37.000
12.000
Subtotal
Engineering. Legal, Adm (20%)
Subtotal
Contingencies (15%)
TOTAL
ROUNDED TO
Estimated
Amount
$ 112.500
937.500
1.312.500
618,750
118.400
12.000
$3.111.650
622.330
$3.733.980
560.097
$4,294.077
$4.300.000
Notes:
1. Assumes no dewatering required/no water to be added.
' '2. Assumes 10 percent increase in solids due to bulking and addition of solidification material.
3. Assumes a six-inch cover of top soil at 1.50 per cu. ft and seeding at $0.10 per sq. ft
4. These costs do not include air permits.
* This cost estimate is considered an order of magnitude estimate with an accuracy of +50 percent
to -30 percent
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TABLE 4 (CONTD)
AMERCAN CYANAMD COMPANY
BOUND BROOK. NEW JERSEY
PRELIMINARY COST ESTIMATE: MODERATE TEMPERATURE THERMAL TREATMENT*
(IMPOUNDMENTS 11. 13. AND 191
Description
Site Preparation
Mobilization/Demobilization
Material Handling
Thermal Processing'"
Solidification of Residual Solids
Analytical
Consolidation in RCRA Facility®
Restoration"
Site Controls (Air Monitoring)14*
Estimated
Quantity
42,592
70.500
70.500
48.600
48.600
53.460
8.8
Unit
sq. yd.
lump sum
cu. yd.
cu. yd.
cu. yd.
cu. yd.
cu. yd.
acres
lump sum
Unit Price
Material
and Labor
$ 2
400,000
25
250
3C
30
15
37. OCC
65.000
Subtotal
Engineering. Legal. Adm (20%)
SuL-tGlal
Contingencies (15%)
TOTAL
ROUNDED TO
Estimated
Amount
$
85.184
400.000
1.762.500
17,625,000
1.701.000
1,458,000
801.900
325.600
65.000
$24.224.184
4.844.837
$29,069.021
4.360.353
$33.429.374
$33.400,000
Notes:
1. Prices obtained from Canonia Draft Thermal Treatment Evaluation and includes post treatment of
the aq. phase.
2. Assumes 10 percent increase in solids due to bulking and addition of solidification material.
.. 3. Assumes a six-inch cover of top soil at $1.50 per cu. ft and seeding at $0.10 per sq. ft
4. Costs do not include air permits.
• This cost estimate is considered an order of magnitude estimate with an accuracy of +50 percent
to -30 percent
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TABLE 4 (CONTD)
AMERICAN CYANAMID COMPANY
BOUND BROOK, NEW JERSEY
PRELIMINARY COST ESTIMATE: MODERATE TEMPERATURE THERMAL TREATMENT'
(IMPOUNDMENT 24)
Description
Site Preparation
Mobilization/Demobilization
Material Handling
Thermal Processing"1
Solidification of Residual Solids
Analytical
Consolidation in RCRA Facility81
Restoration™
Site Controls (Air Monitoring)14
Estimated
Quantity
15.468
37.500
37.000
27.000
27.000
29.700
3.2
Unit
sq. yd.
'ump sum
:j. yd.
cu. yd.
cu. yd.
cu. yd.
cu. yd.
acres
lump sum
Unit Price
Material
and Labor
$ 2
400.000
25
250
35
30
15
3700
40,000
Subtotal
Engineering. Legal. Adm (20%)
Subtotal
Contingencies (15%)
TOTAL
ROUNDED TO
Estimated
Amount
$ 30,976
400.000
937,500
9,375,000
945.000
810.000
45.500
118.400
40.000
$13,102.376
2.620.475
$15.722.851
2.358.428
$18.081.279
$18.100.000
1. Prices obtained from Canonie Draft Thermal Treatment Evaluation and includes post treatment of
the aq. phase.
2. Assumes 10 percent increase in solids due to bulking and addition of solidification material.
3. Assumes a six-inch cover of top soil at $1.50 per cu. ft. and seeding at $0.10 per sq. ft.
4.. .Costs do not include air permits.
* This cost estimate is considered an order of magnitude estimate with an accuracy of +50 percent
to -30 percent.
vrn
402302 K
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TABLE 4 (CONTD)
AMERICAN CYANAMID COMPANY
BOUND BROOK. NEW JERSEY
SUMMARY OF PRELIMINARY COST ESTIMATES FOR ALTERNATIVES'
Alternatives
1. No Action
2. In-Place Containment
3. Solidification
4. Biological Treatment
5. Moderate Temperature
Thermal Treatment
11. 13. and 19
$ 100.000
$ 4.300,000
$ 8.200.000
$33.400.000
$33.400.000
Impoundments
20
$ 20.000
$1.600.000
$1.100.000
24
$ 0
$ 1.600.000
$ 4.300.000
— $18.100.000
Total Costs
$ 120.000
$ 7,500.000
$13.600.000
$33,400.000
$51.500.000
This cost estimate is considered an order of magnitude estimate with an accuracy of +50 percent
to -30 percent *
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