P694-963846
EPA/ROD/R02-94/241
March 1995
EPA Superfund
Record of Decision:
Brook Industrial Park
(O.U. 1), Bound Brook, NJ
9/30/1994
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DECLARATION STATEMENT
RECORD OF DECISION
BROOK INDUSTRIAL PARK
Site Name and Location
Brook Industrial Park
Bound Brook, Somerset County, New Jersey
Statement of Basis and Purpose
This decision document presents the selected remedial action for
contaminated soil, building interiors and ground water at the
Brook Industrial Park site. The remedial action was chosen in
accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986 and, to the
extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan. This decision is based on the
administrative record for the site.
The State of New Jersey concurs with the selected remedy for the
ground water, building interiors, and soil. However, if
institutional controls are not established, the State cannot
concur with the selected remedy for soil.
Assessment of the Site
Actual or threatened releases of hazardous substances from the
Brook Industrial Park site, if not addressed by implementing the
response action selected in this Record of Decision, may present
an imminent and substantial endangerment to public health,
welfare, or the environment.
Description of the Selected Remedy
The remedy described in this document represents the final remedy
for the Brook Industrial Park site and addresses the current and
future threats to human health and the environment associated
with the contamination present in the soil, building interiors
and ground water at the site. It provides for the remediation of
soil and building interiors exceeding site-specific remediation
goals and restoration of the ground water to the more stringent
of the federal and New Jersey Safe Drinking Water Act Maximum
Contaminant Levels (MCLs) and New Jersey Ground Water Quality
Standards (NJGWQS).
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The major components of the selected remedy include:
Excavation and off-site treatment and disposal of
contaminated soil exceeding remediation goals in Area One,
Area Two, Subsurface Pits and the Stirling Center Basement
and backfilling of the excavated areas with clean fill;
Demolition and off-site disposal/incineration of the
contaminated portions of the Blue Spruce Building;
Extraction and treatment of contaminated ground water to
levels attaining HCLs and NJGWQS;
Reinjection of the treated ground water and restoration of
the aquifer to the more stringent of the federal and New
Jersey MCLs and NJGWQS; and
Appropriate environmental monitoring to ensure the
effectiveness of the remedy.
Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with federal and state requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost effective. This remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable and satisfies the statutory preference
for remedies that employ treatment that reduces toxicity,
mobility, or volume as a principal element.
Because this remedy will result in hazardous substances remaining
on the site above health-based levels, the five-year review will
apply to this action.
William J. M£s«y£s49i, P.E. Date
Deputy Regional Administrator
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DECISION SUMMARY
RECORD OF DECISION
BROOK INDUSTRIAL PARK
SITE NAME, LOCATION AND DESCRIPTION
The Brook Industrial Park site is a located at 100 West Main
Street in the Borough of Bound Brook, Somerset County, New
Jersey. It is a 4.5-acre complex of warehouses and light
industries situated on the northern bank of the Raritan River.
The site is bordered by the New Jersey Transit railroad line to
the north; the Lehigh Valley/Port Reading railroad lines to the
south; an oil company to the west; and an undeveloped lot to the
east. Figures 1 and 2 show the location and layout of the site.
The Borough of Bound Brook is considered an urban-suburban
community of approximately 1.6 square miles, located near an
urban center with large residential areas. According to 1990
census data, approximately 9,500 people live in the Borough of
Bound Brook.
The Brook Industrial Park has been in existence since the late
1800s and currently includes several operating light
manufacturing companies and offices. The Industrial Park
consists of three buildings, referred to as Stirling Center, Blue
Spruce and National Metal. Current occupants of Brook Industrial
Park include a manufacturer of steel products, a manufacturer of
extruded plastic products, a manufacturer of specialty chemicals,
a metal plating company, an equipment contractor and several
other small companies (Figure 2).
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Several companies within Brook Industrial Park have been cited by
the New Jersey Department of Environmental Protection (NJDEP) for
inadequate housekeeping and waste disposal practices. These
companies are Blue Spruce International, National Metal
Finishings Corporation and Jame Fine Chemical Incorporated.
Industrial, chemical and pesticide production, usage and storage
operations began at the site in 1971 when Blue Spruce
International occupied a number of the buildings. Substances
handled by the Blue Spruce facility included various pesticides,
dioxin and arsenic compounds. Investigations by the Middlebrook
Regional Health Commission (MBRHC) and NJDEP were initiated in
1980 when workers within these buildings reportedly became ill.
Initial sampling conducted by NJDEP revealed the presence of
dioxin, pesticides, organics and heavy metals.
There have been several reports of spills and drum leakage at the
Blue Spruce facility which at one time stored as many as 300 55-
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gallon drums on the site (MBRHC/NJDEP 1980). Investigations by
NJDEP and MBRHC revealed standing puddles of wastewater on the
floor of the basement (MBRHC 1980). Soil samples from the
basement of the facility collected by the U.S. Environmental
Protection Agency (EPA) contained dioxin and high concentrations
of pesticides. During heavy rains, the basement flooded. Water
from the basement was reported to be pumped to the rear of the
facility and discharged to the ground surface.
Blue Spruce was cited by NJDEP for several violations in the
1970s. NJDEP fined Blue Spruce for shipment of mislabeled
pesticides and for the illegal storage of lindane in 1975. The
NJDEP Bureau of Air Pollution Control cited Blue Spruce in 1977
for installing mixing vats without obtaining an Air Pollution
Control permit. In the 1970s, Blue Spruce accepted shipment of
Agent Orange from the U.S. Air Force for shipment to a third
world country. In 1980, an Order and Settlement was issued by
NJDEP citing violations and outlining a sampling and cleanup
schedule. Subsequent to this settlement, dioxin was discovered
at the site. Since the funding under the settlement was
insufficient to cover the cost on remediating the dioxin
contamination, the cleanup was suspended. Blue Spruce
International has been defunct since the early 1980s.
The National Metal Finishings Corporation has operated at Brook
Industrial Park since the early 1970s. The metal plating process
performed by National Metal Finishings included electroplating
chromium onto large steel rollers followed by a final rinse over
an open pit to remove the residual chromium. The chrome-plating
units are located in two subsurface pits. These pits are
believed to be in direct connection with ground water. NJDEP
collected samples from one pit which revealed the presence of
chromium, nickel, lead, toluene and xylene. In 1982, the New
Jersey Department of Law and Public Safety required National
Metal Finishings Corporation to cease further discharge from Pit
#1 to ground water and to perform a hydrogeological study to
determine the degree of soil and ground water contamination.
This study was never performed. A closed-loop process was
subsequently installed which eliminated any further discharge to
the pits.
Jame Fine Chemicals, Inc. has manufactured specialty chemicals at
Brook Industrial Park for over 20 years. NJDEP conducted an
inspection of Jame Fine's manufacturing operations in 1980 and
found a wastewater discharge which flowed into the Raritan River.
This discharge was found to contain significant levels of several
organic compounds. Subsequently, in that same year, NJDEP issued
an Administrative Order and Notice of Civil Administrative
Penalty assessment to Jame Fine Chemicals, Inc. directing it to
cease the discharge of unpermitted chemicals and contaminated
wastewater to the Raritan River. In 1986, the Company received a
Notice of Violation from NJDEP for improper housekeeping and
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documentation procedures related to the storage of materials
manufactured at the site.
In July 1983, EPA conducted an emergency response action to
address immediate contaminant hazards present at the site. An
asphalt cap was placed on an area of the site which was found to
contain dioxin contamination. EPA conducted subsequent removal
actions in 1990 and 1993 to secure the Blue Spruce Building
against intruders.
In 1986, EPA initiated a focused feasibility study (FS) to
address the contamination found in the Blue Spruce Building.
This study was suspended when the entire industrial park was
being considered for inclusion on the National Priorities List
(NPL) of Superfund sites. However, the results of the field
sampling conducted during the focused FS were incorporated into
the 1994 FS report.
The Brook Industrial Park site was proposed for inclusion on the
NPL in June 1988 and finalized in October 1989. In April 1989,
EPA initiated a remedial investigation and feasibility study
(RI/FS) to determine the nature and extent of contamination,
assess the long-term risk and to develop and evaluate remedial
alternatives.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
A Community Relations Plan (CRP) was developed to ensure the
public opportunities for involvement in site-related decisions.
In addition, the CRP was used by EPA to determine, based on
community interviews, activities to ensure public involvement and
to provide opportunities for the community to learn about the
site.
EPA held a public meeting in November 1989 to explain the RI/FS
process to the public and to report on the progress being made at
the site.
The RI and FS reports were released to the public in July 1994.
A Proposed Plan identifying EPA's preferred remedial alternatives
was released on July 22, 1994. These documents were made
available to the public at the information repository at the
Bound Brook Memorial Library, located on East High Street in
Bound Brook, New Jersey. A copy of the administrative record
file is located at the Bound Brook Memorial Library and the EPA
Docket Room in Region II, 26 Federal Plaza, New York, New York.
The notice of availability of the above-referenced documents was
published in The Courier News on July 22, 1994 and The Bound
Brook Chronicle on July 28, 1994. The public comment period on
these documents, which included the Proposed Plan, was held from
July 22, 1994 to August 20, 1994.
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On August 4, 1994, EPA held a public meeting at the Bound Brook
Memorial Library, to present the findings of the RI/FS and the
Proposed Plan, and to respond to questions and comments from area
residents and other attendees. Responses to the comments
received at the public meeting and during the public comment
period are included in the Responsiveness Summary, which is part
of this Record of Decision (ROD).
This decision document presents the selected remedial action for
the Brook Industrial Park site, chosen in accordance with the
Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA), and, to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan
(NCP). The selection of the remedy for this site is based on the
administrative record.
SCOPE AND ROLE OF RESPONSE ACTION
The remediation of the site is complicated by the distribution of
contaminants across media and within an area of complex
hydrogeology. As a result, EPA has decided to address the site
by evaluating three types of contaminated media (soils and
sediments, ground water, and building interiors) individually
with regard to the risk posed to human health and the
environment, the potential for contaminant migration, and the
development of remedial alternatives. This ROD addresses the
entire site and identifies the selected remedy for contaminated
soil and sediments, building interiors, and ground water. This
is a final remedy which addresses the principal threats posed by
the site.
SUMMARY OF SITE CHARACTERISTICS
Site Geology and Hydrology
The site lies in the floodplain adjacent to the Raritan River.
The geology consists of a layer of fill ranging in thickness from
approximately 1 foot to 17 feet. Bedrock is encountered
approximately 20 feet below ground surface. The top portion of
the bedrock is highly weathered and fractured.
Ground water resources within the area are an unconsolidated
overburden aquifer and a deeper fractured bedrock aquifer which
is part of the Brunswick group. The water table is at an average
depth of 10 feet and appears to be sloping towards the Raritan
River. The source of ground water recharge is precipitation.
The precipitation infiltrates the ground, moving though
subsurface material, and is stored in the aquifers. Generally,
the overburden aquifer recharges the bedrock aquifer. The
continuous pumping of an on-site production well, which draws
water from the bedrock aquifer, is believed to have a direct
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impact on the ground water flow in the area of the site. All
ground water beneath the site, in the portion of the bedrock
aquifer which the production well penetrates, flows towards the
pumping well. In addition, a mounding effect has been observed
in the overburden aquifer which is believed to be the result of
unused ground water flowing back down the production well casing.
The. aquifer, downgradient of the site, is currently not used as a
drinking water supply.
Using the U.S. Fish and Wildlife Service Wetland Classification
System, the wetlands present at the site are classified as
Palustrine and Riverine. The Palustrine wetlands, which are
present in the southern end of the site, are determined based on
the dominant plant species occurring at the site. The Raritan
River and the unnamed tributary are typical of a Riverine System.
The total wetland area is approximately 71,000 square feet.
A Stage IA Cultural Resources Survey performed at the site as
part of the RI concluded that no impacts on prehistoric resources
are expected as a result of the remedial action. A review of
historic site surveys identified no historic structures. Also,
the presence of human-deposited fill on the upper 5 to 10 feet of
the site surface and geological and historical record of river
flooding across the site suggest that the preservation of
prehistoric resources on the site is unlikely in the upper
deposits.
Nature and Extent of Contamination
A series of field investigations, collectively referred to as the
RI, was completed in June 1994. The purpose of the RI was to
determine the nature and extent of contamination associated with
the site. The RI included sampling of ground water, surface and
subsurface soils, ponded water, sanitary sewers, floor drains,
building interior surfaces, debris piles, subsurface pits,
cooling water discharge, surface water and sediments.
The major conclusions of the RI for the site are summarized
below:
Approximately 5,000 square feet of building interior
surfaces (walls and floors within the Blue Spruce Building)
are contaminated with 2,3,7,8-TCDD (dioxin) at
concentrations ranging from 0.03 parts per billion (ppb) to
6.1 ppb.
Approximately 4,600 cubic yards of soil on the site are
contaminated with chromium, arsenic, lead, beryllium,
polychlorinated biphenyls (PCBs), aldrin, dieldrin, and 4,4
DDT (Table 1 and 2). This volume estimate includes soil in
the basement of the Blue Spruce and Stirling Center
buildings, subsurface pits, and sediment in the drainage
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ditch and tributary. The contaminated area within the
drainage ditch and tributary (approximately 2,800 square
feet) is considered wetland area. The highest levels of
soil contamination are found in the eastern and southwestern
portions of the site which are designated as Area One and
Area Two respectively (Figure 3). Chromium is found in
concentrations on-site ranging from 3.2 parts per million
(ppm) to 2,200 ppm, arsenic from i.o ppm to 451 ppm,
beryllium from 0.22 ppm to 23.5 ppm, lead from 3.4 ppm to
2,060 ppm, PCBs at 10 ppm, aldrin from 0.36 ppm to 7.4 ppm,
dieldrin from 0.15 ppm to 6.3 ppm and 4,4 DDT from 3.0 ppm
to 26 ppm (Table 3). Dioxin contamination above 1 ppb was
not detected under the asphalt cap during confirmatory
sampling. However, if contamination is detected above 1 ppb
during subsequent activities, the contaminated soil would be
remediated.
To characterize the ground water beneath the site, 16 ground
water monitoring wells were installed. Samples were
collected from these wells, the on-site production well and
a nearby residential well. The residential is located
upgradient of the site and no contaminants were found to
exceed MCLs. The results of the analysis (Tables 4 and 5)
demonstrated that the overburden aquifer is contaminated
with benzene, chlorobenzene, 1,2-dichloroethane,
trichloroethene (TCE), aluminum, antimony, arsenic, cadmium,
lead, nickel, and chromium at concentrations which exceeded
the Maximum Contaminant Levels (MCLs) or New Jersey Ground
Water Quality Standards (NJGWQS). MCLs are federal or state
standards devised to protect drinking water and NJGWQS are
state standards devised to protect aquifers. Results of
sampling the bedrock aquifer (Tables 6 and 7) have
demonstrated that the aquifer is contaminated with volatile
organic compounds (VOCs), aluminum, lead, nickel, and
chromium at levels that exceed MCLs or NJGWQS. For example,
chromium was detected at concentrations as high as 17,200
ppb in the overburden aquifer. By comparison, the MCL for
chromium is 100 ppb. Similarly, concentrations of benzene
were found as high as 133.8 ppb. The MCL for benzene is 1
ppb. Most of the contaminant plume is believed to be
contained within the site boundary due to the continuous
pumping of the on-site production well (Figures 4 and 5).
However, it is possible that a portion of the plume is
migrating off site. Additional information on aquifer
characteristics will be collected during the remedial
design.
SUMMARY OF SITE RISKS
Based upon the results of the RI, a baseline risk assessment was
conducted to estimate the risks associated with current and
future site conditions. The baseline risk assessment estimates
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the human health and ecological risk which could result from the
contamination at the site if no remedial action were taken.
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 identified the contaminants of concern at the
site based on several factors such as toxicity, frequency of
occurrence, and concentration; Exposure Assessment estimated
the magnitude of actual and/or potential human exposures, the
frequency and duration of these exposures, and the pathways
(e.g., ingesting contaminated soil) by which humans are
potentially exposed; Toxicity Assessment determined the types
of adverse health effects associated with chemical exposures, and
the relationship between magnitude of exposure (dose) and
severity of adverse effects (response); and Risk Characterization
summarized and combined 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.
For risk assessment purposes, individual contaminants are
separated into two categories of health hazard depending on
whether they exhibit carcinogenic or non-carcinogenic effects.
The contaminants of concern are presented in Tables 1, 2, 4 and
6. For known or suspected carcinogens, current federal
guidelines for acceptable exposures are an individual lifetime
excess carcinogenic risk in the range of 10"4 to 10*, representing
a probability of approximately one in ten thousand to one in one
million that an individual could develop cancer due to exposure.
The non-carcinogenic effects (e.g., toxicity) posed by each
contaminant are summarized as a "Hazard Index" (HI) for a
particular exposure pathway. Only Hazard Indices greater than
one are generally identified with potential adverse health
effects.
EPA uses reference doses (RfDs) to calculate the non-carcinogenic
risk attributable to a particular contaminant. An RfD is an
estimate of a daily exposure level that is not likely to result
in any appreciable risk of deleterious effects during a person's
lifetime. The RfD is employed to calculate a Hazard Quotient
which is defined as the chronic daily intake (GDI) of a chemical
divided by its RfD (CDI/RfD). A list of RFDs is contained in
Table 15. A Hazard Quotient greater than 1 indicates the
potential for adverse effects to occur. When toxic endpoints
and/or mechanisms-of-action of contaminants within the same
medium are similar, Hazard Quotients are added to give a Hazard
Index for the exposure pathway of concern. Similarly, a HI of
greater than 1 indicates the potential for adverse effects to
occur.
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EPA uses a slope factor to calculate the carcinogenic risk
attributable to a particular contaminant. A cancer slope factor
establishes the relationship between the dose of a chemical and
the response and is commonly expressed as a probability of a
response per unit intake of a chemical over a lifetime. A list
of slope factors is contained in Table 15.
Although EPA has established RfDs and slope factors for chemicals
evaluated in the baseline risk assessment, lead currently does
not have an RfD, slope factor or similarly accepted toxicological
parameters. Therefore, lead, which was qualitatively evaluated
independent of the other contaminants of concern, will be
discussed separately from the quantitative baseline risk
assessment.
To evaluate human health risk in the quantitative assessment,
several exposure pathways were selected for detailed evaluation
under both current and future land-use conditions. Under current
land-use conditions, the general exposure pathways evaluated were
incidental ingestion or dermal absorption of soil, inhalation of
fugitive dust and dermal absorption of surface water. A detailed
list of all exposure pathways can be found in Table 16. Under
current land-use conditions, the dominant health risk is posed by
the ingestion of on-site soil and inhalation of fugitive dust
emissions in Area One and Area Two by an on-site worker.
Ingestion of soil poses the greatest carcinogenic risk and is
estimated to be 5x10"* (five in one hundred thousand) in Area One
and 1x10"* (one in ten thousand) in Area Two. The risk is
primarily due to heavy metals and the pesticides aldrin and
dieldrin. The Hazard Index related to ingestion in Area One is 1
and in Area 2 is 4x10"'. The Hazard Index related to inhalation
in Area One is 9x10"' and Area Two is 1 (Table 8) .
Elevated concentrations of lead have been detected in on-site
soils in Area One and Area Two at concentrations above 500 ppm1,
EPA's cleanup policy number. As discussed earlier, lead does not
have an RfD, slope factor, or similarly accepted toxicological
parameters and could not be evaluated in the quantitative
baseline risk assessment. Therefore, the risks posed by lead
have been qualitatively evaluated for site soils. Exposure to
lead has been associated with a wide range of non-carcinogenic
effects in humans. High lead concentrations in the blood can .
cause severe irreversible brain damage and possible death. EPA
1 At the time of the field sampling, the current EPA policy on soil cleanup levels addressing lead
was 500 - 1000 ppm. Subsequently, EPA recomnended the use of the Uptake Biokinetic Model (UBK) as a risk
assessment tool to predict blood lead levels and aid the risk management decision on soil lead cleanup
levels at sites. In order to utilize this model, certain site-specific information must be collected. At
the time this guidance was issued, the RI for the Brook Industrial Park site was past the field
investigation stage and the necessary information to run the UBK was not available. However, when the model
is utilized using default parameters, an acceptable soil level of approximately 400 ppm is predicted for
lead.
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has also classified lead as a "B2" carcinogen, which indicates
that it is considered a probable human carcinogen. With regard
to all exposure scenarios considered in the baseline risk
assessment, it is plausible that the cumulative cancer risk and
Hazard Indices discussed above would be even higher if the
effects of lead were quantitatively included.
In addition, a Hazard Quotient for the non-carcinogenic risk due
to the inhalation of chromium, which was detected in Area One
above acceptable levels, is not taken into account in the
quantitative risk assessment. However, the non-carcinogenic
effects due to the inhalation of chromium were qualitatively
assessed in the risk assessment. The main effect of inhalation
of chromium is irritation of the respiratory track and ulceration
of the nasal septum.
The risk in Area One (5x10"*) and Area Two (1x10") is at the upper
bound of EPA's acceptable risk range, however, the risk due to
lead and chromium is not considered in the calculation of these
risk numbers. As stated above, it is plausible that the
cumulative cancer risk and Hazard Indices would be even higher if
the effects of lead and chromium were quantitatively included.
In addition, contaminants from the soil would continue to migrate
into the ground water which already contains the same
contaminants at levels above MCLs. Therefore, EPA has determined
that the potential risks due to Area One and Area Two are
unacceptable.
The remaining exposure pathways evaluated under current land-use
conditions, which include dermal contact with soils and surface
water, are less than or within EPA's target cancer risk range of
10" to 10"6. The Hazard Indices for these exposure pathways were
below levels of concern.
Under future land-use conditions, the general exposure pathways
evaluated were incidental ingestion and dermal absorption of
soils and ingestion of ground water. A detailed list of exposure
pathways can be found in Table 17. The dominant health risk is
posed by incidental ingestion and dermal absorption of soil from
the Stirling Center basement by a future worker and ingestion of
ground water by future workers. The estimated cancer risk due to
the ingestion of soil is 4xlO'5 (four in one hundred thousand) .
The cancer risk due to dermal absorption is 5xlO'5(five in one
hundred thousand). These risks are primarily due to the PCB
Aroclor-1248 and arsenic. The Hazard Index for ingestion of
soils is 1 and is primarily due to arsenic. The estimated cancer
risk due to ingestion of ground water is 4x10" (four in ten
thousand) for the overburden aquifer .and 7x10" (seven in ten
thousand) for the bedrock aquifer. The risk in the overburden
aquifer is primarily due to the presence of benzene, vinyl
chloride, arsenic and beryllium. The risk in the bedrock aquifer
is primarily due to dieldrin, tetrachloroethene and vinyl
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chloride. The Hazard Indices for the overburden and bedrock
aquifers are 30 and 3, respectively, and are primarily due to
manganese (Table 8).
A qualitative risk assessment was performed for debris piles,
ponded water and building interiors because no established method
exists to evaluate exposure risks. Since the debris piles have
been removed from the site, they no longer pose a risk. Direct
contact with the two shallow ponded water bodies by a
child/trespasser or worker could result in dermal absorption of
dieldrin and octachlorodibenzo dioxin (OCDD). However, the
frequency of contact would be expected to be minimal given the
small size of the water bodies and, therefore, the risks are
likely to be negligible. The chemicals detected on the building
surfaces were detected sporadically and at relatively low
concentrations with the exception of dioxin in the Blue Spruce
Building. Chronic exposure to dioxin could result in an elevated
cancer risk and non-cancer effects.
Ecological Assessment
A four-step process is utilized for assessing site-related
ecological risks for a reasonable maximum exposure scenario:
Problem Formulation a qualitative evaluation of contaminant
release, migration, and fate; identification of contaminants of
concern, receptors, exposure pathways, and known ecological
effects of the contaminants; and selection of endpoints for
further study; Exposure Assessment a quantitative evaluation
of contaminant release, migration, and fate; characterization of
exposure pathways and receptors; and measurement or estimation of
exposure point concentrations; Ecological Effects Assessment
literature reviews, field studies, and toxicity tests, linking
contaminant concentrations to effects on ecological receptors;
and Risk Characterization measurement or estimation of both
current and future adverse effects.
The ecological assessment is summarized as follows:
o The most important potential exposure pathway for
ecological receptors at the site is associated with
chemicals in the sediments and surface water of the
unnamed tributary, the drainage ditch, and the Raritan
River (wetland area). Aquatic animals could be exposed
to the chemicals through direct contact or through
ingestion while feeding.
o Chemical concentrations in on-site surface soils are at
levels that may potentially impact plants and
earthworms. However, on-site habitat for plants and
earthworms is limited because of paved areas and
compacted gravelly soils.
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o The potential exposures to birds and mammals are
estimated to be very limited. The site provides very
limited habitat for birds and mammals that feed on soil
organisms, such as worms, since the site consists
primarily of buildings and paved areas.
Uncertainties
The procedures and inputs used to assess risks in this
evaluation, as in all such assessments, are subject to a wide
variety of uncertainties. In general, the main sources of
uncertainty include:
o environmental sampling and analysis
o environmental parameter measurement
o fate and transport modeling
o exposure parameter estimation
o toxicological data
Uncertainty in environmental sampling arises in part from the
potentially uneven distribution of contaminants in the media
sampled. Consequently, there is significant uncertainty as to
the actual levels present. Environmental sample-analysis error
can stem from several sources including the errors inherent in
the analytical methods and characteristics of the matrix being
sampled.
Uncertainties in the exposure assessment are related to the
estimates of how often an individual would actually come in
contact with contaminants of concern, the period of time over
which such exposure would occur, and in the models used to
estimate the concentrations of concern at the point of exposure.
Uncertainties in toxicological data occur in extrapolating both
from animals and from high to low doses of exposure, as well as
from the difficulties in assessing the toxicity of a mixture of
contaminants. These uncertainties are addressed by making
conservative assumptions concerning risk and exposure parameters
throughout the assessment. As a result, the Risk Assessment
provides upper-bound estimates of the risks to populations that
may be exposed to the contaminants of concern and is highly
unlikely to underestimate actual risks related to exposure.
More specific information concerning public health risks,
including a quantitative evaluation of the degree of risk
associated with various exposure pathways, is presented in the
Risk Assessment Report.
Conclusion
Actual or threatened releases of hazardous substances from the
Brook Industrial Park site, if not addressed by implementing the
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response action selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
REMEDIAL ACTION OBJECTIVES
The following remedial action objectives have been established
for the Brook Industrial Park site:
Reduce risks associated with incidental ingestion of and
direct contact with contaminated soils in Area One, Area
Two, basements and sediments (wetland area)
Reduce risks associated with direct contact with
contaminated building interiors
Reduce potential risks associated with ingestion of the
overburden and bedrock ground water
To achieve the remedial action objective relating to soils, EPA
will utilize the risk-based remediation goals developed for the
Brook Industrial Park site and EPA policy. Remediation goals for
soils were established based on EPA's policy of calculating the
concentration of a chemical which equals a risk of one in one
million (1x10"*) . The goals for chromium (50 ppm), beryllium (1.3
ppm), DDT (17 ppm), aldrin (0.33 ppm) and dieldrin (0.35 ppm)
were calculated using this methodology (Table 3). The
remediation goal for chromium below five feet is based on a risk
of one in one-hundred thousand (500 ppm). These remediation
goals were based on the assumption that the site would continue
to be used for industrial purposes only. If a residential land-
use assumption were used, more stringent remediation goals would
likely result. The remediation goal for arsenic (20 ppm) is
based on the New Jersey State background concentration. The
remediation goals for lead (500 ppm)2 and PCBs (1 ppm) are based
on EPA policy. Because significant contaminant concentrations
are present near the ground water table in some areas of the
site, soil in these areas will be remediated to the water table
(approximately ten feet below ground surface).
The goal for the remediation of the ground water is to restore
the aquifer to promulgated federal and New Jersey MCLs and NJGWQS
(Tables 9 and 10).
At the time of the field sampI ins, the current EPA policy on soil cleanup levels addressing lead
was 500 - 1000 ppm. Subsequently. EPA recommended the use of the Uptake Biokinetic Model CUBIC) as a risk
assessment tool to predict blood lead levels and aid the risk management decision on soil lead cleanup
levels at sites. In order to utilize this model, certain site-specific information must be collected. At
the time this guidance was issued, the RI for the Brook Industrial Park site was past the field
investigation stage and the necessary information to run the UBK was not available. However, when the model
is utilized using default parameters, an acceptable soil level of approximately 400 ppm is predicted for
lead.
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The remedial action objective for the Blue Spruce Building
interiors is to remediate areas of the building where dioxin
contamination is above 1 ppb.
DESCRIPTION OF REMEDIAL ALTERNATIVES
CERCLA, as amended by SARA, requires that each selected site
remedy be protective of human health and the environment, be cost
effective, comply with applicable or relevant and appropriate
requirements (ARARs), utilize permanent solutions and alternative
treatment technologies or resource recovery alternatives to the
maximum extent practicable, and be cost effective. 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. Treatment options (e.g.,
soil washing, biological treatment) were considered during the
development of remedial alternatives; however, they were not
determined to be effective in remediating the contaminants of
concern at the Brook Industrial Park site.
The FS report evaluated five alternatives for remediating the
soil, four alternatives for remediating the building interiors
and three alternatives for remediating the ground water. The
estimated capital cost, operation and maintenance (O&M) cost, and
net present worth cost for each alternative discussed below are
provided for comparison. The estimated construction timeframes
do not include the time needed to procure contracts, negotiate
with potentially responsible parties or to perform the design
work which would vary depending on the alternative. The
implementation timeframe, as discussed under ground water
alternatives, is the time required to achieve remediation goals.
SOIL/SEDIMENT REMEDIATION ALTERNATIVES
Alternative SO-1; No Action
Estimated Capital Cost: none
Estimated Annual O&M Cost: none
Estimated Present Worth Cost: $ 64,500
Estimated Construction Timeframe: none
A No Action alternative is evaluated for every Superfund site to
establish a baseline for comparison of remedial alternatives.
Under this alternative, no further action would be taken to
address contamination at the site. The fence which currently
surrounds the site would remain in place, however, it would not
be maintained. Likewise, access restrictions to the contaminated
Blue Spruce Building would not be maintained. Ground water
contamination would continue to migrate from the site. No
environmental monitoring activities would be performed other than
five-year reviews to determine if contamination has spread. The
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cost estimate presented above includes the cost to perform this
review.
Alternative SO-2; Limited Action
Estimated Capital Cost: $ 62,200
Estimated Annual O&M Cost: $ 33,000
Estimated Present Worth Cost: $536,000
Estimated Construction Timeframe: l to 3 months
Under the Limited Action alternative, no measures would be taken
to remediate the contamination on the site. However, minimal
activities would be carried out to restrict access. This
alternative contains provisions for fence maintenance, warning
signs, and restriction of access to the Stirling Center basement,
tributary, and drainage ditch. Site conditions would be
periodically monitored to evaluate the migration of contaminants
from the site and to monitor the ground water. As with the No
Action alternative, a review would be implemented after five
years.
Alternative SO-3; Asphalt Cap
Estimated Capital Cost: $1,503,000
Estimated Annual O&M Cost: $ 63,400
Estimated Present Worth Cost: $2,354,000
Estimated Construction Timeframe: 3 to 6 months
Capping represents an alternative that utilizes containment with
no treatment. Capping would eliminate exposure to contaminated
soil and reduce the mobility of the soil contaminants by
minimizing precipitation infiltration and subsequent leaching of
soil contaminants into the ground water. For cost estimation
purposes, an asphalt cap with an underlying High Density
Polyethylene (HOPE) liner was selected as the representative
process option for the capping alternative.
Prior to the construction of the cap, contaminated soils would be
excavated from the Stirling Center basement and the subsurface
pits and contaminated sediment would be excavated from the
drainage ditch (wetland area) and relocated under the area to be
capped. The excavated soil in the drainage ditch would be
replaced with clean fill and the wetland area would be
revegetated. A stormwater collection system would be constructed
to collect the increased stormwater runoff.
During construction activities, an air monitoring program would
be implemented to assure that no airborne particulate
contamination migrates off site. Dust suppression and other
appropriate measures would also be undertaken.
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Following the installation of the cap, a long-term monitoring
program, including five-year reviews, would be conducted to
ensure the effectiveness of the remedy. Annual inspections of
the cap and ground water monitoring would be performed.
Alternative SO-4; Stabilization
Estimated Capital Cost: $2,940,000
Estimated Annual O&M Cost: $ 36,300
Estimated Present Worth Cost: $3,481,000
Estimated Construction Timeframe: 6 to 9 months
Under this alternative, contaminated soil would be mixed with
setting agents, such as cement or lime, to form a hard, durable
product on which contaminants would be chemically bound and/or
entrapped in the stabilized mass. Approximately 4,600 cubic
yards of contaminated soils and sediments would be excavated,
stabilized and backfilled. Prior to stabilizing, the
contaminated soils in the Stirling Center basement and subsurface
pits would be excavated as well as the sediments in the drainage
ditch (wetland area). The wetland area would be revegetated. An
asphalt cap would be constructed over the stabilized area to
reduce the infiltration of precipitation into the treated soils.
However, because it is not practicable to cap just those areas,
and to ensure the integrity of the cap, a much larger area would
need to be capped. A stormwater collection system would be
constructed to collect the increased stormwater runoff.
During construction activities, an air monitoring program would
be implemented to assure that no airborne particulate
contamination migrates off site. Dust suppression and other
appropriate measures would also be undertaken.
Following the installation of the cap, a long-term monitoring
program, including five-year reviews, would be conducted to
ensure the effectiveness of the remedy. Annual inspections of
the cap would be performed.
Alternative SO-5; Off-Site Resource Conservation and Recovery Act
fRCRA) Landfill
Estimated Capital Cost: $4,562,000
Estimated Annual O&M Cost: none
Estimated Present Worth Cost: $4,562,000
Estimated Construction Timeframe: 1 to 6 months
This alternative consists of the excavation and off-site
treatment and disposal of approximately 4,600 cubic yards of
contaminated soils and sediments in Area One and Area Two. This
includes contaminated soils in the Stirling Center basement and
subsurface pits as well as sediments in the drainage ditch
(wetland area). The excavated areas would be backfilled with
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clean fill and the wetland area would be mitigated, off-site
shipment of excavated soil and sediments would be by rail cars,
which would require construction of a rail spur. If necessary,
excavated material could also be transported by truck.
During construction activities, an air monitoring program would
be implemented to assure that no airborne particulate
contamination migrates off site. Oust suppression and other
appropriate measures would also be undertaken.
BUILDING INTERIORS REMEDIATION ALTERNATIVES
Alternative BI-1; No Action
The No Action alternative for the building interior surfaces is
presented as Alternative SO-1 under the soils remedial
alternatives. Under that alternative, no measures would be taken
to reduce exposures to the contaminated interior building
surfaces on the site. Although combined with the No Action
alternative for soil, No Action for the interior building
surfaces could be independently selected.
Alternative BI-2; Low Pressure Washing with Surface Sealing
Estimated Capital Cost: $ 244,000
Estimated Annual O&M Cost: $ 3,000
Estimated Present Worth Cost: $ 346,000
Estimated Construction Timeframe: 3 to 6 months
Alternative BI-2 involves surface decontamination of the walls
and floors with a two-part, non-flammable solvent/detergent-based
wash where contamination is present only on the surface. The
contaminated liquid generated would be disposed of off site.
To reduce the possible exposure to subsurface contamination, it
would be necessary to seal the surface with a two-part epoxy
coating. The effectiveness of this technology is highly
dependent on the depth of contamination. The epoxy coating would
require periodic inspection and maintenance to ensure long-term
effectiveness.
Alternative BI-3; Carbon Dioxide (CO,) Blasting with Surface
Sealing
Estimated Capital Cost: $ 332,000
Estimated Annual O&M Cost: $ 3,000
Estimated Present Worth Cost: $ 434,000
Estimated Construction Timeframe: 3 to 6 months
Under this alternative, the building interior surfaces would be
decontaminated using dry ice pellet blasting. Contaminated
concrete and brick removed via this process would be transported
to an off-site RCRA-permitted treatment facility. This
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alternative also includes the sealing of surfaces with a two-part
epoxy coating as described in the previous alternative.
Alternative BI-4; Demolition with Off-Site Incineration/Disposal
Estimated Capital Cost: $1,046,000
Estimated Annual O&M Cost: none
Estimated Present Worth Cost: $1,046,000
Estimated Construction Timeframe: 1 to 3 months
This alternative would include the demolition and removal of the
entire Blue Spruce Building from the site. Walls common to other
buildings would only be removed and replaced if the structural
integrity of the adjacent building would not be compromised.
Since the material could be contaminated with dioxin, it would be
sent to a RCRA-permitted incinerator.
Alternative BI4(A); Demolition with OffSite
Incineration/Disposal
Estimated Capital Cost: $ 907,000
Estimated Annual O&M Cost: $ 3,000
Estimated Present Worth Cost: $1,009,000
Estimated Construction Timeframe: 1 to 3 months
This alternative would be implemented if the structural integrity
of the adjacent building is compromised by removing the common
walls as described under Alternative BI-4. This alternative
would include demolition and removal of the entire Blue Spruce
Building from the site with the exception of the common walls.
Contaminated material would be sent to a RCRA-permitted
incinerator. To reduce the possible exposure to contamination on
the remaining walls, it would be necessary to seal the surface
with a two-part epoxy coating.
GROUND WATER REMEDIATION ALTERNATIVES
Alternative GW-1; No Action
The No Action alternative for ground water is presented as
Alternative SO-1 under the soils remedial alternatives. Under
that alternative, no measures would be taken to reduce exposures
to the contaminated ground water. Although combined with the No
Action alternative for soil, No Action for the ground water could
be independently selected.
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Alternative GW-2r Limited Action
Estimated Capital Cost: $ 62,000
Estimated Annual O&M Cost: $ 33,000
Estimated Present Worth Cost: $ 536,000
Estimated Construction Timeframe: none
Implementation Timeframe: 30 years
This alternative includes a long-term ground water monitoring
program and institutional controls to restrict the use of the
ground water. The monitoring program would consist of annual
ground water sampling over a 30-year period to determine the
movement of the contaminated water. This alternative also
includes five-year reviews.
Alternative GW-3; Ground Water Extraction and Treatment
This alternative includes ground water extraction wells to remove
the contaminated ground water prior to on-site treatment.
Contaminated ground water is present in both the overburden and
bedrock aquifers. It is estimated that a pumping rate of 250
gallons per minute (gpm) would be required to prevent off-site
migration of the contaminated ground water. For purposes of cost
estimation, a ground water model was used to characterize ground
water flow and develop an extraction system. It is estimated
that two extraction wells screened over the entire saturated
thickness of the aquifer would be required to provide the desired
extraction rate. The existing on-site production well would be
considered.in the overall remedial design of the extraction
system. Also, two discharge options, reinjection into the
aquifer and discharge to the Raritan River, were evaluated. A
five-year review would be performed as part of the long-term
monitoring program.
Under this alternative, several treatment options were evaluated
and are presented below:
Alternative GW-3(A); Chemical Precipitation and Air
Stripping/Carbon Adsorption
River Discharge;
Estimated Capital Cost: $ 1,521,000
Estimated Annual O&M Cost: $ 342,000
Estimated Present Worth Cost: $ 5,833,000
Estimated Construction Timeframe: 6 to 12 months
Implementation Timeframe: 30 years
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Reinfection;
Estimated Capital Cost: $ 1,664,000
Estimated Annual O&M Cost: $ 342,000
Estimated Present Worth Cost: $ 5,976,000
Estimated Construction Timeframe: 6 to 12 months
Implementation Timeframe: 30 years
Treatment of extracted ground water would consist of chemical
precipitation to remove inorganic contaminants, followed by air
stripping and carbon adsorption to remove the organic
contamination. The chemical precipitation process produces an
insoluble matrix which adsorbs and coprecipitates heavy metals.
The VOCs are then removed through air stripping which is a mass
transfer process in which VOCs are transferred to air blown in at
the bottom of the tower. The remaining organic compounds would
be treated through carbon adsorption. Environmental monitoring
would be required during the life of the process.
Alternative GW-3fB); Chemical Precipitation and Ultraviolet
(UV)/Oxidation
River Discharge;
Estimated Capital Cost: $ 1,881,000
Estimated Annual O&M Costs: $ 539,500
Estimated Present Worth Cost: $ 8,641,000
Estimated Construction Timeframe: 6 to 12 months
Implementation Timeframe: 30 years
Rein"! ect ion;
Estimated Capital Cost: $ 2,023,000
Estimated Annual O&M Cost: $ 540,000
Estimated Present Worth Cost: $ 8,783,000
Estimated Construction Timeframe: 6 to 12 months
Implementation Timeframe: 30 years
Treatment of extracted ground water would consist of chemical
precipitation to remove inorganic contaminants, followed by
UV/Oxidation to remove the organic contaminants. Chemical
precipitation is described in Alternative GW-3(A). UV/Oxidation
consists of mixing the extracted ground water with metered doses
of an oxidant and exposing the mixture to UV light to form
hydroxyl radicals which eventually break down to carbon dioxide,
water and non-hazardous salts.
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Alternative GW-3fCM; Chemical Precipitation and Biological
Treatment
River Discharge;
Estimated Capital Cost: $ 2,290,000
Estimated Annual O&M Cost: $ 533,000
Estimated Present Worth Cost: $ 8,969,000
Estimated Construction Timeframe: 6 to 12 months
Implementation Timeframe: 30 years
Reinfection;
Estimated Capital Cost: $ 2,432,000
Estimated Annual O&M Cost: $ 533,000
Estimated Present Worth Cost: $ 9,111,000
Estimated Construction Timeframe: 6 to 12 months
Implementation Timeframe: 30 years
Treatment of the extracted ground water consists of chemical
precipitation to remove inorganic contaminants followed by
powdered activated carbon treatment (PACT) to remove organics.
Chemical precipitation is described in Alternative GW-3(A) above.
PACT treatment is a combination of biological activated sludge
and activated carbon treatment.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the NCP, a detailed analysis of each remedial
alternative was performed with respect to the nine evaluation
criteria. This section discusses and compares the performance of
the remedial alternatives under consideration against these
criteria. These criteria were developed to address the
requirements of Section 121 of CERCLA to ensure that all
important considerations are factored into remedy selection
decisions. All selected remedies must at least satisfy the
Threshold Criteria. The selected remedy should provide the best
trade-offs among the Primary Balancing Criteria. The Modifying
Criteria are evaluated following the public comment period.
Threshold Criteria
1. Overall protection of human health and the environment ad-
dresses whether or not a remedy provides adequate protection
and describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment, engi-
neering controls, or institutional controls.
2. Compliance with applicable or relevant and appropriate
requirements fARARs) considers whether or not a remedy would
meet all of the applicable or relevant and appropriate
requirements of other federal and state environmental
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statutes and requirements or provides grounds for invoking a
waiver.
Primary Balancing Criteria
3. Long-term effectiveness and permanence refers to the ability
of a remedial alternative to maintain reliable protection of
human health and the environment over time, once cleanup
goals have been met. It also addresses the magnitude and
effectiveness of the measures that may be required to manage
the risk posed by treatment residuals and/or untreated
wastes.
4. Reduction of toxicity. mobility, or volume through treatment
addresses the statutory preference for selecting remedial
actions that employ treatment technologies that permanently
and significantly reduce toxicity, mobility or volume of
hazardous substances as a principal element.
5. Short-term effectiveness considers the period of time needed
to achieve protection and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation period until cleanup goals
are achieved.
6. Implementability refers to the technical and administrative
feasibility of a remedial alternative, including the avail-
ability of materials and services needed to implement the
alternative.
7. Cost includes estimated capital and operation and
maintenance, and present-worth costs.
Modifying Criteria
8. State acceptance indicates whether, based on its review of
the RI/FS reports and Proposed Plan, the state supports,
opposes, and/or has identified any reservation with the
preferred alternative.
9. Community acceptance refers to the public's general response
to the alternatives described in the Proposed Plan and the
RI/FS report. Responses to public comments are addressed in
the Responsiveness Summary section of this Record of
Decision.
Comparisons
The three categories of contaminated media (i.e., soil, ground
water and building interiors) are evaluated separately utilizing
the above criteria. A comparative analysis of the remedial
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alternatives, based upon the evaluation criteria noted above,
follows.
SOIL/SEDIMENT REMEDIATION ALTERNATIVES
Overall Protection of Human Health and the Environment
Soil Alternative SO-1, No Action, would not provide protection of
human health or the environment or any effective remediation in
the long or short term. Alternative SO-2, Limited Action,
provides minimal protection of human health and the environment
through the maintenance of fencing and implementation of a
monitoring program.
Alternatives SO-3, Asphalt Cap, and SO-4, Stabilization, provide
a limited degree of protection of human health and the
environment. Alternative SO-3, Asphalt Cap, reduces the
possibility of direct contact with contaminated soils and,
therefore, reduces human health risks associated with that
particular exposure pathway. However, the existing contaminated
soil would remain on the site. Alternative SO-4, Stabilization,
also reduces the possibility of direct contact with the
contaminated soils through immobilization and containment.
Although contaminated soil would remain on site under
Alternatives SO-3 and SO-4, further migration of contaminants
into the ground water is reduced by minimizing infiltration and
leaching of contaminants into the ground water. However, because
contaminants are immobilized, Alternative SO-4 is more protective
than Alternative SO-3.
Alternative SO-5, Off-site Treatment and Disposal, is protective
of human health and the environment because contaminants are
removed from the site for appropriate treatment and/or disposal.
Under Alternative SO-5, further migration of contaminants into
the ground water is eliminated. This alternative allows for full
industrial use of the property in the future.
Wetlands would be assessed during design to determine the need
for mitigation measures or restoration if they would be
potentially impacted by remedial action under any of the
alternatives.
Compliance with ARARs
Section 121(d) of CERCLA, as amended, requires that remedies for
Superfund sites comply with federal and state laws and
regulations that are applicable and legally enforceable.
Remedies must also comply with the requirements of laws and
regulations that are not applicable, but are relevant and
appropriate. Applicable requirements are defined as cleanup
standards, standards of control, and other substantive
environmental protection requirements, criteria or limitations
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promulgated under federal or state law that specifically address
a hazardous substance, pollutant, remedial action, location or
other circumstance at a Superfund site. Relevant and appropriate
requirements are defined as substantive environmental protection
requirements, criteria or limitations promulgated under federal
or state law that, while not "applicable" to a hazardous
substance, pollutant, remedial action, location or circumstance
at a Superfund site, address problems or situations sufficiently
similar to those encountered at the Superfund site that their use
is well suited to the particular site.
EPA has divided ARARs into three categories to facilitate their
identification:
Action-specific ARARs are usually technology or activity
based requirements or limitations on actions or conditions
involving specific substances.
Chemical-specific ARARs are usually health or risk-based
numerical values or methodologies used to determine
acceptable concentrations of chemicals that may be found in
or discharged to the environment.
Location-specific ARARs restrict actions or contaminant
concentrations in certain environmentally sensitive areas.
Examples of areas regulated under various federal laws
include floodplains, wetlands and locations where endangered
species or historically significant cultural resources are
present.
Alternatives SO-1, No Action, and SO-2, Limited Action, do not
comply with ARARs or the established remediation goals as shown
in Tables 14 and 3, respectively. Since Alternatives SO-1 and
SO-2 do not meet the threshold requirements of overall protection
of human health and the environment or compliance with ARARs,
they will not be considered further in the evaluation of
alternatives.
Alternatives SO-3, Capping, and SO-4, Stabilization, also do not
comply with established remediation goals, however, these
alternatives prevent direct contact with and migration of
contaminants through containment and/or immobilization. Soil
Alternative SO-5, Off-site Treatment and Disposal, satisfies the
remediation goals established for the site. Alternatives SO-3,
SO-4 and SO-5 would be designed to meet all applicable RCRA
requirements. In addition, Alternative SO-5 would satisfy RCRA
Land Disposal Restrictions. The contaminated soils would be
transported according to Department of Transportation
requirements to an appropriately regulated facility.
Because of the presence of wetlands in the area to be excavated,
wetlands mitigation or restoration requirements would be complied
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with for all alternatives. This determination would be made
during remedial design.
Long-Term Effectiveness And Permanence
Alternative SO-5, Off-Site Treatment and Disposal, has the
highest degree of permanence of all the alternatives since
contaminated soil would be excavated and appropriately treated
and/or disposed of off site, and replaced by clean fill. The
long-term effectiveness of Alternative SO-4, Stabilization, is
less certain than Alternative SO-5 since contaminants remain on
site. This alternative relies on the ability of soil-stabilizing
techniques to permanently immobilize the contaminants and a cap
to protect the integrity of the stabilized product. Continued
maintenance of the cap would be required for an indefinite period
of time. Alternative SO-3, Capping, is the least certain of the
three remaining alternatives because its effectiveness relies
solely on the integrity of the cap. Continued maintenance of the
cap under Alternative SO-3 would be required for an indefinite
period of time.
Reduction of Toxicitv. Mobility, and Volume Through Treatment
Alternative SO-5 reduces the toxicity, mobility and volume of
contaminants through excavation and off-site treatment and/or
disposal of soils with contamination above the site remediation
goals. Under this alternative, all soils classified as a RCRA
hazardous waste would be treated prior to disposal, thereby
reducing the toxicity of contaminated soil. This alternative
also reduces the mobility of contaminants by containing the soils
in a regulated landfill. Alternative SO-4, Stabilization,
involves mixing contaminated soils with binding agents to
immobilize the waste, thereby relying solely on the reduction of
mobility. The long-term stability of the treated waste would
need to be evaluated over time to assure the protectiveness of
the treatment along with periodic maintenance of the cap.
Toxicity is not reduced under Alternative SO-4. Also, this
alternative increases the volume of contaminated material due to
the addition of the binding material. Alternative SO-3, Capping,
uses no form of treatment and relies solely on the ability of the
cap to prevent direct contact and to reduce soil contamination
from further adversely affecting surface water and ground water.
Under Alternative SO-3, toxicity and volume are not reduced.
Short-Term Effectiveness
Alternative SO-3, Capping, involves the least intrusive activity
and, as a result, poses the least threat to workers and the
surrounding community. It is estimated that Alternative SO-3
would take one month to construct. Alternatives SO-4 and SO-5
involve excavation of soil and, therefore, would require measures
to manage a short-term risk due to fugitive dust emissions. The
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construction contractor would be required to implement a health
and safety plan to protect nearby residents and on-site workers.
In addition, Alternative SO-5 involves off-site transportation
which would temporarily increase the amount of truck traffic
during construction, if that method of transportation were used.
Alternative SO-4 requires an estimated three months to construct
and Alternative SO-5 requires an estimated one month to
construct. Under all alternatives, coordination with operating
facilities would be conducted in order to minimize disruptions to
the businesses.
Impleroentability
Alternative SO-3, Capping, is the easiest of the alternatives to
implement and uses commonly available materials and equipment.
The proposed asphalt cap is technically feasible to construct,
however, it would increase the elevation of the site which would
impact the operation of the on-site facilities (e.g., loading
dock facilities). Alternative SO-5, Off-site Treatment and
Disposal, is also easy to implement, provided that existing
landfills continue to be able to receive the waste at the time
the remediation occurs. Alternative SO-4, Stabilization,
although successful in remediating inorganic contaminants, is
more complicated to implement. Pilot-scale testing would need to
be conducted in order to carefully determine the operating
parameters of the system. In addition, the volume of soil to be
placed back on site would be increased by approximately 25
percent of the pre-treatment volume.
Cost
Estimated capital costs, annual O&M costs, total present worth
costs and the implementation timeframes are summarized in Table
11. Present worth costs are based on a 30-year period and a
discount rate of 7 percent.
Alternative SO-3, Capping, is the least costly alternative,
however, it is the only alternative that does not include any
form of treatment. Alternative SO-4, Stabilization, is more
costly than capping, and contaminated soil remains on site.
However, the contaminants are immobilized in the bound material
matrix. Alternative SO-5, Off-site Treatment and Disposal, is
the most costly, however, it is the only alternative that
provides for permanent reduction in toxicity, mobility and
volume.
State Acceptance
The State of New Jersey concurs with the soil remedial actions
which constitute the selected remedy. However, if institutional
controls are not established, the State cannot concur with the
selected remedy for soil.
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Community Acceptance
Issues raised during the public comment period and at the public
meeting held on August 4, 1994, are addressed in the
Responsiveness Summary section of this ROD. Comments received
during the public comment period indicated that the local
residents were generally satisfied with the preferred alternative
for the cleanup of contaminated soil. The PRP community did
indicate a preference for capping the site.
BUILDING INTERIORS REMEDIATION ALTERNATIVES
Overall Protection of Human Health and the Environment
The No Action Alternative, BI-1, is not protective of human
health and the environment. The risk of exposure to contaminated
building interiors would not be reduced by any degree under this
alternative. All other remedial alternatives reduce the current
and future risks associated with direct contact with building
interior surfaces and, as a result, are protective of human
health and the environment to some degree. Alternative BI-2,
Washing/Surface Sealing, and Alternative BI-3, CO,
Blasting/Surface Sealing, use surface sealing as the primary
isolation mechanism. Inspection and maintenance of the sealed
surface would continue for an indefinite period of time to assure
protection of human health and the environment. Alternative BI-
4, Demolition and Off-site Disposal, removes the contaminated
portion of the building, thereby removing the contaminants and
protecting human health and the environment.
Compliance with ARARs
Alternative BI-1, No Action, would not comply with ARARs (Table
14) or the remedial action objective for building interiors.
Alternatives BI-2, Washing/Surface Sealing, and BI-3, C02
Blasting/Surface Sealing, comply with the remedial action
objective of reducing risk due to direct contact, however,
contaminants would remain on site. Alternative BI-4, Demolition
and Off-site Disposal, also complies with the remedial action
objective as well as RCRA regulations for disposal of
contaminated construction debris.
Because the No Action alternative does not meet the threshold
requirements of protection of human health and the environment or
compliance with ARARs, it will not be considered further in the
evaluation of alternatives.
Lonq-Term Effectiveness and Permanence
Alternative BI-2, Washing/Surface Sealing, and Alternative BI-3,
Co2 Blasting/Surface Sealing, remove only the surface
contamination. Both alternatives rely on sealing to prevent
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contact with subsurface contamination. As a result, these
alternatives are effective only if the sealant is maintained and
re-applied periodically. Inspections would need to be conducted
over the lifetime of the building. Alternative BI-4, Demolition
and Off-site Disposal, provides the only permanent remedy.
Reduction of Toxicity. Mobility, and Volume Through Treatment
None of the alternatives employ treatment except for that used
for the disposal of residual, contaminated material or washing
solution, or incineration of the dioxin contaminated building
materials. Alternatives BI-2, Washing/Surface Sealing and BI-3,
CO2 Blasting/Surface Sealing, reduce the toxicity and volume of
contaminants by removing surface contamination. Mobility is also
reduced through containment. Alternative BI-4 reduces the
toxicity, mobility and volume of contaminants through demolition
and off-site treatment/disposal.
Short-Term Effectiveness
Alternative BI-2, Washing/Surface Sealing, and Alternative BI-3,
CO2 Blasting, are expected to take approximately three months to
construct. Alternative BI-4, Demolition and Off-site Disposal,
is expected to take one month to implement. Remediation workers
could be potentially exposed to solvent mixtures during
implementation of Alternative BI-2, and to airborne dust during
implementation of Alternatives BI-3 and BI-4. Personal
protective equipment and dust control practices can be used to
manage the short-term risk.
While there would be some increase in traffic as a result of off-
site disposal of the demolished building materials, coordination
with local authorities would allow the development of safe
transportation measures. Minimal disruption to the operating
facilities is anticipated.
Implementabilitv
All alternatives are relatively easy to implement, use widely
available equipment and materials, and use well-established
methods. However, where the contaminants have penetrated below
the concrete or brick surface, it may be difficult to attain
remediation objectives using the technologies discussed in
Alternatives BI-2, Washing/Surface Sealing, and BI-3, CO2
Blasting, since sub-surface contamination may not be removed.
Cost
Estimated capital costs, annual O&M costs, total present worth
costs and the implementation timeframes are summarized in Table
12. Present worth costs are based on a 30-year period and a
discount rate of 7 percent.
27
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Alternative BI-2, Washing/Surface Sealing, is the least costly
alternative. Alternative BI-3, CO2 Blasting, is not much more
expensive than Alternative BI-2. However, BI-2 and BI-3 provide
for reduction of mobility of contaminants only by containment.
These alternatives would require maintenance for the lifetime of
the building. Alternative BI-4, Demolition and Off-site
Disposal, is the most expensive, however, it provides for
reduction of toxicity, mobility and volume through treatment.
State Acceptance
The State of New Jersey supports the building interiors remedial
action called for by the selected remedy.
Community Acceptance
Issues raised during the public comment period and at the public
meeting held on August 4, 1994, are addressed in the
Responsiveness Summary section of this ROD. Comments received
during the public comment period indicated that the local
residents were generally satisfied with the preferred alternative
for the cleanup of contaminated building interiors. The PRP
community did indicate a preference for sealing the contaminated
building interiors.
GROUND WATER REMEDIATION ALTERNATIVES
Overall Protection of Human Health and the Environment
Alternative GW-1, No Action, does not provide protection of human
health and the environment or any effective remediation of the
contaminated ground water. Contaminated ground water would be
governed by natural attenuation, and may likely spread over a
wider area. Alternative GW-2, Limited Action, relies 'on
institutional controls for the protection of human health. The
risk due to exposure to contaminated ground water is only reduced
by restricting its use as a potable water supply. The Ground
Water Extraction and Treatment Alternative, GW-3, Options A, B
and C, are protective of human health and the environment. This
alternative would reduce contaminant levels in the ground water
to below MCLs or NJGWQS, reduce the non-carcinogenic risks to
acceptable levels, and reduce the carcinogenic risk to below
IXIO'6, thus protecting human health and the environment.
Compliance with ARARs
Alternative GW-2, Limited Action, does not remediate contaminated
ground water or comply with ARARs (MCLs or NJGWQS).
Concentrations of chemicals in the aquifer would continue to
exceed MCLs or NJGWQS. The treated discharge under Alternative
GW-3, Ground Water Extraction and Treatment, would achieve MCLs
or NJGWQS in the aquifer if reinjection is implemented, or
28
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surface water quality standards if surface water discharge is
used, thus complying with chemical-specific and action-specific
ARARs. Under Alternative GW-3(A), all applicable air quality
standards would be met. In addition, any treatment residuals
generated under GW-3 Options A, B and C would be managed in
accordance with ARARs. Also, location-specific ARARs regarding
construction activities in a floodplain would be satisfied.
Because of the presence of wetlands, wetlands mitigation or
restoration requirements would be complied with for Alternative
GW-3.
Since Alternatives GW-1 and GW-2 do not meet the threshold
requirements of overall protection of human health and the
environment or compliance with ARARs, they will not be considered
further in the evaluation.
Loncr-Term Effectiveness and Permanence
Alternative GW-3, Options A, B and C, provides long-term
effectiveness by preventing further migration of the contaminated
ground water and treating contaminated ground water so that the
aquifer would meet ARARs. This results in significant reduction
of risk to human health and the environment. Alternative GW-3
would be consistent with the long-term effectiveness goals for
the site by treating the ground water until MCLs or NJGWQS in the
aquifer are achieved. The estimated timeframe to achieve
remediation goals is 30 years. A long-term performance
monitoring program would confirm the effectiveness of the remedy.
An assessment would be made during the design of the remedy to
ensure that any adverse impacts to the wetland areas would also
be mitigated. If appropriate, some of the treated ground water
could be discharged to the wetland areas to help offset any
dewatering effects created by ground water extraction.
Reduction of Toxicity. Mobility and Volume Through Treatment
Alternative GW-3, Options A, B and C, reduces the toxicity,
mobility and volume of the contaminants of concern through
extraction and treatment of the ground water. The toxicity and
volume would be reduced by treating the ground water until MCLs
or NJGWQS are achieved. The extraction system would be designed
to prevent migration of the contaminant plume during remediation,
thus reducing the mobility of the contaminant plume. The
residual sludge, generated from the chemical precipitation of
inorganic contaminants under GW-3, Options A, B and C, will be
disposed of properly. Under Option A, Air Stripping, there will
be controls in place to prevent an unacceptable release of
contaminants to the environment. Under Option C, the biological
sludge will be disposed of properly.
29
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Short-Term Effectiveness
All treatment options under Alternative GW-3 do not create any
significant short-term, health-related concerns beyond those
associated with normal construction activities. The construction
contractor would be required to implement a health and safety
plan to protect nearby residents and on-site workers. Increased
traffic during construction, and transportation of treatment
residuals, is expected. Under all alternatives, coordination
with operating facilities would be conducted in order to minimize
disruptions to the businesses.
An assessment would be made during the design of the remedy to
ensure that any adverse impacts to the wetland areas are
mitigated.
The construction period for all options under Alternative GW-3 is
estimated to be six months, however, Option GW-3C, Biological
Treatment, requires a treatability study, which increases the
timeframe required for design of the system. It is estimated
that it would take 30 years to achieve MCLs or NJGWQS under
Alternative GW-3.
Implementability
All options under Alternative GW-3 are technically feasible,
however, each alternative differs in the complexity of
implementation. Options GW-3A, GW-3B and GW-3C include chemical
precipitation for the removal of inorganic contaminants. This
technology is readily available and widely used in wastewater
treatment. Option GW-3A, Air Stripping, is the easiest to
implement. Air Stripping is a proven and widely used method for
removing VOCs and is readily available. Option GW-3B,
UV/Oxidation, is an innovative technology that has been used at
industrial sites for the removal of organic contaminants and is
available. Option GW-3C, Biological Treatment, would require
treatability studies to provide design information, verify
removal efficiencies, and determine the size of the unit. Option
GW-3C also generates additional sludge from the biological
treatment unit, which would require disposal. The availability
of the treatment unit is limited.
Discharge to surface water is technically easier to implement
than reinjection ground water due to the relative ease of
maintenance. Reinjection to ground water is also implementable,
however, because of potential operational problems due to
difficulty in recharging the volume of water treated or clogging
of the reinjection wells, additional maintenance may be required.
In addition, placement of the reinjection system upgradient of
the plume may be difficult to implement because of space
limitations.
30
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Cost
Estimated capital costs, annual O&M costs, total present worth
costs and the implementation timeframes are summarized in Table
13. Present worth costs are based on a 30-year period and a
discount rate of 7 percent.
The costs of the three treatment options under Alternative GW-3
are relatively similar, with Option GW-3A being the least
expensive, followed by Option GW-3B. Option GW-3C is the most
expensive. With respect to the discharge options, surface water
discharge may be less expensive and require less maintenance than
reinjection.
State Acceptance
The State of New Jersey supports the ground water remedial action
called for by the selected remedy.
Community Acceptance
Issues raised during the public comment period and at the public
meeting held on August 4, 1994, are addressed in the
Responsiveness Summary section of this ROD. Comments received
during the public comment period indicated that the local
residents were generally satisfied with the preferred alternative
for the cleanup of contaminated ground water. The community did
express some reservations regarding the potential release of VOCs
into the atmosphere. As noted in the Responsiveness Summary,
there will be controls in place to prevent an unacceptable
release of contaminants to the environment.
THE SELECTED REMEDY
After careful review and evaluation of the alternatives presented
in the feasibility study, and consideration of all evaluation
criteria, EPA presented Alternative SO-5, Excavation and Off-site
Treatment and Disposal for soils; Alternative BI-4, Demolition
and Off-site Incineration/Disposal for the contaminated Blue
Spruce Building, which includes Option A if necessary; and
Alternative GW-3(A), Ground Water Extraction, Chemical
Precipitation, Air Stripping and Reinjection for ground water, to
the public as the preferred remedy.
The input received during the public comment period is presented
in the Responsiveness Summary section of this ROD. Public
comments did not necessitate any changes to the preferred
alternatives. Accordingly, the preferred alternatives have been
selected by EPA and supported by NJDEP, as the remedial solution
for the site. This is the final remedy for the site.
31
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The remedy includes the following components:
Soils
o Excavation of soil in Area One and Area Two, the soil
in the Stirling Center basement and the sediment in the
National Metal pits;
o Off-site treatment and disposal of the contaminated
soil;
o Backfilling of the excavated areas with clean fill; and
o Mitigation of the Wetland Area as appropriate.
The remedy and associated cleanup goals for soils were based on
continued use of the property for commercial or industrial
purposes.
Building Interior
o Demolition and off-site disposal of the dioxin-
contaminated material from the Blue Spruce Building;
o Sealing of the common walls if demolition compromise
the structural integrity of the adjacent facilities;
and
o Maintenance of the sealed walls over the lifetime of
the building.
Ground Water
o Installation of ground water extraction wells;
o Treatment of the contaminated ground water by chemical
precipitation and air stripping;
o Reinjection of the treated ground water into the
aquifer (if it is determined during design that
reinjection is not feasible, the treated ground water
would be discharged to the Raritan River); and
o Long-term monitoring which will include five-year
reviews.
While EPA plans to treat the extracted ground water to levels
attaining federal and New Jersey MCLs and NJGWQS, if the
reinjection of treated ground water will be within the zone of
capture of the extraction system, EPA may treat to less stringent
levels. However, the aquifer restoration goal will be to attain
the more stringent of the federal and New Jersey MCLs and NJGWQS.
32
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Some additional activities will be performed during the remedial
design and remedial action phases for the site. These activities
are described below.
o An analysis will be made during the remedial design to
ensure that any adverse impacts to any wetland areas
will be mitigated. If appropriate, some of the treated
ground water could be discharged to the wetland areas
to help offset any dewatering effect created by ground
water extraction.
o Additional ground water information will be collected
during remedial design in order to conduct ground water
modeling to evaluate the hydrologic effects of the
remedy and to design the extraction and reinjection
systems.
o Since the remedial action will occur within the 100-
year and 500-year floodplains, additional floodplain
assessment work will be conducted as necessary.
Contingency Measures
As previously discussed, the goal of the ground water remedial
action is to restore the ground water to the more stringent of
the New Jersey MCLs, Federal MCLs and the NJGWQS. Based on
information obtained during the RI, EPA believes that the
selected remedy will achieve this goal.
It may become apparent, during the implementation or operation of
the ground water extraction system, that contaminant levels have
ceased to decline and are remaining constant at levels higher
than the drinking water standards over some portion of the
contaminant plume. In that case, the performance standards
and/or the remedy may be re-evaluated.
The selected remedy will include ground water extraction for a
period which is presently estimated to be 30 years (but which,
depending upon the degree of contaminant reduction, may
ultimately be a longer or shorter period), during which the
system's performance will be carefully monitored on a regular
basis and adjusted as warranted by the performance data collected
during operation. Modifications may include, but may not be
limited to, any or all of the following:
o Discontinuing pumping at individual wells where cleanup
goals have been attained.
o Alternating pumping at wells to eliminate stagnation.
33
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o Pulse pumping to allow aquifer equilibration and to
allow adsorbed contaminants to partition into ground
water.
o Installing additional extraction wells to facilitate or
accelerate cleanup of the contaminant plume.
During the performance of the long-term monitoring program, EPA
may determine that the remedial action objective has been met.
Periodic monitoring will be used to reassess the time frame and
the technical practicability of achieving cleanup goals.
With respect to soil remediation, if dioxin contamination is
detected above 1 ppb during design or excavation activities, the
contaminated soil would be remediated.
Upon meeting all remedial objectives, or determining that the
site has been sufficiently purged of contaminants so that human
health is no longer threatened, EPA will initiate proceedings to
delete the site from the NPL.
STATUTORY DETERMINATIONS
Superfund remedy selection is based on CERCLA as amended and the
regulations contained in the NCP. Under its legal authorities,
EPA's primary responsibility in selecting remedies at Superfund
sites is to undertake actions that are protective 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 remedy must
comply with ARARs unless a statutory waiver is justified. The
selected remedy must also 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 the hazardous wastes, as their
principal element. The following sections discuss how the
selected remedy meets these statutory requirements for the Brook
Industrial Park site.
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy protects human health and the environment by
removing contaminated soils and the contaminated Blue Spruce
Building and by reducing the levels of contaminants in the ground
water through extraction and treatment of the contaminant plume.
There are few short-term risks associated with the implementation
of this remedy. Where excavation occurs, dust suppression
measures can reduce risk of inhalation of contaminated soils.
While no cross-media impacts are expected from the remedy, any
34
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environmental impacts associated with site-related contaminants
or remedial activities will be addressed in the remedial design.
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS
The selected remedy will be designed to meet all chemical-
specific, action-specific and location-specific ARARs and site-
specific remediation goals. These ARARs and remediation goals
are listed in Tables 14 and 3, respectively.
Chemical-Specific ARARs
The contaminants of concern for the soils will be remediated to
meet EPA risk-based remediation goals or policy remediation
goals. The remediation goals are listed in Table 2. All soils
that exceed these levels will be excavated to the average ground
water table (approximately 10 feet below ground surface). During
excavation, confirmatory sampling will be conducted around the
perimeter of the excavation zone to ensure complete removal of
soils exceeding remediation goals. The soil will be transported
off site for treatment and disposal in accordance with all
applicable RCRA regulations.
The contaminants of concern for the ground water will be
remediated to meet the more stringent of the federal or state
MCLs or the NJGWQS.
Location-Specific ARARs
The soil and ground water remediation will be designed and
constructed to minimize the disturbance of areas identified as
wetlands and to comply with the requirements of Executive Order
No. 11990 for the Protection of Wetlands and the New Jersey
Wetlands Act of 1970. Before initiating remedial activities, an
assessment of the wetlands will be performed to determine the
potential impact of the remedial action. If necessary, a
detailed plan for wetland mitigation or restoration will be
developed. Also, since the site lies in a floodplain, all ARARs
governing construction activities in a floodplain will be met.
The project area is not sensitive to the discovery of cultural
resources. Therefore, no additional investigation is considered
necessary.
Action-Specific ARARs
All contaminated material exceeding remediation goals will be
transported off site in accordance with RCRA regulations to a
properly permitted facility. The construction debris from the
Blue Spruce Building will be segregated, if possible, according
to the level of contamination, for appropriate management.
35
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Dust suppressants and other appropriate control measures will be
used if necessary during soil excavation and building demolition
to minimize dust emissions. Air monitoring will be conducted to
ensure compliance with ARARs.
In order to mitigate risks, a site health and safety plan will be
developed and implemented. This plan will address personal
protective equipment for remediation workers, dust suppressant
mechanisms and operation safety.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
EPA has determined that the selected remedy represents the
maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost-effective manner for the
Brook Industrial Park site. Of those alternatives that are
protective of human health and the environment and comply with
ARARs, EPA and the State of New Jersey have determined that the
selected remedy provides the best balance of trade-offs in terms
of long-term effectiveness and permanence, short-term
effectiveness, implementability and cost, and considering the
statutory preference for treatment as a principal element and
State and community acceptance.'
Preference for Treatment as a Principal Element
By treating the contaminated soils and ground water, the selected
remedy addresses the principal threats posed by the site through
the use of treatment technologies. Therefore, the statutory
preference for remedies that employ treatment as a principal
element is satisfied.
Cost Effectiveness
The selected remedy is cost-effective because it provides the
highest overall effectiveness relative to its cost. The remedy
provides for protection of the human health and the environment.
DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the preferred alternative
presented in the Proposed Plan.
36
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From USGS Bound Brook Quodrangle
Scale in Feet
0 1000 2000 3000 *000 5000 '6000 Quodrongie Location
Figure 1 1
Site Location Map
E^cok Industrial Park
around Brock, NJ
1-2
-------
FIGURE 2
i i i i rT1
0\ V ^«
BROOK INDUSTRIAL PARK SITE
BOUND BROOK, SOMERSET COUNTY, NJ
-------
FIGURE 3
SITE MAP
DEPICTING EXTENT OF SOIL CONTAMINATION
I I I J--
I LjrrrrtrrrS: I . I
I I I I I I
i i i i > t ttt t
CMitfflf nn of NMV McsGy
-------
FIGURE 4
SIT- MAP
OVERBURDEN GROUNDWATER CONTAMINATION CONTOURS
. j
:=t:^^l-l^^-'l-^ I | t~rt \- \
I I I I IX I I I
ContamlnManContauft
NOTE: Contour Mwvtto « 60,100,200,
600,1000,8000,10,000 and 15,000 ppb.
-------
SITE MAP
BEDROCK GROUNDWATER CONTAMINATION CONTOURS
l I I =t
Central RR of New Joncy
^
ContamkwtonCofHoun
NOTE: Contour Mwvato w« 200,900
1000, and 1500 ppb.
n> tao m
ApproidnMl* Soil* ((Ml)
-------
TABLE 1
CHEMICALS DETECTED IN AREA 1 AMD AftEA 2 SURFACE SOIUSEDINEHT SAMPLES (a)
(Unite: Orvanics: ug/k8. Inorganics:
Oteaical
Organic*:
Acetone
Aldrin
Aroelor-125*
Aree tor- 1260
beta-BKC
gaoiM-IMC (Lindane)
Eenzene
enzoic acid
is(2-ethylhexyl)phthalate
ronoforn
2*Butanone
uty Ibenzylphtha late
alpha-CMordane
gawaa-Chlordane
Chlorobenzene
Chi or of era
4. 4 '-ODD
4,4'-DD£
4, 4 '-DDT
Di-n-butylphthalate
Di-n-oetylphthalate
1 , 2-0 i eh Icrobenzene
1,4-Dichlorobenzene
1,2-Diehloroethane
1.2-Dichloroethene (total)
2,4-Dichlorophenol
Oieldrin
Diethylphthtlate
2.4.Di«ethylphenol
Dinethylphthalate
Endosulfan 11
Endosulfan tulfate
Endrin
Endrin ketone
Heptaehlor
Kept ach lor epoxide
Mexachlorocyclopentediene
2*Hexanone
I soph or one
Methoxychler
Mcthylene chloride
4-Hethylphenel
N-Nitrosodiphenylamine
Nitrobenzene
Pentachlorophenol
Phenol
1 . 1 ,2,2-Tetrachloroethane
Tet rach 1 oroethene
Toluene
1,2,4'Trichlerobenzene
1.1,VTrichleroethane
1 . 1 ,2-Trichloroethane
Trichl oroethene
2.4,5-Trichlorophenol
Vinyl chloride
Xylenes (total)
frequency of
Detection (c)
«
...
1 / 12
1 / 12
l"/"l2
1 / 12
S / 9
9/12
...
...
2/12
2/12
1 / 12
...
1 / 12
2/12
2/12
6/12
3/12
1 / 12
3/12
1 / 12
2 / 12
1/10
3/12
...
.*.
1 / 12
1 / 12
1 / 12
1 / 12
...
...
...
1 / 12
...
...
1 / 12
...
...
* / 12
2/12
1 / 12
3/12
...
1 / 12
1 / 12
...
AREA 1
Range of Detected
Concent rat ions
...
406
101
...
0.9
1.0
170 520
120 - 150.000
...
...
5* it?*
100 - 220
190
...
2.0
67 140
30 130
28 340
37 2.460
28
230 2.400
120
9 24
310
36 900
...
.
»
»-*
.
800
3.6
200
120.000
...
...
...
3.0
...
...
92
...
...
...
2 110
1.0 - 2.0
42
1.0 2.0
...
37
...
16
...
Frequency of
Detection (c)
2/11
6/11
...
...
1/10
1/10
...
1/10
7/11
1/11
1/10
2/11
5/11
5/11
*
**
9 / 11
5/10
9/11
3 / 11
3/11
4/11
>4 / 11
2/11
2/8
1 / 11
7/11
1 / 11
1 / 11
2/11
1/10
...
1 / 10
...
...
2 / 11
*»
1 / 11
2/11
4/10
4/11
1 / 11
1 / 11
»..
1 / 11
3/11
1 / 10
2 / 11
iTn
r/"n
3/11
2/10
...
1 / 11
AREA 2
ftange of Detected
Concentrations
11 13
4.9 4,100
»*
»
13
300
...
340
215 130.000
2
20
60 92
11 - 200
17-60
.»
...
37 - 3,100
43 - 400
23 11.000
50 1,000
86 1.400
35 - 775
17 - 150
1 - 590
29.0 - 51
910
17 - 3.600
1,500
37
26 - 150
4
...
68
...
...
3.5 - 540
...
20
16 - 390
15 - 970
1-780
96
90
...
700
81 - 730
3
7 - 38
...
Ill
...
2
4 . 19
53 - 1.000
...
1
See footnotes on the following page.
-------
TABLE 1 (Continued)
CHEMICALS DETECTED IN AREA 1 AMD AJtEA 2 SURFACE SOIL/SEDIMENT SAMPLES (a)
(Units: Organic*: iff/kg. Inorganics: as/kg)
Chaarical (b)
MHs
Aeenaphthene
Aeenaphthylene
Anthracene
Mnzo(a)anthracene
8enzo(a)pyrene
ento(b)fluoranthene
BenzoCkWuoranthene
enzotg.h, i )perylene
Carbazole
Chry»ene
DibenzoCa ,h)anthracene
Oibenzofuran
Fluoranthene
Fluorene
Indeno<1,2,3-cd)pyrene
2-Methy I naphtha lane
Naphthalene
Phenanthrene
^, tmm ^
Fyrene
MODS I PCDFs
1,2.3.4.6,7,8-HpCDD
total MpCSD
OCDD
Inorganics:
Aluminum
Antimony
Arsenic
sat- inn
Beryl I inn
Cadmium
Calcium
Chromium
Cobalt
Copper
Cyanide
Iron
lead
.Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadiin
Zinc
Frequency of
Detection (c)
6/12
8/12
9/12
10 / 12
10 / 12
10 / 12
/ 12
J1
1/12
/ 12
/ 12
10 / 12
8/12
10/12
8/12
7/12
10 / 12
11 / 12
...
«.
...
12 / 12
7/12
12 / 12
12 / 12
10 / 12
7/12
12 / 12
12 / 12
12 / 12
12 / 12
2/9
12 / 12
12 / 12
12 / 12
12 / 12
8/10
12 / 12
12 / 12
6/8
6/9
5 / 12
2/12
12 / 12
9/ 9
AREA 1
Range i
Concei
ISO
24
96
520
290
240
SOS
198
78.S
S50
86
15
570
S3
188
12
1S2
310
55S
1.970
12.5
S
17.7
0.4
1.7
1,470
4.2
4.2
18.9
0.3
8.160
15.1
276
151
0.2
6.5
167
0.4
1.2
61.2
0.3
5.3
14.3
rf Detected
it rat ions
1.100
570
2,300
16,000
11,000
17.000
11,000
7,100
540
14,000
s.ioo
1,000
6,800
1,000
9.500
1.300
1,200
7,900
25,000
-*
18.500
591
149
1,800
2.6
15.4
26,500
300
282
2,370
0.6
191,000
10,700
9,920
1.980
3.4
82.1
2,860
2.4
292
837
0.5
90.3
9.950
Frequency of
Detection (c)
6/11
8/11
8/11
11 / 11
11 / 11
11 / 11
11 / 11
8/11
1 / 1
11 / 11
5/11
5 / 11
11 / 11
7/11
10 / 11
4/11
7/ 11
11 / 11
11 / 11
1 / 2
1 / 2
2/2
11 / 11
3 / 11
11 / 11
10 / 11
10 / 11
6/10
10 / 10
11 / 11
11 / 11
11 / 11
...
11 / 11
10 / 10
10 / 10
11 / 11
9/11
11 / 11
11 / 11
1 / 7
8/10
7/11
...
11 / 11
7/ 7
AREA 2
Range of Detected
Concentrations
53-930
38 - 240
89 2,300
360 4,200
380 4,500
430 - 5,700
440 3,200
210 2.100
71
400 4.000
38 1.000
69 560
640 9.000
46 950
220 2.200
94 - 190
40 1,200
380 - 7,200
590 6.300
0.4
0.4
6.2 7.6
4,110 - 17,000
3.4 - 30.2
6.4 284
37.5 436
0.3 - 79.7
0.9 16.6
1.620 13,800
28.4 - 1,170
7.3 - 140
67.7 - 1,730
...
2,880 116,000
10.2 - 1.590
1.290 10,900
247 5.680
0.2 0.6
12.1 - 910
265 - 1.150
1.2
5.6 - 17.5
123 - 1.300
...
19.4 49.5
80.5 - 5.360
Selected as a chemical of potential concern.
Chemical Mas not detected in any of the saaple* «n thia saaple grouping.
(a) Area 1 consists of sample* Ss-4 through S8-11, tt-19, M-34, and sediment samples SD-5 and »-6; and
Area 2 consists of samples tt-13. tt-17, $8-21 through S8-26. 88-28 and sediment sample* SD-3 and SD-4.
Concentrations reported to three significant figures'.
(b) Chemicals of potential concern fro* on-site surface soil and tributary sediment sample groupings Mere
considered chemicals of potential concern for Group 1 end Croup 2 surface so i I/sediment sanple groupings.
CO The nuieer of samples in which the chemical was detected divided by the total nunber of samples, excluding
those rejected by QA/QC.
-------
TABLE 2
CHEMICALS DETECTED IN SOIL MB SEDIMENT SAMPLES
FROM THE STIRLING CENTER BASEMENT ()
(Unite: Organic*: ug/kg. Inorganics: ag/kg)
Frequency of
Chemical Detection (b)
Organic*:
Acetone
Aroclor-1248
enieic acid
enzyl alcohol
Bis(2-ethylhexyl )ph thai ate
Carbon Disulfide
Chlorobenzene
Chloreaethane
Di-n-butylphthalate
Ethylbenzene
PAH*
Acenaphthene
Anthracene
Benzo(a)anthracene
enzo(a)pyrene
BenzoCbJf luoranthene
enzo( k) f luoranthene
Benxo(g,h,i)perylene
Chrysene
Dibenzo(a,h)anthracene
Dibenzofuran
F luoranthene
Fluorene
IndenoO,2,3-cd>pyrene
2-Nethylnephthalene
Naphthalene
henanthrene
F*yrene
Inorganics:
Aluminum (d)
Antinony
Arsenic
ariun
Beryllium
Cadmium
Celeiin (d)
Chromium
Cobalt
Copper
Cyanide
Iron (d)
Lead
Magnesium (d)
Manganese
Mercury
Nickel
Potassium (d)
Selenium
Silver
Sodium (d)
Vanadium
Zinc
1 /7
1 / 1
s/7
2/7
3/7
1 / 7
1/7
1 / 7
5/7
1 / 7
2/7
5/7
5/7
4/7
5/7
5 / 7
5 / 7
5/7
1 / 7
1 / 7
6/7
2/7
5 /7
1 / 7
* / 7
5/7
5/7
?/7
2/7
7/7
7/7
4/7
* / 7
7/7
7/7
7/7
7/7
2/7
7/7
7/7
7/7
7/7
5/7
7/7
7/7
2/7
7/7
7/7
7/7
7/7
Range of Detected
Concentrations
270
10,000
100-400
580 - 1,200
274 - 2,100
5
5
IS
220-650
1
57-240
57 - 370
210 3,800
180 - 3,300
240 - 2,700
61 - 2,900
260 - 2,800
280 - 4,900
580
130
54 3,700
56 - 290
280 - 2.900
110
52 180
270 - 4,100
230 - 5.500
1.010 - 16,200
7.8 - 12.8
2.3 56.8
65.6 756
0.4 - 1
2.8 - 7.7
1,880 - 18,800
5.1 - 8,380
1.5 16
169 - 2,180
2.5 - 4.9
14,700 - 127,000
6.8 - 3.900
672 - 12,700
78.1 538
0.2 6.1
3.8 - 62.9
179 1,020
1.1 - 1.6
5.3 - 218
108-546
3.7 - 58.4
67.5 3.110
Site Specific
Background CO
B (<11)
«D (<35)
D (<690)
m> <«690>
1.100
BV (<11)
m> (
IB (<11)
m> (<690)
NO (<11)
410
.1.000
3,300
2.300
4,900
4,900
1,100
3,200
310
380
4,800
470
1,100
380
350
4,600
5.600
8,780
8.5
R
103
0.43
5.6
5,500
44.8
15.1
209
R
47,200
429
3,600
515
R
43.T
648
R
«D (<0.9)
1,840
$7.9
305
Selected as a chemical of potential concern. See tut..
KD Not detected in aaaple. Detection liarits ahoMn in parentheses.
() Sanples SCSD-1, SCSD-2, SCSS-1 to SCSS-5. Concentrations reported to three
significant figures.
(b) The nuifeer of sables in Mhich the eheaical MBS detected divided by the total
number of sa*ples. excluding those staples rejected by OA/OC.
(c) Sample SB-1.
(d) Essential nutrient.
-------
TABLE 3
SOIL CONTAMINANTS OF CONCERN
and
REMEDIATION GOALS
CONTAMINANT
CHROMIUM
ARSENIC
BERYLLIUM
LEAD
PCBs
ALDRIN
DDT
DIELDRIN
CONCENTRATION RANGE1
3.2 to 2,200
1 to 451
0.22 to 23.5
3.4 to 2,060
10
0.36 to 7.4
3 to 26
0.15 to 6.3
REMEDIATION GOALS2
50/500*
204
1.3
500J
1
0.33
17
0.35
1. alt concentrations are In parti per Million (ppm)
2. all concentrations are In PPM; alt Remediation goals was developed based on a risk of 10 * using an Industrial exposure scenario
3. The Remediation Goal for Chromium Is based on a risk of 10* (0-5 feet) and 10 *
<5 feet to the water table)
4. The NJOEP has determined that 20 ppm represents the typical background levels for arsenic In Hew Jersey
5. Remediation Goal for lead Is based on EPA guidance
-------
TABLE 4
CHEMICALS DETECTED ID BMUBWATl* SAMPLES FMN THE SATURATED OVEMUtDEK ()
(Units: ug/L)
Frequency of tange of Detected
Chemical Detection (b) On-Site Concentrations
Organ ics:
Acetone
kenzene
alpha-IHC
beta-MC
is(2-ethylhexyl)phthalate
Carbon Bisulfide
Chlorobenzene
2-Chlorophenol
4, 4 '-ODD
1 ,2-DicMorobenzene
1 ,3-Dichlorobenzene
1 ,4-Dichlorobenzene
1,1-Dichloroethane
1,2-Diehloroethane
cis-1,2-Dichloroethene
trans-1 ,2-Dichloroethene
Dieldrin
2,4-Dinitrophenol
Endosulfan I!
Endrin
Ethylbtnzer*
Meptachlor
Tetraehloroethene
Toluene
1,1,1-Trichloroethane
Triehleroethene
2,4,6-Trichlorophenol
Vinyl Chloride
Xylenes (total)
PAHs
Acenaphthene
Fluorene
2-Methylnaphthalene
Naphthalene
Phenanthrene
Inorganics:
Alutninun (d)
Antimony
Arsenic
tar i urn
ierylliufc
Caomiun
Calciun (d)
Chromiun
Cobalt
Copper
Iron (d)
Lead (e)
Magnesium (d)
Manganese
Mercury
Nickel
Nitrite/nitrate
Potassim (d)
Silver
Sodium (d)
Vanadium
Zinc
6/8
6/8
2/8
1 / 8
4/8
4/8
6/8
1 / 8
2/8
6/8
2/8
3/8
2/8
3/8
2/8
6/8
1 / 8
1 / 8
1 / 8
1 / 8
6/8
1 / 8
5/8
4/8
5/8
1 / 8
7/ 8
1 / 8
6 / 8
1/8
1 / 8
2/8
3/8
2/8
8/8
2/8
8/8
8/8
1 / 8
6/8
8/8
8/8
7/8
8/8
8/8
7/7
8/8
8 /8
1 / 8
7/8
2/8
8/8
2/8
8/8
6/8
8/8
4.1 400
3.7 - 134
0.01 0.02
0.04
1 25
0.7 - 3.7
13.1 158
0.02 - 0.03
2.9 9.6
0.1 .4
2.8 - S.I
0.3 0.6
0.4 55.3
0.1 0.6
0.4 35.5
0.4
22
0.03
0.1
0.1 280
0.1
0.3 10.1
0.3 820
0.9 - 21.1
4.7
5 - 8
2.5
0.3 - 113
1
1
2 - 20
1 - 26
2
3.880 63,700
38 - 16$
2.6 43.2
121 - 575
4.3
6 - 9.3
20,100 - 85,800
15.4 - 17.200
14.1 - 62.7
11.4 262
17,100 U6.000
2.6 - 8.6
7.340 - 27.900
1.240 19.600
18.4 - 149
1.000 2.400
4.300 16,100
10.7 - nli
13,900 90,400
21.4 - 171
38.1 435
Site- Specific
Background (c)
1.9
ND (<1)
ND <<0.5)>
MD C^0»5))
ND (<10)
ND (<1>
ND (<1)
ND (<10)
ND (O.10)
ND «1)
ND (<1)
ND («1>
ND (<1)
ND (<1)
ND (<1)
ND «1)
NO «1>
ND «25)
ND (O.10)
ND (<0.10)
ND «1>
ND (<0.05)
ND (<1)
ND (<1)
ND <<1)
ND (<1>
5
ND <<1>
ND (<1)
ND (<10)
ND (<10)
ND <<10)
ND (<10)
ND (<10)
17,300
ND «38)
4.9
185
1.1
ND <<5)
48,500
31.8
24.4
20.1
31.200
4.4
19,900
4.900
ND (<0.2)
41
2.100
8,190
ND «S)
22.700
43.7
78.9
* Selected at chemical of potential concern. See text.
HD * not selected in sanple. Detection liaits shown in parentheses.
(a) Sanples MW-1 to MW-8. Concentrations reported to three significant figures.
(b) The nuifeer of sanples in Mhich the chemical Mas detected divided by the total
nu*»r of tanples, excluding those aacples rejected toy 9A/QC.
(c) Upgradient M0ple NU-9.
(d) Essential nutrient.
It) Lead data are fro* a second round of stapling conducted in Spring 1993.
-------
TABLE 5
BROOK INDUSTRIAL PARK Rl REPORT
SUMMARY OF INORGANICS IN OVERBURDEN GROUNDWATER
Aluminum
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Nickel
Zinc
FEDERAL
MCL
50-200
6
SO
4
5
100
1,300
IS
100
NA
STATE
GROUNDWATER
STANDARDS
200
2
8
20
4
100
1,000
5
100
5,000
NUMBER OF
DETECTIONS/
NUMBER OF
WELLS
9/9
2/9
9/9
2/9
6/9
9/9
9/9
8/8
7/9
9/9
NUMBER OF
DETECTIONS
ABOVE
ARAR
9 .
2
5
1
6
3
0
2
2
0
AVERAGE
DETECTION
18,711
100.5
17.8
2.7
7.9
1,974.3
83.5
4.4
70.1
156.4
RANGE OF
DETECTION
3,880 63,700
38-163
2.6 - 43.2
1.1 - 4.3
6-9.3
15.4 - 17,200
11.4-262
2.6 - 8.6
18.4 - 149
38.1 - 279
All values In ug/l.
NA = Not Available.
-------
TABLE 5
BROOK INDUSTRIAL PARK Rl REPORT
SUMMARY OF VOCs IN OVERBURDEN GROUNDWATER
COMPOUNDS
Benzene
Chtorobenzene
1.2 OCA
Trans-1,2-DCE
Ethylbdnzene
PCE
TCE
Toluene
Vinyl Chloride
Xylenes
FEDERAL
MCL
5
100
6
100
700
5
5
1,000
2
10,000
STATE
MCL
1
4
2
100
NA
1
1
NA
2
44
STATE
GROUNDWATER
CLEANUP
STANDARDS
1
4
2
100
700
1
1
1,000
2
40
NUMBER
OF
DETECTIONS/
NUMBER
OF
WELLS
6/9
6/9
3/9
6/9
6/9
5/9
1/9
4/9
1/9
6/9
NUMBER
OF
DETECTIONS
ABOVE
ARAR
6
6
1
0
0
2
1
0
1
1
AVERAGE
DETECTION
58.6
60.5
18.9
6.9
48.4
2.6
8.8
207.5
2.55
27.1
RANGE OF
DETECTION
3.7 - 133.8
17.7 - 157.7
0.4 - 55.3
0.4 - 35.5
0.1 - 279.8
0.1 - 10.1
8.8
0.1 - 820.3
2.55
0.3-113.3
Ad concentrations In ug/l.
NA = Not available.
-------
TABLE 6
CHEMICALS DETECTED IN SWUKHIATE* SAMPLES
ntOM THE BEDROCK AQUIFER (a)
(Units: ug/L)
Range of
Frequency of Detected On-Site Site-Specific
Chemical Detection (b) Concentrations Background (c>
Organics:
Benzene 1/6 20 HD (<1>
beta-IHC 1/6 0.02 IB («0.05>
BisC2-ethylhexyl>phthal«e 6/6 3-8 1
Carbon disulfide 1/6 0.6 HO (<1)
Chlerobenztne 1/6 11.2 MO (<1)
* 1.2-Dichlorob*nxene 1/6 82.2 IB
1,3-Diehlorobeniene 1/6 0.1 IB
1,4-Dichloroeenzene 1/6 1.4 HD
1.2-Dichloroethane 1/6 21.8 IB
eis-1.2-Dichloroethene 1/6 3.8 HD
trans-1,2-Diehloroethene 4/6 0.1 - 968 HD
Dieldrin 1/6 0.3 HO «0.1>
Tetraehloroethene 5/6 0.4 S44 . 0.4
1.1.1-Triehloroethane 1/6 0.1 MD «1)
Triehlereethtne 1/6 65.1 tt> C<1)
2,4,6-Triehlerophcfwt 6/6 4-6 4
Vinyl chloride 1/6 85.4 HO (<1>
Xylenes (total) 1/6 0.2 » (<1>
Inorganics:
Aluninum (d)
ariun
Calciun (d)
ChromiuRi
Iron (d)
Lead (e)
Magnet iun (d)
Manganese
Nickel
nitrite/nitrate
etassiun (d)
Sod inn (d)
Zinc
6/6
6/6
6/6
3/6
6/6
6/6
6/6
6/6
3/6
5/6
6/6
6/6
6/6
218
69.1
11,000
15.1
38?
2.1
660
12.8
20.6
300
1,210
15,000
8.3
2,340
149
88,300
230
3,980
12.4
23,400
1.060
101
2,800
92,100
55,600
22 7
1,470
368
45,800
249
2.880
2.7
22,900
77
189
4,600
1,670
12.300
18.1
« Selected as a chemical of potential concern. Sec text.
an * net detected in sanple. Detection limits shewn in parentheses.
(a) Samples MV-2RS to MW-5HS. MV-7KS and NV-8RS. Concentrations reported to three
significant figures.
(b) The ruifeer of sanple* in Mhich the chemical Mas detected divided by the total
rxrt*r of sanples, excluding those Maples rejected by QA/QC.
(c) Upgredient sample NV-9RS.
(d) Essential nutrient.
(e) Lead data are frcoi a second round of aaapling conducted in Spring 1993.
-------
TABLE ?
BROOK INDUSTRIAL PARK Rl REPORT
SUMMARY OF VOCs IN BEDROCK GROUNDWATER
COMPOUNDS
Benzene
Chlorobenzene
1,2-DCA
Trans-1,2DCE
Ethylbenzene
PCE
TCE
Toluene
Vinyl Chloride
xyiooos
FEDERAL
MCL
5
100
5
100
700
5
5
1,000
2
10,000
STATE
MCL
1
4
2
100
NA
1
1
NA
2
44
STATE
GROUNDWATER
CLEANUP
STANDARDS
1
4
2
100
700
1
1
1,000
2
40
NUMBER
OF
DETECTIONS/
NUMBER
OF
WELLS
-.:
2/8
2/8
2/8
5/8
0/8
7/8
2/8
0/8
2/8
1/8
NUMBER
OF
DETECTIONS
ABOVE
. ARAR
1
2
2
2
0
5
2
0
2
0
AVERAGE
DETECTION
10.5
7.8
9.7
242.4
NO
88.8
42.4
ND
46.2
0.2
RANGE OF
DETECTION
1 -20
4.3-11.2
16.9-21.8
0.1 - 968.3
ND
0.4 - 544.2
19.6 - 65.1
ND
7 - 85.4
0.2
AH concentrations In ug/l.
-------
TABLE 7
BROOK INDUSTRIAL PARK Rl REPORT
SUMMARY OF INORGANICS IN BEDROCK GROUNDWATER
Aluminum
Antimony
Afsente
Beryllium
Cadmium
Chromium
Copper
Lead
Nickel
Zinc
FEDERAL
MCL
50-200
6
SO
4
5
100
1,300
15
100
NA
STATE
GROUNDWATER
STANDARDS
200
2
a
20
4
100
1,000
5
100
5,000
NUMBER OF
DETECTIONS/
NUMBER OF
WELLS
7/8
0/8
2/8
0/8
0/8
5/8
1/8
8/8
4/8
8/8
NUMBER OF
DETECTIONS
ABOVE
ARAR
7 .
0
0
0
0
4
0
4
2
0
AVERAGE
DETECTION
773.4
ND
1.45
ND
ND
458.8
10.5
5.4
89.3
14.8
RANGE OF
DETECTION
2.8 - 2,340
ND
1.4 1.5
ND
ND
15.1 - 1,650
10.5
2.1 - 12.4
20.6 - 189
8.3 - 22.7
All values In ug/l.
ND - Not detected.
NA - Not available.
-------
TABLE 8
SUMMARY OF POTENTIAL HEALTH RISKS ASSOCIATED WITH THE
BROOK INDUSTRIAL PARK SfTE
Exposure Pathway
Upper Bound
Excess Uetime
Cancer Risk*
Hazard Index for
Noncartinogenic
Effects*
CURRENT LAND USE:
an of Son:
Chad/teenage trespasser (6-16 years) on-site
On-site Worker
ChfldAeenager (6-16 years) at railroad tracks
ChfldAeenager (6-16 year) at the subdivided lot
4E-06
3E-C5
6E-08
3E-06
< 1
< 1
< 1
< 1
Dermal Absorption from Soil Matrix6:
Child/teenager (6-16 years) at railroad tracks
Child/teenager (6-16 year) at the subdivided lot
Ingestion of Sediment from Drainage Ditch/Tributary:
Chad/teenager (6-16 years)
Dermal Absorption from Sediment Matrix in Drainage
Ditch/Tributary:
Chad/teenager (6-16 years)
Ingestion of Soil-Sediment in Area 1 and Area 2:
Worker in Area 1
Worker in Area 2
Dermal Absorption from Surface Water.
ChfldAeenager (6-16 years)
Inhalation of Fugitive Dust Emissions:
On-site Worker
Nearby Child Resident
Nearby Adult Resident
Worker in Area 1
Worker in Area 2
2E-07
5E-07
2E-05
6E-07
5E-05
1E-04
2E-07
6E-06
4E-07
2E-06
1E-05
3E-05
< 1
< 1
< 1
< 1
B 1
< 1
< 1
< 1
< 1
< 1
< 1
See footnotes on next page
-------
TABLE 8 (CONTINUED)
SUMMARY OF POTENTIAL HEALTH RISKS ASSOCIATED WTTH THE
BROOK INDUSTRIAL PARK SITE
Exposure Pathway Upper Bound Hazard Index for
Excess Lifetime Noncarctnogenic
Cancer Risk* Effects*
FUTURE LAND USE:
Soil Ingestion:
Workers at Stirling Center basement 4E-05 * «1
Workers at the Subdivided lot 9E-06 < 1
Dermal Absorption from Soil Matrix6:
Workers at the Stirling Center basement 5E-05 < 1
Workers at the Subdivided lot 1E-06 < 1
Ingestion of On-Site Saturated Overburden Groundwater
Workers 4E-04 > 1 (30)
Ingestion of On-Site Bedrock Aquifer Groundwater
Workers 7E-04 > 1 (3)
Ingestion of Jame Fine Groundwater.
Workers 7E-OS
-------
(nut 40 era
ORGANIC CHEMICALS
AD unlU art mlfflgmfitt per Bv (mg/l)
VOLATILE ORGANIC CHEMICALS
Table 9
CHEMICAL' "" *''x' "'" vA//~~
Benzene*
Carton tetrachloride*
ortho-OichJoroberTzene (1,2)*
pert-Olchlbrobenzene (1,4)*
1,2-Dtehloroethine*
1,1-Oichloroethylene*
cfc-1 ,2-Oichloroethytene*
tmns-1 ^-Dichloroethylene'
Dichloromethane* (Methylene chloride)
li-Oithloropropane*
Eth/benzene*
Monochloro benzene*
Styrene*
Tetrtchloroethylene' (PCE)
Toluene*
1 ^,4-Trichlorobenzene*
1.1.1-TrichIoroethane*
1 ,1 ^-TricWoroethane"
Triehloroethylene (TCE)*
Vinyl chloride*
Xylenes (total)'
^CASNo.'^
71-43-2
66-234
8S-50-1
106-44-7
10746-2
7S4M
166-50-2
156-604
7549-2
7647-5
100-41-4
106-90-7
100-42-5
127-16-4
106464
12042-1
71454
79404
79414
7541-4
1330-20-7
;';i3;HCL/S|&
ft ftQ5
QMS
0.6
0.075
POOS
OJ07
0.07
0.1
0.005
0.005
0.7
0.100
0.1
0.005
.1.0
0.07
0.2
O005
0.005
0.002
10.0
%;l%filCL6: ":§^-:"- ':'.:..
nro
nro
0.6
0.075
urn
CJKS7
0.07
0.1
WO
zero
0.7
0.1
0.1
zero
1.0
0.07
0.2
0.003
Ztro
zero
10.0
-------
PESTICIDES
CHEMICAL r^«fi~*,^
Ataehtor*
Aldiart)'
tid'etrt sufonc*
Ajdicfb sutfoxide*
Awzir*'
Ciffcofuran*
Chfodane*
Djlapon'
Dferomochloropropan«(DBCP)*
Dinoseb*
Dlquat*
Endothall*
Endrin*
Ethytene dibromlde(EDB)'
Glyphosate*
Heptachlor*
HeptachJor epoxide*
Undane*
Melhoxychlor*
OxamylfVydate)*
Pantachlorophenol'
Pidoram*
Simazine*
Toxaphene*
2,4-Dichbrophenoxypropionic acid*
2,4.5-TP(Snvex)'
CAS NO.
15972404
116464
16404M
1646474
1912-244
15046-2
67-74-fl
7S494
96-124
8645-7
85-00-7
145-734
72-204
10643-4
1071434
76-444
1024-574
56494
72-434
23135-22-0
87464
191642-1
122444
800145-2
94-75-7
93-72-1
^IICL *";:>*
0402
0403
0402
0404
0403
044
0402
O2
0,0002
0.007
0420
0.1
0402
040005
0.7
04004
0.0002
04002
0.04
0.2
0.001
0.5
0.004
0.003
0.07
0.05
^lf-'IIClfi"-%:;::-
ttro
0.001
0401
0.001
0.003
0.04
HfO
0^
XtfO
0.007
0.02
0.1
0.002
Ztro
0.7
ztro
ztro
0.0002
0.04
0.2
Ztro
0.5
0.004
ztro
6.07
0.05
2-
-------
SYNTHETIC ORGANIC CHEMICALS
Table 9
CHEMICAL ' '- *"' :h&^np?&»>.- ;~ ;
Benzo(a)pyrene*
Dl(2-ethyJhexyl)adipate*
DI(2^yfhexyt)DhthaJa«"
HtJoehlorobcnztfM*
Hexachlorocydopentadlene (HEX)*
PCBs (ts decachloroblphcnyf)*
2,3.7.8-TCDD Picndn)'
CAS No,
50424
10M3-1
11741-7
118-74-1
7T47-4
1336464
17464)1-6
^siici. >
04)002
0.4
0.006
0.001
04B
0.0005
3E48
;> - ^ilCLO^»:-v=
zaro
0.4
Ztro
xtro
O06
»ro
Z«ro
TREATMENT TECHNIQUES
CHEMICAL -:":::? . ''-..
Acrytemide*
Epichlorohydrin*
DISINFECTION BY-PRODUCTS
:' --CAS No.:;^
7946-1
106494
^u^^m
TT
TT
CHEMICAL
Total Trihalometnanes (TTHMs)t
MCL :.m^
0.10
vH-llCLB
zero
zero
.,^A:"-=:K|C|JO -
TT Trtatment Technique
Total Trihalomethanes (TTHMs) - the sum of the eonetntntions of bfomodiehloromethane.
tribromomethane (bromoform). dibromochloromethane, and trichloromethane (chloroform).
J Final value. Published in Frteml Rtglsttr, Nov. 29,1979.
* Final value. Published in frfen/ Weg/tfer, Jury 8,1987.
#Final value. Published in FvJtnl Ktgisttr. Jan. 30,1991.
IRnal value. Published m Fecfera/ fltg/*f§r, Juhy 1,1991.
Final value. Published in Ftdeml Rtgittir. July 17,1992.
-------
40 CPU - Pan 141, 1M2)
INORGANIC CHEMICALS
AH unit* art mODgrama par Mar (mg/l)
Table 9
CHEMJCAL -' -, TTV -
Antimony*
Arsenic*
Asbestos* (fibers/1 > 10um)
B«riumT
Beryllium*
ddmium*
Chromium (total)*
Copper0
Cyanide*
Fluoride*
Lead (at tap)0
Mercury*
Nickel*
Nltnte (as N)'
Nitrite (as N)'
Total Nitrate* Nitrite (as N)*
Selenium*
Sulfate*
Thallium*
CAS*
74404*0
744048-2
1332-21-4
7440494
7440-41-7
7440-04
7440-C74
7440404
67-124
743942-1
743B474
744042-0
14797454
7782-49-2
7440-284
-1ICL
0406
045
7MFL
2.0
0404
0405
0.100
TT
0-200
44
TT
0402
0.1
104
14
104
045
deferred
0402
Cx~" --tlCLC ;'< ; '
0406
..
7MFL
2,0
0404
0405
0.100
1JOO
O200
4.0
»ro
0402
0.1
10.0
14
10.0
045
dafamid
0.0005
MFL Million Fibers per Liter
TT - Treatment Technique Copper - action (aval 1.3 mg/l
Laad action lavai 0.015 mg/l
4Fmaf value. Published in Facfera/ Register. Nov. 13,1985.
JRnal value. Published in Federal Register. Aprl 2,1986.
*Fma! value. Published in Federal Register. Jan. 30.1991.
Final value. Published in Federal Register. June 7.1991.
tFmal value. Published in Federal Register, Juty 1.1991.
Final value. Published in Federal Register, Juty 17,1992.
4-
-------
NEW JERSEY DRINKING WATEA STANDARDS
(NJJLC. 7:10-1 through 11.12. IMf)
ORGANIC CHEMICALS
An tmiu are mnngnms ptr Mar (mg/l)
VOLATILE ORGANIC CHEMICALS
CHEMICAL - ' " -'<*'- rr^'^''"'
Benzene
Cvbon tetrtehloride
mett-Dtehtorobenzene (1.3)
ontw-Otehlorobenzene (1,2)
pen-DtehJorobenzene (1,4)
1,2-Otehloroethane
1.1
-------
TABLE 10
*> -«, ^
'» * v X*' v ' *
CONSTTTUEKT
3.4-Btnzofluoranih»ne
(Benzo(b)f!uonnthene)
B»nzo(Qhl)perylene
B*flzo(k)fluoranth«ne
Btrydium
alph».BHC (alpha-HCH)
beta-BHC (beta-HCH)
gwrwra-BHC (gamma-HCH/Undane)
§teC2-eh!oroethyf) tther
Bte(2-chJorotsopropyf) ether
Bk^-ethythexyl) phthalate
BromodicWoromethane
(Dichlorobromomethane)
BTO^OTO^TI
Butyfbevyl phthalate
Cadmium
Carbofuran
Carbon tetrachloride
Chlorobenrene
CNordane
CWoride
Chloroform
4-Chloro-3-methyt
(o-ehloro-rtvcresol)
2-CWorophenol
Ohlorpyrtfos
Chromium (Total)
~ ^,^^^f^"" i "M
:^r:-^0 :-£--
^^ASNo.^^
IOS«4
101*24-2
2074M
7440-41-7
3l«*-6
31W5-7
66494
111-444
36638-32-0
11741-7
75-274
75-25-2
8548-7
7440434
156346-2
56-23-5
10840-7
57-744
16887404
67464
5940-7
6S474
291248-2
7440474
-GROUND WATER
"Ic-ouAuhr^f^
?~%fcWTBUA^-
NA
NA
NA
0.000006
0.000006
0,000?
0-0002
0.00003
0.3
0.003
0-0003
0.004
0.1
0.004
0.04
0.0004
0.004
0.00001
250.0
0.006
NA
0.04
0.02
0.1
PRACTICAL »,
-* ^^UAHTrrATioN :>
" IEVELS (PQU) ~^
(L010
CL020
0.002
0,020
0.00002
0.00004
0.0002
0.010
0.010
0.030
0.001
0.0008
0.020
0.002
0.007
0.002
0.002
0.0005
2.0
0.001
0^20
0.020
0,0002
0.010
-------
PESTICIDES
CHEMICAL '::"= ^T -:^[-'^i^^^^
Atoehlor
AJdlcart
AJdiwt aJtone
Aldtearb JfoxkJe
Atmzine '
Carbofuran
Chlordane
Dalapon
Olbromoehloropropane PBCP)
Dinoseb
Diquat
Endothatl
Endrin
Ethylene dibromide (EDB)
Glyphosate
Heptachlor
Heptachior epoxide
Undane
Methoxyehlor
Oxamyl
Pantachlorophenol
Pidoram
Simazine
Toxaphene
2.4-0 (2,4-Dichlorophenoxyaeatic add)
2.4.5-TP (SBvex)
18B724M
11WW
164»«M
1M«70
1012-244
1S6M6-2
E7-74-C
7M&O
96-12-8
M5-7
«»-7
145-73-3
' 72-20-8
10643-4
1071434
76-U-8
1024474
68-80-9
72<43-5
23135-22-0
8746-5
191842-1
122444
00145-2
94-75-7
93-72-1
*c^^^^ilCirf^fi^hr"
0002
0010
OJ002
O004
OOQ3
0.040
0.0005
(L200
0*0002
0.007
0.02
0.1
0.0002
0.00005
0.7
0.0004
0.0002
0.0002
0.04
0.2
0.001
0.5
0.001
0.003
0.070
0.050
-------
TABLE 10 .
NEW JERSEY DRINKING WATER STANDARDS
(NJJLC. 7:10-1 through 1112, ItM)
INORGANIC CHEMICALS
AD uniu art mOQgmms fur Star (mo/1)
CHEMICAL " ^r~~voC"r\ :
Antimony
Arsenic
Asbestos .
Barium
Beryllium
Cadmium
Chromium (total)
Copper
Cyanide
Fluoride
Lead'
Mercury
Nickel
Nitrate (as N)
NItrfte (as N)
Total Nitrate/Nitrite (as N)
Selenium
Suffate
Thallium
' *"?deaiifl/-£ V
7440-364
7440464
1332-21-4
7440494
744041-7
7440434
7440474
7440404
87-124
.
743942-1
7439474
7440424
.
*
14797454
778249-2
.
7440-264
fctote: MFL Million Fibers per Uter wRh fiber length > 10 microns
AL Action Level requiring corrective measures
f* .% S
>3§^t^M_ yt
-------
TABLE -10
"#*- *" ' ' ^
CONSTITUEHT
Ruorine
Ruortte
Foaming agents (ABS/LAS)
fflyphosate
Hardnass (as CaCO*)
Haptaehlor
Haptaehlor apoxkJe
Haxaehlorobenzene
Haaehlorobutadiene
HaxBChlorocydopentadiene
Haachloroethane
Hydrogen suffide
Wtno(l ^.3-cd)pyrene
don
tophorone
LMd (Total)
Malathion
Manganese
Marcury (Tma!)
Mathoxyehlor
Mathyt bromide (bromomathane)
Mathyl chloride (chloromathane)
Mathyl eth/ ketone
^Mathy-4,
-*«fr&^K$
^CASWo/^
6-73-7
16964-4M
»
10710-6
76444
1024-57-3
118-74-1
7-68-3
77^74
67-72-1
7783-OM
193-39-5
7439-B9-6
78-S9-1
743M2-1
121-75-5
743946-5
7439474
72-43-5
74434
74474
78434
6940-7
75-09-2
108-10-1
"-JOHOUND WATER' >";
"^^,-^JUAlflY %&&**"
'^'-M1WU^^
04
t-0
04
0.7
«50mg/l
0^00008
0.000004
040002
0.001
0.05
0.0007
0.02
NA
04
0.1
' 0.005
04
0.050
0402
0.04
0.01
043
04
NA
0402
0.4
-:; r*«AcncAL * :* -
^QUANTITATION ^
;^t£VELS'(PQU) ^
0410
0400
0.0005
HA
10mg/l
04004
04002
0410
0.001
0410
0410
NA
042
0.10
0.010
0.010
0.005
0.006
0.005
0410
0402
0.002
NA
0.020
0402
NA
-------
TABLE : 10
v "> - , -V£
f ^#**" "" A »"^
CONSTtTUEKT
SJbte
Ttfte
TCOD &3,7,6-TeAehiorodIbenzo.p-
dlodn)
1 ,1.1,2-Tmchloroethane
1.1A2-T«tmcNoroethan
TetraeNoroethylene
2&4,6-Tstr»chIorophenoI
ThaWum
Tduene
Total dissolved solids (TDS)
Tonphene
2,4,5-TP (Silvex)
1 ,2,4-Trichlorobenzene
1 .1 ,1 -Trichloroethane
1,1i-TrieWoroethane
Tftehlorocthyfene
2,4,5-TriehlDrophenol
2,4,6-TricNorophenol
Vhyl chloride
Xyltnes (Total)
m&o-Xylenes
oOCylene
Zhe
;?4^ttS';
^^l-v- /> ^
-'^CASHo. ~~>'
14W&-7W
174WK
630-204
79-M-5
127-1M
5640-2
7440-2W)
10&-6&-3
8001-35-2
03-72-1
120-62-1
71-55-5
7940-5
7M1-6
9645*4
8646-2
75-01-4
1330-20-7
NA
NA
7440464
?T«R6UNOWAT1R^^
%£Zjuuun .>'; C 2~
x^wtvv^^UJTgpMA "?s }£&*
ISOJDOO
Nont Objecbomblt
»10*»
0.01
0402
04)004
NA
ggOOS
1.0
600,000
0-00003
0.05
0.009
0.03
0.003
0.001
0.7
04)03
0.00008
0.04
NA
NA
M
MicroblologicaJ criteria*. pr»«llng Stf OrWdng
Radionuslides & Water Act R»gJ«aon»
Turbidity (N.JAC. 7:10-1 ft s«q.)
-v-wuenew.' t,:
yC CWAHT1TAT10N ^;
-LEVELS (POU) : :
64)
NA
CU00001
NA
0.001
0.001
04)10
04)10
0.005
10,000
0.003
04)05
0.001
0.001
04)02
0.001 .
0.010
0.020
0.005
0.002
04B2
0.001
0.030
«WB|
-------
TABLE -10
NJ SPECIFIC GROUND WATER QUALITY CRITERIA
CLASS D"'^f :
Aetntphthene
Aetnapthylene
Acetone
Acroletn
AeryUmWe
Aerylonttrfle
Adipttes
PKethylhexyOadipate)
AJaehlor
Aldiearb sutfone
AJdrin
Aluminum
Ammonia
Anthracene
Antimony
Arsenic (Total)
Asbestos
Atrazine
Barium
Bemo(a)anthracene
Benzene
Benzidine
Benzy Alcohol
Benzo(a)pyrene (BaP)
'/**3&&l3% $^^^~
"*&,% w*'«1>.wv'AX^v'C^S' '' /v ,,
v *"£*$» w-wfitf1* tS-gW; 'ZtZK-
'?&#** ajg^^
SW2-8
208^64
6744-1
107424
7W6-1
107-13-1
103-23-1
15972404
1646484
30940-2
742940-5
766441-7
120-12-7
7440464
744046-2
1332-21-4
1B12-244
7440494
66-554
71-43-2
82-67-5
100414
60424
OROUHD WATER r
XX. X ' <^k» fl A MK* -X-' «->S*e*ts f :
4^dQUAlIIY ~A*fcfe^
K^WTERU^^
0.40
NA
0.70
NA
gnQOOOg
0 000060
HA
0.000*3
0.0020
0.000002
0.200
0.500
2.0
0.002
0X0002
7XlO*l/L>10um
0.003
2.0
NA
0X002
0X000002
2.0
NA
A^^FIUCTJCAL f-,*,\
C^^OUANTITATION "S^
"r 1EVEL8 (PQU) ' '*
0X10
0X10
NA
0X50
NA
0.050
0X06
0.002
0X03
0.00004
0200
0.200
0X10
0.020
0.008
10*f/L>10um
0.001
0.200
0.010 .
0X01
0.050
NA
0X20
-------
TABLE 11
BROOK INDUSTRIAL PARK
SUMMARY OF COST ANALYSIS
SOIL REMEDIATION ALTERNATIVES
V^> ?V AU^NATlvfe:§fc^
- X f. . ' \ ^ . . '*$. V-SV . -
* ;,\"« ^ \V - o^,XsvN"5.5|--\ u^^x;"
:..:>>": "'V^jgHSfti.
SO-1 (No Action)
SO-2 (LlmHed Action)
SO-3 (Asphalt Cap)
SO-4 (Stabilization)
SO-S (Off-She
Treatment/Disposal)
tJAPlfAtCOST 5
NV- * .s ''
w.^tX-W - .. '^ *.... ^ "'"..'
NONE
$62.200
$1,503,000
$2,940.000
$4,562,000
^ ANNUAL oftM1
*-. - > *' ~ i
I % ^ "-
NONE
$33,000
$63,400
$36,300
NONE
PRESENT WOfffif
-; ; (b: » ^;r;
s '^\^ ^ ;% s
$64,500
$536,000
$2,354,000
$3,481.000
$4,564,000
^^NftwdnoN^rS^
~V>,^ , . TIMEFRAMES ,- S--^,^
* u%^ Sj-.^ ,. . .. . f :* " ^^% ^ "%
::. ^ ::^ ^t-^L\r <&x
NONE
1 to 3 months
3 to 6 months
6 to 9 months
1 to 6 months
-------
TABLE 12
BROOK INDUSTRIAL PARK
SUMMARY OF COST ANALYSIS
BUILDING REMEDIATION ALTERNATIVES
ALTERNATIVE
BI-2 (Washing/Surface Sealing)
BI-3 (CO, Blasting)
Bt-4 (Demolition w/ Disposal)
BI-4A (Demolition wHh Disposal)
CAPITAL COST
$244,000
$332,000
$1.046,000
$907,000
ANNUAL O&M
$3,000
$3,000
NONE
$3.000
PRESENT WORTH
(7%) ,
$346,000
$434,000
$1,046,000
$1,009,000
CONSTRUCTION/IMPLEMENTATION
TIMEFRAME
3 to 6 months
3 to 6 months
1 to 3 months
1 to 3 months
-------
TABLE 13
BROOK INDUSTRIAL PARK
SUMMARY OF COST ANALYSIS
GROUNDWATER REMEDIATION ALTERNATIVES
^ '.?: & AlTERrtAtM^I ;
.-. 1 \ '' ss > $ -. * " s\^ £. * ,|
GW-'J (No Action)
GW-2 (Limited Action)
GW-3A (Pump & Treat)
Relnjectlon
GW-3B (Pump & Treat)
Relnjectlon
GW-3C (Pump & Treat)
Relnjectlon
'CAPITAL COST ,
\
NONE
$62.000
$1,664,000
$2,023,000
$2,432,000
ANNUAL O&M
NONE
$33.000
$342,000
$540.000
$533,000
PRESENT WORTH/
, (7^) * - *:;
$64,500
$536.000
$5,976,000
$8,783,000
$9,111,000
: CONSTRUCnOM/lMPLEMENTATlbN
';*>^-% :x tiMeFRAwes, ,\w>< '
NONE
NONE/30 yre.
6 to 12 months/30 yre.
6 to 12 months/30 yre.
6 to 12 months/30 yre.
-------
TABLE 14
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
(APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENT
CITATION
DESCRIPTION
FEDERAL ARARS
Resource Conservation and Recovery Act (RCRA), General
Requirements
RCRA, Identification and Listing of Hazardous Waste
RCRA, Standards for Generators
RCRA, Standards for Transporters
RCRA, Standards for Operators of Hazardous Waste
Treatment, Storage, and Disposal Facilities
RCRA, Land Disposal Restrictions
Safe Drinking Water Act (SDWA), National Primary
Drinking Water Standards
SDWA, National Secondary Drinking Water Standards
Clean Water Act (CWA), Water Quality Criteria
Toxic Pollutant Effluent Standards
40 CFR 260-268, 270
40CFR261 .
40 CFR 262
40 CFR 263
40 CFR 264, 265
40 CFR 268
40 CFR 141
40 CFR 143
40 CFR 131
40 CFR 129
-
Establishes regulations for Hazardous Waste
management.
Establishes procedures for Identification and listing
of hazardous waste.
Establishes procedures for generators of hazardous
waste.
Establishes procedures for transporters of
hazardous waste.
Establishes procedures for hazardous waste
treatment, storage, and disposal.
Identifies hazardous wastes that are restricted from
land disposal.
Establishes health-based standards (Maximum
Contaminant Levels) for public drinking water
systems
Establishes welfare-based standards (Secondary
MCLs) for public drinking water systems
Establishes criteria for surface water quality based
on toxicity to organisms and human health.
Establishes effluent standards or prohibitions for
certain toxic pollutants: aldrln, dieldrin, DDT, endrln,
toxaphene, benzidine, PCBs.
-------
TABLE 14
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
[APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENT
CITATION
DESCRIPTION I
Clean Air Act, National Ambient Air Quality Standards
Federal Criteria, Advisories, and Guidance
Federal Criteria, Advisories, and Guidance
Federal Criteria, Advisories, and Guidance
Executive Order on Roodplain Management
CWA, Regulations on Discharge of Dredged or Fill Material
U.S. Army Corps of Engineers, Nationwide Permit Program
Rivers and Harbors Act of 1899
40 CFR 50
EPA Carcinogen
Assessment Group,
Potency Factors
EPA Risk Reference
Doses (RfDs)
EPA Office of Drinking
Water Health
Advisories
Exec. Order No.
11988
40 CFR 230, 231
33 CFR 330
33 CFR 320-330
Defines levels of air quality adequate to protect the
public health and welfare. Establishes non-
attainment zones with respect to health-based
criteria.
Potency Factors are developed from health effects
assessments on evaluation of the EPA.
RfDs are dose levels developed by the EPA for
non-carcinogenic effects.
Health advisories are estimates of risk due to
consumption of drinking water considering non-
carcinogenic effects only.
Requires federal agencies to evaluate the potential
effects of actions, and to avoid, to the maximum
extent possible, adverse Impacts to a floodplaln.
Prohibits discharge of fill material onto wetlands
without a permit. Preserves and enhances
wetlands.
Prohibits activity that adversely impacts wetlands if
a practicable alternative that has less Impact Is
available.
Establishes a COE permit program for construction
in navigable waters.
-------
TABLE 14
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
[APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENT
CITATION
DESCRIPTION
- 1
Executive Order protecting wetlands
U.S. Fish and Wildlife Service Coordination Act
National Pollutant Discharge Elimination System
Occupational Safety and Health Act
Hazardous Materials Transportation Act
Exec. Order No.
11990
16 USC 661
40 CFR s 6:302(g)
40 CFR 122, 125
29 CFR 1910, 1926,
1904
49 CFR 100-1 77
Requires federal agencies to minimize the
destruction, loss.or degradation of wetlands on
federal property.
Requires consultation with the USFWS when a
federal agency proposes modifications to a water
body.
Requirements for permits for discharges Into
navigable waters.
Regulates worker health and safety, specifies
training requirements, safety equipment, and
procedures to be followed for workers at hazardous
waste operations.
Regulates transportation of hazardous materials.
STATE ARARS
NJ SDWA, MCLs
NJ Water Pollution Control Act (WPCA), Wastewater
Discharge Requirements
NJ WPCA, Groundwater Standards
NJ WPCA, Sealing of Abandoned Wells
NJAC 7:10
A-280 Amendments
NJAC 7:9-5
NJAC 7:9-6
NJAC 7:9-9
Establishes State criteria for drinking water.
Establishes effluent standards for wastewater
discharge.
Establishes State groundwater quality criteria.
Establishes standards for sealing of abandoned
wells.
-------
TABLE 14
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
1 APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENT
CITATION
DESCRIPTION
NJ Water Pollution Control Act, Sludge Quality Criteria
NJ Pollutant Discharge Elimination System (NJPDES)
NJ Water Pollution Control Act, Surface Water Criteria
NJ Air Pollution Control Act, Prohibition of Air Pollution
NJ Air Pollution Control Act, Ambient Air Quality Standards
NJ Air Pollution Control Act, Permitting Requirements
NJ Air Pollution Control Act
NJ Air Pollution Control Act, Control and Prohibition of Air
Pollution by Toxic Substances
NJ Air Pollution Control Act
NJ Air Pollution Control Act, Air Stripping Guidelines
NJAC 7:14-4
Appendix B-1
NJAC 7:14A
NJAC 7:9B
NJAC 7:27-5
NJAC 7:27-13
NJAC 7:27-8
NJAC 7:27-16
NJAC 7:27-17
Memorandum from
William O'Sullivan
(3/23/87)
Memorandum from
Assistant
Commissioner, Tyler
Establishes procedures for management of sludge
generated through water treatment.
Requires permit for surface water discharges. May
provide criteria for discharge concentrations.
Defines surface water classes and establishes
surface water quality-based effluent limitations.
Prohibits emissions that result In air pollution.
Establishes State ambient air quality criteria.
Establishes permit and operating certificate
requirements.
Provides requirements for emissions of toxic
substances
Provides requirements for emissions of toxic
substances.
Information required for air permits must be
submitted for State review, approved equipment
must be used.
Provides criteria for air stripping emissions air
pollution control equipment.
-------
TABLE 14
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
[APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENT
CITATION
DESCRIPTION
NJ Air Permits
NJ Rood Hazard Area Control Act
NJ Wetland Act of 1970
NJ Policy/Procedures for Discharge to Surface Waters
(DSW) from Superfund Sites
NJ Requirements for Groundwater Monitoring
NJ Well Drillers and Pump Installers Act
NJ Noise Control Act
NJ Letter to R.
Palasits,
Elizabethtown Water
Company 6/1 7/85
NJAC 7:13
NJSA 13:9A-1
Memorandum from E.
Post. 11/1/83
NJAC 7:26-9
NJSA 58:4A-5
NJAC 7:29
Provide permit conditions with respect to total flow
rate, emissions rate, and testing.
Establishes permit requirements for construction
and development In floodplalns.
Establishes listing and permitting requirements for
regulated activities.
Provides information required for a Superfund site
DSW permit.
Establishes groundwater monitoring requirements.
Establishes requirements for well and pump
installation.
Establishes criteria for protection of public from
noise from industrial, commercial, public service, or
community service operations.
-------
Table 15
ORAL TOXICITY CRITERIA MR CNEMCALS Of WTEMTIAL CONCERN
ChoBical
QRGAHICS:
Aeenaphthene
Acetone
Aldrin
tenxene
8enxo(a>anttiracene
genzo IK **
thene 2E-02
SE-OS
1E-01
1E-01
4E-02
4E-02
rrene
6E-02
7E-OS (d)
3E-02 (j)
1E-09
1E-02
me 9E-02 (n)
7.35E-03
,4.6- ---
2E»00
4E-04
3E-04
7E-02
SE-03
SE-04 (f)
1E-03 (S)
1E»00
SE-03
3.7E-02 (t)
2E-02
1.4E-01 (k)
SE-03 (I)
3E-04 ()
2E-02
5E-03
5E-03
7E-03 ()
SE-01
3.000
1,000
1.000
...
...
...
...
1
1,000
1,000
100
1.000
...
*ioo
1,000
1,000
1,000
1.000
1,000
3,000
1,000
100
1.000
1.000
3.000
3.000
100
100
3,000
1,000
1,000
1.000
1,000
100
1.000
3
100
10
10
1.000
SOD
500
1
1
1.000
300
3
3
100
3
Target Organ/
Critical
Effect
Liver
Kidney/Liver
Liwr
...
...
Halaise
ForMtoBBch
Liver
Fetotoxicity
Liver
...
Liver lesion*
Liver
Liver
Kidney
Kidney
Liver
HeMtelogical
Liver
Liver
Mortality
Liver /Kidney
Liver /Kidney
lood
Liver
< Rirth weight
Kidney
Reproductive
Liver
Liver
Liver
CMS
Hood Chemist ry
Skin
Increased tf
Hone Observed
Kidney
Kidney
Liver
OS (h)
SI irritation
Myelin deg.
CMS
Source
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
MUST
IRIS
IRIS
IRIS
IRIS
IRIS
EAST
IRIS
IRIS
MA 1967
HA 1987
REAST
IRIS
IRIS
REAST
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
MA 1987
IRIS
BEAST
MA 1987
IRIS
(BUST
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
NEAST
IRIS
IRIS
Slope Height of
Factor/ Evidence
(g/kg-day>-1 Class (b)
1.7E*01
2.9E-02
7.3E-01 CO
7.3E*00
7.3C-01 (c)
7.3E-01 CO
1.8E*00
1. 46-02
1.3E-02
7.3E-02 CO
3.4E-01
7.3E+00 (c)
2.4E-02 (o)
9.1E-02
6E-01
1.6E«01
7.3E-01 CO
7.SE-03
7.7E*00 CP>
1.5E*05 (o)
S.2E-02
1.1E-02
1.1E-02
1.9E»00
...
1.75*00 (e)
4.3E*00
CHS IRIS
CMS IRIS
Kidney MEAST
« Body weight MIS
Selenosis IRIS
Argyria IRIS
one Observed BEAST
load CtMBistry REAST
D
12
A
12
2
2
R2
D
C
82
D
C
2
82
82
D
»
C
C
82 .
C
0
82
D
D
0
82
82
82
D
82
C/B2
0
B2-C
2
A
0
0
A
D
82
»
D
D
82
0
0
D
0
D
D
0
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
KEAST
IRIS
IRIS
IRIS
'!£
NEAST
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
NEAST
ECAO
IRIS
ECAO
IRIS
NEAST
f IjfC
IK**
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
-------
Table 15
INHALATION TOXIC1TT CRITERIA FOR CHEMICALS OF POTENTIAL CONCERN
ChaBical
OR6AHICS:
Aldrin
enzo(a)anthracene
enso(s)pyrene
enxo(b)f luorenthene
lenzo(k)fluoranthene
Chrysene
4.4'-OOT
Oibenzo(a.h)anthracene
Oieldrin
lndeno(1.2,3-c.d)pyrene
PCSs (total)
IMRfiANICS:
Antiaeny
Arsenic
ariua
MrylliUB
ChroaiiiB III
ChroBiun VI
Copper
Lead
HefTCury
Nickel
Silver
Zinc
Chronic Target Organ/
RfC Uncertainty Critical
(ag/aS) Factor (a) Effect Source
..
..
..
..
..
..
..
..
..
5£
..
..
..
..
..
3£
..
..
04 (e)
04
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
Cancer IRIS
Cancer IRIS
000 Fetotoxieity REAST
IRIS
EAST
IRIS
CMS IRIS
SO Mauretoxicity REAST
IRIS
IRIS
IRIS
inhalation Height of
unit Risk Evidence
(ug/e3)-1 Class (b)
4.9E-03 12
.7E-04 (c) 12
.7E-03 12
.7E-04 (c) 12
.7E-04 (c) 12
.7E-OS (c) R2
9.7E-05 (d) 12
*l6E-03 12
1.re*04 (c) 12
2
... ...
4.3E-03 A
... ...
2.4E-03 12
... ...
1.2-02 A
. ...
2
8
. ...
. ... .
0
Source
ItIS
HEAST
HEAST
HEAST
HEAST
NEAST
ItIS
HEAST
ItIS
HEAST
HIS
*
HIS
...
HIS
ItIS
IRIS
...
ItIS
ItIS
ItIS
...
IRIS
(a) Uncertainty factors used to develop reference doses generally consist of aultlples of 10, with each factor represent ins a
specific area of uncertainty in the data available. The standard uncertainty factors include the following:
A 10-fold factor to account for the variation in sensitivity along the eaters of the huaan population;
- A 10-fold factor to account for the uncertainty in extrapolation aniavl data to the case of huajns;
- A 10-fold factor to account for uncertainty in extrapolating froa leu than chronic MOAELs to chronic KMELs; and
A 10-fold factor to account for the uncertainty in extrapolating fro* LOAELs to MAIL*.
Cb) EPA Height of Evidence for Carcinogenic Effects:
DO Hunan csrcinogen based on adequate evidence from huaan studies;
O8 Probable human carcinogen based on inadequate evidence fro*, huaan studies and adequate evidence fro* ania*l studies;
tC] Possible htn»n carcinogen based on liirited evidence fro» aniavl studies in the absence of huaan studies; and
(D) Not classified as to human carcinbgenicity;
(c) The unit risk for benzo(s)pyrene was conservatively used as a surrogate to evaluate carcinogenic PAHs along with the
TEF approach receonended by EPA Region II. See text.
(d) Value based on route-to-route extrapolation.
Ce) value MS derived using ecthodologies not currently practiced by the RfO/RfC workgroup.
NOTE: ItIS « Integrated tisk Information System, May 1, 1993
HEAST Health Effects Assessment Stmary Tables, Annual 1992
Ho information available
CHS « Central Nervous System
-------
Table 16
POTENTIAL rXfOStmr PATHWAYS: CUMWNT LAW)-USB CORDITIORS
Exposure
Medium
Source end Mschenles)
of Rsleai*
Exposure Point
Potential Receptor Exposure Rout*
Pathway Potentially Complete?
IB.
t
Qu
Butfece Soil
odleient
Surface Soll-
Bedtmnt In
Areas I end 2
1'eet spill* and direct
dlecherge ot Maatee to
surface toll
pill* end direct
dlecherge of waetee t*
nurfece toll
Peel pill* Mid direct
rtl (charge at waetee tp
nurfece loll
Aerlet ttensport of
chemlcelc releeeetf dl-
(reetly. te elr during
pest eperetloni er
veielt of «lnd er trehl-
ole etoelon.
llurfeae veter nmoff.
itrmepert of contenlnet-
*d toll, Breundweter
neepeie
Uurtete octet runoff,
Uteneporl ot contwlnet-
ad eoll, iroundweter
neepete
nee Surfece Soil end
aedlaent
On-ilte
OH-elte. Stlrllni
beeeieent
Off-elte. eub-dl*ld-
ed lot
Off-elte, rellroed
trecke
Off-elte drelnege
dltcti/trlbuterir
Rerlten River
Areee 1 end 2 (On-
elte eurfece eoll
end Off-site
drelnege ditch
sediment)
Worker*, child/
t**n«g«r (*-!»
yo*ri> trespeeser
Workers
Chlld/teeneger
U-lt yeere)
CM Id/teeneger
U-U yeere)
ChiId/teen*(er
(*-U yeere)
Chlld/teensier
(«-U yeere)
Workcri.
chlId/teeneger
<».! year*)
trespeiter
Incldentel Ingeetlon,
dermel absorption
Incldentel Ingeetlon,
deneal absorption
Ineldentel Ingeetlon,
darnel ebaorptlon
Incldentel Ingeetlon,
da ratal ebsorptlon
Ineldentel Infection.
denaal ebeorptlon
Incldentel Inseetlon,
danaal ebiorptlon
tneldentel Ingeatlon,
deraial absorption
Tee. Cheeilcels ere present
In on-aIt* aurfece eoll. 81*
companies ere currently oper-
etlni et the alt*, end evi-
dence ot on-alte treipaialng
eilete.
Ro. Beseejent Is not current-
ly «sed by workere or other
Indlvlduete.
Tee. Chesilcels are present
In off-elte surface soil et
the subdivided lot. Thla lot
le accessible to the public.
and la known to be frequented
by locel populetlone princi-
pally as a shortcut.
Tea. Chsailcete are preaant
In surface soils near rail-
toad tracke.
Tea. Chosjlcele detected In
ditch adjaeenl to alt*, and
thle la on etttaetlve pley
aree tot children.
Tea. BOB* chesjlcele detected
In tlver eadlewnt were ele-
vated coMpered to the
upttadlent ssajpla.
Tee. as described for on-site
surtece eoll and drainage
ditch aadlaient.
Rone.
Quantitative.
Quantitative.
Quentltetlve.
Blinlt-
Icent uncertain*
ty essoeleted
with presence ot
ehawlcele end
exposures llkaty
to be low.
Quantitative.
for Incldentel
IngestIon by
workers only
(focuased
eseesssient)
-------
Table 16 - Continued
POTENTIAL EXPOSURE PATHWAYS: CURRENT LAND-USE CONDITIONS
Elpoiur*
Medlue
Surfic* Water
Saute* *nd HechinlM
ot Releeie Bipoeure Point
Spill* *nd ether releei- On-lit* ponded weler
durlns pl*nt op*t*- bodl**
tlon*
8urr*c* w*ter runoff, Olf-*ll* drelnege
tr*n*pori of eonte»ln*t- dltch/trlbutitr
d *oll, wid groundwetor
eeepege
Surleee weter runoff, Off-*lt* drelnage
ttineport of contOBtMt- ditch/tributary
d *oll, «od groundweter
eeepege
Surf*c* weter runoff. Kerltin River
treneport *f eont*»ln*t-
d toll, wd gtoundweter
eepege
Potential Receptor Eipoiure Rout*
Mother*, child/ , Detmel ebeorptlon
teeneger (4-U
feere) tteipeeier
Chi Id/teeneger Deneel btorpilon
(t-U y*ere)
Chlld/t**n*(*r Incident el Ingeetlon
(t-U ***r*>
Chi ld/t*en«ger Ineldentel Ingeetlon,
(t-U yeete) deneel *b*orptlon
Pethwey PotentUlly Complete?
Belli.
Tee. Cheat c*le ere preeent
In ponded Niter.
Te*. ChMileel* d*t*ct*d In
ditch adjicent to *lt* *u>« be
denMlly ibiorbed during w*d*
Ins. Th* ditch 1* en ettree-
11 v* pley *r*« for children.
No. Th* eurfec* weter 1*
hollow.
Te*. Tetrechtoroethene de-
tected In rlv*r.
Method ot Cvelu-
tlon
Quell tetlve.
Ponded «eter
bod lei ere mil
IO eq.lt.) end
contect fre-
qiiency li likely
to be ulnlHel.
Quentltetlve.
None.
None. 8l«nlf-
Icent uncertain-
ty enocleted
with pr*i*nce of
cheeileele end
poiur** likely
to be low.
Oroundw*t*r
Air
Leechlni ot eontnelnet*
fro* eoll with percola-
tion through »*doi* ton*
Into equlfer
Voletlllictlon of choMl-
c*l* fro* urfM* loll.
ubiurfece eoll. build-
ing lurCecei end weitei
On-ilte end
downgredlent well*
On-*lte. off-elte
None
worker*, child/ Inheletlon
teeneger trei-pm-
er, neerby resi-
dent*
Mo. Ho on-fit* or
downgredlent w«t*r *upply
well* e«lil. Local drinking
weter obtelned fro* the
Rerlten River, et en
upgredlent location.
Tee. VoletII* coMpound* were
detected In *oll boring* end
In loll gei *MpU*.
Ron*.
Rone. No vola-
tile chenlceli
were ulected
chenleele of
concern beeed on
toilclty-con-
centretlon
ecreen. Sewil-
voletlle ehe«l-
cell were pitei-
ent et low ton-
cent ret I oni *nd
therefore will
not reeutt In
Ignflcent Inhi-
letlon Inpiel*.
-------
Table 17
ADDITIONAL rOTCNTIAL EXPOSURE PATHWAYS: rUTURB UMD-USE COW) IT IONS
Cipoaur* Ne-
dlue
Source end Mechanic*)
ot Raleaaa
Cipoaure taint
Potential Reeep-
tor
Exposure Rout*
Pettmar Potentially Canute? B**l*.
Method of
Evaluation
Surface Soil
P«it ipllla end direct
dlechergo ol Mattel to
urtec* coll
Peat apllU and direct
dlecherge of weataa to
aurfaca toll
On-alta. Stirling
baawaent
Otf-alta. aubdlvldad
lot
Mocker*
Horkera
Incidental Ingeatlon,
danaal abaorptlon
Incldentel tngeetlon.
denial abaorptlon
Surface Hater Oroundwatar aaepege
Oroundwater
Air
Leeching of contan-
Inanta (roa> eoll with
percolation through
vadoaa tone Into aqul-
Car
On-alte. Stirling
beaaatent
On-alte well*, J*
Fine veil
Morkara
Morkera
Incidental Ingeatlon,
dermal abaorptlon
Ingeitlon
fee. Cheatlcale detected In Stirling Quantitative.
baaaaMnt aoll.
Tea. Chaeilcali detected In eolle of Quantitative.
the aubdlvldad lot and en office/
construction equipment atorage build*
Ing haa been propoaed for thle lend.
Thla property la unattractive for
realdentlal davalopatant became It la
bordered by too railroad tracke and
contalna power tinea.
Tea. Low eonoentretton of chanleala None.
detected In aurfaca water, and Infre-
quent contact will reault In negligi-
ble rlake.
Tea. Cheeilcala preaent In on-alte Quantitative.
annltorlng well*.
Duet during eonatrue- On-alte/off-alte Worker*, nearby Inhalation Tee. Cheaiteele detected In aoll. An
lion and Industrial reeldente offlce/conitructlon equlpiMnt atorag*
operattona/trafflc building hae bean propoaed on the
aubdlvlded lot. and portlona of thla
area have been cleared In the prepa-
ration of construction.
Nona, leeaua
no aubaurface
aoll aaoplee
were collect*
at aubdlvlded
lot. Inautfl-
clent data la
available to
aaaeaa thla
eipoaure. It
la unlikely
thet eonatrue
tlon will oc-
cur on alt*.
-------
RESPONSIVENESS SUMMARY
FOR THE
BROOK INDUSTRIAL PARK SITE
BOUND BROOK, SOMERSET COUNTY, NEW JERSEY
I. INTRODUCTION
This Responsiveness Summary provides a summary of public comments
and concerns regarding the remedial investigation and feasibility
study (RI/FS) report and the Proposed Plan for the Brook
Industrial Park Superfund site. It also provides the U.S.
Environmental Protection Agency's (EPA's) responses to those
comments. EPA has selected a final remedy for the Brook
Industrial Park site after reviewing and considering all public
comments received during the public comment period.
EPA held a public comment period from July 22, 1994 through
August 20, 1994 to provide interested parties with the
opportunity to comment on the RI/FS reports and the Proposed Plan
for the Brook Industrial Park site. In addition, EPA held a
public information meeting to discuss the remedial alternatives
described in the RI/FS report and to present EPA's preferred
remedial alternatives for cleaning up the site. The meeting was
held at the Bound Brook Memorial Library on August 4, 1994 at
7:00 p.m.
In general, the community responded positively to EPA's Proposed
Plan. A majority of the residents recognized the importance of
remediating the contamination at the Brook Industrial Park site
and supported EPA's preferred remedy. However, the potentially
responsible parties did not fully support EPA's preferred remedy.
The next section of this Responsiveness Summary provides a
comprehensive summary of major questions, comments, concerns and
responses, by summarizing oral comments raised at the public
meeting, written comments submitted during the public comment
period and EPA's responses.
The last section of this Responsiveness Summary includes
appendices which document public participation in the remedy
selection process for the site. There are five appendices
attached to this Responsiveness Summary. They are as follows:
Appendix A: The Proposed Plan that was distributed to the
public for review and comment;
Appendix B: The public notices which appeared in The Courier
News and the Bound Brook Chronicle;
Appendix C: The public meeting transcript;
Appendix D: The written comments received by EPA during the
public comment period; and
-------
Appendix E: The index to the administrative record developed
for the site.
II. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS. COMMENTS. CONCERNS
AND EPA'S RESPONSES
ORAL COMMENTS RECEIVED AT TEE PUBLIC MEETING
This section summarizes oral comments raised at the public
meeting and EPA's responses. The comments and corresponding
responses are presented in the following categories:
1.0 Remedial Investigation/Feasibility Study
2.0 Risk Assessment
3.0 EPA's Proposed Plan
4.0 Cleanup Schedule/Cost
5.0 Other
1.0 Remedial Investigation and Feasibility Study
1.1 Comment: A representative of a PRP asked if EPA knew how the
New Jersey Transit Railroad tracks were kept free of weeds.
Response: EPA has no knowledge of New Jersey Transit's weed
control practices. However, EPA collected five surface soil
samples along the railroad tracks located to the north of the
site. These samples were analyzed for herbicides. The only
compound detected was octachlorodibenzo dioxin (OCOD). Based on
EPA's risk assessment for the site, OCDD did not pose an
unacceptable risk at the railroad tracks.
1.2 Comment: A representative of a PRP commented that OCDO was
detected near the railroad tracks and that high energy can cause
OCDD to dehalogenate to 2,3,7,8 TCDD.
Response: OCDD was detected near the railroad tracks but at
levels that did not present an unacceptable risk. Furthermore,
the likelihood of high energy in the soil is minimal.
1.3 Comment: A representative of a PRP asked about the presence
of heavy metals along the railroad tracks.
Response: EPA did not sample for heavy metals along the railroad
tracks. However, samples taken on the northern border of the
site did not reveal the presence of lead or chromium at levels
above EPA's remediation goals.
-------
1.4 Comment: A representative of a PRP asked if EPA studied the
"canal" that runs along the southern boundary of the site.
Response: EPA sampled the "canal" (referred.to as the drainage
ditch in the RI/FS report and Proposed Plan) that runs along the
southern boundary of the site. A surface water sample was
collected at the point where a storm sewer discharges into the
drainage ditch. No volatile organic compounds (VOCs) and only
low concentrations of inorganic contaminants were detected.
1.5 Comment: A representative of a PRP asked if pesticides were
generated on site and if the drainage ditch or area along the
river were sampled for pesticides.
Response: The Blue Spruce Company, which operated on site in the
1970s, was a pesticide manufacturing facility. EPA sampled the
drainage ditch and tributary which run along the southern border
of the site. One sediment sample was found to contain a
pesticide of concern above remediation goals.
1.6 Comment: A representative of a PRP asked what the source of
contamination is and if contamination has migrated.
Response: EPA believes that contamination is a result of on-site
operations by several companies that have been identified as
PRPs. Results of sampling have shown that contamination has not
migrated off site.
1.7 Comment: A resident asked if the concentration of
contaminants in the ground water could increase during the "dry
season" and would this increase the risk.
Response: EPA did not estimate the effects of seasonal
fluctuations of precipitation on the concentration of
contaminants in the ground water. The effect on the degree of
risk was not estimated. However, EPA does not believe that
normal variation of precipitation would significantly affect the
concentration of contaminants in the ground water.
1.8 Comment: A resident questioned whether the site is
contaminated.
Response: Analysis of samples collected from many different media
revealed the presence on contaminants in the soil, ground water
and Blue Spruce Building at levels that pose an unacceptable
long-term threat to public health and the environment.
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1.9 Comment: A representative of a PRP asked how monitoring well
9RS could be contaminated with chromium.
Response: Although chromium was detected in monitoring well 9RS
at levels above the Safe Drinking Water Act Maximum Contaminant
Levels (MCLs), the concentration was significantly less than the
chromium level found in the on-site production well. The
mechanism by which well 9RS was contaminated has not been
established. Chromium was not found to be above MCLs in
upgradient residential wells.
1.10 Comment: Several residents asked if the contamination has
spread to the off-site monitoring wells and if any private wells
could be affected by the contamination spreading off site.
Response: Three contaminants were detected in an off-site
monitoring well at levels above MCLs. However, all private wells
that EPA has knowledge of are upgradient of the site and,
therefore, are unlikely to be affected by the site. In addition,
the analysis of samples taken from a residential well
approximately one-quarter mile upgradient from the site did not
show any contaminant above MCLs.
1.11 Comment: A resident asked why it took five years to conduct
the RI/FS.
Response: Initially, EPA was denied access to the site. Access
was granted only after EPA issued a unilateral administrative
order which demanded access to the site. This denial of access
was responsible for a substantial delay. In addition, the RI/FS
conducted at the Brook Industrial Park site was quite extensive.
EPA sampled many different media and collected many samples.
Once the samples were collected and analyzed, the analysis was
subjected to an extensive quality assurance process.
1.12 Comment: A resident asked if any buildings on site other
than the Blue Spruce Building are contaminated.
Response: The soil in the Stirling Center basement is
contaminated as well as the sediment in the National Metal pits.
These areas would pose a risk if a worker were exposed to the
soils or sediments daily on a long-term basis. Therefore, those
areas will be remediated.
1.13 Comment: A representative of a PRP stated that Blue Spruce
did not occupy a number of buildings on site.
Response: EPA records indicate that Blue Spruce occupied more
than one building on site.
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2.0 Risk Assessment
2.1 Comment: A representative of a PRP asked for an explanation
of chronic daily intake.
Response: The chronic daily intake (CDI) represents the
reasonable maximum amount of exposure to a site-related
contaminated medium (e.g., soil). It is a function of the
magnitude (e.g., amount of soil ingested per day), frequency
(e.g., number of days per year), and duration (e.g., number of
years) of exposure.
2.2 Comment: A representative of a PRP asked how a person can
ingest soil.
Response: The main route for ingestion of soil by adults is
through hand-to-mouth activity.
2.3 Comment: A resident asked for an explanation of risk, what
the degree of risk posed by the site is, and if there is a danger
to the surrounding community.
Response: The term "risk" refers to an individual's probability
of an adverse effect (e.g., cancer) occurring. The purpose of
the risk assessment is to estimate the long-term threat due to
exposure to the site. The risks presented in the Proposed Plan
and the Record of Decision (ROD) are based on a 25-year worker or
30-year residential exposure scenario and deal with chronic
toxicity. EPA looks at the cumulative effect of chronic exposure
to a chemical rather than a single acute dose. If an immediate
risk is present at a site, such as an exposure to a single acute
dose, that site would be addressed through an emergency response
action. This site poses a long-term risk resulting from daily
exposure to site contaminants. Also, the risk assessment has
indicated that the site currently does not pose an unacceptable
risk to the surrounding community.
2.4 Comment: A resident asked how accurate the risk calculations
are, if EPA is confident that the risk actually exists, and if
there is a scientific basis for the calculations.
Response: The actual risk calculations are based on EPA's risk
assessment guidance which utilizes the best available science.
For example, slope factors, which establish the relationship
between the dose of a chemical and the response, are generally
based on extrapolation of animal data and on human epidemiology.
These factors are subject to very rigid criteria and a peer-
review process before EPA adopts them for use in its risk
assessment process. Of course, the procedures and inputs in the
risk assessment, as in all risk assessments, are subject to a
variety of uncertainties. However, these uncertainties are
addressed by making conservative assumptions concerning risk and
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exposure parameters and, as a result, it is highly unlikely that
actual risks related to exposure have been underestimated. The
risk calculations for Brook Industrial Park are based on results
of site-specific sampling data; therefore, EPA is confident in
stating that the site poses a risk to human health and the
environment.
2.5 Comment: A representative of a PRP asked how a person can
drink the water that is contaminated and how much a person would
have to consume to increase their cancer risk by seven in ten
thousand.
Response: The current access to the ground water is the on-site
production well and EPA based its assessment on consumption of
the ground water by an on-site worker. A standard assumption of
one liter a day for 25 years was used in the risk assessment to
arrive at a risk of seven in ten thousand. Additionally, there
is currently no prohibition to the installation of potable wells
on the site.
2.6 Comment: A representative of a PRP asked what areas of the
Stirling Center pose the risk and whether the risk calculation
was based on someone working in the basement for 25 years.
Response: Exposure to contaminated soils in the Stirling Center
basement was determined to pose a risk to a future worker.
Standard industrial exposure assumptions were used to calculate
the risk posed by the soils to someone working in the basement
over a 25-year period.
2.7 Comment: A representative of a PRP asked if the risk due to
soil contamination in the Stirling Center basement is based on
ingestion of the soil and if inhalation increases the risk.
Response: The risk to workers in the Stirling Center basement is
based on ingestion of soil. Inhalation of hazardous substances
would increase the risk to workers.
2.8 Comment: A representative of a PRP questioned the conclusion
of EPA's ecological assessment.
Response: The results of the ecological assessment were
threefold. First, the most important potential exposure pathway
for ecological receptors at the site is associated with chemicals
in the sediments and surface water of the unnamed tributary, the
drainage ditch, and the Raritan River (wetland area). Aquatic
animals could be exposed to the chemicals through direct contact
or through ingestion while feeding. These areas would be
remediated as part of Area One and Area Two. Second, chemical
concentrations in on-site surface soils are at levels that may
potentially impact plants and earthworms. However, on-site
habitat for plants and earthworms is limited because of paved
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areas and compacted gravelly soils. Lastly, the potential
exposures to birds and mammals are estimated to be very limited.
The site provides very limited habitat for birds and mammals that
feed on soil organisms, such as worms, since the site consists
primarily of buildings and paved areas.
2.9 Comment: A resident asked if this site is as bad as Times
Beach or Love Canal where EPA evacuated the sites. The resident
also asked if the companies on site can continue to operate.
Response: This site is not similar to Times Beach or Love Canal.
It does not need to be evacuated.
2.10 Comment: A resident expressed some concern about risks to
companies operating on a Superfund site.
Response: The risk posed by the site is a long-term risk, not an
immediate threat.
2.11 Comment: A representative of a PRP asked if there is an
immediate danger posed by the site. The representative also
asked if capping the dioxin was what EPA refers to as the removal
action.
Response: The immediate threat due to the dioxin contamination
was addressed by EPA through removal actions. Currently, EPA
believes that no other immediate threat remains. The removal
actions already taken at the site consisted of limiting access to
the dioxin contamination by capping the contaminated area and
securing the Blue Spruce Building.
2.12 Comment: A representative of a PRP asked if EPA's "lack of
action" means that the site poses no danger to the community or
workers.
Response: The site currently does not pose a threat to off-site
areas or residents. With respect to workers, the risk posed by
the site is a long-term risk, not an immediate threat. EPA
addressed the immediate threat of the dioxin through capping the
contaminated area in 1983 and securing the Blue Spruce Building
in 1991.
2.13 Comment: A representative of a PRP commented that he
believes the risk posed by the site is based on miscalculations.
Response: The risk estimates are based on the results of actual
data analysis and are calculated based on EPA guidance using
standard industrial use assumptions.
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3.0 Proposed Plan
3.1 Comment: A representative of a PRP asked how the chromium in
the ground water was going to be removed.
Response: The chromium and other inorganic contaminants will be
removed using chemical precipitation as part of the ground water
extraction and treatment program.
3.2 Comment: A resident questioned whether air stripping the
ground water to remove organic contaminants would result in
releasing VOCs into the atmosphere.
Response: If it is determined during design that the level of
VOCs in the air emissions will exceed allowable levels, they will
be captured by carbon and disposed of properly.
3.3 Comment: A resident questioned the concentration of organics
in the vapor discharged during air stripping.
Response: The concentrations of VOCs in air emissions from the
air stripper will be estimated during the design of the remedy
and will be verified during initial unit testing. If it is
determined during design that the level of VOCs in the air
emissions will exceed allowable levels, they will be captured by
carbon and disposed of properly. VOC concentrations will be
monitored during the operation of the treatment system as part of
a long-term monitoring program.
3.4 Comment: A resident commented that he was not happy with the
air stripping alternative to address organic contamination in the
ground water due to the potential discharge of organics to the
atmosphere and would prefer Alternative GW-3(B), Chemical
Precipitation and Ultraviolet (UV)/Oxidation.
Response: EPA appreciates the resident's concern, however, EPA
believes that air stripping can be safely implemented and is a
proven technology for treating organic contamination in the
ground water. If it is determined during design that the level
of VOCs in the air emissions will exceed allowable discharge
levels, the organics will be captured by carbon and disposed of
properly. While Alternative GW-3(B), Chemical Precipitation and
UV/Oxidation, would also be effective in treating the organic
contamination, it was estimated to cost almost $3 million more
than the air stripping alternative. Therefore, EPA believes air
stripping is the best alternative for addressing the organic
contamination in the ground water.
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3.5 Comment: A representative of a PRP asked what would happen to
the demolished building material.
Response: The material will be taken off site for appropriate
disposal and treatment as necessary.
3.6 Comment: A resident asked what portion of the building would
be removed.
Response: Only the contaminated portion of the building which was
occupied by the Blue Spruce Company will be demolished. This
portion of the building is currently vacant.
3.7 Comment: A resident asked if the Blue Spruce Building is the
only one to be demolished.
Response: The vacant Blue Spruce Building is the only building to
be demolished.
3.8 Comment: A resident asked what will happen to the
contaminated soil after it is transported off site.
Response: The contaminated soil would be transported to a
facility that is licensed to accept the waste. The soil would
then be treated, if required, at the facility prior to disposal.
4.0 Cleanup Schedule/Cost
4.1 Comment: A resident and a representative of a PRP voiced
concern about maintenance costs not being included in the
$12 million cost estimate.
Response: The $12 million cost estimate is a present worth cost
estimate which includes all maintenance costs associated with the
remedy for a 30-year period.
4.2 Comment: Residents asked who will pay for the cleanup and who
will benefit, i.e., would EPA pay contractors to conduct the
action, and what role PRPs have in the cleanup process.
Response: It is EPA's policy to first offer the PRPs the
opportunity to conduct the cleanup. If the PRPs refuse, EPA may
order them to perform the cleanup or fund the cleanup and seek
reimbursement of costs from the PRPs at a later date.
4.3 Comment: A resident asked if funds were available to conduct
the cleanup at the site.
Response: Annual funding of the Superfund program is subject to
Congressional Appropriation and EPA cannot predict the
availability of funds. However, historically, funds have been
available for all sites ready to begin construction activities.
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4.4 Comment: A resident asked if there is anything that would
stop or delay EPA in moving forward with cleanup of the site.
Response: Although EPA hopes to move forward as quickly as
possible, there are several things that could delay cleanup of
the site. First, Superfund is currently up for reauthorization.
Second, although unlikely, funding may not be available when the
action is ready to begin. Lastly, any litigation regarding the
site may delay cleanup. All three of these occurrences could
delay cleanup.
4.5 Comment: A resident asked when the construction would begin.
Response: Construction will not begin until the remedial design
is completed which would likely be several years away. There are
several steps that EPA takes before starting construction. First,
EPA offers the PRPs the opportunity to conduct the work. If the
PRPs do not accept this offer, EPA would may proceed using
federal funds. If the PRPs offer to conduct the work, EPA and
the PRPs would proceed to negotiate a consent decree. This
consent decree would then go through a public comment period
before it becomes effective. The next step would be to design the
remedy. Since the design for the building remediation would
probably be the easiest, the building remediation might begin
first. The ground water would take the longest to design;
therefore, this phase of construction would probably occur last.
4.6 Comment: A resident asked how long it will take before the
site is clean.
Response: The site would be considered clean after all
remediation is completed. EPA estimates that the soil and
building remediation can be completed six months from the start
of the remedial action. Construction of the ground water
extraction and treatment system is estimated to take one year
from the start of remedial action. The operation of the ground
water treatment system will be ongoing for approximately 30
years.
4.7 Comment: A representative of a PRP voiced a concern about the
accuracy of EPA's cost estimates.
Response: EPA's cost estimates are based on the best available
data and are used primarily for comparison between the
alternatives. All cost estimates will be refined during design.
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5.0 Other
5.1 Comment: Representatives of a PRP asked several questions
regarding re-evaluating the site's eligibility for inclusion on
the National Priorities List (NPL).
Response: All requests regarding a re-evaluation of the site's
eligibility for inclusion on the NPL have been referred to the
office in EPA Headquarters responsible for the NPL-listing
process.
5.2 Comment: A representative of a PRP asked how much money EPA
has spent on the RI/FS.
Response: As of July 1994, EPA expended $1,946,590 on the RI/FS
under the ICF work assignment.
5.3 Comment: A representative of a PRP commented that EPA's
reports did not indicate that anyone was asked if the heavy
metals of concern were ever produced on site.
Response: Through EPA's search for PRPs, several companies were
identified that used the contaminants of concern found on the
site. Such PRP-search information is not included in RI/FS
reports.
5.4 Comment: A representative of a PRP asked how much EPA spent
on securing the Blue Spruce Building.
Response: EPA.spent approximately $75,000 on the two emergency
response actions to secure the Blue Spruce Building.
5.5 Comment: A representative of a PRP asked what the land could
be used for in the future.
Response: Although EPA cannot predict future land use, EPA's risk
assessment was based on an assumption that the land would
continue to be used for industrial purposes only.
5.6 Comment: A representative of a PRP asked if the site was
correctly evaluated.
Response: This RI/FS was conducted in accordance with EPA
guidance and the National Oil and Hazardous Substances Pollution
Contingency Plan, and provided EPA with sufficient information to
evaluate alternatives and select a remedy.
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5.7 Comment: A representative of the PRP asked why it took EPA 10
to 14 years, with three studies to get to this point in the
process.
Response: EPA's involvement in the site began in 1983 when dioxin
was discovered in the Blue Spruce Building. EPA addressed the
immediate threat posed by the dioxin contamination through a
removal action in 1983. Subsequently, the site went through the
NPL ranking process which ended with it being included on the NPL
in 1989. In 1989, EPA initiated the RI/FS to determine the long-
term threat posed by the site. This process was delayed when a
PRP denied EPA access to the site.
5.8 Comment: A resident asked if written comments would be
accepted after the public meeting.
Response: EPA indicated that written comments or questions would
be accepted following the public meeting through August 20, 1994.
Responses to those comments or questions are included in this
Responsiveness Summary.
5.9 Comment: A resident asked if EPA would take no action if the
contamination on site was below EPA cleanup criteria and there
was no risk. Would it be turned over to some other group?
Response: If contamination on the site did not exceed cleanup
criteria and the risk was in the acceptable range, EPA would not
take an action under the Superfund'program. However, the Brook
Industrial Park and the companies operating there would still be
subject to other environmental laws. EPA and the state would be
responsible for enforcing provisions of those laws.
5.10 Comment: A resident asked if NJDEP would perform another
study if the site were turned over to NJDEP.
Response: There are no current plans to transfer the lead for the
site to NJDEP. However, if that were to occur, NJDEP would
utilize EPA's data and make a determination at that time if any
additional information would be required to be obtained under an
additional study.
5.11 Comment: A resident asked when the Superfund law is due to
be reauthorized.
Response: Funding under the current legislation expires September
30, 1994. New legislation is now before the Congress.
5.12 Comment: A resident asked when the final report would be
finished.
Response: The final RI and FS reports were issued in July 1994.
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5.13 Comment: A representative of a PRP asked what companies
other than Blue Spruce were cited for poor housekeeping
practices.
Response: National Metal Finishings Corporation and Jame Fine
Chemicals Incorporated were also cited for various violations by
NJDEP.
5.14 Comment: A representative of a PRP asked if any remediation
had been done other than capping the dioxin-contaminated area.
Response: Two additional removal actions have been conducted to
secure the Blue Spruce Building.
5.15 Comment: A representative of a PRP asked if any
contamination has been removed.
Response: No contamination has been removed, however, the
objective of this ROD is to select a remedy to remediate the
site.
5.16 Comment: A representative of a PRP asked if the U.S. Air
Force is considered a PRP.
Response: EPA considers the U.S. Air Force to be a PRP.
5.17 Comment: A representative of a PRP asked if Blue Spruce was
operating when EPA became involved in the site in 1983.
Response: According to EPA records, Blue Spruce was not operating
on site when EPA became involved in the Brook Industrial Park.
5.18 Comment: A representative of a PRP asked if EPA knew when
Jaroe Fine Chemicals Incorporated was cited for poor housekeeping
and if it was prior to 1983.
Response: According to EPA's records, Jame Fine was cited by
NJDEP for environmental violations between 1980 and 1986.
5.19 Comment: A representative of a PRP asked if EPA knew when
National Metal was cited for poor housekeeping practices and if
it was prior to 1984.
Response: According to EPA's records, National Metals was cited
by NJDEP in 1982 for improper discharging of plating waste to the
subsurface pits. National Metal was ordered by NJDEP to cease
discharging to the pits and to perform a hydrogeological study.
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5.20 Comment: A representative of a PRP asked if EPA was aware of
any environmental violations subsequent to 1984.
Response: According to EPA's records, Jams Fine was issued a
Notice of Violation by NJDEP in 1986 for improper housekeeping
and documentation procedures.
5.21 Comment: A representative of a PRP commented that a fund of
$100,000 was established to perform the cleanup of Blue Spruce
which was known at that time to be contaminated with pesticides.
The person also commented that EPA did not allow cleanup of the
contamination to proceed.
Response: According to EPA records, the settlement which
addressed pesticide contamination was reached before dioxin was
discovered. At that point, the cleanup was suspended and the
site turned over to EPA to address the dioxin contamination. The
immediate threat due to the dioxin contamination was addressed by
EPA through a removal action. Subsequently, the Brook Industrial
Park site was listed on the NPL and EPA conducted the RI/FS to
determine the nature and extent of contamination. This ROD sets
forth the remedial action selected to address the long-term
threat posed by the site.
5.22 Comment: A representative of a PRP asked if EPA was aware of
the system of wells installed by the owner of the site under the
direction of NJDEP.
Response: EPA was aware of the existence of wells, which were
properly sealed by EPA during the RI/FS.
5.23 Comment: A representative of a PRP asked if EPA was aware
of the owner's plan and that EPA instructed the owner and NJDEP
to put the plan on hold.
Response: EPA is not familiar with "the plan" and is not aware
of any direction to suspend work.
5.24 Comment: A representative of a PRP asked if EPA has higher
authority than NJDEP. The representative also asked if NJDEP
were to use the $100,000 in escrow to clean up the site, if EPA
would no longer be involved.
Response: EPA and NJDEP work as partners in the Superfund
program. Brook Industrial Park is a federal-lead site, meaning
that EPA has ultimate responsibility for addressing the
contamination. Therefore, NJDEP would not conduct an action at
the site without EPA agreement. Finally, the $100,000 in escrow
would be insufficient to remediate the site.
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5.25 Comment: A resident asked if the owners would be compensated
for the loss of the Blue Spruce Building.
Response: Since the owners are considered to be PRPs, they would
not be compensated for the loss of the Building. However, they
would essentially be left with an area that could be rebuilt.
5.26 Comment: A representative of a PRP commented that ICF
Technologies won a bid in 1986 to perform the RI/FS at Brook
Industrial Park. The representative also commented that he did
not receive a response to a Freedom of Information Act (FOIA)
request which asked for copies of losing bids.
Response: ICF was utilized under an Alternate Remedial
Contracting Strategy (ARCS) contract. A work assignment for the
RI/FS was issued to ICF under the ARCS contract in 1989. With
respect to the FOIA request, an interim response was submitted,
pending a final response.
5.27 Comment: A representative of a PRP commented that EPA began
testing at Brook Industrial Park in 1979 or 1980.
Response: EPA has no indication of any involvement with Brook
Industrial Park before dioxin was discovered in 1983.
5.28 Comment: A representative of a PRP commented that EPA left
drums of "toxic waste" on site for an extended period of time.
Response: The drums referred to contained RI waste which was
generated as a result of extensive soil and ground water
sampling. The drums were stored on site until arrangements were
made for proper disposal. The drums were removed from the site
in 1992.
5.29 Comment: A representative of a PRP commented that National
Metal never used lead or arsenic.
Response: In its search for PRPs, EPA determined that National
Metal used lead and Blue Spruce used arsenic trioxide.
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WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
This section summarizes the written comments received during the
public comment period. The comments and corresponding responses
are presented in the following categories:
1.0 Proposed Plan
2.0 Other
1.0 Proposed Plan
1.1 Comment: Representatives of several PRPs stated that EPA
proposed unnecessary remediation on a site that posed no risk to
the surrounding areas and an almost undetectable risk to 70 on-
site workers. The representative also stated that no action or
limited action is appropriate for this site.
Response: The site does not, at this time, pose an unacceptable
risk to the surrounding areas, however, it does pose an
unacceptable risk to on-site workers. EPA has proposed
remediation of those areas of the site which exceed EPA's
acceptable risk levels as well as certain areas which are within
the Agency's acceptable risk range. EPA determined that
remediation of areas within the acceptable risk range is
necessary since these areas are also contaminated with lead and
chromium, two contaminants which EPA cannot quantitatively
evaluate in its risk assessment. Inclusion of these contaminants
would increase the quantitative value of the risk posed by the
site.
1.2 Comment: A representative of a PRP questioned why the
Proposed Plan did not discuss the 1983 settlement with NJDEP nor
the 1982/1983 remediation plan. The representative also
questioned why the Proposed Plan did not provide a comparison of
the 1983 remediation plan with the current remediation plan.
Response: The purpose of the Proposed Plan was to present a
summary of the results of EPA's RI/FS and proposed remediation
alternatives to the public. The Proposed Plan was not meant to
contain an extensive history of the site. That information is
contained in the RI report which is part of the Administrative
Record for the site. The 1983 remediation plan cannot be
compared to the current alternatives since the 1983 plan was
developed before the full extent of contamination of the site was
known.
1.3 Comment: A representative questioned why the map contained in
the Proposed Plan identified only Blue Spruce, National Metal and
Stirling Center.
Response: The map was provided as a reference to the areas of the
site to be remediated. It was not meant to depict all companies
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operating on site or those parties which are considered by EPA as
PRPs.
1.4 Comment: A representative of a PRP commented that the
Proposed Plan failed to discuss the results of the Focused
easibility Study (FFS).
Response: The purpose of the Proposed Plan was to present a
summary of the results of the RI/FS and EPA's proposed
remediation alternatives to the public. The results of the
FFS report were used by EPA in developing alternatives for
remediating the Blue Spruce Building. This is reflected in the
1994 FS report which is part of the Administrative Record for the
site.
1.5 Comment: A representative of PRP asked why EPA did not
consider letters from the U.S. Air Force in 1984 and the Federal
Centers for Disease Control in 1983 which stated that no further
sampling of the site was needed.
Response: These letters addressed only the dioxin contamination
and not the threat posed by other contaminants. EPA cannot
develop and evaluate alternatives for a particular medium until
the nature and extent of contamination is known.
1.6 Comment: A representative of a PRP questioned why there was
no mention of the 1986 written agreement in the Proposed Plan.
Response: The purpose of the Proposed Plan was to present a
summary of the results of the RI/FS and EPA's proposed
remediation alternatives to the public. The Proposed Plan was
not meant to.contain an extensive history of the site. That
information can be found in the Administrative Record for the
site.
1.7 Comment: A representative of a PRP asked why there was no
consideration in the Proposed Plan of NJDEP's 1986 position that
dioxin was the principal concern at Brook Industrial Park.
Response: EPA considers dioxin to be a contaminant of concern at
the site and is remediating the dioxin contamination. The RI,
which contains the results of the baseline Risk Assessment, has
shown that the site poses a significant risk even without
consideration of the risk posed by the dioxin contamination.
1.8 Comment: A representative of a PRP questioned whether the
dioxin had been cleaned up to the satisfaction of EPA or whether
the Proposed Plan encompasses dioxin cleanup.
Response: Dioxin contamination has not been remediated to the
satisfaction of EPA; however, the immediate threat posed by the
dioxin contamination has been addressed through a removal action.
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The Proposed Plan addressed remediation of the dioxin
contamination in the Blue Spruce Building. The Proposed Plan
also stated that dioxin contamination above 1 part per billion
(ppb) was not detected under the asphalt cap during confirmatory
sampling. However, if dioxin contamination is detected above 1
ppb during subsequent activities, the contaminated soil would be
remediated.
1.9 Comment: A representative of a PRP stated that EPA's proposed
expenditure for remediating the site is $17 million.
Response: The present worth cost estimate of the remedy is $12
million. This cost estimate will be further refined during
design.
1.10 Comment: A representative of a PRP questioned to what extent
the selected remedy will introduce its own contaminants to Brook
Industrial Park site.
Response: The selected remedy will not introduce any new
contamination to the Brook Industrial Park. Any migration of
contaminants, such as through fugitive dust emission, will be
limited through dust suppression measures.
1.11 Comment: A representative of a PRP commented that EPA
ignored economic responsibility and the latest technical
developments throughout the RI, FS and Proposed Plan.
Response: EPA must balance economics with overall protection of
human health and the environment and compliance with ARARs when
screening alternatives. If an alternative does not protect human
health and the environment or comply with ARARs, then the
alternative cannot be evaluated further in the screening process
even if it is more economical. EPA believes that the latest
technical information was considered in the development of
remedial alternatives for the site.
1.12 Comment: A representative of a PRP stated that the RI
contains a high level of uncertainty and that the risk assessment
used oral toxicity data in the absence of dermal toxicity
information.
Response: In the absence of specific "portal of entry" effects
resulting from dermal exposure, the use of appropriately adjusted
(to account for differences in absorption) oral toxicities data
in the absence of corresponding dermal toxicities data is
scientifically justifiable.
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1.13 Comment: A representative of a PRP stated that EPA ignored
the unique geological setting which tends to contain the site
soil and ground water in a nearly impervious bowl and that the
clean fill deposited on site will be subject to contamination by
the rising and falling of the ground water table.
Response: EPA does not believe that the geological setting would
serve to confine contamination to the site. The results of EPA's
hydrogeological study have shown that the overburden aquifer
likely flows into the Raritan River and is in direct connection
with the bedrock aquifer. The bedrock aquifer is not part of any
"impervious bowl" referred to in the comment. With respect to
the clean fill, EPA does not believe that the ground water will
contaminate the clean fill. However, EPA believes that reducing
the contamination in the soil will lessen the time required for
ground water remediation.
1.14 Comment: A representative of a PRP commented that the delay
in remediating the site from the time of the NJDEP settlement to
the present has significantly escalated the cost of remediation.
Response: The remediation plan resulting from the NJDEP
settlement is not comparable to the current Proposed Plan since
the full extent of contamination of the site was not known at the
time of the NJDEP settlement.
1.15 Comment: A representative of a PRP stated that Jame Fine
Chemicals and National Metal Finishings has made good-faith
efforts to remediate the soil and ground water but have been
unable to accomplish this due to inclusion of the site on the
NPL.
Response: EPA has no knowledge of efforts or requests by Jame
Fine Chemicals or National Metal Finishings to remediate the site
since it was listed on the NPL. In fact, it is EPA's
understanding that National Metal never conducted the
hydrogeological study which was to be conducted under a 1982
settlement with NJDEP.
1.16 Comment: A representative of a PRP stated that the findings
of the RI included contamination of the bedrock aquifer with VOCs
and metal.
Response: The bedrock aquifer as well as the overburden aquifer
are contaminated with VOCs and heavy metals.
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1.17 Comment: A representative of a PRP stated that the findings
of the RI/FS included an on-going program of continuous pumping
of the Jame Fine well to provide process cooling water for Jame
Fine's manufacturing operations.
Response: The RI/FS did not state that there would be an on-
going program of continuous pumping of the production well to
provide Jame Fine with cooling water. EPA did make an assumption
that the well would continue to operate and could be used as part
of the extraction system. This was done for the purpose of
providing a cost estimate of the extraction system only. EPA
stated in the Proposed Plan that the on-site production well
would be considered in the overall remedial design of the
extraction system.
1.18 Comment: A representative of a PRP commented that there is
no evidence that the ground water plume is migrating off site and
that, based on geological history of the site, the plume is
confined within the boundary of the site.
Response: EPA has no evidence to support the statement that the
plume is confined within the site boundary. Any limitation of
the migration of the plume is likely the result of the pumping of
the on-site production well, and not any geological conditions.
A determination of the exact boundaries of the plume is not
necessary for the selection of a remedy. Additional ground water
data will be collected for use in the design of the extraction
and reinjection systems.
1.19 Comment: A representative of a PRP commented that it is
difficult to accept the proposed risks associated with ingestion
of soil where property is not used for agricultural purposes or
where even earthworms could not eat the soils.
Response: There is no correlation between property being used for
agricultural purposes and risk posed by ingestion of soil. Soil
can be ingested by adults through hand-to-mouth activities. The
risk due to on-site workers at the Brook Industrial Park site was
calculated using a standard industrial exposure scenario. In
addition, the exposure scenario for earthworms cannot be compared
to the exposure scenario for humans.
1.20 Comment: A representative of a PRP stated that the long-
term continual ingestion of 50 milligrams (ing) of soil per day by
a worker is unlikely.
Response: 50 mg, which is the default assumption for adults in
EPA's Risk Assessment guidance,is an extremely small amount of
soil to be ingested particularly when one considers the ways that
it can be ingested, such as through daily hand-to-mouth activity.
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1.21 Comment: A representative of a PRP commented that the
assumption that workers would drink one liter of ground water a
day for 25 years is not supportable since the facility uses a
public water supply and the conclusion that there is a risk of 7
in 10,000 is insupportable.
Response: EPA recognizes that the facility uses a public water
supply and that is why risk due to ground water ingestion is
presented in the RI and Proposed Plan as a potential future risk.
The risk calculations for the ground water use standard
industrial assumptions which include the assumption of one liter
per day for 25 years.
1.22 Comment: A representative of a PRP stated that the soil is
at the "cusp" of EPA's acceptable risk range.
Response: The risk due to exposure to the soils is at the lower
end of EPA's acceptable risk range; however, the quantitative
assessment did not consider the risk due to exposure to lead or
chromium since the risks posed by those contaminants were not
quantifiable. It is plausible that the cumulative cancer risk
and Hazard Indices would be higher if the effects of lead and
chromium were quantitatively included. In addition, the
contaminants in the soil are contributing to the ground water
contamination. Therefore, EPA determined that remediation of
soil is necessary-
1.23 Comment: A representative of a PRP stated that "since birds
and small mammals living on the property would be exposed to on-
site contamination 24 hours per day, it does not follow that
contaminant concentrations on these fauna causing very limited
exposure to small animals would significantly impact workers on-
site for forty hours per week" [sic].
Response: The Proposed Plan states that the potential exposures
to birds and mammals are estimated to be very limited. This is
because there are limited areas available for habitat. This
exposure scenario cannot be compared to a human exposure scenario
since different exposure assumptions were used in the latter such
as workers being exposed to the site for approximately 40 hours
per week.
1.24 Comment: A representative of a PRP commented that
consideration of the likelihood that a worker would ingest soil
would clearly discount the conclusion that the risk would fall
within EPA's acceptable risk range.
Response: EPA used a standard ingestion assumption in the
estimation of risk resulting from the ingestion exposure pathway.
The likelihood of ingestion of soil was factored into the
development of that standard assumption.
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1.25 Comment: A representative of a PRP questioned basing the
total Hazard Index for soils on the effects of manganese. The
representative also stated that after remediation, naturally
occurring manganese may still exist.
Response: The Hazard Index was calculated using standard
assumptions and based on the actual concentrations of
contaminants detected in samples from the site. The Hazard Index
was not calculated based solely on manganese, but included a
number of other inorganic compounds and pesticides. In addition,
EPA did not propose remedial action because of the presence of
manganese.
1.26 Comment: A representative of a PRP questioned the validity
of assessing the risk due to exposure to the soils in the
Stirling Center basement and the subdivided lot.
Response: EPA could not eliminate the potential for future use of
the basement or exposures on the adjacent subdivided lot.
Therefore, EPA assessed the risk posed by the soil in the
Stirling Center basement based on the potential for exposure of
an on-site worker in the future. EPA also evaluated the risk to
trespassers on the subdivided lot.
1.27 Comment: A representative of a PRP stated that conservatism
in the RI, such as using oral toxicity data in absence of dermal
toxicity data, led to improper conclusions in the FS.
Response: In the absence of specific "portal of entry" effects
resulting from dermal exposure, the use of oral toxicity data,
appropriately adjusted to account for differences in absorption,
in the absence of corresponding dermal toxicities data is
scientifically justifiable. Further, EPA believes that the
conclusions of the RI provided sufficient information to develop
and evaluate alternatives in the FS.
1.28 Comment: A representative of a PRP commented that EPA
erroneously calculated hazard quotients that resulted in a Hazard
Index of one or higher.
Response: The hazard quotient calculations were arithmetically
correct and were generated according to EPA's Risk Assessment
Guidance for Superfund.
1.29 Comment: A representative of a PRP commented that since the
RI could not quantify the bioavailability of chemicals to
terrestrial organisms and due to the speculative nature of the
findings, any FS conclusion regarding the effect on such
organisms is considered suspect.
Response: EPA evaluated the impact on terrestrial organisms using
all available information, following standard practice and
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guidelines. Where site-specific information was not available,
information from similar studies was utilized. The Agency
believes that the selected remedy will result in the protection
of the environment.
1.30 Comment: A representative of a PRP stated that the
assumption that chemicals found in the overburden aquifer could
be of concern to aquatic organisms if the chemicals discharge to
the river fails to consider the slow rate at which this discharge
would occur.
Response: The results of the ecological assessment indicate that
aquatic organisms in the Raritan River are not expected to be
affected by the site.
1.31 Comment: A representative of a PRP stated that the RI
contains an inordinate amount of uncertainty, greatly exaggerates
the requirement for remediation and that the FS is overly
conservative.
Response: EPA believes that the RI provided an accurate
characterization of the site. Risks were estimated using
appropriate guidance and EPA believes that they were not overly
conservative. In fact, EPA's risk assessment did not include two
inorganic contaminants which would have likely increased the
estimated risk if they had been considered in the assessment.
EPA also believes that the RI provided sufficient information to
develop and evaluate alternatives for remediating the site, and
that the FS evaluated reasonable remediation alternatives.
1.32 Comment: A representative of a PRP stated that wholesale
removal of soils to an undetermined depth is unwarranted and
uneconomical and that it is clear that the vertical delineation
of contamination was not done.
Response: EPA did not state that soil would be removed to an
undetermined depth. EPA conducted extensive soil sampling
efforts to determine the extent of contamination. EPA plans to
excavate contaminated soil to the ground water table. EPA also
believes that the RI provided sufficient information to develop
and evaluate alternatives for remediating the site. Any
additional information necessary for the implementation of the
remedy will be developed during design activities.
1.33 Comment: A representative of a PRP commented that the
objective and recommendation of the RI seems to be to remediate
soils until all contaminants are non-detectable.
Response: The RI/FS reports do not make recommendations
regarding the remediation of the soil at the site. It is not
EPA's intention to remediate all soil contamination to a non-
detectable level. As summarized in the Proposed Flan, the
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remedial action objective for soil is to remediate soil in Areas
One and Two where the contaminants of concern exceed EPA risk-
based remediation goals. There are areas of the site where
contamination is present at detectable levels, but below the
remediation goals, which will not be excavated.
1.34 Comment: A representative of a PRP commented that EPA
disregarded emergent technology, particularly bioremediation of
areas contaminated with organic compounds, including dioxin,
pesticides and herbicides.
Response: Bioremediation technologies were evaluated in the
initial screening of alternatives. Bioremediation was screened
out because it is not effective in remediating all contaminants
of concern in the soil, particularly the inorganic compounds.
Although bioremediation can be considered an emergent technology
for remediating pesticides, with the exception of the Blue Spruce
Building, pesticides were never detected without inorganic
contamination.
1.35 Comment: A representative of a PRP commented that demolition
of the Blue Spruce Building is not a cost-effective solution.
Response: EPA evaluated several alternatives to address
contamination of the Blue Spruce Building and determined that
demolition of the building provided the only solution which is
permanent and protective of human health.
1.36 Comment: A representative of a PRP stated that the soil in
the Blue Spruce Building could be bioremediated.
Response: Bioremediation was considered in the FS, but was
screened out in the initial assessment of alternatives since it
is considered to be generally ineffective in remediating the
older, more chlorinated pesticides, such as those found in the
Blue Spruce Building.
1.37 Comment: A representative of a PRP stated that the
contaminated walls of the Blue Spruce Building can be foam
cleaned and sealed to preclude contact with the contaminated
surfaces by future workers.
Response: EPA considered and evaluated a similar option in the FS
and the Proposed Plan. Such an approach would not provide a
permanent solution, and would be subject to continuous
maintenance over the lifetime of the building. EPA believes that
it is preferable to demolish the contaminated portions of the
building since that would provide a permanent remedy and would be
more protective of human health.
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1.38 Comment: A representative of a PRP commented that the
disposal of the contaminated construction debris can be separated
from noncontaminated debris in order to decrease disposal costs.
Response: EPA agrees that this may be possible. In fact, the
Proposed Plan states that the "the demolition could occur in
phases in order to segregate the dioxin-contaminated material
which could reduce disposal costs."
1.39 Comment: A representative of PRP commented that the study
indicated a "doming" effect in the overburden aquifer and that
ground water and soils are contained by the railroad tracks.
Response: EPA believes that the ground water "mounding effect"
indicated by the RI is the result of leakage from the on-site
production well. While the presence of the railroad tracks may
have prevented some migration of soil, it is highly unlikely that
the ground water contamination is impeded by the railroad tracks.
1.40 Comment: A representative of a PRP commented that concerns
for possible migration of the ground water plume due to cessation
of operation of the on-site production well can be dispelled by
long-term monitoring and long-term access to EPA.
Response: EPA is not concerned that the operation of the on-site
production well might cease. EPA does not believe that operation
of the well is sufficient to contain the ground water
contamination. Although EPA would welcome long-term access to
the well, operation of only that well may not provide for
remediation of the aquifer even with a modified pumping scenario.
1.41 Comment: A representative of a PRP stated that the VOCs in
the ground water can be treated within Jame Fine's operations
rather than constructing a separate system.
Response: While VOCs are being extracted by the on-site
production well, no treatment is being provided. Further,
current ground water pumping rates are insufficient to capture
and remediate the ground water contamination. EPA plans to
consider the production well in the overall design of the
extraction system. The selected remedy also includes treatment
to remove both organic and inorganic contaminants.
1.42 Comment: A representative of a PRP commented that the area
has been an industrial site and it is highly unlikely that the
site will be converted to residential or recreational purposes
which would call for mitigation to a standard beyond that
required for a comparable-use facility.
Response: As stated in the Proposed Plan, EPA used industrial
exposure assumptions to develop the soil remediation goals.
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1.43 Comment: A representative of a PRP stated that the soils in
the drainage ditch can be bioremediated.
Response: EPA screened out bioremediation in the initial
assessment of alternatives since it is not known to be effective
in remediating inorganic compounds.
1.44 Comment: A representative of a PRP commented that since
there is no evidence that vegetation on site or in the area of
the drainage ditch and tributary has been adversely affected by
the defoliant characteristic of the chemicals, this contamination
is not a hazard.
Response: The major contaminants in the area of the drainage
ditch and tributary are inorganic compounds which do not exhibit
defoliant characteristics. Regardless, EPA also considered the
risk posed to human health as unacceptable in determining the
need to remediate the area.
1.45 Comment: A representative of a PRP stated that the use of
railroad cars is an unnecessary expense.
Response: EPA would consider transporting the contaminated soil
by truck if it were determined during design that it was more
efficient and economical than rail transportation. This is
referenced in the Proposed Plan.
1.46 Comment: A representative of a PRP commented that the
Proposed Plan "concedes" that washing and surface sealing in the
Blue Spruce Building would achieve compliance with ARARs.
Response: The Proposed Plan states that washing and surface
sealing would "comply with the remedial action objective of
reducing risk due to direct contact." However, it would not
provide a permanent remedy since contamination would remain in
the building materials and would need long-term monitoring and
maintenance.
1.47 Comment: A representative of a PRP stated that the
contaminated walls in the Blue Spruce Building could be easily
cleaned and sealed and be inspected by EPA for maintenance of the
sealant and that EPA offers no compelling argument to justify
demolition.
Response: Such an approach would not provide a permanent
solution, and would be subject to continuous maintenance over the
lifetime of the building. EPA believes that it is preferable to
demolish the contaminated portions of the building since that
would provide a permanent remedy and would be more protective of
human health.
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1.48 Comment: A representative of a PRP commented that the
Proposed Plan does not address the costs that demolition would
impose upon the owners of the property in terms of deprivation of
use of the property.
Response: The owners of the Blue Spruce Building are considered
to be PRPs. In addition, they currently do not have use of the
Blue Spruce property. Remediating the Blue Spruce Building would
leave the owners with an essentially clean property which could
be used.
1.49 Comment: A representative of a PRP stated that after a
decade of monitoring, there is no evidence to suggest that the
ground water contamination has spread beyond the boundaries of
the site and that the existing process of removing the ground
water for cooling water use can continue to control the plume.
Response: EPA does not have knowledge of a decade of ground water
monitoring and does not have any evidence to suggest that the
ground water contamination will not migrate. Further, if the
plume were controlled and not remediated, monitoring and
containment would need to continue indefinitely.
1.50 Comment: A representative of a PRP commented that a pumping
rate of 250 gallons per minute and two extraction wells to
contain the contaminant plume is an unsubstantiated conclusion.
Response: The pumping rate and number of extraction wells were
presented in the Proposed Plan for cost estimation purposes only.
Specific extraction system details will be developed during
design.
1.51 Comment: A representative of a PRP proposed remediating the
ground water by continuous pumping of the Jame Fine well, use of
the extracted ground water by Jame Fine as cooling water, and
treatment of the used cooling water to remove VOCs and metals.
Response: EPA has selected ground water extraction and treatment
to remediate the contaminant plume. EPA will consider
integrating the on-site production well into the design of the
extraction system; however, EPA does not believe that current
well operating parameters would be sufficient to capture and
remediate the ground water contamination. Specific details of
the system will be determined during design.
1.52 Comment: A representative of a PRP proposed bioremediation,
and sealing and capping of exterior areas with a six-inch asphalt
cap to reduce and contain contaminants in the upper soil levels.
Response: Bioremediation is not effective in remediating
inorganic compounds. Further, capping is not a permanent
solution; it would require maintenance of the cap and monitoring
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over an indefinite period. Finally, capping certain portions of
the site might not be feasible due to the layout and nature of
use of the site.
2.0 other
2.1 Comment: Several representatives of PRPs requested that EPA
recalculate the ranking of the site on the NPL.
Response: All requests regarding a re-evaluation of the site's
eligibility for inclusion on the NPL have been referred to the
office in EPA Headquarters responsible for the NPL-listing
process.
2.2 Comment: A representative of a PRP stated that EPA is
responsible for any contamination found on site after the
1979/1982 NJDEP study due to a delay in remediating the site.
The representative also stated that EPA is responsible for any
increase in cost over the remediation that could have been
conducted in 1983.
Response: The NJDEP study did not fully delineate the nature and
extent of contamination at the Brook Industrial Park site.
Dioxin, for example, was not discovered on site until after the
study was completed. EPA cannot evaluate alternatives for a
selected medium until the nature and extent of contamination of
that medium is known. 'In addition, several companies within the
Industrial Park were cited for environmental violations after the
NJDEP study was completed.
With respect to the claim that EPA delayed remediation, EPA did
not become involved in the site until dioxin was discovered in
1983. At that time, EPA addressed the immediate threat posed by
the dioxin contamination through a removal action. Subsequently,
the site proceeded through the NPL-listing process which ended
with the site being included on the NPL in 1989. EPA initiated
the RI/FS in 1989 to determine the long-term threat posed by the
site. However, the RI/FS was delayed when the owner of Brook
Industrial Park denied EPA access to the site. The purpose of
this ROD is to select the alternatives which will address the
long-term threats posed by the site. EPA believes that the cost
to remediate the site is the responsibility of those parties
which contributed to the pollution of the site.
2.3 Comment: A representative of a PRP questioned why the
Proposed Plan did not discuss the effect, if any, caused by a
delay in site cleanup.
/
Response: EPA addressed the immediate health threat posed by the
dioxin contamination through the 1983 removal action as well as
subsequent removal actions in 1990 and 1992 which secured the
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Blue Spruce Building. The remaining threats are addressed in
this ROD.
2.4 Comment: A representative of a PRP stated that EPA performed
duplicative sampling and has given insufficient weight or ignored
the sampling conducted by NJDEP and the draft reports prepared by
NUS.
Response: The sampling conducted by NJOEP did not delineate the
nature and extent of contamination associated with the site nor
did it follow the rigorous quality assurance process EPA
requires. With respect to the NUS reports, additional sampling
was not conducted in the Blue Spruce Building. However, EPA
relied on the data collected during the NUS study and by NJDEP in
developing alternatives for remediating the site.
2.5 Comment: A representative of a PRP asked if EPA could assure
the public that the Proposed Plan would remediate environmental
concerns at the site including concerns about contaminants that
originated on site as well as those introduced from off-site
sources.
Response: EPA will perform confirmatory sampling to assure that
contaminants of concern are remediated to levels established in
this ROD, thus remediating the environmental concerns posed by
the site. With respect to off-site sources, EPA's sampling has
not indicated any off-site sources of contamination.
2.6 Comment: A representative of a PRP asked that EPA consider
the railroad operators PRPs.
Response: EPA does not consider the railroad operators (New
Jersey Transit) to be a PRP at this time.
2.7 Comment: A representative of a PRP commented that although
other occupants of Brook Industrial Park have been cited for
improper housekeeping and waste disposal, the facts point to Blue
Spruce as a significant contributor to on-site contamination.
Response: EPA recognizes several occupants of Brook Industrial
Park as contributors to the on-site contamination. These
occupants include Blue Spruce, National Metal Finishings
Corporation and Jame Fine Chemicals Incorporated. EPA has no
indication that the Blue Spruce contamination contribution was
more significant than the other contributors to site
contamination.
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ROD FACT SHEET
SITE
Name
Location/State
EPA Region
HRS Score (date)
Site ID #
ROD
Date Signed
Remedies
Operating Units:
Capital Cost
O & M/year
Present worth
Brook Industrial Park
Bound Brook, Somerset County, New Jersey
II
58.12 (6/88)
NJD 078 251 675
9/30/94
Contaminated soil will be excavated and
transported off site for treatment and
disposal. The excavated soil will be
replaced with clean fill. The dioxin-
contaminated portion of a building on the
site will be demolished and incinerated or
disposed of in an appropriate off-site
landfill. The contaminated ground water will
be extracted, treated by air-stripping and
chemical precipitation, and reinjected.
OU-1, OU-2, OU-3, and OU-4
$7,272,000
$342,000
$11,584,000
LEAD
Lead agency U.S. EPA
Primary contact (phone) Donna Vizian (212) 264-6478
Secondary contact (phone)Robert McKnight (212) 264-1870
WASTE
Type (metals, PCB, &c)
Medium (soil, g.w., &c)
Origin
Est. quantity
heavy metals, dioxin, organics
soil, buildings, ground water
specialty chemical manufacturer, metal
plating company, pesticide production
and storage company
approx. 4,600 cu. yd. of soil
approx. 5,000 sq. ft. of building
interior surfaces
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