U.S. Environmental Protection Agency
Region II! Hazardous Waste
Technical Information Center
841 Chestnut Street, 9th Floor
Philadelphia. PA 19107
PB96-963820
EPA/ROD/R02-96/288
AprU 1997
EPA Superfund
Record of Decision:
American Cyanamid Company,
(ffill Property Soils), Bound Brook, NJ
Bound Brook, NJ
7/12/1996
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SUPERFUND RECORD OF DECISION
FOR HILL PROPERTY SOILS
AMERICAN CYANAMID SITE
AMERICAN HOME PRODUCTS CORPORATION
BRIDGEWATER TOWNSHIP, SOMERSET COUNTY
NEW JERSEY
Prepared by: N.J. Department of Environmental Protection
Site Remediation Program
Bureau of Federal Case Management
July 1996
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TABLE OF CONTENTS
RECORD OF DECISION
HILL PROPERTY SOILS AT AMERICAN CYANAMID SITE
AMERICAN HOME PRODUCTS CORPORATION
BRIDGEWATER TOWNSHIP, SOMERSET COUNTY
DECLARATION STATEMENT 1
DECISION SUMMARY 3
CLASSIFICATION EXCEPTION AREA (CEA) 11
GLOSSARY 17
ADMINISTRATIVE RECORD FILE INDEX 19
RESPONSIVENESS SUMMARY 22
ATTACHMENT 1 - FIGURES
ATTACHMENT 2 - TABLES
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DECLARATION STATEMENT
\
RECORD OF DECISION
HILL PROPERTY SOILS AT AMERICAN CYANAMID SITE
AMERICAN HOME PRODUCTS CORPORATION
BRIDGEWATER TOWNSHIP, SOMERSET COUNTY
Sire NAME AMD LOCATION
Hill Property Soils at the American Cyanamid Site
Bridgewater Township, Somerset County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document, prepared by the New Jersey Department of
Environmental Protection (NJDEP) as lead agency, presents the selected
remedy for the Hill Property Soils at the American Cyanamid Site. The
selected remedy was chosen in . accordance with the requirements of the
Comprehensive Environmental Response, Compensation, and Liability Act of
1980 (CERCLA), as amended' by the Superfund Amendments and Re-
authorization Act of 1986 (SARA) and .the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). This decision document explains
the factual and legal basis for selecting the remedy for this site and is based
on the administrative record. The attached index identifies the items that
comprise the administrative record.
The U.S. Environmental Protection Agency (USEPA). support agency for this
site, concurs with the selected remedy and has provided a concurrence letter
to that effect, which is attached to the responsiveness summary section of
this document.
DESCRIPTION OF THE SELECTED REMEDY
This ROD addresses only Hill Property Soils. The selected remedy is "No
Further Action with Ground Water Monitoring".
The major components of the selected remedy include:
• Continue recovery of the residual ground water contamination from the
Hill Property to the Main Plant area of the site
• Continue ground water monitoring at the Hill Property Area to verify that
the residual ground water contamination is being recovered at the Main
Plant from the Hill Property
• Water Use Restrictions that have been established under the'NJDEP
Classification Exception Area remain in effect until all of the residual
ground water contamination has been recovered at the Main Plant from
the Hill Property
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DECLARATION of STATUTORY DETERMINATIONS
The No Further Action with Ground Water Monitoring remedy has been
selected based on the results of the Remedial Investigation and the Baseline
Endangerment Assessment for Hill Property Soils, which have shown the
remedy to be protective of human health and the environment.
Because this remedy will result in residual ground water contamination
remaining on the site until it is completely recovered at the main plant area,
a review will be conducted pursuant to CERCLA after the complete removal
of the residual ground water contamination to ensure that the remedy
continues to provide adequate protection of human health and the
environment. In accordance with CERCLA, NCP and State requirements, NJDEP
has determined that no further action is necessary to ensure protection of
human health and the environment for the Hill Property Soils. NJOEP has
determined that its response • at this portion of the site is complete.
Therefore, the Hill Property site may qualify for partial deletion from the
National Priorities List of Superfund.
Signature
Richard.J. Gimello.
Site Remediatio
Esist^nt Commissioner
irar
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DECISION SUMMARY
RECORD OF DECISION
HILL PROPERTY SOILS AT THE AMERICAN CYANAMID SITE
AMERICAN HOME PRODUCTS CORPORATION
BRIDGEWATER TOWNSHIP, SOMERSET COUNTY
1. SITE NAME, LOCATION AND DESCRIPTION
American Cyanamid Company's (Cyanamid's) Bound Brook -facility is located
in north-central New Jersey in the southeastern section of Bridgewater
Township, Somerset County. The facility encompasses approximately 575
acres and is bounded by Route 28 to the north, the Raritan River to the
south, Interstate 287 and the Somerset Tire Service property to the east, and
Foothill Road and the Raritan River to the west. A site map identifying
important features of the site with a highlight of the Hill Property area is
attached (Figure 1).
The Hill Property area is approximately 140 acres in size (Block 7101-Lots
1 and 2, 7207-AII Lots, Block 7208--AII Lots. Block 7209- All Lots except
14. 16, 18. 20, 21, 23 and 24. Block 7210--AII Lots except 5, 7, 9, 11, 13
and 15 and Block 7211--AII Lots), bounded to the south by the New Jersey
Transit rail road tracks, to the east by Interstate Highway 287. to the north
by Route 28 (Union Avenue), and to the west by Foothill Road. The Hill
Property is bisected by Main Street and encompasses a small traffic circle
where Van Home Avenue and Main Street intersect.
2. SITE HISTORY AND ENFORCEMENT ACTIVITIES
American Home Products Corporation purchased American Cyanamid Company
in December 1994 and has assumed the full responsibility for the ongoing
environmental remediation at the site.
American Cyanamid Company and the NJDEP executed an Administrative
Consent Order (ACO) in May 1988 which was amended in May 1994 requiring
American Cyanamid to address the site-wide contamination and implement a
remediation program as necessary.
Historical records, aerial photographs and site reconnaissance of the Hill
Property show no indications of past manufacturing or waste disposal. Until
1900s, the Hill Property area was used for farming activities. In the late
1940s, Cyanamid began constructing the research laboratory and administration
buildings which occupied the southeast corner of this segment. The research
laboratory and administrative buildings had been decommissioned and
demolished.
One surface Impoundment!* 23) is located within the Hill Property area. This
impoundment is approximately three acres in size and was used from'the late
1940s through the early 1980s as a dewatering basin for river sediments
dredged from Impoundments 21 and 22 located at the main plant.
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Impoundments 21 and 22 were used as settling basins for water pumped from
the Raritan River for use in the main plant. The settled river sediments were
dredged periodically and placed in Impoundment 23. Based on the investigation
performed by Cyanamid in 1987, the NJOEP approved a no further action
closure for this impoundment.
Three areas. Laboratories Waste Drum Storage, Boiler House and Van Home
House Fuel Oil Tank were identified as areas of concern during the Remedial
Investigation (Rl).
3. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The following documents were made available to the public for review:
• Remedial Investigation Report;
• Baseline Endangerment (Risk) Assessment Report; and
• Superfund Proposed Plan.
These documents are part of the administrative record and are located in an
information repository maintained at the NJDEP Docket Room in Trenton, New
Jersey, at the Somerset County Public Library and at the Bridgewater
Township Municipal Complex. The notice of availability for these documents
was published in the Courier News on January 10, 1996. A public comment
period on the documents was held from January 10, 1996 to February 24,
1996. A briefing with the Bridgewater Township officials and a public meeting
were held on February 22, 1996. At .this meeting, representatives from
NJDEP answered questions about the results of investigations and risk
assessment and the preferred no further action with monitoring remedy under
consideration for Hill Property Soils. Limited comments were received during
the public meeting and comment period concerning the preferred remedy for
the Hill Property Soils. A complete background on community involvement
throughout the remedial process is included in the Responsiveness Summary.
4. SUMMARY OF SITE CHARACTERISTICS
The Rl for the Hill Property area was completed in March 1991. The
significant findings of the Rl are described below:
Geology/Hydro geology
The elevation of the Hill Property ranges from about 70 feet above sea level
in the northeast, to about 35 feet above sea level in the southwest. The Hill
Property area is underlain by a series of overburden surficial deposits. The
overburden consists of a silty clay soil, derived from the underlying bedrock.
Below the surficial deposits is a zone of weathered shale ranging in thickness
from 5 to 10 feet. The weathered shale consists of shale and slltstone
fragments in a clay matrix, and acts as a low permeability boundary between
the over lying surficial deposits and the under lying bedrock. Directly,below
the weathered shale lies the Passaic Formation, which consists of a series of
reddish-brown shale, siltstone and fine sandstone.
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Test pits and borings on the Hill Property have infrequently encountered
overburden ground water indicating that there is no significant overburden
aquifer component in the Hill Property. When ground water in the overburden
does occur, it is usually found perched about one foot above the bedrock.
Ground Water
The* ground water flow in the Passaic Formation aquifer has been reversed due
to the ground wat.er pumping from production wells at the main plant. The
current ground water flow is to the south, toward the main plant area.
Ground water production wells have been relocated to the Main Plant Area
from the Hill Property. Residual bedrock ground water contamination at the
Hill Property, a result of the past ground water contamination recovery
system, is now being recovered at the Main Plant Area. The existing produc-
tion wells at the Hill Property have been converted into monitor wells.
Quarterly bedrock ground water monitoring is being performed by using these
monitor wells to ensure that all of the residual ground water contamination,
as described above, is being recovered at the Main Plant Area of the site. A
ground water Classification Exception Area (CEA) and Ground Water Use
Restrictions have been established to provide public notification restricting the
ground water use at the Hill Property area until the residual ground water
contamination is removed below the applicable standards. The CEA and ground
water use restrictions will remain in effect until all of the ground water
contamination at the Hill Property has been recovered at the Main Plant. The
January 1996 Proposed Plan discussed establishing a Declaration of
Environmental Restriction (DER) at the Hill Property. However, since there is
no soil contamination above the NJDEP Cleanup Criteria (both residential and
non-residential) or background, there is no need to establish the DER at the
Hill Property. Results of the effectiveness of ground water recovery (from the
Hill Property to the Main Plant) system, together with the results of the
ground water 'monitoring program, will be addressed with a subsequent ROD
in the future.
Soils
As part of the Rl, three areas of concern at the Hill Property were
investigated in detail. The Rl sampling locations are shown on Figure 2. Areas
of concern investigated during the Rl and the results of investigations are
described below. The soil analytical results were compared to the NJDEP
Direct Contact Soil Cleanup Criteria (DCSCC) and Impact to Ground Water Soil
Cleanup Criteria (IGWSCC) using compliance methods published by NJDEP. This
compliance process involves comparing average concentrations to the DCSCC
and IGWSCC as well as comparing maximum detected concentrations to a
multiplication factor of the Soil Cleanup Criteria (SCO. It is important to note
that NJDEP has not developed IGWSCC for Metals. These criteria are to be
developed on a case-by-case basis. Metals data for the Hill Property Soils are
provided for the portion of the soil column where potential impact to ground
water would be more likely to occur than direct contact; ^therefore,
background concentrations developed during the Rl are used for the evaluation
of Metals data. Comparison of detected contaminants to NJDEP SCC is
included in Table 1.
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• Background Sampling Program:
Three test pits (HT-1 through HT-3) were completed in undisturbed areas
of the Hill Property to obtain samples for analysis for background values.
for chromium and vanadium. These locations are at a great enough
distance from the Boiler House and in undisturbed areas to be considered
indicative of background. One additional test pit (HT-4) was completed
-to examine the soil horizons surrounding the Boiler House. Soil samples
were obtained from these test pits between 7 to 11 feet below ground
surface (bgs).
Chromium was detected in the range of 27.5 to 379 mg/kg while
vanadium was detected in the range of 56.5 to 327 mg/kg.
• Laboratory Waste Storage Area:
This area is located in the northern portion of the Hill Property. Due to
the potential for spills or leaks which may have originated from the
drums stored in this area, surface soil samples were collected from the
four sides of the concrete storage pad area. Each sample was analyzed
for the Target Compound List (TCL) Volatile Organic Compounds (VOCs),
TCL Semi-Volatile Organic Compounds (SVOCs), TCL Polychrorinated
Biphynels (PCBs) and TCL Metals. Analysis for dioxins was not conducted
because the sampling and analysis program completed in 1983 by NJDEP
had confirmed that no dioxin contamination was present at the Cyanamid
facility. Pesticides/herbicides were not analyzed because historical records
indicated that they were never manufactured or disposed at the Cyanamid
facility.
The average TCL VOCs and SVOCs concentrations in surface soil samples
collected to a depth of 2 feet bgs are less than the residential and non-
residential NJDEP DCSCC and the- IGWSCC. No single sample exceeds the
SCC by the appropriate multiplication factor.
PCBs were not detected above the method detection limits (MDLs), which
are less than the residential and non-residential DCSCC and IGWSCC.
The average concentrations of TAL Metals are less than the residential
and non-residential DCSCC. No single sample exceeds the SCC by the
appropriate multiplication factor.
• Boiler House Area:
This area is located in the southern portion of the Hill Property. This
area is no longer in use as a boiler house and was converted into a
maintenance shop. Historical records indicate that a 20.000-gallon
underground fuel oil tank existed north of the Boiler House, but was
removed probably at the time the Boiler House was converted into a
maintenance shop. Two aboveground fuel oil tanks once existed, east of
the Boiler House. To detect possible soil contamination resulting from the
fuel oil tanks or any other activities at the former Boiler House, four soil
samples were collected between 6 to 11 feet bgs. One test trench was
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completed north of the Boiler House in order to substantiate records that
indicated the underground fuel oil tank had been removed.
The average TCL VOCs and SVOCs concentrations in soil samples
collected between 6 to 11 feet bgs are less than the IGWSCC. No single
sample exceeds the SCC by the appropriate multiplication factor.
•The average PCB concentrations (Aroclor 1254) in soil samples are less
than the IGWSCC. No single sample exceeds the SCC by the appropriate
multiplication factor.
The maximum and average concentrations for TAL Metals are within the
background range identified in the Hill Property Rl.
• Van Home House Fuel Tank Area:
The Van Home House, a building of historical significance, was used by
Cyanamid for administration purposes only. An underground fuel oil tank
(already removed) was located directly to the south of this house. This
tank represented a potential source for soil or ground water
contamination. Four soil samples were collected between 4 to 8 feet bgs.
As the former tank was used solely for the storage of fuel oil, and no
manufacturing or disposal activity occurred in this area, the samples were
analyzed for total petroleum hydrocarbons (TPH) only.
TPH were not detected above the method detection limits, which are less
than the NJDEP Criteria of 10,000 mg/kg.
5. Summary of Site Risk
Based upon the results of the Rl, the Baseline EA was completed to estimate
the risks associated with current site conditions. The Baseline EA estimates
the human health and ecological risks presented by the contamination at the
site if no remedial actions were taken. The results of the Baseline EA were
reported in March 1992.
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—identifies
the contaminants of concern at the site based on several factors such as
toxicity, frequency of occurrence and concentration. Exposure Assessment—
estimates the magnitude of actual and/or potential human exposures, the
frequency and duration of these exposures and the pathways (e.g., ingesting
contaminated well-water) by which humans are potentially exposed. Toxicity
Assessment—determines the types of adverse health effects associated with
chemical exposures and the relationship between magnitude of exposure (dose)
and severity of adverse effects (response). Risk Characterization—summarizes
and combines outputs of the exposure and toxicity assessments to provide a.
quantitative (e.g., one-in-a-million excess cancer risk) assessment'of site-
related risks.
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As a first step in the Baseline EA. contaminants of concern were selected
that would be representative of site risks. All contaminants detected in
surface soils, for which there are toxicity criteria, were included as
contaminants of concern. Contaminants of concern consist of 5 VOCs, 16
SVOCs and 1 metal. 10 out of the 22 contaminants of concern are considered
carcinogenic. Contaminants of concern with their toxicity criteria are listed
in Table 2.
Using the Baseline EA evaluation for exposure pathways for human receptors,
a number of significant exposure pathways (both current and future use) were
identified and evaluated quantitatively to determine the risk levels presented
by existing site conditions.
Summary of Human Health Risks
Through an assessment of exposure pathways for the contaminants of
concern, specific health risk levels were calculated for each significant
exposure pathway to enable a quantitative evaluation of health risks for
human receptors.
Current federal guidelines for acceptable exposures are individual lifetime
excess carcinogenic risk in the approximate range of 1 x 10'4 to 1 x 10'*.
This can be interpreted to mean that an individual may have a one in 10,000
to a one in 1,000,000 increased chance of developing cancer as a result of
a 'site-related exposure to a carcinogen under specific exposure conditions.
Current federal guidelines for acceptable exposures for non-carcinogenic risk
are maximum Hazard Index of 1.0. The Hazard Index is defined as the sum
of the Hazard Quotients for all contaminants of concern within a particular
exposure pathway that have a similar mechanism of action or end point.
Hazard Quotient greater than 1.0 indicates that the exposure level exceeds
the protective level for that particular chemical.
New Jersey Public Law P.L. 1993, c. 139 (NJSA 58:108) has set acceptable
cancer risk for human carcinogens at 1x10'* (one-in-one-million) and acceptable
non-carcinogenic risk at the Hazard Index for any given effect to a value not
to exceed 1.0. These established acceptable risk values are for any particular
contaminant and not for the cumulative effects of more than one contaminant
at a site.
A quantitative analysis of the risks associated with the Hill Property soils was
conducted in the Baseline EA to evaluate risks associated with exposure
through incidental ingestion, dermal contact, and inhalation as a result of
intermittent maintenance employees performing work activities.
Exposure levels were conservatively estimated based on current NJDEP and
USEPA guidance methodologies. The estimated exposure levels were then
compared to critical toxicity values to quantify the risks. Summary of
calculated risks is included in Table 3.
« f
The highest potential carcinogenic risk calculated was 1.0x10'*, and the
highest potential Hazard Index calculated was 0.0002, which were, associated
with the future business use scenario of an individual ingesting site soils.
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The March 1992 Baseline Site-Wide Endangerment Assessment Report (Hill
Property Quantitative Risk Assessment, Appendix VII) established that there
is no current or future unacceptable risk (above the NJDEP 10'* carcinogenic
risk level and Hazard Index of 1 for non-carcinogenic risk as well as USEPA's
carcinogenic risk range of 10"* to 10*e and Hazard Index of 1) to human
health associated with the Hill Property.
Qualitative Ecological Risk Assessment
In the Ecological Assessment, a reasonable maximum environmental exposure
is evaluated utilizing a four step process for assessing site-related ecological
risks. These steps are: Problem Formulation—development of the objectives
and scope of the ecological assessment; description of the site and
ecosystems that may be impacted; identification of contaminants of concern.
Exposure >*ssess/ne/»f--identification of potential ecological receptors and
exposure pathways; quantitative evaluation of exposure pathways; fate and
transport mechanisms for contaminants. ' Ecological Effects Assessment—
literature reviews, field studies, and toxicity tests, linking contaminant
concentrations to effects on ecological receptors. Risk Characterization—
measurement or estimation of both current and future adverse effects.
The results of the site-wide habitat survey and direct field observations were
compared to the Natural Heritage Data Base (NJDEP, 1991). This assessment
concluded that the on-site habitat does not support threatened or endangered
species.
It is unlikely that there has been or will be any adverse ecological impacts
associated with the Hill Property because; 1) the Hill Property Rl showed no
indication of past manufacturing or disposal activities; 2) there are no direct
contact exposures; and 3) contamination was detected, at background levels,
and is limited to small areas. Therefore, a more formal ecological assessment
was not performed.
5. SELECTED REMEDY FOR THE HILL PROPERTY SOILS
The Rl data indicate that the contaminants detected in the soils are below the
NJDEP ' DCSCC (both residential and non-residential), IGWSCC and/or
background. The Baseline Endangerment Assessment concluded that there is
no current or future unacceptable risk to human health and the environment
associated with the Hill Property. Therefore, in accordance with CERCLA, NCP
and State Requirements, NJDEP and USEPA have determined that no further
action is necessary to ensure protection of human health and the environment.
Based upon the results of the Rl and the Baseline EA, NJDEP and USEPA have
selected no further action with ground water monitoring as the remedy for the
Hill Property soils. Because this remedy will not result in hazardous
substances remaining on the site, a five-year review is not required. NJDEP
has determined that its response at this portion of the site is complete.
Therefore, the Hill Property site may qualify for partial deletion. f/om the
National Priorities List of Superfund.
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The residual bedrock ground water contamination at the Hill Property, a result
of the past ground water contamination recovery system, is now being
recovered at the Main Plant Area. Ground Water Classification Exception Area
(CEA) and Ground Water Use Restrictions have been established to provide
public notification restricting the ground water use at the Hill Property area
until the residual ground water contamination is removed below the applicable
standards. The CEA and ground water use restrictions will remain in effect
until, all of the ground water contamination at the Hill Property has been
recovered at the Main Plant. The January 1996 Proposed Plan discussed
establishing a Declaration of Environmental Restriction (DER) at the Hill
Property. However, since there i» no soil contamination above the NJDEP
Cleanup Criteria (both residential and non-residential) or background, there is
no need to establish the DER at the Hill Property. Results of the effectiveness
of ground water recovery (from the Hill Property to the Main Plant) system,
together with the results of the ground water monitoring program, will be ad-
dressed with a subsequent ROD in the future.
7. DOCUMENTATION OF SIGNIFICANT CHANGCS
There is no change from the preferred remedy described in the Proposed Plan
and the selected remedy described in this ROD.
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CLASSIFICATION EXCEPTION AREA (CEA)
, RECORD OF DECISION
HILL PROPERTY SOILS AT AMERICAN CYANAMID SITE
AMERICAN HOME PRODUCTS CORPORATION
BRIDGEWATER TOWNSHIP, SOMERSET COUNTY
Pursuant to the requirements of the NJDEP Ground Water Quality Standards
(GWQS), NJAC 7:d-6 et seq., a CEA and Water Use Restriction Area (WURA)
must be established as part of an approved remedy whenever contaminants
standards applicable to a ground water classification area are not or will not
be met for the term of the remediation. The ground water at the American
Cyanamid site (including the Hill Property) is classified as Class IIA. The
primary designated use for Class IIA ground water is potable water and
conversion (through conventional water supply treatment, mixing or other
similar technique) to potable water. Class IIA secondary designated uses
include agricultural water and industrial water.
Because of the past ground water contamination recovery system, bedrock
ground water in the Passaic Formation at the Hill Property became
contaminated. The ground water contamination- recovery system has been
moved to the Main Plant area and the residual ground water contamination at
the Hill Property is now being recovered at the Main Plant Area. Because of
the past ground water contamination recovery system which resulted in
residual ground water contamination at the Hill Property, the contaminant
concentrations are not meeting the Class IIA GWQS. As such, a CEA and
WURA are established until it is verified that all of the residual ground water
contamination at the Hill Property is recovered at the Main Plant area.
• CEA Boundaries:
As shown on Figure 1, the entire Hill Property and the Main Plant areas have
been designated as a CEA. The affected area of the Passaic Formation has
also been included in this CEA designation.
• CEA Contaminants:
Because of the recovery at the Main Plant, now, only tetrachloroethene and
1,2,4-trichlorobenzene exceed the GWQS (based on first quarter 1996
monitoring data). However, at the time the ground water recovery system was
moved from the Hill Property to the Main Plant, several TCL VOCs, SVOCs,
Metals as well as chloride and cyanide were detected above the GWQS in the
ground water at the Hill Property. For the purpose of the CEA monitoring, all
TCL VOCs, SVOCs, Metals as well as chloride and cyanide are included as
contaminants of concern.
• CEA Longevity:
The longevity of the CEA (i.e., time it will take for contaminants 'to meet
GWQS) has been calculated based upon the analytical solution as described
within the NJDEP's "Final Guidance for Classification Exception Areas, dated
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April 17, 1995". The following briefly describes the variables used to
calculate the duration and length of the CEA:
• T.he duration of transport is based upon the degradative half-life,
concentration and GWQS for the given contaminant. The high-end of the
half-life range for each contaminant was used in this calculation to
conservatively bias the time to degrade to GWQS.
• The length of transport is based upon the transport velocity of the
ground water, the retardation factor of the contaminant and the duration
of transport.
The duration of the CEA is based upon the tetrachloroethene since it takes
the longest to degrade to GWQS (7 years). The length of transport does not
factor into the duration of the CEA since this area is within the capture zone
of the Main Plant ground water recovery system. Manganese was detected in
Well PW-16 above the GWQS during the Fourth Quarter 1995 sampling event.
However it was not detected above the GWQS during the First Quarter 1996.
PARAMETER
Time to Meet GWQS (t) (Days)
Length of Transport (d) (ft)
TETRACHLOROETHENE
2.413
471
The calculation details for the duration and length of the CEA are provided
below.
A. DURATION OF TRANSPORT:
I. Calculation of Half-Life (t,/2):
Half-life ranges for the contaminants of concern were obtained from P.H.
Howerd et. al., " Handbook of Environmental Degradation Rates,* Lewis
Publishers, 1991, for unacclimated aerobic biodegradation in ground
water.
Tetrachloroethene: Half-life Range-360 to 56 days
Assume t,,, ~ 360 days
1,2,4-Trfchlorobenzene: Half-life Range—360 to 56 days
Assume t,/2 = 360 days
Manganese: No half-life
Assume transport as ground water velocity
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II.
B.
I.
II.
Time to Meet GWQS:
Tetrachloroethene:
1.2,4-Trichloro benzene:
LENGTH OF TRANSPORT:
Seepage Velocity (V,):
Where: K =
fS
dh/dl
n.
3=
V, = 30 x 0.024/0.10 =
Retardation Factor (Rd):
Tetrachloroethene:
Where: pb
P.
Where: C - GWQS « 1 ug/l
C. - Most Recent Concentration
- 10.2 ug/l
ti« = 720 days
t = ln(C/C*)/(0.693/tm)
- In(1/l0.2)/(0693/720)
= 2,413 days
Where: C » GWQS - 1 ug/l
C. = Most Recent Concentration
«= 83.9 ug/l
t,/2 = 360 days
t « ln(9/83.9)/(0.693/360)
= 1,160 days
Hydraulic Conductivity (ft/day)
Estimated to be 30 ft/day, 1992 Ground
Water Modeling Report,'.Camp, Dresser &
McKee (COM).
Hydraulic Gradient (ft/ft)
0.024 ft/ft. Site Bedrock Ground Water
Contour Map, January 22, 1996
Effective Porosity
0.10, 1992 CDM Report.
7.2 ft/day
Rd
Bulk density of Formation (gm/cm3)
p.(1-n.) = (2.65(1-0.10)} = 2.39 gm/cm3
Grain Density (gm/cm3)
2.65 gm/cm3 (Ref., Quartz-Fetter)
Distribution Coefficient = Kee x f,c
Soil-Water Partition Coefficient - 303. (Fetter, 1988)
Fraction of Organic Carbon - 0.5% (Fetter, 1988)
1 + {(303 x 0.005) x 2.39}/0.10 = 37
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1,2.4-Trichloro benzene:
Where: Pb
Kec
2.39 gm/cm3
1,080 (Fetter, 1988)
0.5% (Fetter, 1988)
Rd = 1 + {(1,080 x 0.005) x 2.39}/0.10
Manganese:
Ra - 1 (no retardation)
Ml. Pollution Transport Rate (V,,):
Tetrachloroethene:
= 130
Where: V.
= 7.2 days (Item I)
= 37 (Item II)
VDt = V./Rd
1,2,4-Trichloro benzene:
Where: V.
7.2/37
0.195 ft/day
7.2 days (Item I)
130 (Item II)
V./Rd
7.2/130
0.055 ft/day
Manganese:
Where:
V.
R-
= 7.2 days (Item I)
= 1 (Item II)
Vp« = V,/Rd = 7.2/1
IV: Length of Transport (d):
Tetrachloroethene:
Where: Vpt = 0.195 ft/day (Item III)
t •= 2,413 days (Item A)
d = 0.195 x 2.413 = 471 feet
1,2,4-Trichlorobenzene:
Where: Vpt =0.055 ft/day (Item III)
t =1,160 days (Item A)
d = 0.055 x 1,160 = 64 feet
7.2 ft/day
14
-------
SUMMARY:
Parameter
Half-Time
(tujHdays)
Time (t)
to Meet
GWQS
(days)
Seepage
Velocity
-------
• Deletion of CEA and WURA Designations:
Once the residual ground water contamination at the Hill Property is
recovered at the Main Plant and the GWQS are met in the monitor wells
at the Hill Property, the CEA and WURA designations will be lifted and
deleted for the Hill Property area. The CEA and WURA designations for
the remainder of the American Cyanamid site will remain in effect until
-the site-wide ground water contamination meets the applicable GWQb.
16
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GLOSSARY
RECORD OF DECISION
HILL PROPERTY SOILS AT AMERICAN CYANAMID SITE
AMERICAN HOME PRODUCTS CORPORATION
BRIDGEWATER TOWNSHIP, SOMERSET COUNTY
This glossary defines the technical terms used in this Record of Decision.
The terms and abbreviations contained in this glossary are often defined in
the context of hazardous waste management, and apply specifically to work
performed under the Superfund program. Therefore, these terms may have
other meanings when used in a different context.
Administrative Consent Order: A legal and enforceable agreement between
NJDEP and the potentially responsible parties (PRPs). Under the terms of the
Order, the PRPs agree to perform or pay for site studies or cleanup work.
It may also describe the oversight rules, responsibilities, and enforcement
options that the government may exercise in the event of non-compliance by
the PRPs. This Order is signed by the PRPs and the state government; it
does not require approval by a judge.
ARAR: Applicable or relevant, and appropriate requirements.
Berm: A ledge, wall, or a mound of earth used to prevent the migration of
contaminants.
Cap: A layer of material, such as clay or a synthetic material, used to
prevent rainwater from penetrating wastes and spreading contaminated
materials. The surface of the cap is generally mounded or sloped so water
will drain off.
CERCLA: Comprehensive Environmental, Response, Compensation, and Liability
Act of 1980, 42 U.S.C. § 9601 et.seq., as amended, commonly known as
Superfund.
Closure: The process by which a landfill stops accepting wastes and is shut
down under federal and state guidelines that provide' protection for human
health and the environment.
Grubbing: Clearing the ground of roots and stumps by digging them up.
HSWA: Hazardous and Solid Waste Amendments to the Resource Conservation
and Recovery Act of 1976.
NJDEP: New Jersey Department of Environmental Protection.
NCP: National Contingency Plan.
PPM: Parts per million.
RCRA: Resource Conservation and Recovery Act of 1976 as amended.
17
-------
RCRA Cap: A multi-layer material cap (see definition of "cap* above) which
incorporates several impermeable covers to assure integrity. Geomembrane
liners, filter fabrics, clay, sand and selected layers of fill materials are used
to reach maximum reasonable impermeability.
SARA: Superfund Amendments and Reauthorization Act.
USEPA: United States Environmental Protection Agency.
Volatile Organic Compounds (VOCs): VOCs are produced as secondary
petrochemicals. They include light alcohols, acetone, trichloroethylene,
perchloroethylene, dichloroethylene, benzene, vinyl chloride, toluene, and
methylene chloride. These potentially toxic chemicals are used as solvents,
degreasers, paints, thinners. and fuels. Because of their volatile nature, they
readily evaporate into the air, increasing the potential exposure to humans.
Due to their low water solubility, environmental persistence, and wide-spread
industrial use, they are commonly found in soil and ground water.
Wetland: An area that is regularly saturated by surface or ground water and,
under normal circumstances, capable of supporting vegetation typically adapted
for life in saturated soil conditions.
18
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ADMINISTRATIVE RECORD FILE INDEX
RECORD OF DECISION
HILL PROPERTY SOILS AT AMERICAN CYANAMID SITE
AMERICAN HOME PRODUCTS CORPORATION
BRIDGEWATER TOWNSHIP. SOMERSET COUNTY
1. Lagoon 1 & 2 Characterization Report, O'Brien & Gere, October
1982.
2. Phase IV Report Source Assessment and Remedy Program, O'Brien
& Gere, February 1983.
3. Monitoring Groundwater Impact on the Raritan River Report, Lawler,
Matusky, & Skelly (LMS), October 1983.
4. Source Assessment and Remedy Program Final Report, O'Brien &
Gere, December 1984.
5. Sludge Solidification Report for Lagoon 20, IT Corporation, November
1986.
6. Final Report on Continuous Monitoring Assessment Program for
Lagoons 6,7,13,19, and 24. Camp Dresser & Mckee (CDM), March
1983.
7. Ground water investigation and site-wide ground water model results,
CDM 1985.
8. Continued assessment of ground water at Impoundments 17 and 18,
CDM 1986.
9. New Jersey Pollutant Discharge Elimination System-Discharge to
Ground Water (NJPDES/DGW) permit # NJ0002313, effective October
30, 1987.
10. Modification to the existing NJPDES/DGW permit # NJ0002313
issued on November 07, 1987 for the closure of Impoundment 8
facility (Impoundments 6,7,8 and 9A) under the authority of RCRA
delegated to the New Jersey Department of Environmental Protection
(NJDEP) from USEPA.
11. Continued assessment of ground water at Impoundments 6,7,13,19
and 24, CDM 1988.
12. NJDEP Approval Letter for "No Action" Closure of Lagoon 23, May
1988.
13. Administrative Consent Order (ACO) signed by Cyanamid and NJDEP,
May 1988.
14. Quality Assurance/Quality Control (QA/QC) Plan Submitted for
Impoundment Characterization Program by Cyanamid, Blasland, Bouck
& Lee (BB&L). September 1988.
15. Hazardous and Solid Waste Amendments (HSWA) permit I.D. #
NJD0002173276 issued by USEPA on November 8, 1988.
16. Impoundment Characterization Program Sampling and Analysis Work
Plan, BB&L, November 1988.
17. NJDEP Approval Letter for QA/QC Program for Impoundment
Characterization, December 1988. . ,
18. Berm Failure Prevention Plan, BB&L, February 1989.
19. Impoundments 11, 20, and 26 Resource Conservation and Recovery
Act (RCRA) Facility Investigation Work Plan, BB&L, February 1989.
19
-------
20. NJOEP Community Relations Plan, February 1989.
21. NJDEP Approval Letter for Berm Failure Prevention Plan, March
1989.
22. NJDEP Approval Letter for Impoundments 11, 20, and 26 RCRA
Facility Investigation Work Plan, August 1989.
23. Impoundment Characterization Program Final Report, BB&L, January
1990.
24. - NJDEP Approval Letter for Implementation of Fuel Blending Program
as Interim Remedial Action For Lagoons 4 and 5, August 1990.
25. NJDEP Approval Letter for Impoundment Characterization Program
Final Report, October 1990.
26. Impoundment Corrective Measure Study/Feasibility Study (CMS/FS)
Work Plan, (BB&L), October 1990.
27. NJDEP Air Permit for Lagoon 4 & 5 Fuel Blending Program, October
1990.
28. NJDEP Stream Encroachment Permit for Lagoon 4 & 5, March 1991.
29. Amended Hill Property Remedial Investigation Report (Rl), BB&L,
March 1991.
30. NJDEP/USEPA Approval for Hill Property Rt, April 1991.
31. NJDEP RCRA Permit Application Approval For Lagoons 4 & 5, June
1991.
32. Technology Evaluation Work Plan (TEWP) for Group I Impoundments,
BB&L, July 1991.
33. NJDEP/USEPA Review and Concurrence Letter for TEWP-I, September
1991.
34. TEWP for Group II Impoundments, BB&L, December 1991.
35. NJDEP/USEPA Review and Concurrence Letter for TEWP-II, January
. 1992.
36. Amended Baseline Site-Wide Endangerment Assessment Report
(Including Hill Property), BB&L, March 1992.
37. NJDEP/USEPA Approval Letter for Baseline Site-Wide Endangerment
Assessment Report, April 1992.
38. Amended Soils RI/FS Work Plan, BB&L, May 1992.
39. Surface Soils Remedial/Removal Action (SSR/RA) Plan, BB&L, July
21, 1992.
40. A Work Plan for Coal Pile Removal to Impoundment 8 Facility,
Cyanamid, August 13, 1992.
41. Hazardous Waste Site Safety and Health Program, Cyanamid. August
31, 1992 (prepared on 07/20/88).
42. CMS/FS report for Group 1 Impoundments, BB&L, October 1992.
43. NJDEP/USEPA approval letter for Group 1 Impoundments CMS/FS
report, October 29, 1992.
44. Relocation of Production Wells from Hill Property to Manufacturing
Area, Ground Water Modeling Report, CDM, October 1992.
45. Surface Soil Removal/Remedial Action Final Report, BB&L, March 5,
1993.
46. Superfund Proposed Plan for Group I Impoundments, June 30, 1993.
47. Draft Modified HSWA permit I.D * NJD002173276, June 30, 1993.
48. Transcript for August 5, 1993 Public Meeting/Hearing for the -Group
I Impoundments (11, 13, 19 & 24) Proposed Plan and Draft Modified
HSWA Permit.
20
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49. Record of Decision for Group I Impoundments (11. 13, 19 and 24),
NJDEP, September 28, 1993.
50. Phase IA Cultural Resource Reconnaissance Report, The Cultural
Resource Consulting Group, Revised September 1993.
51. Final HSWA Modified Permit for Group I Impoundments (11, 13, 19
and 24), USEPA, March 4, 1994.
52. Addendum to 'Final Design Report-Impoundment 8 East Liner Design
Modifications. March 1994, BB&L.
53. Amendment to the 1988 ACO, NJDEP. May 4, 1994.
54. Group II Impoundments (1. 2, 15, 16, 17 & 18) CMS/FS Report,
BB&L, May 1994.
55. Group I Impoundments (11, 13, 19 and 24) Remedial Design Report,
BB&L, May 1994.
56. Final Renewed NJPDES/DGW Permit dated July 15, 1994, NJDEP.
Effective September 1, 1994.
57. Remedial Action Plan for Impoundment 19, ENSR and BB&L, July
1994.
58. NJDEP Approval for Group II Impoundments (1, 2, 15, 16. 17 and
18). July 19. 1994.
59. September 16, 1994 Modifications to Remedial Action Plan for
Impoundment 19, American Cyanamid.
60. Final Summary Report for Startup of Production Wells PW-2 and PW-
3, CDM, August 1994.
61. Impoundment 7 Closure Status Report, BB&L, December 1994.
62. Superfund Update, December 1994, NJDEP.
63. January 30, 1995 letter from American Home Products (AHP)
indicating that it has assumed full responsibility for the site
remediation as required by the ACO.
64. Petition for Designation of Impoundment 8 as Corrective Action
Management Unit (CAMU), February 21, 995, AHP.
65. Lagoon 8 Closure Certification Report, BB&L, May 1995.
66. NJDEP letter dated May 3, 1995 to Walt Sodie of CRISIS including
legal opinion (dated April 25, 1995) from the Deputy Attorney
General's office concerning removal of Group II Impoundments (15,
16, 17 and 18) from Flood Hazard Area.
67. USEPA's response to AHP dated May 18, 1995 for CAMU Petition.
68. • AHP's response to USEPA dated June 29, 1995 for May 18, 1995
letter concerning CAMU Petition.
69. October 20, 1995 letter from AHP including revised cost estimates
for remediation of the Group II Impoundments (15, 16, 17 and 18).
70. Impoundment 19 Closure Certification Report, O'Brien & Gere
(OB&G), November 1995.
71. Superfund Proposed Plan for Group II Impoundments (15, 16, 17 &
18) and Hill Property Soils, NJDEP, January 1996.
72. Transcript for February 22, 1996 Public Meeting concerning the
Proposed Plan for Group II Impoundments (15, 16, 17 and 18) and
Hill Property Soils.
73. March 27, 1996 Letter from OB&G concerning the supporting
information for the Classification Exception Area at the Hill. Property.
74. 5/10/90 Letter from AHP concerning Security Signs Off Road
Vehicles.
21
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RESPONSIVENESS SUMMARY
RECORD OF DECISION
HILL PROPERTY SOILS AT AMERICAN CYANAMID SITE
AMERICAN HOME PRODUCTS CORPORATION
BRIDGEWATER TOWNSHIP, SOMERSET COUNTY
1. INTRODUCTION
A responsiveness summary is required by the New Jersey Department of
Environmental Protection (NJDEP) and Superfund program. It provides a
summary of residents' comments and concerns received during the public
comment period and the public meeting, and NJOEP's and U. S. Environmental
Protection Agency's (USEPA) responses to those comments and concerns. All
comments summarized in this document have been considered in NJDEP's and
USEPA's final decision for the selection of a remedy for the Hill Property
Soils at the American Cyanamid Site.
2. OUTLINE
This Responsiveness Summary is divided into the following sections:
A. Overview
B. Background on Community Involvement and Concerns
C. Summary of Comments Received During the Public Meeting and Comment
Period and Agency Responses
D. Community Relations Activities at the American Cyanamid Company Site
A. Overview
This is a summary of the public's comments and concerns regarding the
Proposed Plan for Remediation of the Hill Property Soils at the American
Cyanamid Company Superfund Site and NJDEP's responses to those comments.
Th'e public comment period extended from January 10, 1996 to February 24,
1996 to provide interested parties the opportunity to comment on the
Proposed Plan, Remedial Investigation (Rl) Report and the Baseline
Endangerment Assessment Report (Baseline EA) for the Hill Property Soils at
the American Cyanamid Company Site. During the comment period, the NJDEP
and USEPA held a public meeting/public hearing on February 22, 1996 at the
Bridgewater Township Municipal Court to discuss the results of the Rl and
Baseline EA and to present the preferred remedy. This public comment period
and meeting also met the public participation requirements for the Hazardous
and Solid Waste Amendments (HSWA) requirements for the American Cyanamid
Site.
On the basis of the information contained in the above referenced documents,
NJDEP and USEPA have selected the following remedy for the Hill Property
Soils at the American Cyanamid Site: No Further Action with Ground Water
Monitoring.
-------
B. Background on Community Involvement and Concerns
Since 1988, there has been a great deal of concern about a proposal by
American Cyanamid to build a commercial hazardous waste incinerator on the
site. At present, Cyanamid has no plans to pursue the incinerator, nor does
American Home Products. .The Somerset-Raritan Valley Sewage Authority
already operates a sludge incinerator on property adjoining the American
. Cyanamid site. In addition, the Somerset County Freeholders designated a
tract next to the Authority site for a trash incinerator. While this facility is
no longer proposed, a solid waste transfer station is now in operation at this
location.
In January 1989, a briefing for public officials and concerned residents was
held in Bridgewater to discuss the remedial work under the 1988 ACO and
the initiation of the Remedial Investigation/Feasibility Study (RI/FS). A public
meeting was held on February 21, 1989 in Bridgewater to discuss the RI/FS.
On both occasions residents and local officials expressed concern and anger
that they were bearing more than their fair share of society's waste cleanup
burden. They made it clear that they did not want the Superfund remediation
process to become a mechanism for Cyanamid to site a commercial hazardous
waste incinerator.
Attendees at the January and February 1989 meetings also were confused
about the remedial process at the site. The main cause of confusion is that
some lagoon closures at the site are being handled under the Resource
Conservation and Recovery Act (RCRA) because the Cyanamid plant is an
operating facility. NJDEP representatives prepared a response to these
concerns and forwarded it along with the RCRA response document to public
comments received at the June 14, 1988 RCRA public hearing to those
attending the January and February 1989 Superfund meetings. The subject
of the June 14, 1988 RCRA hearing was the permitting of a permanent waste
impoundment 'for storage of treated materials from the closure of other site
impoundments.
NJOEP held a public meeting in Bridgewater on March 11, 1991 to provide
an update on the progress of the Rl. Residents and officials again expressed
their opposition to any type of incineration at the site. Attendees at the
meeting also raised concerns about the ongoing closure of the RCRA
impoundments and the consolidation of these materials in the new
Impoundment 8 facility. Concerns focused on the location of the new
facility, safety of the liner and air pollution from ongoing site activities.
NJDEP issued a fact sheet addressing these concerns in June of 1991.
Residents' concerns at the American Cyanamid site have been focused through
two local groups, CRISIS and the Bound Brook Citizens Association. In March
1991 representatives of CRISIS expressed concerns regarding a proposed
modification of a Hazardous Waste Facility permit to allow ' storage and
blending of tars from lagoons 4 and 5. ' This permit modification was needed
so that materials could be blended and heated for off-site shipment^for use
as alternative fuel in cement kilns. During the summer of 1991, Mayor
Dowden of the Township of Bridgewater and other local officials and residents
23
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publicly stated that NJDEP was working too closely with ° Cyanamid and
keeping the township in the dark on site activities.
NJDEP' representatives met with Mayor Dowden and other township
representatives in Bridgewater to discuss these concerns and review the status
of remedial activities on November 27, 1991. As a result of the November
meeting, a representative of the Bridgewater Health Department was invited
to attend monthly site remediation progress meetings, NJDEP reaffirmed its
policy of placing site information in local repositories .as soon as documents
were completed and NJDEP offered to meet with township and citizen
representatives before the start of major site activities.
In 1992, CRISIS received a Technical Assistance Grant (TAG) under the
Superfund program from USEPA and hired a consultant to review and evaluate
documents on the ongoing Superfund remedial program. On August 4, 1992,
NJDEP held a briefing for local officials and representatives of CRISIS in
Bridgewater to discuss the planned Surface Soils Remedial/Removal Action
(SSR/RA) at the American Cyanamid Site. Township and CRISIS
representatives were supportive of the surface soil work but asked for
additional information on the health and safety plan for this project which
was provided before commencement of work. During the August 4, 1992,
meeting officials expressed concern about possible pollution of Cuckhold's
Brook during the work and stated that the public was still not convinced that
Cyanamid's ground water pumping system was controlling water pollution at
this site. In an August 31, 1992 letter, CRISIS requested additional
information from NJDEP on other site remediation issues including the
development of the Risk Assessment document, health evaluations,
construction of chemical processing plants as part of the cleanup process, and
proposed ground water cleanup standards. NJDEP responded in a September
8, 1992 letter. NJDEP held a formal public comment period on the SSR/RA
from September 17, 1992 through October 16, 1992. No additional comments
on the SSR/RA were received during this period.
Representatives of NJDEP and USEPA visited the site with Congressman Robert
Franks, Township officials and members of CRISIS on April 16, 1993. In
response to concerns raised about remedial activities at the site by CRISIS
representatives during this visit, NJDEP and USEPA offered, in. an April 20,
1993 letter, to meet again with Bridgewater and CRISIS officials to address
these concerns.
NJDEP issued a Superfund Update for the American Cyanamid site in
December 1994.
NJDEP issued a Superfund Proposed Plan for the Group II Impoundments and
Hill Property Soils in January 1996 and held a public comment period from
January 10, 1996 to February 24, 1996. NJDEP held a briefing with the
Bridgewater Township officials and a public meeting on .February 22, 1996 to
discuss the Proposed Plan for the Group II Impoundments and Hill Property
soils.
24
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C. Summary of Comments Received During the Public Comment Period and
Agency Responses,
At the February 1996 public meeting, CRISIS stated its support for NJDEP's
preferred alternative for the Hill Property Soils. Also, a member of CRISIS
requested information .about American Home Products' plans for -future
development at the Hill Property and the remainder of the site. An American
Home Products representative indicated that the company would like to sell
the Hill Property, but that it has no plans to sell the remainder of the site.
A copy of a .transcript for the February 22, 1996 public meeting is attached
to this ROD.
D. Community Relations Activities at the American Cyanamid Site
NJDEP established information repositories at the following locations:
Bridgewater Town Hall
700 Garretson Road
Bridgewater, NJ 08807 Phone * (908) 725-6300
Somerset County/Bridgewater Library
North Bridge Street & Vogt Drive
Bridgewater, NJ 08807 Phone # (908). 526-4016
New Jersey Department of Environmental Protection And Energy
Bureau of Community Relations
401 East State Street, CN 413
Trenton, NJ 08625 Phone * (609) 984-3081
•Contact: Fred Mumford
NJDEP held a briefing for public officials and concerned residents in
Bridgewater to discuss the corrective action portion of the 1988
Administrative Consent Order and the initiation of. the Remedial
Investigation/Feasibility Study (RI/FS) (January 1989).
NJDEP held a public meeting in Bridgewater to discuss the RI/FS (February
21, 1989).
NJDEP prepared a Community Relations Plan (February 1989).
NJDEP forwarded information requested at the February 21. 1989 meeting to
those attending (April 20, 1989).
"i
NJDEP held a public meeting in Bridgewater to update the RI/FS progress
(March 11, 1991).
NJDEP issued a Superfund Site Update fact sheet in response to concerns
raised at the March 11, 1991 meeting (June 1991).
NJDEP met in Bridgewater with township officials to discuss concern's raised
by Bridgewater regarding ongoing site activities (November 27, 1991).
25
-------
NJDEP held a briefing in Bridgewater for officials and CRISIS representatives
to discuss initiation of the Surface Soils Remedial/Removal Action (SSR/RA)
(August 4, 1992).
NJDEP held a public comment period on the SSRRA from September 17, 1992
through October 16. 1992.
NJOEP held a public comment period from June 30, 1993 through September
12, 1993 and a public meeting in Bridgewater on August 5, 1993 to discuss
the Proposed Plan for Remediation of the Group I Impoundments and
Modification of the Hazardous and Solid Waste Amendments Permit.
NJDEP issued a Record of Decision for the Group I (11, 13, 19 and 24)
Impoundments in September 1993.
NJDEP issued a Superfund Update for the American Cyanamid site in
December 1994.
NJDEP issued a Superfund Proposed Plan for the Group II Impoundments and
Hill Property Soils in January 1996 and held public comment period from
January 10, 1996 to February 24, 1996.
NJDEP held a briefing with Bridgewater Township officials and a public.
meeting on February 22, 1996 to discuss the Proposed Plan for the Group II
Impoundments and Hill Property Soils.
E. Transcript of Public Meeting
Copy of a transcript for the February 22, 1996 meeting is attached to the
Responsiveness Summary.
26
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 8
2 W BROADWAY
NEW YORK, NY 10007-1668
JUN 28 1996
Robert C. Shinn, Jr., Commissioner
State of New Jereey
Department of Environmental Protection and Energy
401 East State Street, CN 402
Trenton, New Jersey 08625-0402
Re: Record of Oecieion
American Cyanamid Superfund Site
Bridgewater Township, Somerset County, New Jersey
Doar Cotnmiealoner Shirm:
The United States Environmental Protection Agency (EPA) ,
Region II, haa reviewed the two draft Records of Decision (RODS),
dated May 1996, for the American cyanamid Buperfund site (Bite),
which is located in Bridgewater Township, Somerset County, New
Jersey.
EPA concurs with the selected remedy for the Group II
Impoundments, which includes the in-plaue containment of waste
material from Impoundments 15 and 16, excavation, en-site
solidification and containment of the waste material from
Impoundment 17, and No Action with Monitoring for Impoundment IB.
In addition, EPA concurs with the decision of No Action with
Monitoring for the Kill Property portion of the site. EPA has
determined that the selected remedies* are consistent with Section
121 of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) based on the administrative record for the
Site. Thit* finding shall not affect EPA1 a right to conduct five-
year reviews of the Site or to take or require appropriate action
pursuant to such review, in accordance with Section 121 (c) of
CERCLA. EPA further reserves the right to take response and
enforcement actions pursuant to Sections 104, 106 and 107 of CERCLA
with respect to the remedy and any additional future work at the
Site.
Sincerely,
atrator
-------
FIGURE 1
LEGEND
FORMER PRODUCTION
WELL LOCATION
CURRENT PRODUCTION
WELL LOCATION
QUARTERLY MONITORING
WELL LOCATION
- — — - CEA uMrrs
AMERICAN CYANAMID COMPANY
BOUND BROOK, NEW JERSEY
HILL PROPERTY
N.T.S.
FILE No. 5772.010
CMOtNCCNS. IMC
-------
FIGURE 2
MfCRCAN CtNMMO
BOUND BROOK.NJ
*
MIL PROPERTY
SAMPUNO LOCATIONS
9CMJC f'Ot
-------
TABtfl
AHC1IICANCVANAMB COMPANY
MM. ntorcmv • AHALVTKAI. DATA aumumr
NJDCPkiVKliM
CXxio O»»rli
»•<*)
I
MB
«
HO
W
MO
NM
10B
NM
80
NO
NM
100
NO
100
900
900
NO
90
WO
NM
MO
NO
NO
BO
MM
NM '
NT*
NM
NM
NM
OWN* MM
«*"•)
40
1000
1
woo
4M
no
NM
MHO
NM
10000
1300
NM
noao
1300
•70S
o.t • .
•
40 .
0»
0.0*
NM
on
9700
not-
040
1
MM
NOO
NM
NM
NM
~*
VCXAH.ES
MMtntmCMoftta
An4m
Butim
THum
TtMXiMM
8CM.WOIA1«.CS>
N»MtMliiu
Mmu«M«n
tVJMlBHl PMIkBB^ta
nuoran*
nmmmtmt
tH»m*m
nuoanBiM
Pvmtt
BOftlBI BlMWIfMMW
OvfMM
Bhp.tll.^.^pX^.
BMMaAV'OTMfW
Obtnnd.lilMtnnn*
H-N-BuMCMMM*
PC**
MOWWNRS*
BOTMMt
OiramlM»fT
-------
AMCMCAN CTANAMO COMPANY
MU MKWCRTV • AMALVTICM. MM suanuurr
Nota
I AH concei*alion an nporttcl in pirn on a dry-weight haiit.
All >amnle* were analyzed for the entire TCL volatile and TCL aemivolalile list Thoae volatile! and Kmivolitiln listed are those which were detected in at leul one lampte.
Inorgania Hated indnde only thoee eneeding NIOF.P foil cleanup criteria.
HS 1.1. J, Mid 4 - Dram atorage pad aurfaceaoih.
HBI. I A. l.and 2A • Boiler Hone tank anbturfaoi aoib.
HB 3.3A. 4. and 4A . Van Home Home lud oil tank.
N/A NTOEP cleanup crfcria not iviiUMe.
J OmfM»rdk|iftMt«ataconm«ntic«belowtheinmmmdeted The reported value h estimated.
U Undetected Concentalioroii below the MDL
B An.lytewaaloundwUanki.aawenastheiampfe.
• Or4yTTOamryie4«r«aootw of potential c«>ri«nina«lwaj a foel oil tank.
**• Based on background toil aanyliMg. chromium, vanadium, and beryllium were determined to be comparable to background.
-------
Table 2-Record of Decision
SUMMARY OF TOXICITY CRITERIA
CHEMICALS OF INTEREST
HILL PROPERTY
AMERICAN CYANAMID COMPANY
BOUND BROOK. NEW JERSEY
Chemical
Volatiles
Methylene Chloride
Acetone
Benzene
Toluene
Xylenes (total)
USEPA
Carcinogenicitv
Classification3
B2
D
A
D
D
Semivolatiles
Naphthalene
2-Methylnaphthatene
Acenaphthene
Diethyl Phthalate
Fluorene
Fluoranthene
Pyrene
6enzo(a)anthracene
Chrysene
Bis(2-ethy!hexyl)phthalate
Benzo(b)fluoranthene
6enzo(k)fluoranthene
6enzo(a)pyrene
Dibenzo(a,h)anthracene
Di-n-butyl phthalate
Butyl Benzyl Phthalate
Inorganics
* Beryllium
Note«:
D
D
0
D
D
62
.B2
B2
B2
62
62
62
D
C
62
i
2
3
Oral CPF1
(Slope Factor)
fmp/ko/davr1
7.5E-3
2.91-2
1.15E+0
1.15E + 0
1.40E-2
1.15E + 0
1.15E + 0
1.15E + 1
1.15E-H
4.3E+0
Oral
RID2
(ma/kQ/dav)
6.0E-2
1.0E-1
2.0E-1
Cancer Potency Factor (CPF)
Reference Dose (RID)
IRIS (1992)
Toxicity values from IRIS (1992)
Toxicity values from USEPA (1991b)
Toxicity values from USEPA as per case-specific guidance (1991/1992)
Analogous criteria
4.0E-3
4.0E-3
6.0E-2
6.0E-1
4.0E-2
4.0E-2
3.0E-2
2.0E-2
1.0E-
2.0E-
5.0E-3
JV24/B2
182S62.H
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Table 3-Record of Decision
Page 1 of 4
HILL PROPERTY
INGESTION EXPOSURE TO SURFACE SOILS
BASELINE CONDITIONS - MAINTENANCE EMPLOYEES
CARCINOGENIC RISKS
AMERICAN CYANAMID COMPANY
BOUND BROOK. NEW JERSEY
Chemical
Volatile*
Melhylene Chloride
Benzene
Semlvolatllea
. Benzo(a)anthracene
Chrysene
Bl8(2-eh)phthalate
Benzo(b)lluoranthene
Benzojkjlluoranlhene
Benzo(a)pyrene
Dlbenzo(a,h)anthracene
•'
Inorganics . .
v
Beryllium
Tola):
Assumed
Exposure
Concentration
(ma/ka drv wt.l
0,006
0.003
0.22
0.28
2.0
0.20
0.18
0.21
0.006
Ingestlon
Exposure
Dosage
fma/ko/davl
5.03E-10
2.52E-10
1.85E-08
2.35E-08
1.68E-07
1 67E-08
1.51E-08
1.76E-08
5.03E-10
1.1
9.23E-08
Oral CPF
fmo/ko/davr1
7.50E-03
2.90E-02
.15E+00
.15E+00
.40E-02
.15E+00
.15E400
.15E401
.15E401
4.30E+00
Cancer
Risk
4E-12
7E-12
2E-08
2E-08
2E-09
2E-08
2E-08
2E-07
6E-09
I
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4E-07
7E-07
arzr/92
192S62.H
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Table 3-Rccord of Decision
Page 2 of 4
HILL PROPERTY
INGESTION EXPOSURE TO SURFACE SOILS
BASELINE CONDITIONS - MAINTENANCE EMPLOYEES
NONCARCINOGENIC RISKS
AMERICAN CYANAMID COMPANY
BOUND BROOK. NEW JERSEY
Chemical
Volatile*
Methylene Chloride
Acetone
Toluene
Total Xylenes
Semhrolatllet
Naphthalene
2-Methylnaphlhalene •
Acenaphthene
Olethyl Phlhalate
Fluorene
Fluoranthene
Pyrene
Bl8(2-eh)phthalate
DI-N4>utyl phthalate
Butyl Benzyl Phthalate
v
Inorganics
Beryllium
Total:
Assumed
Exposure
Concentration
fma/kn dry wt.l
0.006
0.011
0.016
0.023
0.01
O.OOB
0.029
0.022
0.024
0.65
0.98
2.00
0.012
0.038
1.1
Ingestlon
Exposure
Dosage
fmg/hg/davl
1.41E-09
2.5BE-09
3.76E-09
5.40E-09
2.35E-09
1.88E-09
6.81E-09
5.17E-09
5.64E-09
1.53E-07
2.30E-07
4.70E-07
2.82E-09
8.92E-09
2.58E-07
Oral RFD
Chronic
(mg/Ko/dav)
6.00E-02
1.00E-01
2.00E-01
2.00E+00
4.00E-03
4.00E-03
6.00E-02
8.00E-01
4.00E-02
4.00E-02
3.00E-02
2.00E-02
2.00E-01
5.00E-03
Hazard
Index
2E-08
3E-08
2E-08
3E-09
6E-07
5E-07
1E-07
6E-09
1E-07
4E-08
8E-06
2E-05
4E-08
•
5E-05
9E-05
-------
Table 3--Record of Decision
Page 3 of 4
HILL PROPERTY
INOESTION EXPOSURE TO SURFACE SOILS
FUTURE USE SCENARIO - OFFICE WORKERS
CARCINOGENIC RISKS
AMERICAN CYANAMID COMPANY
BOUND BROOK. NEW JERSEY
Chemical
Volatile*
Melhytene Chloride
Benzene
Semhrotatllea
Benzo(a)anthracene
Chrysene
Bl8(2-eh)phthalate
Benzo(b)lluoranlhene
Benzo(k)fluoranthene
Benzo(a)pyrene
Dlbenzo(a.h)anthracene
Inorpfnlet'
Beryllium ^ •
Total:
Assumed
Exposure
Concenlralion
(ma/ka dry wl.l
0.006
0.003
0.22
0.28
2.0
0.20
0.18
0.21
0.008
Ingesllon
Exposure
Dosage
(mo/ko/dav)
1.05E-09
S.24E-10
3.84E-08
4.89E-08
3.49E-07
3.49E-08
3.15E-08
3.67E-08
t.05E>09
Oral CPF
(mq/kd/davl
-1
1.1
1.92E-07
7.50E-03
2.90E-02
.1SE+00
.15E4-00
.40E-02
.15E+00
.15E400
.15E401
.15E+01
4.30 E-I-00
Cancer
Risk
BE-12
2E-11
4E-08
6E-08
5E-09
4E-08
4E-08
4E-07
IE-OB
8E-07
1E-06
3WT/B2
19Z5BZ.H
-------
Table 3-Record of Decision
Page 4 of 4
HILt PROPERTY
INGESTION EXPOSURE TO SURFACE SOILS
FUTURE USE SCENARIO - OFFICE WORKERS
NONCARCINOGENIC RISKS
AMERICAN CYANAMID COMPANY
BOUND BROOK. NEW JERSEY
Chemical
Volatile*
Melhylene Chloride
Acetone
Toluene
Total Xylenee
Semhrolatllet
Naphthalene
2-Methylnaphthalene
Acenaphthene
Dlelhyl Phthalate
Fliiorene
Fluoranthene
Pyrene
Bl«(2-eh)phlhalale
DI-N-bvlyl Phthalate
Butyl Benzyl Phthalate
t
Inorganic*
Beryllium
Tolal:'
Assumed
Exposure
Concentration
fmn/ko drv wt.i
0.006
0.011
0.016
0.023
0.01
0.008
0.029
0.022
0.024
fr.65
0.98
2.00
0.012
0.038
1.1
Ingestlon
Exposure
Dosage
(mo/kq/dav)
2.94E-09
5.38E-09
7.83E-09
1.13E-08
4.-B9E-09
3.91E-09
1.42E-08
1.0BE-08
1.17E-08
3.18E-07
4:79E-07
9.78E-07
5.87E-09
1.86E-08
5.38E-07
Oral RFD
Chronic
fmq/Hq/dav)
6.00E-02
1.00E-01
2.00E-01
2.00E+00
4.00E-03
4.00E-03
6.00E-02
8.00E-01
4.00E-02
4.00E-02
3.00E-02
2.00E-02
1.00E-01
2.00E-01
5.00E-03
Hazard
Index
5E-08
5E-08
4E-08
6E-09
1C-08
IE-OS
2E-07
1E-08
3E-08
8E-06
2E-05
6E-05
BE-jOB
9E-'08
1E-04
2E-04
3CWB2
-------
Attachment 1
Am Cyanamid Site-Record of Decision
Responsiveness Summary
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HEW JERSEY DEPARTMENT OP ENVIRONMENTAL PROTECTION
SITE REMEDIATION PROGRAM
PUBLIC MEETING TO DISCUSS A PROPOSED PLAN FOR
THE REMEDIATION OP THE GROUP II IMPOUNDMENTS
(15, 16, 17 6 18) AND HILL PROPERTY SOILS
PUBLIC MEETING AGENDA
Division of Responsible Party Site Remediation
AMERICAN CYANAMID SUPERFUND SITE
Thursday, February 22, 1996
7:00 p.m.
* ' *
Bridgewater Township Municipal Court
Bridgewater Township, New Jersey
APPEARANCES: .
ROMAN LUZECKY, Section Chief, NJDEP
HAIYESH SHAH, Case Manager, NJDEP
STEVEN J. ROLAND, O'Brien and Gere Engineers, Inc.
J ft J TRANSCRIBERS, INC.
TRANSCRIBER, PATRICIA C. DUPRE
268 Evergreen Avenue
Hamilton, New Jersey 08619*
(609) 586-2311 FAX (609) 587-3599
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MR. LUZECKY: Excuse me, we're ready to start thank
you. My name Is Roman Luzecky, I am a Section Chief with the
Mew Jersey Department of Environmental Protection, in the site
remediation program.
I would like to acknowledge the presence of
councilman Bob Ulvano, Health Officer Dick Martini, and Sharon
Jaffes, EPA Project Manager.
He are here to discuss the proposed plan for the
American Cyanamid site, that presents NJDEP's preferred
cleanup plan, for a portion of this contaminated site. I'd
like to remind you that we have a handout that includes an
agenda, a fact sheet, and a summary of the community relations
program. . \
A meeting evaluation form is also attached, and we
would ask you to fill out both sides, and leave it at the sign
in table, before leaving.
I would also request that anyone who has not signed
in, to please do BO, as we will use these lists for future.
mailings. . .
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We are here tonight to both share information w.ith
you, and receive your comments and questions. This is part of
our commitment, to community involvement that is described in
detail in the community relations summary in the handout
you've received tonight.
On the back of this sheet, is a flow chart of the
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major steps in the site cleanup. And we are at step six now.
The floor will be open for questions and comments after the
presentation. We do have an audio transcriber here to record
our proceedings. This is required under Superfund
regulations. • • •
If you would like to speak, please come up to the
microphone, and identify yourself, and your affiliation
clearly, so the transcriber can hear you.
Also, the fact sheet gives details on wh-r»
submit written comments if you prefer. The comment per-..
officially closes this Saturday,'but comments will be accepted
until Monday. Also, an extension of the comment period can be
requested here tonight, or 'contact us by Monday if you need
additional time. ' '.
We will try to keep our presentation brief, to allow
sufficient time for your questions and comments. We hope that
you will also limit the length of your comments, so that
everyone who wishes to speak has the opportunity to do so.
Please hold any comments and questions until we
finish our presentation. Now, I'd like to introduce Baiyesh
Shah, Case Manager at the DEP Site Remediation Program, who
will present a brief overview of the site history.
Steve Roland of O'Brien and Gere, consultants for
American Home Products, who will discuss the remedial
investigation and feasibility-study, and present the remedial
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alternatives for the site.
* •
I would also like to acknowledge Fred Mumford, the
Department's Community Relations Coordinator, for the site.
MR. SHAH: Good evening everyone. Can you hear me
back there? My name is Baiyesh Shah and I'm the Case Manager
for the American Cyanamid site, with the New Jersey Department
of Environmental Protection.
Tonight, I'll present a brief history of the site,
and the overall strategy for site cleanup, at the American
Cyanamid site. First of all, I would like to mention'that the
American Home Products Corporation, purchased American
Cyanamid in December 1994, and has assumed the full
responsibility for ongoing environmental remediation at this
site. .
The map on the screen shows important features of
the site, and site location. The site was used for 75 years
to manufacture various chemicals, dyes, pigments, and
Pharmaceuticals by using various inorganic and organic raw
materials. Currently, all -- only Pharmaceuticals are being
manufactured.
The manufacturing area is most of the waste
generated from the past manufacturing operations were stored
in the on-site surface impoundments, and the general plant
waste and debris were stored in the West Yard area. This is
West Yard area, and this is production area. And surface
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impoundments are this.
The site was included on the National Priorities
list of Superfund in December of 1982. American Cyanamid
Company and the New Jersey DEP signed an Administrative
Consent Order, which is an enforcement document in May 1988,
which was amended in May 1994. This ACO was signed to address
the site-wide remediation at this site, including all surface
impoundments, contaminated soils, and contaminated ground
water.
The United States Environmental Protection Agency
issued the hazardous and solid waste amendment permit in
November of 1988. This permit is equivalent to the ACO, and
% . "
it's also consistent with the ACO. . \ .
The proposed plan we are discussing tonight,.
preferred proposed plan is equivalent to the RCRA's statement
of basis, since the cleanup at the site is being addressed
under the State Administrative Consent Order, as well as the
Superfund program, USEPA will avoid duplication of effort, and
will not at this time, renew the ESWA permit.
American Cyanamid is currently pumping at least
650,000 gallons of contaminated ground water, to control the
ground water contamination at the main plant, and production
area of the site. Ground water recovery wells are shown on
the map. PW-1 and PW-2.
This ground water pumping has been in operation
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since 1982, and is effectively controlling ground water
contamination at the main plant area of the site. In order to
more efficiently control ground water contamination, the
former production wells, at the Bill Property areas, 6 --
PW-16, 17, and 18, have been relocated to the main plant area,
PW-2 and PW-3.
The residual ground water contamination at .the Hill
Property area, is now being recovered at the main plant area,
through PW-2 and PW-3 ground water recovery wells.
The former recovery wells at the Hill Property have
been converted into the monitor wells, and these monitor wells
are being routinely monitored to verify that the residual
ground water contamination at .the Bill Property is being
decreased by the recovery pumping at PW-2 and PW-3 area.
We have seen between 90 and 95 percent decrease in
ground water contamination. through' the pumping of PW-2 and
PW-3.
American Cyanamid has completed several remedial
programs to date. Including pumpable «•- removal of pumpable
tars from the impoundments one and two, a berm stability
program surrounding main plant and West Yard area, hot spots
removal for surface soil contamination and removal of pumpable
tars from impoundments 4 and 5, blending them on the site, and
then shipping them off-site, for beneficial use as
supplemental fuel in cement kiln process.
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American Cyanamid is currently performing remedial
« .
actions on impoundment* 6, 7, and 8. The remedial
investigation conducted at the Bill Property did not find any
contamination above the New Jersey. DEP soil cleanup criteria,
or the background, therefore no further actions, no further
remedial actions are required at the Hill Property soils.
The site-wide remediation program has been divided
into three units. First unit is surface impoundments. The
*
surface impoundments have been divided further into three
groups. Group X includes impoundments 11, 13, 19 and 24.
Group IX impoundments which is the focus of tonights
discussion includes impoundments 15,„ 16, 17, and 18. And
Group XXX impoundments includes impoundments 1> 2, 3,. 4, 5,
14, and 20 and 26.
A Superfund Record of Decision was signed for the
Group X impoundments in September of 1993. Selecting
solidification and consolidation of solidified material, into
the impoundment 8 facility, as a remedy. Remediation of
impoundment 19, has been complete -- has been completed.
9
Remedial design for the remaining Group X
impoundments is in progress, containing impoundments 11, 13,
and 24.
A feasibility study evaluating different remedial
alternatives for the Group XXX impoundments, -is expected to be
completed in April of this year. The proposed plan we are
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discussing tonight, only addresses Group II impoundments and
the Hill Property soils.
The second unit is site-wide soils. A remedial
investigation for the site-wide soils has been completed, a
feasibility study evaluating different remedial alternatives •
will be initiated after completion of the remediation of all
surface impoundments.
And the final unit is ground water. As I discussed
earlier, ground water is currently being controlled at the
West Yard and production areas of-the site. And since
impoundments and soils are the major source of ground water
contamination, once these sources have been addressed, the
final site-wide ground water contamination will be addressed
at that time. And will comply with all state and Federal
applicable requirements at that time.
Now, at this time, I would like to turn over to Mr.
Steven Roland of O'Brien and Gere, consultant to American Home
Products who will present a review of the studies conducted
for the Group II impoundments, and the Hill Property soils.
Mr. Roland please.
MR. ROLAND: Good evening. Thanks.Haiyesh.
MR. SHAH: You're, welcome. . •
MR. ROLAND: I'd like to first indicate I appreciate
the opportunity to talk to each of you tonight, to share with
you the next step in this fairly complex remedial program. As
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Roman indicated, the comments tonight are very— are very
general overview, that the technical detail .is contained in
the proposed plan, or the reports which are available at the
local library.
As Z go through the Group ZZ impoundments, and the
remedial investigation for the Bill Property, Z'd like to hit
on a few aspects on the overall site remediation at the site.
First off, Haiyesh hit or discussed the current
status. This figure is a little difficult to find *••
•>
basically there are 26 impounds at the site.
Of those there are six which currently have a no
further action required. Four in which remediation has been
completed. Five, in which 'the plans, the remedial plans, have
been approved. And are pending implementation:
The four impounds that we're discussing tonight, and
presenting what remedial alternative is appropriate, for these
impounds, and in the Group ZZZ impounds, which are the
remaining 8 impounds, in which the feasibility study will be
completed by April of this year. • ' .
*
Z'd also like to give you a little overview of the
plans, for what's coming up in 1996, it's a. very aggressive
remedial program. Currently planned are impounds 15, 16, 17
and 18, which are subject to tonight's discussions. •
Completing the remediation for these impounds.
Impounds ,n, and 13 > where the Designs are ongoing.
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and we hope to complete these, the closure of these impounds,
during 1996. And we've also found a potential market for the
remaining tars in impounds 4 and 14. And if this market
proves viable, we would hope to basically remediate and remove
^
these tars, for beneficial re-use, during 1996. ,
Also, the remedial design for impound 6, Lagoon 6,
will happen in 1996. And the completion of the Group III
treatability studies and feasibility study report. As you can
see, 1990 -- this RCRA program for 1996, is budgeted roughly
at 15 to 20. million dollars.
Also fundamental to the. overall remediation at this
site, is a ground water control program. Haiyesh discussed
this during his opening remarks, I'd just like to hit on a few
other points. The production wells are -- currently consist
of two production wells over 300 feet in depth. And basically
have been proven to control site ground water. Pumping rate
650,000 gallons per day, as monitored by DEP. And required by
the consent order.
Quarterly ground water sampling is used to monitor
contaminant levels in various wells at the site. And it is
also used to confirm the containment of the site hydraulics.
The ground water is based --is upon pumping, is used as
non-contact cooling water, and in discharge the 8RVSA for
treatment under the accepted permit with the POTW.
Haiyesh also mentioned that the production wells had
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been moved from the Bill Property down to the main plant. The
other fundamental pieces of the overall remedial program, at
this site, is the impound 8/ waste management facility.
This facility is a state-of-the-art triple lined,
permitted RCRA waste management facility. Okay, it contains
leachate detection and collection systems, which are monitored
monthly. It also has a ground water cutoff wall, and
interceptor trap -- trench, to make sure ground water does not
come in contact with the facility.
Quarterly ground water monitoring is also conducted
along with the leachate collection and detection sumps.
Here's a picture of what the impound 8 waste
management facility looks like. You can 'see the treated .
facility -- treated material is placed over a leachate '
collection system, this collect any leachate that is generated
from the material. Below that is the primary liner. Which
basically is an impermeable liner. Underneath that is a
secondary leachate detection system, if there was ever any
breach in that liner, the leachate would come through and be
collected, and detected by this liner'-- by this layer.
And underneath that, are the secondary and tertiary
liners. Also, as you can see, existing ground water control
system trench around the site, maintains anywhere from 10 to
25 foot separation between ground water and lowest liner.
I do -- just do an overview on the results of the
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remedial investigation, from the Bill Property. The Bill
Property basically consists of approximately 140 acres,
located north of the main plant. Major features include a
former research and development buildings, the main plant
parking lot, the Van Borne house, which is a local historic
landmark. And the majority of the area consisting of open
fields* and woodlands.
Lagoon 23, is also located in this Bill Property,
it's a former de-watering basin for river sediments. Which
received a no further action closure from DEP in 1987.
Remedial investigation was conducted, just like to
review briefly the results. The research and development
buildings had been decommissioned and demolished. They're no
longer at the site.
Three areas of potential concern, were identified
where contaminants were handled. These were investigated, the
results of this investigation indicated that the soil
constituents are below both residential and non-residential
DEP cleanup criteria.
And based on that, concluded that the current and
future risk to human health and environment are below
acceptable DEP and EPA levels.
We also talked about the relocation of the ground
water production wells, which has resulted in a significant
decrease in ground water constituents.
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Ground water will continue to be monitored at this
*
site, under declaration of environmental restriction, and a
classification exemption area.
The first two impounds I'd like to talk about in
Group: ii, are 15 and 16, which are located on the southern
portion of the facility. A remedial investigation was also
conducted, to basically characterize the materials within
these impounds. From this investigation we found that the
• *
impound was used for storage of non-hazardous, iron oxide
material.
Impound 15 is roughly 2.8 acres in size.- A depth of
six to nine feet, and contains approximately 27,000 cubic
yards. • . •
Impound 16, similar, slightly larger, 3 acres, depth
five to 10 feet, and 31,000 cubic yards.
The primary -- the results of the analytical
identified primarily inorganic constituents, associated with
this material. .
Due to that, there is no vegetative cover. We also
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conduct -- or a subsurface investigation was also conducted,
and through that was identified that there's a continuous silt
and clay layer, which underlies both impounds, 15 and 16.
This basically acts as a confining layer, for many
leachate as generated from these impounds. And as such, there
is minimal to no impact identified on ground water in the
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vicinity of these impounds.
The baseline endangerment assessment, is basically
an assessment to determine the risk as they exist in their
current state. Identified only slight human and ecological
risk. Human risk via ingestion, dermal and inhalation.
Again, in its existing stage before remediation. •
Next impound I'd likeato discuss is impound 17,
which is located next to impounds 15 and 16. Impound 17 was
used for storage of non-hazardous primary treatment sludge,
which was generated from the on-site waste water treatment
facility. It's 6.2 acres in size., eight feet in depth, and
contains approximately 67,000 cubic yards.
The material in essence, is a lime sludge, with
trace amounts of both volatile and semi-volatile organic
compounds. And inorganic constituents identified through the
analytical analysis.
This material does support vegetation, there are
small brushes, grasses and small.trees located on this. The
subsurface investigation around impound 17, however,
identified that the silt and clay layer, which was a confined
layer under impounds 15 and 16, was discontinuous underneath
impound 17. . . ;
And as such, it basically has openings in the silt
and clay, which has allowed local ground water to be impacted
in this area. The baseline endangerment assessment identified
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however, that there was only slight human risk; Again, via
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ingestion, dermal and inhalation in its existing state.
Impound 18, is located adjacent to impound 17.
Similar to impound 17, it was used for storage of
non-hazardous primary treatment sludges from on-site treatment
facility. It's a much larger lagoon, 15.4'acres, nine feet in
depth, and totaling over 200,000 cubic yards of sludge.
The material is similar to impound 17, it's a lir*"
sludge, and through the chemical analysis we only />>••-
amounts of volatile and semi-yolatiles, and inorganic
constituents.
This impound has been out of operation for over 30
years, and as such, there is a densely -- it is now densely
vegetated, with well established trees, and what we term a
successive vegetative community in place, currently.
The subsurface investigations under this impound,
did identify the continuous silt and clay layer, and in the
vicinity of this impound, was found to be continuous,
underneath this impound, therefore there was no ground water
impact, associated with this impound, found in this area.
Based on current or future -risk, all were found
below acceptable DEP and EPA levels, in its current condition.
With completion of the remedial investigation, we
undertook the feasibility study, first step of that is to
identify what are the objectives that you want to accomplish.
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Three objectives were identified. First one to eliminate the
potential for the incidental ingestion, dermal contact and
inhalation, the risk -- the minimal risk that had been
identified.
To eliminate or control the sludge material, and
also to contribute to the compliance of ground water ARARs at
the site.
For as we develop these alternatives, this is a
listing of the nine CERCLA criteria, which are used in the
feasibility, study. We used these criteria to basically short
list down to a select number of alternatives.
For impounds 15 and 16 four remedial alternatives
were identified. First one no action,' limited action. Second
in place containment. Third, solidification. And fourth is
recycling.
The no action, limited action is a -- an alternative
that's required to be analyzed as a baseline under the
Superfund program. And would consist of institutional
controls, site security, fencing around the impound, and
ground water monitoring.
The estimated cost is approximately £300,000 and
estimate -- estimated time to implement one month.
Alternative two is in place containment, this would
consist of excavating impound 16 material, placing this
material in impound 15, capping and basically capping impound
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15 then with a synthetic liner, and a two foot soil cover, 00
we can re-vegetate the area.
This cap would be designed to withstand the effects
of-any floods that may happen, in this area,, and would be also
designed in accordance with the requirements.for any
construction in a flood plain.
Also included in this would be ground water
monitoring, and regrading and vegetation of the impound 16
hole that would be left. Costs for this, 2.7 million, and one
year estimated implementation time frame.
Alternative three is very similar, with this
alternative Xn-Situ solidification, the binding of the
material, would happen for both impounds,\and similar to
alternative two, consolidation and impound 15 capping with a '
similar cap. Re-Vegetation of impound 16. And ground water
monitoring.
This alternative was estimated to be 8.6 million and
estimated to take two years to implement.
Impound 15 and 16 was recycling alternative, .this
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alternative is contingent upon finding a viable market for
this iron oxide material. If this market was identified, this
alternative would have consisted of excavation, shipment to
the re-use facility, grading re-vegetation of the area, and
ground water monitoring.
Based on market conditions, this was identified with
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identified costs as 8.1 million, and time to implement would
be dependent upon the final user.
For impound 17 and 18, again four alternatives were
identified. First alternative was the no action, limited
action alternative. Similar to impounds 15 and 16,
institutional control, site security, ground water monitoring,
$300,000 estimated cost, and three months to implement.
Alternative two, basically consisted of clearing and
grubbing impound 17, then the excavation and solidification of
impound 17 material. This material would then be placed up
into the impound 8 facility, that I talked about earlier.
Upon removal of the material, impound 17 area would
be regraded, and basically re-vegetated.
Impound 18, there is basically no further action was
identified. Current condition, it's a well vegetated area.
There was no risk identified associated with impound 18. And
as such, only tree maintenance was identified, in which large
diameter trees, would be removed, so that the roots would not
disrupt the silt and clay liner, underlying this impound.
Site security would also be. included, and ground
water monitoring. Estimated cost 13 .and a half million. And
implementation time to put in would be a year and a half.
Alternative 2A is very similar to alternative two.
The only difference is that impound 18 basically would be --
I'm sorry. The only difference is impound 17 -- 18 -- impound
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17 would be graded, or I'm eorry, excavated, solidified and
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placed in 8.
I'm sorry. And then impound 18, instead of ho
further action, would be capped. Similar to impound 15 'and
16. This cap would be designed to withstand any flood
effects. And design in accordance with the requirements for
construction of flood plain.
This is -- the cost of this. 15.7 million, time to
• •
implement, year and a half;
Alternative three, is more of a consolidation in
place, in which impound 17 and 18 would be grubbed, the top
four feet of impound 18 would be strengthened, so that
material from impound 17 could then be solidified, and placed
on top of 18. This whole impound 18 area would then be
capped, graded, and ground water monitoring. Total cost for
this 14.1 million, and estimated time frame, four and a half
years.
3A is a slight variation of this, in which the --
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all the material in impound 18 would be solidified, and then
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as with impound 17, and then the consolidation of impound 17
into impound 18. Cost, 35.3 million and time to implement,
three years.
The last alternative was just for comparative
purposes, to look at what the cost implications would be if
talcing the largest impound we're dealing with, and putting it
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into the Impound 8, waste management facility.
Thi>* would require also action, by 'impound 17.to be
-- added onto it. But to excavate, solidify the impound 18
sludge, place it in impound 8, estimated cost would be 41.7
million, time to implement, two years.
With these alternatives, we then re-evaluated based
on the nine CERCLA criteria and coming up with the
recommendations, at this point I'll turn it back over to
Haiyesh to present the recommendations for these impounds.
MR. SHAH: Based on these studies we performed, and
after evaluating various remedial alternatives, for Group II
impoundments, and the Hill Property soils, we are recommending
the following alternatives as proposed remedy for' Group II
impoundments and the Hill Property soils.
For impoundments 15 and 16, we are recommending
alternative two, which includes excavation of impoundment 16.
And then placement of excavated material into impoundment 15.
Construction of a cap, synthetic .liner, and ground water
monitoring. . ,
For impoundment 17 and 18, we are also recommending
alternative two, which includes solidification of impoundment
17, and consolidation of the solidified material into the
impoundment 8 facility, and limited action for impoundment 18,
including fencing, routine maintenance, and ground water
monitoring.
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And for tne am.
no further action, with ground water contamination recovery at
the main plant, and ground water monitoring of the Bill
Property.
We are recommending these alternatives because they
satisfy the CERCUL 9 evaluation criteria. And they also meet
the CERCLA threshold criteria, as they are — they will be
protective of human health and the environment, they will
comply with all applicable state and Federal requi--*"
they will be cost effective.
As part of this remedy, a review will be conducted
every five years, to insure that the selected remedy provides
adequate protection of human health in the environment. And
again, as Z said earlier, final site wide remediation program
will insure that there is no current or future unacceptable
risk, to human health in the environment.
With this, we conclude our presentation, and I'm
turning it over to Roman Luzecky.
MR. LUZECKY: Thank you Baiyeah. I'd also like to
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recognize council President DeSensio.
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A SPEAKER: Thank you.
MR. LUZECKY: Oh, I'm sorry.
A SPEAKER: --Council President --
MR. LUZECKY: I'm sorry.
A SPEAKER: That's all right.
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MR. LUZECKY: If you wish to comment, please come up
to the microphone. And state your affiliation, and your name,
.so that the transcriber can hear you. Have any comments or
questions?
MR. GERMINE: Good evening, my name is Thomas J.
Genuine, I'm the Technical Advisor to Crisis, which is the
citizens group that has been involved with this Superfund
cleanup and has gotten the TAG Grant in connection with the
Superfund cleanup of the site.
Very briefly, we have concerns principally with the
cleanup plan for the four Group XX impoundments. We support
the proposed plan for the Hill Property, and we don't have any
real problem with that.
With respect to the Group XX impoundments, our
principal concern is with the location of the impoundments in
the hundred year flood plain, and the fact that though the
impoundments are surrounded by berms, that those berms are not
high enough and. will not be high enough to prevent a 100 year
storm events, and of course greater storm events. Prom
causing the impoundments to be covered with water.
Therefore, we feel that there is an extra level of
care that should be taken, as far as the remediation in this
particularly sensitive area. Because of.the likelihood of
contact, not only with ground water but with river water.
We support the feature of the program, that involves
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the removal and solidification of impoundment 16, and its
consolidation or disposal into the impound 8 facility. We had
some initial concerns about the two other elements of the
plan, namely the consolidation of impoundment 16, into 15..
And the containment in place of impoundment 18.
Our concerns on that score, were first of all
related to the point of the fact that these proposals wouldn't
involve leaving a certain amount of contaminated material in
the flood plain, which we feel for policy reasons, is
undesirable .on the face of it.
And also, the fact that certain monitoring well
results, in the area, were at best ambiguous, as to whether
these impoundments individually or jointly were continuing
sources of ground water contamination.
Our initial response therefore, to the first draft
of the proposed plan, was to come back with the suggestion
that perhaps all of this material would be better removed from
the flood plain area and disposed of into impound 8.
After considerable amount of back and forth review,
and I have to give thanks to Baiyesh Shah, the Case Manager on
this, he was very helpful, and patient with us, in providing
information. We came to see that the --as the consultant had
mentioned earlier, the impoundments 15 and 16 are apparently
underlaying with a continuous layer that has an impermeable
effect and tends to isolate the impoundments from ground
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We feel however, nonetheless/ that with the location
of this in a flood plain, the additional step of
solidification -- In-Situ solidification of the contents of
impoundments 15 and 16 prior to consolidation, into
impoundment 15 would be more desirable.
We also note, from review of the proposed plan, that
the proposed plan rated, this is alternative three, involving
In-Situ solidification. Rated alternative three superior,
both in terms of long term effectiveness, and in terms of
immobilization of contaminants.
We didn't see in that analysis a cost benefit
approach. We recognize that there's a substantially higher
price 'tag involved in the solidification process, and that
normally under Superfund analysis there would be some
consideration given to whether the' incremental environmental
benefit of the solidification would warrant the additional
cost. .
However, I don't believe that there is analysis in
the plan, indicating that there is a negative or adverse cost
benefit return on that additional investment, and again, based
on the fact that we are dealing with a flood plain area, it.
may well be that the additional cost given the recognized
benefit of solidification in terms of immobilization of the
inorganic contaminants, may be a warranted approach.
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And we would ask that that be reconsidered and that
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perhaps a cost benefit analysis be undertaken, on that
particular point.
Turning now to impoundment 18, we recognize the fact
that there is a -- an established Ecosystem there, that we as
O'Brien and Oere has pointed out this evening, there is an
established vegetated community, and well established trees,
on that 15 acres. And that it -- from that perspective, is
undesirable to disturb the area. Which would be involved in
either solidification or capping of that particular portion of
the site. .
Therefore, we are going to support the portion of
the plan involved with in place containment, and maintenance
of impoundment 18, because we believe that it's worth talcing
the opportunity and the chance to try and maintain that area,
in its current condition.
Provided that there be a monitoring protocol which
sets out well defined attenuation goals for the monitoring
program, and by that I mean, that at the end of five years, if
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certain well defined reductions in contaminant levels in the
wells, downgradient from impoundment 18 are not evidenced,
that there would be then a re-evaluation of the remedial
design, with consideration given to potentially capping or
solidifying if necessary.
And that's all, and again I'd like to thank the
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department for being very helpful to myself, especially and
the to the group, in helping us prepare our evaluation of this
plan. Thank you.
MR. LUZECKYt Thank you. Your comments are fairly
extensive, and X won't attempt to address them today, I do
share your concerns about the barms, we have investigated
that, we will be including berm evaluation, and reinforcing
during the design process.
In terms of the cost benefit analysis, we'll include
that in the responsiveness summary. Ha have evaluated the
cost differences, an additional six million dollars. With
minimal incremental benefit for human health in the
environment, but we will address that more.specifically so you
can look at that.
And as far as the defined ground water monitoring
program, we do agree with that also, and it also will be
included in the record of decision.
MR. GERMINE: .Roman, if I might ask, in light of the
fact that we'll be getting hopefully accost benefit analysis,
would it be possible to extend the public comment period, so
that we could respond if we had any comments on the cost
benefit approach, or would that take us. too long, and I don't
know what you're time frame.
MR. LUZECKYt The normal time frame under Super fund
regulations, is 30 days for public comment period. We have
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extended this one for 45 days. We can extend it for another
15 days, without delaying the project too much. We can
probably give you the cost benefit analysis before we do the
Record of Decision. We'll attempt to do that for you.
MR. OERMZNEt Thank you and I do have a written
version of the comments which I'll hand you.
MR. LUZECKY: Great, thank you.
MR. GERMINE: Thank you.
MR. SHAH: Yes, we will provide you with an
opportunity to comment on our you know, cost benefit «....
before signing the ROD.
MR. GERMINE: Thank you.
MR. LUZECKY: Yes.
MS. COWALL: My name is Valerie Cowall, and I live
in Finnderae and I'd like to say one of the members of Crisis
died since we had our last cleanup meeting, she had MS. The
last time I spoke with her, she said her doctor told her MS
may be caused by Mercury poisoning* She wondered if it came
from the contamination in the area. She lived about 300 feet
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from impound 8. . .
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The location of impound 8, has been known to flood,
there are pictures indicating during Hurricane Doria, that
area was under water. Impound 8 1m on Polhemus Lane
approximately 50 feet from the road. Polhemus Lane is the
only way you can reach the water company, sewerage authority,
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trash transfer, and recycling.
The residents of Bridgewater line up alongside
impound 8 during spring cleanup when they use the trash
transfer. You need to address the problem of being able to
get in there to clean it up without harming the residents and
businesses if it leaks.
One of your proposals is to recycle the metal from
the compounds to be cleaned up, that to me' is the best way to
go, but only if contaminants are removed, and no one else's
health is in danger. No toxic should be put in impound 8.
I realize the DEP is doing its best, I know American
Home Products wants the best for their employees and the
residents of the area. I pray for a safe solution, I pray for
the DEP and American Home Products to find it, and I thank you
for your help.
I'd also like to add, that there are many smoke
stacks at the American Home Products plant now, when they're
manufacturing a product, it -- and it's a cloudy overcast day,
the plant is covered in a white haze.
You can't catch a breath of fresh air. It's like
being behind a car with a bad pollution problem, or a smoker,
blowing; cigarette smoke in your face, and we all know how
harmful that is to our health. X would, like a printout of all
the chemicals being emitted from these smoke stacks, and the
effects on our health.
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American Cyanamid had left American Home Products
with a smoky unhealthy operation, and better, pollution
controls should be put on the smoke stacks now. And I'd also
like to know impound 8 what kind of toxic would be put in
there now. . .
Is there going to be Mercury, or --
MR. LUZECKY: There is no Mercury at the site. All
investigation that has been conducted, to date, shows that
there's no Mercury contamination at the site. So.
MS. COWALL: My main concern is impound 8 is. very
close to my home, and it just feels like we have a lot of
health problems in Pinnderne and I know you're trying to
address them, and I know you're doing the\best, but --
MR. LUZBCKY: All the waste that goes into impound'8
is solidified with some type of cement material, prior to
placement.
MS. COWALL: I didn't understand that.
MR. LUZECKY: And after placement is completed, and
the impoundment is full it will be capped. So there will be
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no exposure to the environment, from that impoundment.
MS. COWALLt Thank you.
MR. LUZECKY: Thank you for your comments. Yes.
MR. DeSENSXO: All right, my name is Prank DeSenaio,
I'm a Bridgewater resident, I also happen to be a Councilman,
the record should reflect that our Council President, Mr.
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Harrison left the meeting, because he does not want to have a
quorum here, while I make my comments.'
I wasn't going to say anything tonight, but after
listening to Mr. Genuine comment about impoundment 17 and 18 a
thought struck me. During the Doria flood, that whole area
was under substantial amounts of water. And I know it was
nine feet, because Z worked there at the time, so my .office
was under five feet of water, so Z know that the problems they
had.
And Z'm a little bit familiar with the use of slurry
cutoff walls, and capping for landfills, which are normally
above grade, and don't get inundated. And the question that Z
would have is in your review of the structural integrity of
these impounds, if they're going to be used to store the
solidified material, are you going to take into account, the
hydraulic and stress effects of having the entire site
inundated where the cap might be breached, and then the slurry
cutoff wall, is in the sense act as a tub. And entrap the
water, and prevent it from draining out*
And how that would be dealt with, if that were to
happen. . .
MR. LUZBCKY: He did discuss that, and we did look
at it, we've looked at designing spill ways, where if the
impoundments are inundated with flood waters, the waters can
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go over the spill way without compromising the cap, or the
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berms, and once the flood recedes, the water can then drain
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from the impoundment. So we have considered that. Thank you.
I was also told that it'll be designed for a 500
year flood. Hopefully we won't see one. • • "
MR. HAMMERSLAG: My name is Pete Bammerslag, and I'm
a Bridgewater resident. I'm also a member of Cris'is. When
you responded to Prank DeSensio, by saying you have considered
that, what does that mean, that you have considered it? In
terms of implementation?
MR. LUZECKY: That we looked into it, to implement
that type of design, is what I meant by considered it.
MR. HAMMERSLAO: Meaning --
MR. LUZECKY: That we thought about it also. Just
as you have..
MR. SHAH: It's going to be implemented, yes.
MR. HAMKERSLAG: It will be implemented?
MR. LT7ZBCKY: Correct.
MR. HAMMERSLAO: Okay, that's clear. I'd like to
follow up on the flooding aspect a little bit, X have two
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photographs which are photocopies of. photographs, so they're
not particularly clear. Well, they're fairly clear. They're
not as clear as I'd like, they're from a report prepared by
the US Geological Survey, in 1972, entitled Floods of August
and September 1971, in Mew Jersey.
And this is available at the library. I have taken
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the liberty of marking many of the impounds in red Flair pen.
And they're pretty accurate.
I've used a map that I've had, .which I think I
acquired at one of the last hearings, and I'd like you to take
a look at all of the water here, there's no telling
particularly where the water has come from, whether it's rain
water, or flood water. But we all know how close most --many
of these impounds and particularly the Group II ones, are to
the Raritan River.
With a copy of the cover page. You could see, on •
impound 16, impound 15, I think I might have 15 and 16
switched on one of those. There's a breach in the berm, and
of course this is 25 years ago, I don't know what condition
those things are in now. I'd like to think they're in a lot
better condition, but you could see lots and lots of water.
I wonder if you have seen these kinds of photographs
before, and have considered this amount of water, in that
area. There were reports 'at the time, that the Raritan River
was 40 feet above its banks, that it was 16 feet above
previous flood levels, that American Cyanamid couldn't
function for several months, although I'm sure Frank DeSensio
was back at work the following week. .. •
And that all 150 buildings were flooded. Does
anything that I've showed to you, or said to you affect what
you- have considered up till now?
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MR. LUZECKY: He are aware of the flooding
conditions that occurred in the seventies, no additional
material was placed in these impoundments since that time.
And they're still standing there today. So they withstood
that flood. Those berms will be re-evaluated and re-designed
to withstand a 500 year flood.
MR. HAMMERSLAO: Okay.
MR. SHAH: For impoundments which will remain in "!"
year flood plain, we would upgrade the berms, •urr.'Urt'"
impoundment 18, and 15, to withstand a 500 year flood.
MR. HAMMERSLAG: Okay. Since you're going to be
doing that, I won't take issue with your statement that those
berms withstood those floods. Because some of them are
clearly breached.
MR. LUZECKY: I'm not disagreeing that they are --
aren't breached, what I'm stating is that the flood occurred
and that the berms still exist today.
MR. HAMMERSLAO: Okay. Has anybody -- did anybody
monitor these berms and the extent of flooding on last month's
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X believe it was January 19th, flooding, which of course was
nothing like that. But --
MR. LUZECKY: Yes, I --
MR. HAMMERSLAO: -- is a fairly recent maybe small .
flood.
MR. LUZECKY: Yes, those flooding conditions were
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monitored by Z believe the township health department/ Chris
Paulson, I believe was out there, during the worst times.
MR. SHAH: And Tim Farrell.
MR. LUZBCKY: And Tim Farrell.
MR. SHAH: From American Home Products.
MR. HAMMERSLAG: Okay. Maybe afterwards, he could
fill us in on what he saw, or they could fill us in on what
they say. How did you determine that the clay and silt
underlayment under 15 and 16 and 18, but not 17, is
continuous? And unbroken?
MR. SHAH: Based on subsurface hydro geological
data, we had soil borings, through the impoundments, and based
on the information we received through that.
MR. HAMMERSLAG: Okay, was that a DEP done project,
or was it a engineer consultant done project.
MR. SHAH: No, consultant -- consultant done project
but it was reviewed in full by DEP.
MR. HAMMERSLAG: Okay, just out of curiosity, and --
impoundment 18, for example, which is 15.4 acres, how many
•oil borings would you have done in an area that large, to
satisfy yourselves that it's continuous?
MR. SHAH: Right, X mean we — Z forget the exact
numbers and -- and Z don't remember from the top of --
MR. HAMMERSLAG: Does Mr. Roland know?
MR. SHAH: No, because they weren't involved. ' They
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are new consultants.
MR. HAMMERSLAG: Oh, this was the previous --
MR. €HAH: Yes.
MR. HAMMERSLAG: -- group.
MR. SHAH: Previous consultant. Yes.
MR. HAMMERSLAO: Okay. . ..
MR. SHAH: Z mean, I can get —
MR. HAMMERSLAG: You've been very helpful and
straight with us, we feel, you're satisfied that it's there?
MR. SHAH: Yes. Because X reviewed the information
and X think the numbers they used -- X wasn't involved, X did
not approve that, because X became Case Manager in 1990.. And
this was done prior to that, but my Section Chief he was
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project manager at that time, and subsequently to that, X
viewed the information, and I feel — X feel confident that
the numbers they used, is still appropriate.
MR. HAMMERSLAG: Would those numbers be available
for Mr. Genuine to review? . •
MR. SHAH: That is correct. They were included in
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the CMS/FS report.
MR. HAMMERSLAG: Mr. Roland referred to impoundment
15, as storing "non-hazardous" iron filings, and such things.
My information indicates that there are significant heavy
metal contamination, maybe X missed something because I'm not
a environmental technical type person, not technical at all.
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But I have things such as arsenic, chromium, lead, copper and
nickel contamination in that iron oxide material, could you
clarify your statement please?
MR. ROLAND: Sure. The term hazardous waste is a
RCRA defined term, based on specific testing criteria.
Although there may be metals present, there are standard,
there are threshold levels, which will determine whether it's
classified as a hazardous waste, or non-hazardous waste. In
this case, that testing found out that it was below the
threshold and therefore, classified as a non-hazardous waste
material.
MR. BAKMERSLAG: Okay, so you wouldn't say that
there's nothing dangerous there, but it's not using the
technical term, hazardous, didn't quite meet that level. Is
that fair to say?
MR. ROLAND: Yeah. Yes.
MR. HAKMERSLAG: Okay. Somebody mentioned while
Mrs. Cowall mention mercury, and a few people said there's no
mercury there, X have something that indicates that in
impoundment 17 and/or 18, there's 101 parts per million -- oh,
here it is. 17 has 101 parts per million, and 18 has 254
parts per million, maybe they're not significant hazardous
wise of mercury, is 'that true?
MR. SHAH: Cement's in the bottom impoundment they
not in ifflp^^Tt^T"**"^ 17 and 18 •
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MR. HAMMERSLAG: Okay. Isn't 17 --
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MR. SHAH: There is no mercury in impoundment --'
MR. HAMMERSLAG: -- going to be solidified and put
in 8?
MR. SHAH: Right.
MR. HAKMERSLAO: Okay, so 17 having 101'parts per
million, of Mercury, maybe when it's solidified it'll be
harmless essentially?
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MR. SHAH: Right;
MR. HAMMERSLAGt But I don't want anybody to feel
mislead when I see something that says mercury. There is
mercury out there, right?
MR. SHAH: Right. .
MR. LDZECKY: That would be my mistake. .When X
asked Haiyesh the question, I wasn't clear on his -- I didn't
understand his question, or his answer clearly. And Z made
that statement incorrectly.
MR. HAMMERSLAG: Okay, Z just wanted to clarify
that, to make sure Z have correct information and that Mrs.
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Cowall understood the response to her question.
How does a cap avoid flood problems? How does a cap
that again, non technically, Z would think would go over the
top of some of these materials, the term Z think used by Mr.
Roland was would control flooding or in the flood --in the
flood plain, something about the cap insuring that what's
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underneath it, doesn't get flooded. IB it in the method of
securing to the ground?
MR. LUZBCKY: Maybe --
MR. HAMMERSLAO: Well, could you give us a quick,
two second, two minute explanation of how caps deal with flood
waters?
MR. ROLAND: Sure. The concern on capping in a
flood plain, is catastrophic failure, which would lead to a
release of the material. The flood study that was conducted,
evaluated both 100 and 500 year flood, in determining what the
velocity of the water which is the erosional, which is what
causes erosion.
Was identified that on a 500 year, flood, the maximum
velocity you're going to see, is approximately 1.8 feet per
second of water. So in your cap design, what you would design
is a system through vegetative growth, and your synthetic
liner. That would be able to withstand that ^»*1T""™ velocity,
such that there's minimal to no erosion associated with any
flood event. '
MR. HAMMERSLAO: Okay, so it's erosion, by basically
water speed, rather than like infiltration of the flood waters
themselves?
MR. ROLANDt That's correct.
MR. HAMMERSLAG: Is infiltration of the flood waters
a problem in this area, being so near to the river?
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MR. ROLAND: No. Basically right now you have a
situation with four impounds that are open, and subject to
flooding. And the results of the remedial investigation
except for impound 17 identified minimal to no ground water
impact, in this area. •
And what we're looking to do, is basically improve
the area, through cap -- consolidation and capping, so that
even though we're seeing minimal to no ground water impact
now, what we will do will even improve it that mucV *'
MR. HAMKERSLAG: What does ground water impac.
when you're not dealing with a flood?
MR. ROLAND: I think the concern is you have sludge,
and iron oxide materials. The concern is the release of those
materials into the environment. Whether it's through a
catastrophic release, such as a breach of a berm, and
releasing the material, or a release to the ground water. And
I think the cap will be designed so that erosion will not be
an issue, it will not cause the catastrophic breach, and that
the ground water will only improve with implementation of this
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remediation, remedial alternatives.
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MR. HAMMERSLAOs Okay, that's as far as my
non-technical questioning lets me go on that one. I'm almost
done with my questions. When we --when you talk about long
term monitoring, and long term maintenance, what kinds of
terms are you talking about?
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MR. LUZECKY: He would evaluate this —we would do
monitoring on a regular basis, for a five year period. Then
re-evaluate the results, based on that monitoring, and
determine the next course of action. •
MR. SHAH: Can X --
MR. LUZECKY: Sure.
MR. HAMMERSLAO: Okay, so it's -- oh, I'm sorry.
Did you want to add to that?
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MR. SHAH: Actual definition for short term
monitoring is a five year duration, during the five year we
would monitor the ground water on a quarterly basis. And long
term monitoring, would include at least 30 year monitoring
program.
For first five years in the long term monitoring,
ground water would be monitored on a quarterly basis, and then
would be re-evaluated at the end of the five year period to
determine the frequency for the remaining years from five to
30. And also the parameters.
MR. HAMMERSLAO: So 30 is the long term period?
MR. SHAH: Yeah, that's defined in their National
Contingency Plan, in Superfund.
MR'. HAMMERSLAO: Thank you. X read something in the
paper about American Home Products wanting to sell the
property* X don't know if they're interest in selling the
Hill Property separate from the manufacturing property. But,
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how do they propose to sell the manufacturing property with
all of these impoundments that will be ringing three sides of
it. Maybe when they get a chance they can answer that.
MR. LUZBCKY: Pat Welsh from American Home Products
is here, maybe she could address it.
MS. WELSH: Is there some confusion the American.
Home would like to sell the Hill Property, but there's no
plans at this time at all, to sell the manufacturing property.
' MR. HAMMERSLAG: Okay.
MS. WELSH: So.
MR. HAMMERSLAG: Maybe I misunderstood the article.
Okay, Z think that's all Z have, thank you for your responses.
MR. LUZECKY: Well, thank you. \Does anyone else
have any comments? .
MR. SIMPSKY: My name is Oreg Simpsky, and I'm a
resident of Pinnderne, Bridgewater area there. My first .
question would be during the excavation of the impound areas,
to put the capping and the liners what if any possible
contaminants in the air, would be released? That might get
quite windy, because these areas here haven't been disturbed
through 30 maybe 50 years. So has any consideration been made
to anything released in the air.
MR. SHAH: Yes. Air monitoring program is part of
all of these alternatives, requiring excavation, and
installation of cap or any other these kinds of things. We
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have completed remediation of impoundment 19, and we have
extensive air monitoring program, with a contingency plan and
Crisis also reviewed the information, and provided input in
development of the work plan for our monitoring also. So we
would have -- for this impoundment we would have extensive air
monitoring program also.
MR. SIMPSKY: Okay, my next question would be based
on the condition of the property, below the Bill area, what --
it's current commercial viability, based on -- you know, the
contaminants and improvements that.'11 be made in the coming
year, is that a judgment made by the township, or is the EPA
get involved with it's future usability based on its
contamination. .
MR. LUZECKY: I think the property owner would
consider the future use of the site. We are interested in
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remediating the site. For industrial purposes, or
residential. But after that any further development would be
up to the property owner. *
MR. SIMPSKY: And is that all contingent on the
changes that are made to the contaminated areas that has a --
an effect on what it could possibly be used for?
MR. LUZECKYt Hell, I'm -- any remedial actions that
are -- we're looking for the best protection of human health
in the environment, when we select an alternative. We don't
look at its commercial viability, per se. I'm certain that if
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it cost a little bit more to move or treat an impoundment
differently, for a future development, that the company would
probably do that.
MR. SIMPSKY: Okay, thank you. •
MR. McKEOWNt Hi, my name is Cameron McKeown, I'm a
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neighbor of the site, in Bound Brook, two things. * One,
everybody that lives anywhere near the site, knows that
there's a lot of activity with off road vehicles, recreation .
vehicles, big trucks, that takes place south of these ponding
areas, and the river.
And I'm wondering, I know it's a very difficult
thing with the railways there, to try to do something about
the -- these vehicles, but I can't believe they're doing any
good to the berms, can't believe that it's a great.thing that
a Superfund site's a recreation area.
MR. LUZECKY: Right, and that's one of the main
reasons that when we are -- when we evaluated the
alternatives, for impoundments 15 and 16 and 17 and 16, we
chose to cap them, to minimize or eliminate the exposure to
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airborne particles, and also to fence that area. It's the
best we can do to prevent off road vehicle use.
MR. McKBOWN: Well, just as one suggestion, the --
apparently DBF issued permits to the water company, t'o install
huge sewers, that run along the Raritan, between Bound Brook
and Bridgewater. And the installation of these sewers
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required some sort of road improvements that more or less go
along the Raritan.
These things just function now, as freeways, for off
road vehicles. ' And I must say they - - the lower portion of
Middle Brook is being severely impounded, by quite large
vehicles. Going up and down the banks, eroding them, seems to
me that if DEP took a look at what's going along -- what's
happening on the southern side of Bound Brook, to the banks of
the Raritan, and what's happening in both Bridgewater and
Bound Brook, along the lower regions of Middle Brook, that
you'd be very surprised. Unpleasantly surprised.
That's just on the other side of 287 there, 287 is
over Middle Brook in some parts. Okay,
MR. LUZECKY: Okay, we'll look into that, thank you.
MR. McKEOWN: Okay, good. And the other thing I
wanted to mention is that for people that live in Finndeme
and Bound Brook it's -- it's very difficult knowing what we
do, about the potential for flood, to conceive that these
berms are going to be a safe as reported.
X mean it -- we don't say that we're experts in the
science of building these things, but just to give you a
couple of figures, the flood event that we had in January
apparently was a one in ten year event. And there was
flooding in parts of what's called the Hill Property here. So
on the other side of Mew Jersey Transit there was some
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flooding.
The flood in '73, which I think was larger than the
one in '71, wa> only an 80 year event, and in terms of our
local economy here, that was huge, so to go from that 80 year
event, to a 500 so five times as large, or more than five. It
would be engineering for quite a catastrophe.
MR. LUZECKY: That's right. We are supposed --we
are engineering for 100 --is it a 100 year or 500 year flo~-"
MR. ROLAND: It would be a 500 year flooJ. '
the criteria used in the design. For the berm protect*-
MR. McKZOWN: All right, and just to follow up on
the last person's question about the effect of flood on these
berms, do 1 understand correctly that the only danger from
flood is that --is erosion?
That the -- the increased amount of water in the
soil, for a very extended period, the flows of waters subsoil,
that will be affected by the increased drainage, and stuff,
these don't pose any additional dangers, to what we're
proposing here?
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MR. ROLAND: Yeah, that was the aspect of looking at
you know, is there infiltration and a leachate generated from
that.
Currently, you have a situation with all the
impounds that during a flooding event, when the pictures
indicate here, that the berms have been breached, and they're
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filled with water. You basically have a situation where you
have a continuous potential source of creation of leachate.
What we have found through the studies, is that in
an open condition now, we found -- excuse me -- minimal to no
impact on ground wattfr, which is where'you would see that
potential leachate.
What we're proposing with this remediation, is to
basically create a situation where the flpod waters will not
openly flow into an impound but rather flow either over the
top or around the impound.
MR. McKEOWN: Right. Right. But it would seem like
there would have to be consideration of a difference in the
way contaminants might get into the ground water, through a
flood event.
That is to say, if you test for leaching, which
would be mostly vertical, when there's no flood, right, that
would be a different situation, from when the ground is super
saturated, and there would be leaching going out sideways,
right?
MR. ROLAND: In either case, you can end up with
basically what's called saturated condition. And then they
will —• which means this water impregnated in the materials. .
And they will stay that way until it drains out, as leachate.
But what I can tell you is that the situation now
has been identified to have minimal or no impact and theh
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implementation of this program will improve this situation out
there. So it will only get better.
MR. McKEOWN: Thank you.
MR. TDTRONI: John Tutroni, Bridgewater/ I have one
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question. Adjacent neighbor to this property is Elizabethtown
Water, are they issued an opinion, on the remediation of your
current plan?
MR. LUZECKY: No they have not.
MR. TDTRONI: Do you anticipate to receive one.
MR. SHAH: Well, we provided -- they're on our
mailing list, and they received this proposal, and we have
established a public comment period, and if they have any
concerns they will, they can certainly, submit their comments,
but to date we haven't received any comments from them.
But they are fully aware of what's going on at this
site, because their site is actually under another DEP
program, and last week they called another program, at DEP to
say that contamination they had at the property or ground
water contamination they had at the property may be remediated
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by the pumping of -- ongoing pumping of American Home
Products.
So, I mean, they are fully aware of you know, what's
going on at this site, and they are fully aware of this.
proposal, but they haven't provided any comments to us
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specifically on this proposal.
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MR. TUTRONI:. Will you -- do you plan on soliciting
them for an opinion. '
MR. LTTZECKY: We can out reach to them one more time
to see if they have any comment* on the proposed plan.
MR. SHAH: Right. . .
MR. TDTRONI: Thank you.
MR. SHAH: Welcome.
MR. SODEY: May X use the lectern. My name is Walt
Sodey, I'm the Executive Director of. the Citizens Group
Crisis, really more of an Advisor to the Oroup. We had to
give' ourselves titles and incorporate when we applied for the
Grant. And make it a little more formal.
As an Advisor of the Group, I've spent quite a bit
of time on these plans, for the last three years, and also
quite a bit of time probably even more time, talking to people
from the group, as to their feelings.
And it's my job to explain in a little bit more
detail, why the Group has taken the position its taken, which
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is in support of our technical advisor, Mr. Genuine's
recommendation. The Group formalized that position at a
meeting we held on February 6th, by the way. Just for the
record. . .
Crisis, I think you would have to agree has been
very diligent in not being alarmists, about this project.
Which is a factor that I think you sometimes find with
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environmental oriented groups that are monitoring a particular
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project of concern.
We've tried to be not only reasonable, but we've
tried to maintain a good line of communication, with DEP,-
between these public meetings, because we found out that that
approach enabled all of us to come into these meet'ings much
better informed of each other's positions and better able to
respond to them. . . '
And I also want to commend a job that's been done by
this particular section of the Department of Environmental
Protection, because they have Kept us informed, they've been
very responsive. Any time that we've had inquiries to make,
and really we have no complaints at all, in that regard.
The only things that I have to relate to.you are I
think a little bit more detail on why our members remain
concerned.
About some of the factors involved that Mr. Genuine
addressed, and why we would not only like to see some of the
extra protections, put into your proposed plan, that Mr.
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Genuine has suggested, but also in one respect where it may
even be a benefit to the company itself, to do so.
In reviewing these official documents and kitting
and listening to comments made in support of the plans at
these public meetings, and this goes back to -the first one
that I think was held in 1991. If I'm not mistaken, almost at
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this time of year.
Which was really before any plans were proposed, but
you were into the feasibility studies, Z think it was the
impoundment characterization program. Which had been the one
that was most recently released then.
Then we had the public meeting about two and a half
years ago, on the Oroup X impoundments.
If you sit and listen to the comments that are made
in support of the plans at those meetings, the impression
tends to come across, as though you're saying that there's no
real danger from the site.
For instance, in using the term non-hazardous, we
realize that you're correct. In terms of ,the definition, how
RCRA and how Super fund defines what is hazardous, I guess it's
really more RCRA. That some of this material is not
hazardous.
But at times, that you almost seem to be saying, and
X know you're not, that the material is not dangerous. This
concerns members of our Group.
And it concerns us in terms of some things that come
my way, that X initiate and bring to the Group, and it -- and
probably more cases, material that the Group brings to me;, and
calls to my attention. Really is a two way street.
And X just like to read a couple of these, and you
can: interrupt me, after each one if you'd like to comment on
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them. If you feel that we're misrepresenting anything.
But, just to read from one publication of the £PA,
it's called setting the record straight, was.a response to
myths about Superfund, it's dated April 3rd, 1995.'
I'm just taking one of their facts out of this.
"Superfund sites do pose a serious threat to communities,
public and economic health and to the environment. Analysis
by the Agency for Toxic Substances, and Disease Registry,
demonstrates that people are being exposed to haza-d
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individuals presented testimony, who identified as medical
experts.
They said that people living near hazardous waste
sites, may suffer more health problems than the rest of the
public. That according to medical researchers.
They cited growing evidence to support a link
between releases from waste sites, and a small but increased
risk for developing adverse health affects. And so on.
If you'd like, X believe I have an extra copy of
this, that .1 can enter into the record, but again, it's a
general statement, it's not reflective of any statement that
was being made toward this site by any means. And I don't
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want to represent it as such.
I -- I'm only bringing these things up now, to give
you better idea- why the Oroup feels that when we propose an
extra measure of protection, beyond what the company
apparently would like to see, beyond what their Advisors,
their environmental consultants would like to see, that we're
doing it not so much you know, out of the desire just to spend
the company's money, simply for the sake of seeing a more
expensive plan implemented.
But by virtue of the fact that we feel the extra
protection would alleviate fears such as those raised in
statements and testimony. Such as these.
We also had a point brought up by one of our members
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at the last meeting, in terms of the company's own posture on
this, whether by implementing a plan with a greater degree of
protection, while it would cost in some cases, millions of .
dollars more, wouldn't this give the company some measure .of
protection against potential future liability, should
something go awry, with a plan that's implemented with lesser
protections and the company then being exposed to lawsuits, of
any nature.
Whether it be a Group action, or some other type of
action, legal action that might be filed against them?. In
some cases, an investment of a couple million dollars up
front, could potentially save tens of millions of dollars in
legal liability down the road. ..
The only other point that I had in -- the public
meeting two years ago, two and a half years ago, was August of
'93, on the Oroup Z impoundments, when we had asked for again
for a greater measure of protection, that was offered in that
plan.
We did reach certain accommodations concerning the
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long range ground water monitoring, and that there was a more
specific statement put into the Record of Decision, on the
commitment to long term site wide ground water remediation, Z
believe it is.
There was also a suggestion made at that meeting,
that in terms of impoundment 8, which the expanded section was
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not completed yet. That a bettenite blanket be added to the
triple liner.
We were told somewhere along the line, that the
company had decided to do that, but we never received any
notification that that had been done. Or not. Is there
anything that --
. SHAH: It has been done.
MR. SODEY: The bettenite blanket does exist then?
MR. SHAH: Yes.
MR. SODEY: In impoundment 8.
MR. SHAH: In the newer cells.
MR. SODEY: Okay.
MR. LUZECKY: Hell, .excuse me, I would like to point
out that the focus of this meeting is the Group II
impoundments.
MR. SODEY: Right.
MR. LUZECKY: So if you can keep your comments to
that, we can handle your other issues and concerns any time,
you know, you're welcome to call us.
MR. SODEYi Right.
MR. LUZECKY: But for the purpose of this meeting,
if you can just direct your comments to the Group II
impoundments, I'm sure the public and we would certainly
appreciate that.
•
MR. SODEY: I did that only because you still you do
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have one of the impoundments under your recommended remedies/
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going into the contents of that impoundment.
Going into number 8. Which I felt would be a
consideration for us, and any further remark we may want -to
get to, you after the meeting.
Also with regards to the concerns that nave been
raised on flooding. And potential effects on the impoundments
in Group XX.
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Has there been any recent delineation of -- I know
over time/ with development, the flood parameters changed/
have there been any updating of the delineation for the flood
plain, for the -- for this site, in this region?
MR. SHAB: Two years ago,' something/ when we had---
MR. LUZECKY: We'll get you the exact date, but a
delineation has been made.
MR. SHAH: As part of first evaluation for Group XX
impoundments, they included a history of flood events, and
then flood assessment was conducted.
Also the company is required to assess this flood
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condition as part of their remedial design program for
selective remedies, where they going to have to conduct
remedial actions in the hundred year flood plain.
So, recently for impoundment 19, they submitted
stream encroachment permit to DEP, and they had to re-evaluate
flood assessment information as part of the application
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process, which was done recently, about two years ago.
MR. SODEY: Would this show in any of the
documentation that we have, or not?
MR. SHAH: No, because that's a separate permitting
program. But that's public information you know, at DEP, you '
can review that information.
MR. SODEY: So if Mr. Genuine wanted to review that
then we could make arrangements. Okay.
MR. SHAH: Of course, yes.
MR. SODEY: Good, then one final question, in
regards to the recommendations that our technical advisor has
made, which are supported by our organization, what will the
DEP be doing, in response in terms of evaluating bur position.
MR. LUZECKY: We will be taking all comments that we
received today, and consider all of them in the selection of
our final remedy.
MR. SHAH: And as suggested by Tom Genuine, we will
evaluate or will perform cost benefit analysis, for his
recommendation in detail, and will present that information
for his review, before we select a remedy and finalize the
Record of Decision.
MR. SODEY: You may have stated it earlier, and I
could have missed it?
MR. SHAH: Yes.
MR. SODEY: Do you have a time that you're
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estimating a Record of Decision will be published?
MR. LUZECKY: Depends on the responses to these
comments, and any other written comments that we receive,
before the end of the public comment period, so that it
depends on the extent of those comments, how long it will take
us to finalize the Record of Decision.
MR. 80DEY: Mr. Genuine raised the possibility of
extending the public comment period, do you feel Tom, that
based on what you've heard that there's a need for th?
MR. GERMINEs Well, I think it's adequate as .
has stated, if we have an opportunity to review and comment or*
the cost benefit analysis, before they finalize the ROD,
that's certainly better than even having the opportunity to
comments. •
MR. SHAH: It's on the Record, and then --we have
stated that so I mean, you know is there any reason for
extending the public comment period —
MR. OERMINE: I don't see that's superfluous.
MR. SHAH: We won't sign the ROD, you know, without
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giving you an opportunity.
MR. SODEYt You have nothing else to submit then?
MR. GERMINE: X don't have any problem with that.
MR. SODEY: Okay, all right, thank you.
MR. LUZECKYt Thank you. Any other comments?
Questions? In closing, I'd like to reiterate that this
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meeting is part of our ongoing community relations outreach
program.
We have a strong commitment to two way
communications with you, and if you have not already done so,
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please complete our meeting evaluation form, and sign the
attendance sheet, so we can include you in the future
mailings, regarding this site.
After all comments are. received/ during the public
comment period, DEP and EPA will select the remedial
alternative. This final selective remedy will be presented in
the Record of Decision.
Copies of the Record of Decision will be available,
and the same repositories listed in the proposed plan, and
those are the public library, and the Township Ball.
An announcement of the Decision will be sent to
everyone on the mailing list, likely this spring or summer,
depending upon the number and complexity of the comments that
we receive, and must evaluate.
If all goes according to plan, the next time you
will hear from us, will probably be in the fall of 1996, to
discuss that proposed plan, for the Group IZZ impoundments,
when we move forward, move towards signing a third Record of
Decision for this site. •
Z do want to emphasize that your questions and
comments are welcome throughout the remedial action process.
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Please -- plea«e direct them to Fred Mumford. Thank you very
much.
(Meeting adjourned)
CERTIFICATE
I certify that the foregoing is a correct transcript
to the best of my ability from the record of proceedings in
the above-entitled matter.
Q,
DATED;
J & J COURT TRANSCRIBERS
BY: PATRICIA C. DUPRE
February 26, 1996
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