PB96-963821
EPA/ROD/R02-96/289
April 1997
EPA Superfund
Record of Decision:
American Cyanamid Site,
Group II Impoundments (15, 16, 17 & 18),
Bound Brook, NJ
7/12/1996
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SUPERFUND RECORD OF DECISION
FOR GROUP II IMPOUNDMENTS (15, 16, 17 AND 18)
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
GROUP II IMPOUNDMENTS AT AMERICAN CYANAMID SITE
AMERICAN HOME PRODUCTS CORPORATION
BRIDGEWATER TOWNSHIP, SOMERSET COUNTY
DECLARATION STATEMENT 1
DECISION SUMMARY 3
GLOSSARY 27
ADMINISTRATIVE RECORD INDEX 29
RESPONSIVENESS SUMMARY , 32
ATTACHMENT 1 - FIGURES
ATTACHMENT 2 - TABLES
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DECLARATION STATEMENT
RECORD OF DECISION
GROUP I! IMPOUNDMENTS AT AMERICAN CYANAMID SITE
AMERICAN HOME PRODUCTS CORPORATION
BRIDGEWATER TOWNSHIP, SOMERSET COUNTY
SITE NAME AND LOCATION
Group II Impoundments (15, 16, 17 and 18) 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 Group II Impoundments (15, 16, 17 and 18) 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 (NCR). This decision document explains
the factual and legal basis for selecting the remedy for the Group II
Impoundments at this site and is based on the administrative record. The
attached index identifies the items that comprise the administrative record.
The United States Environmental Protection Agency (USEPA), support agency
for this site, concurs with the selected remedy and has provided a
concurrence letter to that effect which is attached to the responsiveness
summary section of this document.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in this Record of
Decision (ROD), may present an imminent and substantial endangerment to
human health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
This ROD addresses only Group II Impoundments consisting of four on-site
surface impoundments 15, 16, 17 and 18. The selected remedy is: 1)
Impoundments 15 and 16—Consolidation of Impoundment 16 into Impoundment
15, Capping and Ground Water Monitoring; 2) Impoundment 17--Solidification
with Consolidation into the on-site Impoundment 8 Waste Management Facility;
and, 3) Impoundment 18—No Further Action with Ground Water Monitoring.
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The major components of the selected remedy are listed below.
1. Impoundments 15 and 16:
• Excavation of the material in Impoundment 16;
• Consolidation of the excavated material into Impoundment 15;
• Construction of a cap (synthetic liner); and,
• Ground water monitoring.
2. Impoundment 17:
• Excavation of the material of Impoundment 17 and mixing with
cement-like material (process may be reversed); and,
• Placement of the solidified material into the Impoundment 8 Facility.
3. Impoundment 18:
• Construction of a fence;
• Maintenance of natural vegetation; and,
• Ground water monitoring.
DECLARATION OF STATUTORY DETERMINATIONS
The remedy, as described above, for the Group II Impoundments has been
selected based on the results of the Impoundments Characterization Program,
Baseline Endangerment Assessment and the Corrective Measure
Study/Feasibility Study (CMS/FS) for Group II Impoundments, which have
shown the remedy to be protective of human health and the environment. The
selected remedy is protective of human health and the environment, complies
with State and Federal requirements that are legally applicable or relevant and
appropriate to the remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment technologies to the maximum
extent practicable for this site.
Because this remedy will result in hazardous substances remaining on the site,
a review will be conducted pursuant to CERCLA every five (5) years after the
commencement of the remedial action to ensure that the remedy continues to
provide adequate protection of human health and the environment.
Final site-wide remediation including all impoundments, soils and ground water
will comply /tyith the applicable or relevant and appropriate requirements
(ARARs) inc^up/noXiPTiplijfdce with the State of New Jersey 10'* risk level.
"Signature
Richard J.
Date
ello./Assistant Commissioner
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DECISION SUMMARY
RECORD OF DECISION
GROUP II IMPOUNDMENTS AT AMERICAN CYANAMID SITE
AMERICAN HOME PRODUCTS CORPORATION
BRIDGEWATER TOWNSHIP. SOMERSET COUNTY
1. Sire DESCRIPTION, BACKGROUND AND HISTORY
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 Group II Impoundments
is attached (Figure 1).
Throughout its more than 75-year manufacturing history, numerous organic and
inorganic chemical raw materials were used at the Cyanamid facility to
produce products including rubber chemicals, Pharmaceuticals, dyes, pigments,
chemical intermediates, and petroleum-based products. Currently, only Pharma-
ceuticals are being manufactured at the site.
Preliminary investigation work efforts completed by Cyanamid in 1981 verified
that approximately one-half of the site never supported manufacturing, waste
storage, or waste disposal activities and that contamination source areas are
confined primarily to the main plant area (including the production area and
West Yard) and the on-site waste storage impoundments. Most of the wastes
generated from past manufacturing operations were stored in the on-site
surface impoundments, while general plant wastes, debris, and other materials
were primarily disposed of on the ground at various locations in the West
Yard. The impoundments and contaminated soils are the primary focus of
current remedial efforts because they constitute sources contributing to ground
water contamination.
While a total of 27 impoundments exist at the Cyanamid facility, 16 of these
were determined through investigative efforts to be potentially contributing to
ground water contamination and are covered by this Superfund cleanup
program. These 16 impoundments include Impoundments 1, 2, 3, 4, 5, 11,
13, 14, 15, 16, 17, 18, 19, 20, 24 & 26. The other 11 impoundments (Im-
poundments 6, 7. 8, 9, 9A, 10, 12, 21, 22. 23 & 25) were either never
used (Impoundments 9, 10, and 12), contain only river silt from the facility's
former river water treatment plant (Impoundments 22 and 23), contain emer-
gency fire water (Impoundment 21), have been closed with NJOEP approval
(Impoundment 25, in 1988) or are being closed in accordance with approved
Resource Conservation and Recovery Act (RCRA) closure plans (Impoundments
6, 7, 8 and 9A). Impoundments 6, 7, 8 and 9A are being closed under
RCRA because they were classified under RCRA as Treatment/Storage/Oisposal
(TSD) facilities. Closure procedures under RCRA were implemented for
Impoundments 6, 7, 8 and 9A after the use of Impoundments 6 and 7 was
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discontinued in 1984 and interim TSD status expired. Impoundment 9A has
been closed in-place. The 16 Impoundments being addressed under this
Superfund cleanup program were never given interim status as TSD facilities
under RCRA. The 16 impoundments potentially contributing to ground water
contamination were used for storing by-products of rubber chemical produc-
tion, dye production, and coal tar distillation as well as for disposal of
general plant waste and demolition debris. These 16 impoundments contain
a total of approximately 877,000 tons of waste material.
On June 8, 1981, Cyanamid filed a general notification of release of
hazardous substances with the USEPA. In December 1982, the entire
Cyanamid facility was listed on the National Priorities List (NPL) of Superfund
sites.
Cyanamid and the NJDEP entered into an Administrative Consent Order (ACO)
in May 1988 to address the 16 on-site impoundments, site-wide contaminated
soils, and ground water. In addition to the regulatory requirements established
under the ACO, a New Jersey Pollutant Discharge Elimination System/Discharge
to Ground Water (NJPDES/DGW) permit number 0002313 was also issued. This
permit, which was issued to Cyanamid in 1987, required that Cyanamid
conduct extensive ground water monitoring on a quarterly basis and continue
pumping three bedrock production wells, at a . minimum rate of 650,000
gallons per day, to contain ground water contamination within the production
area and West Yard area of the site.
In May 1994, Cyanamid and NJDEP executed an ACO Amendment (1994 ACO
Amendment) which incorporated the existing site-wide ground water pumping
and monitoring requirements of the NJPDES/DGW permit, including the ground
water monitoring requirements for the on-site Impoundment 8 facility
(Impoundment 8 Facility). The 1994 ACO amendments supplement the 1988
ACO. The RCRA operating permit (the NJDEP NJPDES/DGW permit issued under
the state's federally authorized program) for the Impoundment 8 Facility was
not renewed. The current NJPDES/DGW permit includes only closure and post-
closure requirements for the Impoundment 8 Facility. Site-wide ground water
monitoring will continue to be performed pursuant to the requirements of the
1994 ACO Amendment. In accordance with the 1994 ACO Amendment,
Cyanamid will continue to pump, at a minimum, 650,000 gallons per day from
the newly installed production wells, PW2 and PW3, located in the main plant
area. Former production wells PW16, PW17, and PW18 located on the Hill
Property have been converted into monitoring wells.
In November 1988, USEPA issued the HSWA Permit that, in conjunction with
the operating permit issued by NJDEP, constitutes the RCRA permit for the
Cyanamid facility. The HSWA Permit was modified (effective March 4, 1994)
to incorporate the selected remedy for the Group I Impoundments (11, 13, 19
and 24). The HSWA Permit is consistent with the ACO. the NJPDES permit
and the 1994 ACO Amendment.
In December 1994, American Home Products corporation purchased American
Cyanamid Company and assumed full responsibility for envjrpnmental
remediation as required under the ACO for the site.
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There are two ground water aquifer systems that underlie the site: a shallow
overburden aquifer system (flow direction to the south towards the Raritan
River) and a deeper, semi-confined bedrock aquifer system (flow direction
towards the north, influenced by pumping). Any ground water in the area of
the Group II Impoundments that is not captured by the ongoing pumping
system flows to the Raritan River. A previous study (Lawler, Matuskey, &
Skelley, 1983) concluded that the Cyanamid facility did not have a significant
impact on water quality in the Raritan River upstream of the Calco Dam and
above the Cuckolds Brook discharge to the river.
A Natural Resource Assessment (NRA) completed by American Cyanamid is
being evaluated by the NJOEP Office of Natural Resource Damage (ONRD) with
support from Federal Natural Resource Trustees. The NRA consists of the
following: a Wetlands Assessment (using state and federal guidance); a
Cultural Resources Survey (Stage IA and IB); a Floodplain Assessment; an
Endangered Species Assessment; and, an assessment of the Raritan River and
Cuckolds Brook. Based on its evaluation of the NRA, the ONRD, in consulta-
tion with the Federal Trustees, will determine any impacts to natural
resources related to the American Cyanamid site. If this determination
indicates any impacts to natural resources from the American Cyanamid site,
the ONRD, in consultation with the Federal Trustees, will establish appropriate
requirements for mitigation and will negotiate financial settlement with
American Home Products for any damage to the natural resources.
2. ONGOING AND COMPLETED REMEDIAL PROGRAMS
American Home Products has completed, or is conducting, several remedial
programs at the site. Completed programs include: removal of pumpable tars
(3.1 million gallons) from Impoundment 2 for off-site use as a supplemental
fuel (1986-1987); removal of pumpable tars from Impoundment 1 (1960s); a
berm stability evaluation program (1989); and a remedial investigation of the
Hill Property. Each of the ongoing programs is discussed briefly below.
Impoundments 4 & 5 Fuel Blending Program
American Cyanamid has performed an interim remedial measure on
Impoundments 4 and 5 by pumping/removing the tars, blending and/or
containerizing them on-site and shipping them off-site for use as a
supplemental fuel in a cement kiln process. These Impoundments contained
approximately 5,000,000 gallons of pumpable tars, that when blended
together, produced the supplemental fuel product. A blending process was
designed and installed for heating and blending these tars for loading into
tank wagons. Operation began in July 1991 and through October 1994
approximately 3,800,000 gallons of tars were successfully removed, blended
and shipped off-site from these impoundments. This system has been shut
down since October 1994 after removal of all pumpable material. An
evaluation of an alternative approach to removing any residual tars, by
excavation and shipment in sealed roll-off boxes for off-site blending to
produce a fuel product, will be made during the next several months. After
all material having a supplemental fuel vaJue is recovered, the residuals will
be addressed as part of the Group III Impoundments CMS/FS.
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On-site Impoundment 8 Facility Program
This program involves closure and post-closure of four (4) on-site
impoundments (Impoundments 6, 7, 8 & 9A) and the construction of a waste
consolidation facility (Impoundment 8 facility). These construction, closure and
post-closure activities are being conducted in accordance with the May 1994
AGO. Half of the state-of-the-art Impoundment 8 facility has been constructed*
(western half) and includes a triple liner, leachate detection and collection
system and ground water monitoring system. American Cyanamid has
completed sludge processing and has removed the old liner as of November
1994 from the old Impoundment 8 (eastern half). Most of the waste from
Impoundment 7 has been removed, dewatered, solidified, and consolidated into
the western half of the Impoundment 8 facility. Waste from Impoundment 6
will be solidified and consolidated into the eastern half of the Impoundment
8 facility. The construction of this eastern half of the Impoundment 8 facility
will also include a multi-liner (4-liner) system, leachate detection and collec-
tion and ground water monitoring system. This activity has been initiated and
is expected to be completed by the spring of 1996. After retrofitting the
eastern half of Impoundment 8, consolidation of the Impoundment 6 sludges
into this half of Impoundment 8 will begin. This activity is expected to
require approximately 15 months to complete. After completion of the
Impoundment 6 consolidation, remediation of the remaining Group I Impound-
ments (11, 13 and 24) and other impoundments involving consolidation into
the eastern half of Impoundment 8 will begin. This project will continue for
the next several years. The May 1994 AGO as well as the RCRA and HSWA
Permits allows the Impoundment 8 facility to receive other on-site solidi-
fied/stabilized waste materials, if compatible with the Impoundment 8 liner
system. Impoundment 9A has been closed in-place by installing a double
synthetic liner capping system (60-mil High Density Polyethylene).
Surface Soils Remedial/Removal Action Program
The 1992 Surface Soils Remedial/Removal Action (SSR/RA) Program was
completed in December 1992 addressing areas of surface soil contamination
that posed a potential risk to worker health and safety. The program included
excavation and off-site disposal of Polychlorinated Biphenyl (PCB)-contaminated
soils, excavation and disposal of Polyaromatic Hydrocarbon (PAH)-contaminated
soil in the on-site RCRA permitted facility, and capping of another PAH-
contaminated area (in the West Yard Area near Impoundment 14), as well as
placement of a geotextile, soil and vegetative cover over a chromium-contami-
nated area. These areas, except for one PAH Area (Area 11), will be
revisited as part of the site-wide soil remediation program. PAH Area 11 was
determined to be clean based on post-excavation sampling results that
indicated no surface contamination and based on the Soil Remedial
Investigation data that indicated no subsurface contamination above the appli-
cable State Cleanup Criteria.
Impoundments 11, 13, 19 and 24 (Group I)
Remediation of the Group I Impoundments, consisting of solidification and
consolidation into the Impoundment 8 facility, has been initiated in accordance
with the September 1993 Record of Decision, May 1994 Remedial Design
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Report as well as July and September 1994 Impoundment 19 Remedial Action
Plan for the Group I Impoundments. To date, the remediation of Impoundment
19 has been completed.
Bedrock Ground Water Pumping/Control System Program
For the past 60 years, Cyanamid has withdrawn water from the on-site
bedrock production wells for use as non-contact cooling water in the
production operations. Cyanamid's present average withdrawal of over
650,000 gallons per day results in ground water flow inward from the perime-
ter of the site towards the pumping wells. This system effectively contains
the majority of the ground water contamination within the production area and
West Yard area on the site. Recovered ground water is used as non-contact
cooling water on-site before discharge to the adjacent Somerset-Raritan Valley
Sewerage Authority (SRVSA) wastewater facility for subsequent treatment.
Any ground water not captured by the production well pumping system flows
to the Raritan River. A previous study (Lawler, Matuskey, & Skelley, 1983)
concluded that the Cyanamid facility did not have a significant impact on
water quality in the Raritan River. Further study of the Raritan River/Cuckolds
Brook water quality was conducted as part of the NRA. The NRA is currently
under evaluation, as stated earlier.
3. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The following documents were made available to the public for review:
Impoundment Characterization Program Final Report (ICPFR);
Technology Evaluation Work Plan for Group I Impoundments;
Baseline Site-Wide Endangerment Assessment Report;
Group II Impoundments CMS/FS Report; and
Proposed Plan for the Group II Impoundments.
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 remedy under consideration for Group II
Impoundments. A response to the comments received during the public
comment period and the public meeting is included in the Responsiveness
Summary, which is attached to the ROD. A complete background on
community involvement throughout the remedial process is included in the
Responsiveness Summary.
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4. SCOPE AND ROLE OF OPERABLE UNIT OK RESPONSE ACTION WITHIN SITE
STRATEGY
This ROD addresses the remediation of the Group II Impoundments only.
Remediation of the remaining group of impoundments (Group III) will be
addressed in a separate CMS/FS which was submitted in April 1996. A
Remedial Investigation of the site-wide soils was completed in 1992. A
Feasibility Study addressing the site-wide soils will be initiated after comple-
tion of the remediation of the 16 on-site impoundments. Final remediation for
site-wide ground water contamination will be addressed after completion of
the remediation of site-wide soils.
Due to practical limitations, all 16 of the Superfund/CMS impoundments
cannot be remediated concurrently. Therefore, they have been grouped into
three impoundment groups according to waste type, nature of contaminants,
and geographical location on the site. This concept allows this complex site
to be subdivided into discrete, more manageable units. The impoundment
groups are as follows:
Group I - Impoundments 11, 13, 19 & 24
Group II - Impoundments 15, 16, 17 & 18
Group III - Impoundments 1, 2, 3, 4, 5, 14, 20 & 26
Remediation of the Group I Impoundments, consisting of solidification and
consolidation into the Impoundment 8 facility, has been initiated in accordance
with the September 1993 Record of Decision, May 1994 Remedial Design
Report as well as July and September 1994 Impoundment 19 Remedial Action
Plan for the Group I Impoundments. To date, remediation of Impoundment 19
has been completed.
Impoundments 1 snd 2 were initially part of the Group II Impoundments.
However, these two impoundments contain RCRA-classified hazardous waste
while the other impoundments in Group II do not contain RCRA-classified
hazardous waste. While all of the impoundments do contain CERCLA hazardous
substances, the required treatment standards for the different classification
of wastes and substances vary. At the time the original treatability studies
were performed for the Group II Impoundments, the regulatory treatment
standards for some RCRA-classified hazardous waste were not yet regulatory
requirements. However, as of September 1994, such treatment standards
became regulatory requirements. American Home Products evaluated the
existing treatability study data for Impoundments 1 and 2 and could not meet
these treatment requirements. As such, American Home Products is performing
supplemental treatability studies for the RCRA-classified hazardous waste in
Impoundments 1 and 2. In order that the remedial process proceed for the
remaining Group II Impoundments, without waiting for completion of the
supplemental studies for Impoundments 1 and 2, NJDEP has shifted
Impoundments 1 and 2 into Group III. The CMS/FS for the Group III
Impoundments, incorporating the results of the supplemental treatability
studies for Impoundments 1 and 2, was completed in April 1996.
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5. CHARACTERIZATION OF GROUP II IMPOUNDMENTS
The Group II Impoundments were characterized as reported in the January
1990 ICPFR. A summary of the analytical results of the contents of the Group
II Impoundments is provided in Table 1. The locations of the impoundments
are indicated as the shaded areas on Figure 1. An overview 'of the
characterization of the Group II Impoundments follows:
Impoundment 15
Impoundment 15 has a surface area of approximately 2.8 acres. Its surface
is devoid of topsoil and vegetation, and is sloped from the southwest to the
northeast corner. This impoundment contains a homogeneous material
composed of greater than 99 percent iron oxide (or magnetite). The iron oxide
ranges from approximately 6 to 9 feet in depth and occupies a volume of
approximately 29,500 cubic yards. Impurities in the iron oxide include trace
organics, metals, stones and dirt. The detected predominant volatile organic
contaminants of concern range in average concentration from 0.002 to 0.069
parts per million (ppm) and are Acetone, Benzene, Methylene Chloride and
total Xylenes. The predominant semivolatile organic contaminants of concern
range in average concentration from 0.092 to 17 ppm and are 4-Chloroaniline,
N-nitrosodiphenytamine, Anthracene, Naphthalene and Phenanthrene. The
predominant inorganic contaminants of concern range in average concentration
from 55 to 4,490 ppm and include Arsenic, Copper, Lead and Zinc. Polychlori-
nated Biphenyl (PCB-1254) was also detected in the range of 0.9 to 3 ppm.
The contents of Impoundment 15 are not classified as RCRA hazardous
wastes.
Impoundment 16
Impoundment 16 has a surface area of approximately 3.0 acres. Its surface
is devoid of topsoil and vegetation and has been graded in the southeast
corner to facilitate drainage of precipitation. This impoundment contains a
homogeneous material composed of greater than 99 percent iron oxide. The
iron oxide ranges from approximately 5 to 10 feet in depth and occupies a
volume of approximately 38,000 cubic yards. Impurities in the iron oxide
include trace organics, metals, stones and dirt. The detected predominant
volatile organic contaminants of concern range in average concentration from
0.002 to 0.073 ppm and are Acetone, Benzene, Methylene Chloride and total
Xylenes. The predominant semivolatiie organic contaminants of concern range
in average concentration from 0.046 to 6 ppm and are 4-Chloroaniline, N-
nitrosodiphenylamine. Anthracene, Naphthalene, Phenanthrene and Pyrene. The
predominant inorganic contaminants of concern range in average concentration
from 20 to 2,620 ppm and include Arsenic, Copper, Lead and Zinc. PCB-1254
was also detected in the range of 1.5 to 6 ppm. The contents of
Impoundment 16 are not classified as RCRA hazardous wastes.
Impoundment 17
Impoundment 17 has a surface area of approximately 6.2 acres. Its surface
supports vegetation consisting primarily of small bushes. Impoundment 17
contains approximately 67,000 cubic yards of homogeneous primary
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wastewater treatment sludge with a depth of approximately 8 feet. The
predominant volatile organic contaminants of concern detected in Impoundment
17 range in average concentration from 1 to 16 ppm and are Acetone,
Chlorobenzene, Ethylbenzene, Toluene and total Xylenes. The predominant
semivolatile organic contaminants of concern detected in Impoundment 17
range in average concentration from 17 to 70 ppm and are 1,2,4-
Trichlorobenzene, Benzo(a)anthracene, Bis(2-ethyl hexyljphthalate, Naphthalene
and N-Nitrosodiphenylamine. The predominant inorganic contaminants of
concern detected in Impoundment 17 range in average concentration from 100
to 3,500 ppm and are Chromium, Copper, Lead, Nickel and Zinc. The contents
of Impoundment 17 are not classified as RCRA hazardous wastes.
Impoundment 18
Impoundment 18 has an estimated surface area of 15.4 acres and is densely
vegetated by a variety of well-established trees and undergrowth.
Impoundment 18 contains approximately 217,000 cubic yards of homogeneous
primary wastewater sludge to a depth of about 9 feet. The predominant
volatile organic contaminants of concern detected in Impoundment 18 range
in average concentration from 1 to 2.5 ppm and are Acetone and
Chlorobenzene. The detected predominant semivolatile organic contaminants of
concern range in average concentration from 26 to 780 ppm and are 2-
Methylnaphthalene, 4-Chloroaniline, Acenaphthalene, Benzo(a)anthracene, Bis(2-
ethyl hexyDphthalate, Naphthalene, Fluorene and Phenanthrene. The detected
predominant inorganic contaminants of concern have a range of average
concentrations from approximately 180 to 2,200 ppm and are Arsenic,
Chromium, Copper, Lead and Zinc. The contents of Impoundment 18 are not
classified as RCRA hazardous wastes.
6. SUMMARY OF EXISTING SITE RISK
Based upon the results of the ICPFR, 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 contamina-
tion 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 /c/enf/fVcaf/o/7--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
/4ssessmes?f--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. The contaminant selection criteria
was based primarily on frequency of detection, the availability of toxicity
criteria, and numerical threshold criteria. The Baseline EA identified a total
of 55 contaminants of concern for the Cyanamid site. Of these 55 contami-
nants, those that were detected most frequently or in the highest concen-
trations within the Group II Impoundments are Acetone, Benzene, Carbon
Disulfide, Chlorobenzene, Ethylbenzene, Methylene Chloride, Toluene, total
Xylenes, Acenaphthalene, Benzo(a)Anthracene, Bis(2-Ethyl HexyUPhthalate, 4-
Chloroanaline, 1,2-Dichlorobenzene, 1,4-Dichloro'benzene, Fluorene, 2-Methylnap-
hthalene, Naphthalene, Nitrobenzene, N-Nitrosodiphenylamine, Phenanthrene,
1,2,4-Trichlorobenzene, Arsenic, Cadmium, Chromium, Copper, Lead, Mercury,
Nickel, Selenium and Zinc. Of these contaminants of concern, only Benzene,
Bis(2-Ethyl HexyDPhthalate, Methylene Chloride, N-Nitrosodiphenylamine,
Arsenic, Cadmium, Chromium, Nickel and Lead are known or suspected
carcinogens according to the USEPA Carcinogen Assessment Group (CAG)
classification system.
Using the Baseline EA evaluation for exposure pathways for on-site and off-
site human receptors, a number of significant exposure pathways were
identified and evaluated quantitatively to determine the risk levels presented
by existing site conditions.
Exposure to contaminated ground water was not identified as a significant
exposure pathway at the present time because American Home Products pumps
650,000 gallons per day of contaminated ground water from on-site production
wells that control the ground water contamination in the production area and
west yard area of the site. Ground water not being captured by the
production well pumping flows to the Raritan River at a point that is not
being used as a drinking water source. Therefore, a ground water exposure
pathway does not exist at the present time. A summary of the analytical
results of ground water down gradient of Impoundments 15, 16, 17 and 18
is provided in Table 2.
Summary of Human Health Risks
Through an assessment of exposure pathways for the 55 contaminants of
concern, specific health risk levels were calculated for each 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. A
Hazard Quotient greater than 1.0 indicates that the exposure level exceeds
the protective level for that particular chemical.
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New Jersey Public Law P.L. 1993, c. 139 (NJSA 58:10B) has set an
acceptable cancer risk from a human carcinogen at 1x10 * (one-in-one-million)
and an 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 Group II
Impoundments was conducted in the Baseline EA to evaluate risks associated
with exposure to impoundment solids through incidental ingestion, dermal
contact, and inhalation as a result of unauthorized operation of off-road
recreational vehicles (ORVs) on Impoundments 15, 16, 17 and 18. While
direct access to these impoundments by standard vehicles is not possible,
ORVs may gain access via a dirt trail from a private road.
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 site-
wide risk characterization is included in Table 3.
The Baseline EA concluded that exposure to the Group II Impoundments'
contents would not result in a significant impact to human health and the
environment; however, a cumulative Hazard Index of 1.15 and a carcinogenic
value of 1.19 x 10'e via exposure to impoundments' solids (through incidental
ingestio'n, dermal contact and inhalation) to on-site trespassers were
conservatively estimated. Both of these values slightly exceed the limits
established by NJDEP for Hazard Index and carcinogenic risk. The carcinogenic
risk value is within the acceptable range established by USEPA while the
Hazard Index risk value slightly exceeds the established value. Implementation
of the selected remedy for Impoundments 15, 16, 17 and 18 will insure that
the exceeded risk values are below the acceptable limits.
A quantitative analysis of the risks associated with future use of site ground
water was not conducted. However, with the exception of Impoundment 18,
there is a potential future risk to human health and the environment if the
Group II Impoundments are not remediated. The Group II Impoundments
(except Impoundment 18) are a continuous source of ground water
contamination, which eventually discharges into the Raritan River. The ground
water in the vicinity of the site is classified as a source of drinking water
but it is not used as drinking water. Although there is a pumping program to
control migration of contaminated ground water by recovering 650,000 gallons
of contaminated ground water per day, the population around the site could
potentially be exposed to contaminated ground water under a future use
scenario. Further, the Group II Impoundments pose potential risks to
trespassers that exceed acceptable risk levels established by NJDEP. Finally,
the Group II Impoundments (except Impoundment 18) may pose an ecological
risk at the site if left unremediated. For these reasons, remediation of the
Group II Impoundments (except Impoundment 18) is warranted. Final site-wide
remediation will insure that there are no unacceptable risks to human health
and the environment. ' '
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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—d6ve\oomeni of the objectives
and scope of the ecological assessment; description of the site and
ecosystems that may be impacted; identification of contaminants of concern.
Exposure /Assessment—identification of potential ecological receptors and
exposure pathways; quantitative evaluation of exposure pathways; fate and
transport mechanisms for contaminants. Ecological Effects Assessment--
literature reviews, field studies, and toxicity tests, linking contaminant
concentrations to effects on ecological receptors. Risk Characterization—
measurement or estimation of both current and future adverse effects.
The results of 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.
As stated earlier, a Natural Resource Assessment (NRA) completed by
American Cyanamid is being evaluated by the NJDEP Office of Natural
Resource Damage (ONRD) with support from the Federal Natural Resource
Trustees. The NRA consists of the following: a Wetlands Assessment (using
state and federal guidance); a Cultural Resources Survey (Stage IA and IB);
a Floodplain Assessment; an Endangered Species Assessment; and, an
assessment of the Raritan River and Cuckolds Brook. Based on its evaluation
of the NRA, the ONRD, in consultation with the Federal Trustees, will
determine any impacts to natural resources related to the American Cyanamid
site. If this determination indicates any impacts to natural resources from the
American Cyanamid site, the ONRD, in consultation with the Federal Trustees,
will establish appropriate requirements for mitigation and will negotiate a
financial settlement with American Home Products for any damage to the
natural resources. The findings of the NRA along with any requirements for
mitigation will be incorporated into the Remedial Design of the Group II
Impoundments.
Because Impoundment 18 is heavily vegetated, a qualitative ecological
assessment was performed. Impoundment 18 has been characterized as a
successional floral community comprised predominantly of facultative upland
and obligate species (Tree of Heaven, Eastern Cottonwood, Sycamore, Princess
Tree, Eastern Red Cedar, Big-Tooth Aspen, Black Cherry, Dwarf Sumac,
Staghorn Sumac, Red Maple, Gray Birch and Silver Maple). A natural balance
exists between the vegetation and the surface cover of Impoundment 18 that
restricts the release of contaminants to the surface. Because of this,
Impoundment 18 is considered to be of high ecological value.
7. SCOPE AND ROLE OF ACTION
With the. exception of Impoundment 18, there is a potential future., risk to
human health and the environment if the Group II Impoundments are not
remediated. The Group II Impoundments (except Impoundment 18) are a
continuous source of ground water contamination, which eventually discharges
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into the Raritan River. The ground water in the vicinity of the site is
classified as a source of drinking water. Although there is a pumping program
to control migration of contaminated ground water by recovering 650,000
gallons of contaminated ground water per day, the population around the site
could potentially be exposed to contaminated ground water under a future use
scenario. Further, the Group II Impoundments pose potential risks to
trespassers that exceed acceptable risk levels established by NJDEP. Finally,
the Group II Impoundments (except Impoundment 18) may pose an ecological
risk at the site if left unremediated. For these reasons, remediation of the
Group II Impoundments (except Impoundment 18) is warranted. Final site-wide
remediation will insure that there are no unacceptable risks to human health
and the environment.
This ROD addresses the remediation of the Group II Impoundments only.
8. REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human health and the
environment; they take into account the contaminant(s) of concern, the
exposure route(s), receptor(s), and acceptable contaminant level(s) for each
exposure route. These objectives are based on available information and
standards such as applicable or relevant and appropriate requirements (ARARs).
The remedial action objectives for the Group II Impoundments are as follows:
1. Eliminate and/or control source(s) of contamination;
2. Eliminate the potential for incidental ingestion, dermal contact and
inhalation of impoundments' solids; and,
3. Contribute to compliance with ground water ARARs.
9. SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA requires that each selected site remedy be: protective of human
health and the environment; be cost-effective; comply with other statutory
laws; and, utilize permanent solutions, alternative treatment technologies, and
resource recovery alternatives to the maximum extent practicable. In addition,
the statute includes a preference for the use of treatment as a principal
element for the reduction of toxicity, mobility, or volume of the hazardous
substances.
The CMS/FS report includes a preliminary screening of all potentially
applicable technologies, followed by elimination of inappropriate or infeasible-
alternatives and identification of applicable technologies based solely on
technical feasibility. The remaining technologies were then developed into
remedial alternatives and evaluated in detail by comparing them to the
CERCLA evaluation criteria.
Based on the similarities in chemical and physical characteristics of the waste
materials contained in Impoundments 15 and 16 (iron oxide), and Impound-
ments 17 and 18 (primary wastewater treatment sludge), these two -groups
were evaluated separately in the detailed and comparative analysis of remedial
alternatives. The unique characteristics of the two distinct waste types
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(primary wastewater treatment sludge and iron oxide) prevented a single
evaluation of remedial alternatives for all four Group II Impoundments. The
preferred remedial alternatives presented in the Group II CMS/PS Report and
the Proposed Plan and the selected alternatives presented in this ROD include
a combination of remedial actions that will address all of the Group II Im-
poundments.
The remedial alternatives evaluated included the following:
1. No-action/limited Action;
2. In-Place Containment;
3. Solidification; and,
4. Recycling.
Several points should be noted about each of the alternatives evaluated. First,
all remedial alternatives will require ground water monitoring as a component.
For the alternatives that involve leaving the contaminants in place, such
monitoring would be required on a long-term basis, while for the alternatives
that involve removal of the contaminants, the monitoring would only be
required until it can be confirmed that the removal has been effective.
With respect to costs, the total cost for each alternative reflects both capital
cost to implement and operation and maintenance costs over a period ranging
from 5 to 30 years. The costs of all alternatives for the Group II
Impoundments included in this ROD are different than the May 1994 CMS/FS
report. The costs specified in the 1994 CMS/FS report were obtained in 1993
and are now outdated in light of the current market conditions. The costs
were revised in October 1995 by American Home Products Corporation and the
revised costs are reflected in this ROD.
Finally, with regard to the time to implement each alternative, the estimated
time frames provided reflect both the time to design and construct the
remediation system. However, several of the alternatives include consolidation
of treated residuals in the on-site Impoundment 8 facility. Consolidation of
these treated residuals in Impoundment 8 will be implemented after completion
of consolidation of treated materials of Impoundments 6, 11, 19 and 24,
currently scheduled to be completed in 1997.
A brief description of each of the remedial alternatives is provided below:
Note: The Superfund program requires that the "no-action* alternative be
considered as a baseline for comparison with other alternatives.
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Impoundments 15 and 16
Alternative 1»No Action (or Limited Action)
• impoundments remain in-place in current condition;
• establishment of institutional controls (environmental restrictions) and
improvements in physical site access controls (additional fencing); and,
• -short-term ground water monitoring.
Total Cost: $ 300,000
Time to Implement: 1 month
Alternative 2--ln place Containment
Note: Impoundment 15 is able to accommodate its content as well as
Impoundment 16's contents because Impoundment 15 is not completely full.
• consolidation of Impoundment 16 contents into Impoundment 15;
• capping with a synthetic liner, drainage layer, soil cover, and vegetation;
• backfilling and reseeding; and,
• short-term ground water monitoring.
Total Cost: $ 2,700.000
Time to Implement: 1 year
Alternative 3--Solidification
Note: Impoundment 15 is able to accommodate its content as well as
Impoundment 16's contents because Impoundment 15 is not completely full.
in-situ solidification of the contents of both impoundments;
consolidation of solidified Impoundment 16 iron oxide into Impoundment
15;
capping of the solidified material with a soil cover and vegetation;
backfilling and natural revegetation of former Impoundment 16 area; and,
short-term ground water monitoring.
Total Cost: $ 8,600,000
Time to Implement: 2 years
Alternative A—Recycling
• excavation of iron oxide;
• transport and reuse of the iron oxide at an off-site recycling facility;
• backfilling, regrading and natural revegetation of former impoundment
areas; and,
• short-term ground water monitoring.
Total Cost: $ 8,100,000
Time to Implement: Dependent on users and contract agreements
Impoundments 17 and 18
Impoundments 17 and 18 are adjacent, have similar characteristics and exist
within the same type of hydrogeologic regime. However, Impoundment 17
appears to be impacting the quality of ground water due to the absence of
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a confining clay layer. Impoundment 18 does not appear to be impacting the
quality of ground water due to the presence of a clay layer and has a high
ecological value (see ecological assessment section). Therefore, different
remedial alternatives were considered for the remediation of Impoundments 1.7
and 18.
Alternative 1--No Action (or Limited Action)
• Impoundments remain in-place in current condition;
• establishment of institutional controls (environmental restrictions) and
improvements in physical site access controls (fencing); and,
• long-term ground water monitoring.
Total Cost: $ 300,000
Time to Implement: 3 months
Alternative 2>-Solidification of Impoundment 17 with Placement into
Impoundment 8 facility; No Action/Limited Action for Impoundment 18
• clearing and grubbing of Impoundment 17;
• solidification of Impoundment 17 wastewater treatment sludge;
• placement of solidified material into the Impoundment 8 facility;
• backfilling of former Impoundment 17 and natural ecological succession
of the area;
• Impoundment 18 remains in place with fence installation around the
perimeter;
• periodic selective removal of large trees on Impoundment 18 to prevent
potential disturbance of the clay layer; and,
• long-term ground water monitoring.
Total Cost: $ 13,500,000
Time to Implement: 1.5 years (Impoundment 17)
Alternative 2A--Solidification of Impoundment 17 with Placement into
Impoundment 8 facility; Capping of Impoundment 18
• clearing and grubbing of both Impoundments;
• solidification of Impoundment 17 sludge;
• placement of solidified material into the Impoundment 8 facility;
• backfilling of former Impoundment 17 and natural ecological succession
of the area;
• capping of Impoundment 18 with filter fabric, Low Density Poly Ethylene
(LDPE) liner, fill, topsoil and vegetation;
• fence installation around Impoundment 18 perimeter; and,
• short-term ground water monitoring.
Total Cost: $ 15,700,000
Time to Implement: 1.5 years
Alternative 3--Solidification and Consolidation: 17 into 18; Strengthen and Cap
Impoundment 18
• j
• clearing, grubbing and strength improvement (e.g., addition of cement)
of the Impoundment 18 surface;
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• excavation of Impoundment 17 sludge, strength improvement and
consolidation of material into Impoundment 18;
• capping of consolidated unit;
• backfilling of former Impoundment 17 and natural succession of the area;
and,
• short-term ground water monitoring.
Total Cost: $ 14,100,000
Time, to Implement: 4.5 years
Alternative 3A--ln-sltu solidification of Impoundment 18; Solidification of
Impoundment 17 and Placement in Impoundment 18, with cap
clearing, grubbing and in-situ solidification of Impoundment 18;
solidification of Impoundment 17 sludge;
consolidation of solidified Impoundment 17 material into Impoundment 18;
capping of consolidated unit;
backfilling of former Impoundment 17 and natural revegetation of the
area; and,
• short-term ground water monitoring.
Total Cost: $ 35,300,000
Time to Implement: 3 years
Alternative A—Solidification of Impoundment 18 and placement into
Impoundment 8 facility
This alternative does not include Impoundment 17.
• clearing and grubbing of Impoundment 18 surface;
• excavation of Impoundment 18 wastewater treatment sludge;
• consolidation of solidified material into Impoundment 8 facility;
• backfilling of former Impoundment 18 and natural revegetation of area;
and,
• short-term ground water monitoring.
Total Cost: $ 41,700,000
Time to Implement: 2 years
This alternative is significantly different from all of the alternatives previously
evaluated for Impoundments 17 and 18. As such, this alternative was
evaluated for Impoundment 18 only to satisfy the CERCLA/NCP requirements.
A similar option for Impoundment 17 is included as Alternative 2A.
10. EVALUATION OF REMEDIAL ALTERNATIVES
During the detailed evaluation of remedial alternatives, each alternative was
assessed against the nine CERCLA evaluation criteria for each of the two
types of impoundments containing wastes with similar chemical and physical
characteristics (i.e., iron oxide in Impoundments 15 and 16 and primary
wastewater treatment sludge in Impoundments 17 and 18). New Jersey Public
Law P.L. 1993, c. 139 (NJSA 58:10B) establishes that the NJDEP cannot
require a permanent remedy, unless the cost of implementing a non-permanent
remedy is 50 % or more than the cost of. implementing a permanent remedy.
The NCP/CERCLA criteria are more stringent than the NJSA 58:108
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requirements concerning the cost of implementing a permanent remedy.
Therefore, the more stringent NCP/CERCLA criteria are employed for this
Superfund site.
A summary of the comparative analysis is provided below:
Impoundments 15 and 16
• Overall protection of human health and the environment: addresses
whether or not a remedy provides adequate protection and describes how
risks posed through each pathway are eliminated, reduced or controlled
through treatment, engineering controls or institutional controls.
Alternative 1 would not achieve this criterion because it would not elimi-
nate the potential for inhalation of dust. Alternatives 2 and 3 would
protect human health and the environment by eliminating the potential for
direct contact with the iron oxide and by minimizing the potential for
releases of contaminants to the ground water. Alternative 4 would
achieve overall protection of human health and the environment by
removal of the iron oxide material from the site. Alternative 2 and 3
would achieve this criterion better than Alternative 1. This criterion is
best achieved by Alternative 4 among all alternatives.
• Compliance with applicable or relevant and appropriate requirements
(ARARs): addresses whether or not a remedy will meet all of the
applicable or relevant and appropriate requirements of federal and state
environmental statutes and other requirements or provides grounds for
invoking a waiver.
Alternative 1 would not trigger ARARs. Alternatives 2, 3 and 4 would
not trigger RCRA Hazardous Waste Regulations or Land Disposal Restric-
tions (LDRs) since the iron oxide is not a RCRA Hazardous Waste. Air
emissions ARARs would be achieved through the use of foam sprayers or
controlling operation rates. Alternative 1 would not contribute to achiev-
ing site-wide ground water ARARs. Alternatives 2, 3 and 4 would
contribute in achieving site-wide ground water ARARs by containment
(Alternative 2), solidification and consolidation (Alternative 3) and,
recycling (Alternative 4). Ground water monitoring is an ARAR under the
State requirements and under the RCRA program (40 CFR 264.97).
Location-specific ARARs consist of 'wetlands, cultural resources and flood
plains. The NRA, currently under evaluation, will determine the
compliance of the site-wide remediation program with location specific
ARARs. Based on the preliminary findings, location-specific ARARs would
not be triggered for Impoundments 15 and 16 because the proposed
remedial actions would not impact the natural resources. Compliance with
the Group II Impoundments location-specific ARARs will be further
evaluated as part of the Remedial Design process. Alternative 3 achieves
this criterion better than Alternative 2. This criterion is best achieved by
Alternative 4 among all alternatives.
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Long-term effectiveness and permanence: refers to the ability of a
remedy to maintain reliable protection of human health and the
environment over time, once cleanup goals have been met.
Alternative 1 would not achieve this criterion at all because it does not
address the potential for dust generation or direct contact exposure.
Alternatives 2 and 3 equally meet this criterion by containing the
material. Alternative 3 would provide better long-term effectiveness than
Alternative 2 because Alternative 3 provides some level of treatment for
inorganics while Alternative 2 relies on containment. Alternative 4 is the
most effective in the long-term because it does not require long-term
maintenance of a cap or containment structure.
Reduction of toxicity. mobility, or volume: through treatment is the
anticipated performance of the treatment technologies a remedy may
employ.
This criterion is not applicable to Alternatives 1 and 2 because they do
not involve treatment or recycling. Alternative 3 would decrease the
mobility of contaminants by binding them in a solidified matrix while only
slightly increasing the volume of waste material. Alternative 4 would re-
sult in removal of the iron oxide from the site for reuse, thereby elimi-
nating concerns with reducing toxicity, mobility and volume of contami-
nants. Alternative 3 achieves this criterion better than Alternatives 1 and
2. Alternative 4 would achieve this criterion better than all other
alternatives.
Short-term effectiveness: addresses the period of time needed to achieve
protection from any adverse impacts on human health and the
environment that may be posed during the construction and imple-
mentation period until cleanup goals are achieved.
Alternative 1 would not result in short-term impacts to human health or
the environment because no remedial action would be taken. The other
alternatives might require that workers use personal protective equipment
to reduce the potential for inhalation of dust particles generated during
excavation. The time required to implement the alternatives would be
the shortest for Alternative 1 (one month), slightly longer for Alternatives
2 and 3 (1-2 years), and dependent on potential users for Alternative 4.
Alternatives 2 and 3 achieve this criterion equally. The relative degree
of achievement of this criterion by Alternative 4 could not be
determined. Also, the implementation time could not be determined due
to inability to identify a recycling vendor.
Implementability: is the technical and administrative feasibility of a
remedy, including the availability of materials and services needed to
implement a particular option.
Alternative 1 would be the simplest alternative to implement from a
technical standpoint because it would involve no construction or^opera-
tion (other than fence installation). The operations associated with Alter-
natives 2, 3 and 4 employ well-established, readily available construction
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methods and are all considered technically and administratively feasible.
Alternative 4 is not likely to be implementable because a recycling
vendor has not been found despite many years of pursuing this alterna-
tive. Alternatives 2 and 3 achieve this criterion equally. The relative
degree of achievement of this criterion by Alternative 4 could not be
determined. Also, the implementability could not be determined due to in-
ability to identify a recycling vendor.
• Cost: includes estimated capital and operation and maintenance costs and
net present worth costs.
The total cost for Alternative 1 is $300,000; Alternative 2, $2,700,000;
Alternative 3, $8,600,000; and. Alternative 4. $8,100,000.
• USEPA concurrence: indicates whether, the federal regulatory agency
concur, oppose, or have no comment on the selected remedy.
USEPA concurs with the selected remedy.
• Community acceptance: assessment of the public comments received on
the ICPFR, Baseline EA report, CMS/FS report, Proposed Plan and the
draft modified HSWA permit.
Community concerns/comments received during the public comment period
and the public meeting are included in the Responsiveness Summary,
together with NJDEP responses, which is part of this ROD. The
community group CRISIS, which has received a Technical Assistance
Grant (TAG) from USEPA, requested that NJDEP change its preferred
alternative for Impoundments 15 and 16 to Alternative 3. NJDEP's
response is included in the Responsiveness Summary.
Impoundments 17 and 18
• Overall protection of human health and the environment
Alternative 1 would fail to remedy the adverse impact that Impoundment
17 is having on ground water quality, since it offers no control of
potential releases of contaminants to shallow ground water. All of the
other alternatives would be protective of human health and the
environment since they all involve removal of the source of ground water
contamination (Impoundment 17). All of the alternatives will provide for
adequate protection of human health for Impoundment 18. However,
except for Alternatives 1 and 2, the work would require the clearing and
grubbing of generally healthy ecosystems (i.e.. trees, plants, shrubs) at
Impoundment 18. Only Alternatives 1 and 2 protect the ecosystems that
Impoundment 18 underlies. Alternatives 2 and 2A would provide an
additional level of protection over Alternatives 3 and 3A by placing the
solidified Impoundment 17 sludge into the Impoundment 8 facility.
Alternative 4 would eliminate the potential for future adverse impacts to
ground water from Impoundment 18. Alternative 2A achieves this criterion
better than Alternative 2 because it includes capping of Impoundment 18.
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Alternative 3A achieves this criterion better than Alternative 3 because
it includes in-situ solidification of Impoundment 18.
Compliance with ARARs
All of the remedial alternatives except Alternative 1 would contribute to
achieving the compliance with site-wide ground water ARARs by
solidification and consolidation of the material (Impoundment 17). Ground
water ARARs have not been exceeded for Impoundment 18. Alternative
2 would provide confirmation of ground water ARARs compliance for
Impoundment 18 through routine ground water monitoring. RCRA LDRs are
not ARARs for Impoundment 17 and 18 because the materials in these
impoundments are not hazardous wastes. Ground water monitoring is an
ARAR under State requirements and under the RCRA program (40 CFR
264.97). Except for Alternative 1, all other alternatives would require
that air emissions ARARs be met during excavation and treatment
operations. This would be achieved by the installation of air emission
control measures (such as a carbon absorber), if necessary. Location
specific ARARs consist of wetlands, cultural resources and flood plains.
The NRA, currently under evaluation, will determine the compliance of
the site-wide remediation program with location specific ARARs. Based
on the preliminary findings, location specific ARARs would not be
triggered for Impoundments 17 and 18 because the proposed remedial
actions would not impact the natural resources. Compliance with the
Group II Impoundments location specific ARARs will be further evaluated
as part of the Remedial Design process. Alternative 2A achieves this
criterion better than Alternative 2 because it includes capping of Im-
poundment 18, minimizing infiltration of rain water. Alternative 3A
achieves this criterion better than Alternative 3 because it includes in-
situ solidification of Impoundment 18, minimizing leachability of contami-
nants to ground water.
Long-term effectiveness and permanence
Alternative 1 would not remedy the current or future adverse impact of
Impoundment 17 on ground water quality. Alternatives 2, 2A, 3 and
3A would achieve this criterion by removing and treating the source of
ground water contamination (Impoundment 17). Alternative 4 would
achieve this criterion by solidification and consolidation of Impoundment
18 material into the Impoundment 8 facility. All alternatives, except
Alternative 1, would meet this criterion by removal/contain-
ment/consolidation of the contamination sources (Impoundment 17) and
by long-term maintenance and ground water monitoring (Impoundment 18).
Alternative 2A achieves this criterion better than Alternative 2 because
it includes capping of Impoundment 18, minimizing infiltration of rain
water. Alternative 3A achieves this criterion better than Alternative 3
because it includes in-situ solidification of Impoundment 18, minimizing
leachability of contaminants to ground water.
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Reduction of toxicity, mobility, or volume through treatment
This criterion is not applicable to Alternative 1 because it does not
involve treatment or recycling. Alternatives 2A, 3, and 3A would reduce
the mobility of contaminants in the Impoundment 17 sludge through
solidification. Alternatives 2, 2A, 3, 3A and 4 would decrease the
mobility of both organic and inorganic contaminants by binding them in
a solidified matrix while slightly increasing the volume of waste material.
Alternative 4 would provide further reduction in mobility of the Impound-
ment 18 material by solidification and consolidation. Alternative 2A
achieves this criterion better than Alternative 2 because it includes
capping of Impoundment 18, minimizing infiltration of rain water. Alterna-
tive 3A achieves this criterion better than Alternative 3 because it
includes in-situ solidification of Impoundment 18, minimizing teachability
of contaminants to ground water.
Short-term effectiveness
Alternative 1 would not have any short-term adverse impact because it
does not involve any excavation and treatment. Alternatives 2, 2A, 3,
3A and 4 would achieve protection of human health and the environment
in a relatively short period of time and would result in minimal short-
term impacts associated with its implementation. Alternatives 2, 2A and
3 would provide better short-term effectiveness over Alternatives 3A
(more time to perform in-situ solidification of Impoundment 18) and 4
(more time to excavate and solidify large volume of Impoundment 18)
because they can be implemented in a shorter time resulting in less
short-term impacts.
Implementability
Alternative 1 would be the simplest alternative to implement from a
technical standpoint because it would involve no construction or
operation (other than fence installation). The operations associated with
Alternatives 2, 2A, 3, 3A and 4 would employ well established, readily
available construction methods and are all considered technically and
administratively feasible. Alternatives 2, 2A and 3 would achieve this
criterion better than Alternatives 3A (involves in-situ solidification of
Impoundment 18) and 4 (involves excavation and solidification of a large
volume of Impoundment 18) because they can be implemented in a
shorter time.
Cost
The total cost for Alternative 1 is $300,000; Alternative 2,
$13,500,000; Alternative 2A, $15,700,000; Alternative 3, $14,100,000;
Alternative 3A, $35,300,000, and, Alternative 4, $41,700,000.
USEPA concurrence
USEPA concurs with the selected remedy.
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• Community acceptance
Community concerns/comments received during the public comment period
and the public meeting are included in the responsiveness summary,
together with NJDEP responses, which is part of this ROD. The
community group CRISIS supports NJDEP's preferred alternative for
Impoundments 17 and 18.
11. SELECTED REMEDY FOR GROUP II IMPOUNDMENTS
Based upon an evaluation of the various alternatives and after consideration
of public comments, NJDEP and USEPA have selected the following
alternatives for the Group II Impoundments:
Consolidation of the iron oxide from Impoundment 16 into Impoundment 15
with capping (synthetic liner) of the consolidated material (Alternative 2);
solidification of the wastewater treatment sludge in Impoundment 17 with
placement of the solidified material into the Impoundment 8 facility, and no-
action/limited action (fencing, institutional controls and ground water
monitoring) for Impoundment 18 (Alternative 2 for Impoundments 17 and 18).
The selected remedy (involving excavation) includes removal of six (6) inches
of underlying soils and any other obviously contaminated material after
removal of the contents of the impoundments and post-excavation evalua-
tion/sampling of the underlying soils. If the results are above the NJDEP Soil
Cleanup Criteria, the underlying soils will be removed/remediated. The selected
alternatives also include a ground water monitoring program and an air
emission control measure (such as a carbon absorber), if necessary.
The in-place containment alternative for Impoundments 15 and 16 would
involve the consolidation of Impoundment 16 into Impoundment 15, and the
capping of the entire consolidated unit. The ground water monitoring program
would be implemented within six months of signing the ROD on a quarterly
basis for the first five years by using monitor wells hydrologically down grad-
ient of Impoundments 15 and 16 to assess potential influences of residual
contaminants on ground water quality, surface water quality in the Raritan
River and associated ecosystems. Based on the results of the first five years
monitoring data, frequency and duration of further ground water monitoring
will be determined. Ground water monitoring would be performed for contami-
nants of concern (as determined by prior chemical analyses) associated with
Impoundments 15 and 16. Appropriate monitor well locations will be
determined during a Remedial Design. Additional monitor wells will be installed
if necessary. If, after five years of ground water monitoring (after completion
of the remediation of Impoundments 15 and 16), it is determined that the
ground water ARARs are exceeded in the selected down gradient monitor
wells, a need for further remedial actions for Impoundments 15 and 16 will
be evaluated.
Solidification of the sludge from Impoundment 17 would involve either
excavating the sludge from the impoundment, mixing it with cement-like
materials (most likely in a mixing unit) or pre-excavation solidification., This
would be followed by consolidation of the solidified sludge in the
Impoundment 8 facility. The ability to control air emissions would be used as
24
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criteria during the Remedial Design phase to determine whether ex-situ solidifi-
cation process or pre-excavation reagent mixing solidification process should
be implemented. The No-Action/Limited Action (fencing and institutional
controls) alternative for Impoundment 18 would involve continued natural
revegetation of the area with periodic (5 to 10 year basis) harvesting of the
larger trees to ensure that tree roots do not breach the silt and clay layer
beneath the impoundment. The ground water monitoring program would be
implemented within six months of signing the ROD on a quarterly basis for
the first five years by using monitor wells (including Monitor Well CCC)
hydrologically down gradient of Impoundments 17 and 1 8 to assess potential
influences of residual contaminants on ground water quality, surface water
quality in the Raritan River and associated ecosystems. Based on the results
of the first five years monitoring data, the frequency and duration of further
ground water monitoring will be determined. Ground water monitoring would
be performed for contaminants of concern (as determined by prior chemical
analyses) associated with Impoundments 17 and 18. Appropriate monitor well
locations will be determined during the Remedial Design. Additional monitor
wells will be installed if necessary. If, after five years of ground water
monitoring (after completion of the remediation of Impoundments 17), it is
determined that the ground water ARARs are exceeded in the selected down
gradient monitor wells, a need for further remedial actions for Impoundment
18 will be evaluated.
These selected alternatives satisfy the remedial action objectives and the
requirements of: CERCLA, as amended by SARA; the National Contingency
Plan, RCRA, as amended by HSWA; and. the AGO, including the NJDEP
Ground Water Quality Standards. Because these remedies would result in
hazardous substances remaining on the site, a review would be conducted
every five years after implementation of this remedy to ensure that the
remedy continues to provide adequate protection of human health and the
environment.
Rationale for Selected Remedy for Group II Impoundments
The in-place containment alternative for Impoundments 15 and 16 would
eliminate nuisance dust from the impoundments and the potential for direct
exposure to the iron oxide, in addition to reducing the area requiring a cover
and maintenance. Moreover, this alternative would contribute to improving
site-wide ground water quality by reducing rain water infiltration to ground
water by installing a cap. This alternative would serve two purposes
simultaneously: protecting human health and the environment and leaving the
option open for recycling of the iron oxide material if such a user is found
in the future. (If a user is found in the future, the material can easily be
accessed and removed by opening a cap.)
Solidification of the wastewater treatment sludge in Impoundment 17 would
chemically and physically bind the inorganic contaminants in the sludge into
a solid matrix, greatly reducing the potential for migration of contaminants.
Consolidation of the solidified sludge into the Impoundment 8 faciljty would
further reduce the mobility of any residual contaminants by reducing the
potential for infiltration of water and by collection and treatment of any
leachate that is generated.
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No-action/limited action for Impoundment 18 would be appropriate based on
the ground water quality data and the aquifer hydrogeologic characteristics
that demonstrate that Impoundment 18 is effectively isolated from the
environment and that it is not a source of ground water contamination in its
present condition. Studies also support the determination that the silt and
clay confining layer beneath Impoundment 18 is continuous and that it is of
sufficiently low permeability to prevent the leaching of contaminants to
ground water. If, after remediation of Impoundment 17 (Impoundment 17 is
a major contributor of ground water contamination in this area), ground water
ARARs in down gradient monitor wells are exceeded in the future, further
remediation of Impoundment 18 will be required.
The on-site Impoundment 8 facility is a multi-lined RCRA waste management
facility and has a leachate detection and collection system as well as a
ground water monitoring system that would cumulatively provide adequate and
appropriate protection of human health and the environment. The compatibility
study demonstrated that the residuals from the solidified Impoundment 17
sludge would be compatible with the Impoundment 8 facility liner. Adequate
capacity for the solidified waste materials is available in the Impoundment 8
facility.
12. STATUTORY DETERMINATIONS
Under thejr legal authorities, NJDEP's and USEPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve adequate
protection of human health and the environment. In addition, section 121 of
CERCLA establishes several other statutory requirements and preferences.
These specify that when complete, the selected remedial action for this site
must comply with applicable or relevant and appropriate environmental
standards established under State and Federal environmental laws unless a
statutory waiver is justified. The selected remedy also must be cost-effective
and utilize permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable. Finally, the
statute includes a preference for remedies that employ treatment that
permanently and significantly reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element.
The selected remedy for the Group II Impoundments is protective of human
health and the environment, complies with State and Federal requirements that
are legally applicable or relevant and appropriate to the remedial action, and
is cost-effective. This remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable for this site.
Because this remedy will result in hazardous substances remaining on the site,
a review will be conducted every five (5) years after commencement of the
remedial action to ensure that the remedy continues to provide adequate
protection of human health and the environment.
73. DOCUMENTATION OF SIGNIFICANT CHANGES
There is no change from the Preferred Remedy described in the Proposed Plan
and the Selected Remedy described in this ROD.
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GLOSSARY
RECORD OF DECISION
GROUP II IMPOUNDMENTS AT AMERICAN CYANAMID SITE
AMERICAN HOME PRODUCTS CORPORATION
BRIDGEWATER TOWNSHIP, SOMERSET COUNTY
This glossary defines the technical terms used in this ROD. 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 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.
ARAB: 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.
NJDEP: New Jersey Department of Environmental Protection.
NCP: National Contingency Plan, 40 CFR part 300.
PPM: Parts per million. . .,
RCRA: Resource Conservation and Recovery Act of 1976 as amended.
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RCRA Cap: A multi-layer material cap (see definition of "cap" above) which
incorporates several impermeable covers to assure absolute 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.
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ADMINISTRATIVE RECORD INDEX
RECORD OF DECISION
GROUP II IMPOUNDMENTS 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 (IMS), 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. n
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.
20. NJDEP Community Relations Plan, February 1989.
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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 Rl, 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. * '
49. Record of Decision for Group I Impoundments (11, 13, 19 and 24),
NJDEP. September 28. 1993.
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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,
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. 5/10/96 Letter from AHP concerning Security Signs for Off Road
Vehicles.
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RESPONSIVENESS SUMMARY
RECORD OF DECISION
GROUP II IMPOUNDMENTS AT AMERICAN CYANAMID SITE
AMERICAN HOME PRODUCTS CORPORATION
BRIDGEWATER TOWNSHIP. SOMERSET COUNTY
7. INTRODUCTION
A responsiveness summary is required by the New Jersey Department of
Environmental Protection (NJDEP) and Superfund policies. It provides a
summary of comments and concerns received during the public comment period
and the public meeting, and NJDEP's and the U.S. Environmental Protection
Agency's (USEPA) responses. 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 Group II Impoundments (15, 16, 17 and 18) 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;
E. Attachments
A. Overview
This is a summary of the public's comments and concerns regarding the
Proposed Plan for Remediation of the Group II Impoundments at the American
Cyanamid Company Superfund Site and the NJDEP's responses to those
comments. The comments that were received in writing are attached to this
section.
This is a summary of the public's comments and concerns regarding the
Proposed Plan for Remediation of the Group II Impoundments at the American
Cyanamid Company Superfund Site and the New Jersey Department of
Environmental Protection's (NJDEP) responses to those comments.
The public comment period extended from January 10, 1996 to February 24,
1996 to provide interested parties the opportunity to comment on the
Proposed Plan, Impoundment Characterization Program Final Report (ICPFR),
Baseline Site-Wide Endangerment Assessment Report (Baseline EA) and the
Corrective Measure Study/Feasibility Study (CMS/FS) for the Group II
Impoundments 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
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the results of the ICPFR, Baseline EA and the CMS/FS 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 Group II
Impoundments (15, 16, 17 and 18) at the American Cyanamid Site:
Consolidation of the iron oxide from Impoundment 16 into Impoundment 15
with capping (synthetic liner) of the consolidated material; solidification of the
wastewater treatment sludge in Impoundment 17 with placement of the solidi-
fied material into the Impoundment 8 facility,, and no-action/limited action
(fencing, institutional controls and ground water monitoring) for Impoundment
18.
B. Background on Community Involvement and Concerns
Since 1988 there has been a great deal of concern about a proposal by
American Cyanamid to build a commercial hazardous waste incinerator on the
site. At present, Cyanamid has no plans to pursue the incinerator. The
Somerset-Raritan Valley Sewage Authority already operates a sludge
incinerator on property adjoining the American Cy'anamid 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 1989 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 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.
NJDEP 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
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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 1991.
Residents concerns at the American Cyanamid site have been focused through
two local groups, CRISIS and the Bound Brook Citizens Association. In March
of 1991 representatives of CRISIS expressed concerns regarding a proposed
modification of a Hazardous Waste Facility permit to allow storage and
blending of tars from lagoons 4 and 5. This permit modification was needed
so that materials could be blended and heated for off-site shipment for use
as alternative fuel in cement kilns. During the summer of 1991, Mayor
Dowden of the Township of Bridgewater and other local officials and residents
publicly stated that 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, NJDEPE reaffirmed its
policy of placing site information in local repositories as soon as documents
were completed and NJDEPE offered to meet with township and community
representatives before the start of major site activities.
In 1992, CRISIS received a Technical Assistance Grant (TAG) under the
Superfund program from USEPA and hired a consultant to review and evaluate
documents on the ongoing Superfund remedial program. On August 4, 1992
NJDEPE held a briefing for local officials and representatives of CRISIS in
Bridgewater to discuss the planned Surface Soils Remedial/Removal Action
(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. At the August 4th meeting
officials expressed concern about possible pollution of Cuckhold's Brook during
the work and stated that the publrc was still not convinced that Cyanamid's
ground water pumping system was controlling water pollution at this site.
In an August 31. 1992 letter, CRISIS requested additional information from
NJDEPE on other site remediation issues including the development of the Risk
Assessment document, health evaluations, construction of chemical processing
plants as part of the cleanup process, and proposed ground water cleanup
standards. 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 visite'd 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 Apfil 20,
1993 letter, to meet again with Bridgewater and CRISIS officials to address
these concerns.
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NJOEP issued a Superfund Update for the American Cyanamid site in
December 1994.
NJOEP issued a Superfund Proposed Plan for the Group II Impoundments and
Hill Property Soils in January 1996 and provided public comment period from
January 10, 1996 to February 24, 1996. NJOEP 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.
C. Summary of Comments Received During the Public Comment Period and
Agency Response
Comment:
Response:
2. Comment:
Response:
3. Comments:
Response:
CRISIS, Bridgewater Township officials and local residents
asked what measures will be taken to prevent
contaminated soils left in Impoundment 15 from being
impacted and released by 100-year and 500-year storm
events? Questions about flooding were related to aerial
photographs taken during August 1971 that showed
flooding at the American Cyanamid site. The photocopies
of the black and white photographs submitted to NJDEP
included the locations of the various on-site impoundments
highlighted in red and numbered. Also, questions were
raised about how the cap for Impoundment 15 will be
designed to deal with flood waters?
Information on these issues was provided in NJDEP letters
dated March 4, 1996, March 26, 1996 and April 23, 1996
to CRISIS (attached).
CRISIS requested a cost benefit analysis to compare the
alternatives for Impoundments 15 and 16. Specifically,
would the added cost of in-situ solidification for the
contents of Impoundments 15 and 16 prior to placing this
material into Impoundment 15 be justified in terms of
increased protection to human health and the environment?
After such an analysis was completed, it was requested
that NJDEP's preferred alternative for these impoundments
be reconsidered.
See response to Comment number one. It should be noted
that the Township of Bridgewater fully concurs with the
proposed remedy for the Group II Impoundments (15, 16,
17 and 18).
CRISIS requested explanation from NJDEP concerning the
Department's March 4, 1996 and March 26, 1996 letters
in the group's letters dated March 20, 1996 and April 10,
1996, respectively (both letters attached). , ,
NJDEP provided a response and explanation in its March
26, 1996 and April 23, 1996 letters to CRISIS (attached).
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4. Comment:
Response:
5. Comment:
Response:
6. Comment:
Response:
CRISIS requested clear, defined goals for monitoring the
anticipated natural attenuation of contaminant levels in
ground water down gradient of Impoundments 15 and 18.
Further, if anticipated reductions in contaminant levels do
not occur, CRISIS requested a re-evaluation of the selected
remedial actions by NJDEP.
This information is included in the Proposed Plan on page
14 under the section "Preferred Alternatives for Group II
Impoundments" and is included in the ROD.
According to a resident, a member of CRISIS died recently
and her doctor said that her illness, multiple sclerosis,
may be due to mercury poisoning. She lived about 300
feet from Impoundment 8. Could this type of
contamination have come from the site?
The waste material in Impoundment 8 has been stabilized
and covered. Also, there are hydraulic controls and
monitoring in place that indicate leachate an-d/or ground
water from Impoundment 8 are contained within the
Impoundment 8 Facility. As such, there are no exposure
pathways for contaminants (including mercury) from which
the nearby residents could get exposed from this facility.
NJOEP does not have any past information about the
release of mercury from the Impoundment 8 area. A flyer
from the New Jersey Department of Health (DOH)
concerning exposures to hazardous substances has been
included as an attachment to this Responsiveness
Summary. Also, a site review and update prepared by
DOH is included as an attachment. Please consult
Jacqueline Solomon, Community Involvement Coordinator,
Environmental Health Services, DOH, at (609) 984-2193 for
more information related to health concerns.
A resident asked if appropriate measures are being taken
to protect residents who use Polhemus Lane from
contaminants being permanently stored in the Impoundment
8 East and West facility. Because this area was under
water during Hurricane Doria, is it adequately protected
from such flooding events. What types of contamination,
including mercury, have been and will be placed in the
Impoundment 8 facility?
Impoundment 8 Facility has been designed to withstand
100 and 500-year flooding. It is completely fenced and
secured by a berm around it. There is a cover on the
portion of this facility where waste material has already
been placed. Once the facility is full, a permanent cap will
be installed. There are hydraulic barriers for ground' water
and a collection system for any leachate that may be
generated. The facility has been and will be routinely
36
-------
7. Comment:
Response:
8. Comment:
Response:
9. Comment:
inspected and monitored. The types of contaminants that
have been and will be placed in the facility include
volatile and semi-volatile organic compounds and metals
(including mercury). Please note that any material placed
in this facility has been or will be solidified to meet a 15
pounds per square inch strength criteria required under the
ACO:.
A resident complained about air emissions from the
American Cyanamid facility on certain days and requested
a printout of all chemicals being emitted during its
operations and the health effects associated with these
emissions.
American Cyanamid has numerous permits with NJDEP to
control air emissions. Currently, NJDEP is in the process
terminating several permits for American Cyanamid as the
company downsizes its operations at the site. NJDEP's
Bureau of Release Information and Prevention maintains an
inventory of chemicals at the facility meeting certain
criteria under the state Worker and Community Right to
Know Act and the federal Emergency Planning and
Community Right to Know Act. Also, certain chemicals
discharged from the facility are required to be reported
under the federal act and are disclosed as part of an
annual Toxic Chemical Release Inventory report. Lastly,
American Cyanamid's annual emission statement covering
the overall release of pollutants in 1993 and 1994 are
attached. The above information includes the latest data
available that is required to be submitted by American
Cyanamid and is included as an attachment to this
Responsiveness Summary. For questions about health
related concerns please call the DOH contact listed in the
response to comment number 5.
CRISIS questioned how NJDEP determined that the clay
and silt layers under Impoundments 15, 16 and 18 are
continuous, but discontinuous under Impoundment 17?
Specifically, how many soil borings were done over the
15.4-acre Impoundment 18 area?
Information on the clay and silt layers under Impoundments
15, 16, 17 and 18 was obtained from the soil borings and
Aqtessolv Aquifer Analysis (pumping test). Thirty five soil
borings were established for Impoundment 18. Detailed
information on this subject is included in Attachment 1A
(Hydrogeologic Investigation Report) of the CMS/FS Report
for the Group II Impoundments.
. 4
Why is the material currently stored in Impoundment 15
considered non-hazardous iron fillings even though it
37
-------
includes elements like arsenic, chromium, lead, copper and
nickel?
Response:
10. Comment:
Response:
1 1. Comment:
Response:
12. Comment:
Response:
Hazardous characteristics of waste material is determined
by using four categories: Ignitability (Plash Point),
Corrosivity (pH), Reactivity (cyanide and sulfide) and
Toxicity (teachability of organic compounds and metals).
Iron oxide material in Impoundments 15 and 16 is
classified as non-hazardous because it is below the
regulatory threshold for all four characteristics. The metals
like arsenic, chromium, lead, copper and nickel are present
in Impoundments 15 and 16 at such low levels that they
do not exceed the threshold criteria when subjected to the
extraction procedure under the Toxicity Characteristics
Leaching Procedure developed by USEPA. Therefore, the
material in Impoundments 15 and 16 is classified as non-
hazardous.
CRISIS asked for a time period associated with long-term
monitoring proposed by NJDEP.
Long-term monitoring would last for at least 30 years. For
the first five years ground water would be monitored on
a quarterly basis. This protocol would be re-evaluated at
the end of the five-year period to determine the frequency
and parameters for the remaining years. The duration of
short-term monitoring is five years.
CRISIS asked if American Home Products proposes to sell
the American Cyanamid property, specifically how would it
sell the manufacturing portion of the site with the
impoundments remaining on site?
According to an American Home Products representative,
the company would like to sell the Hill Property, but there
are no plans at this time to sell the manufacturing portion
of the site. Should American Home Products chose to sell
the property, they could do so provided that use
restrictions are in place, and an agreement is in place
requiring the purchaser to complete the remediation.
A resident asked if any contamination would be released
to the air during excavation and construction activities
involving the impoundments on site.
Contamination would not be released in the air above the
regulatory threshold limits during excavation and
construction activities for these impoundments. Extensive
air monitoring will be performed to verify this.^ If air
monitoring indicates exceedence of regulatory threshold,
remedial activities will be stopped and appropriate
corrective actions will be taken.
38
-------
13. Comment:
Response:
14. Comment:
Response:
15. Comment:
Response:
1 6. Comment:
A resident asked what is the commercial viability of the
site based on ongoing cleanup actions at the site and who
makes that determination?
NJDEP's role is to guide the remedial activities at the site
in a manner that is protective to human health and the
environment and meets state and federal statutes,
regulations and criteria. It is up to the property owner to
propose or take steps to allow any further development or
reuse of the facility.
A resident asked if there were any actions that could be
taken to prevent off road vehicles from using the area
along the Raritan River on site where there are several
impoundments? Also, a request was made for NJDEP to
investigate damage from off road vehicles to banks of the
Middle Brook near Interstate 287.
NJDEP has requested American Home Products (AHP) to
increase the frequency of its security patrolling and to
place warning signs at the areas of Impoundments 15, 16,
17 and 18. These are the only actions NJDEP can take to
prevent unauthorized off road vehicles from using this
portion of the site. NJDEP cannot investigate off-site
damage from off-road vehicles to banks of the Middle
Brook near Interstate 287 because it is not within the
scope of remediation for this site.
Was the Elizabethtown Water Company notified of the
proposed remediation plan for the Group II Impoundments?
Can NJDEP solicit comments from them directly?
The water company is on NJDEP's mailing list that is used
to announce remedial actions at the American Cyanamid
site. The company, along with the entire mailing list, was
sent two notices about the plan, public comment period
and public meeting in early January 1996 and early
February 1996. Also, as requested at the public meeting,
a copy of the Proposed Plan was sent to the company via
Express Mail on February 23, 1996 offering them a chance
to comment until March 11, 1996. The company's
environmental coordinator also spoke with NJDEP on.
February 23, 1996 about the public meeting held the
previous day. NJDEP did not receive any comments from
the company.
CRISIS stated that at times it seems NJDEP is saying the
material in some impoundments is not dangerous and the
group is concerned about such descriptions because the
risks to human health and the environment are
understated.
39
-------
Response: NJDEP never said that the material in some impoundments
is not dangerous. NJDEP said that material in some
impoundments has been classified as non-hazardous or it
has been detected below the regulatory cleanup standards.
NJDEP required the responsible party to conduct a risk
assessment for this site and to use a more conservative
approach than is required by USEPA for Superfund sites
throughout the country. As such, the risk assessment
performed at this site is still valid and is not understated.
17. Comment:
Response:
18. Comment:
Response:
CRISIS asked if there has been any recent delineation of
the flood plain in the area of the site?
Flood plain delineation was updated for the site area at
Impoundment 19 prior to its remediation. Flood plain
delineation at the area of Impoundment 11 is being
updated. This procedure will be followed for the
remediation of remaining site impoundments (requiring
excavation) located in the flood plain.
CRISIS asked how the comments of its technical advisor
would be used by NJDEP in formulating its final Record of
Decision.
NJDEP has considered all comments received during the
public comment period in selecting the remedy in the
Record of Decision. Please see the response to comments
numbers one through four.
D. Community Relations Activities
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 # (90S) 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 citize/is in
Bridgewater to discuss the corrective action portion of. the 1988
Administrative Consent Order (AGO) and the initiation of the Remedial
Investigation/Feasibility Study (RI/FS) (January 1989),
40
-------
NJOEP held a public meeting in Bridgewater to discuss the RI/FS (February
21, 1989).
NJDEP prepared a Community Relations Plan (February 1989).
NJOEP forwarded information requested at the February 21, 1989 meeting to
those attending (April 20, 1989).
NJDEP held a public meeting in Bridgewater to update the RI/FS progress
(March 11, 1991).
NJOEP 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 concerns raised
by Bridgewater regarding ongoing site activities (November 27, 1991).
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 SSR/RA from September 17, 1992
through October 16, 1992.
NJDEP 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 provided 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.
E. Attachments
The following documents are included as- attachments to the Responsiveness
Summary:
1. Public meeting transcript;
2. Written comments received during the public comment period;
41
-------
3. Written NJDEP and CRISIS correspondence;
• March 4, 1996 NJDEP letter to CRISIS
• March 20, 1996 CRISIS letter to NJDEP
• March 26, 1996 NJDEP letter to CRISIS
• April 10, 1996 CRISIS letter to NJDEP
• April 23, 1996 NJDEP letter to CRISIS
4. "Am I exposed to Hazardous Waste," (2/95) and "Site Review and
Update, American Cyanamid Company," (8/93) New Jersey Department of
Health;
5. Community Right to Know Information for American Cyanamid Company
(4/8/96) and Annual Emission Statement for American Cyanamid Company
(1993, 1994); and,
6. Concurrence letter from USEPA.
42
-------
FIGURES AND TABLES REFERRED IN TEXT
AMERICAN CYANAMID SITE-RECORD OF DECISION
GROUP II IMPOUNDMENTS (15,16,17 AND 18)
-------
RTE 28
FIGURE 1
AMERICAN CYANAMID COMPANY
BOUND BROOK, NEW JERSEY
GROUP II IMPOUNDMENTS
N.T.S.
FILE NO. 5772'.010
G
tTMENE
-------
TABLE 1
AMERICAN CVANAMIO COMPANY
BOUND BROOK, NEW JERSEY
CROUP R IMPOUNDMENTS
DATABASE SUMMARY FOR CONTAMINANT CONCENTRATIONS
1 OF 2
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Mm 1 MM 1 Mem 1 Detect*
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ooir OMI oo« 8 oi8
oon OOM ooos sore
0007 0007 0007 1 oC 8
oon OMI oom 7<*e
0001 OOOS OOM 40(6
OOM oon OOM 3«»e
0700 0700 0700 loie
0780 I'OOO SM7 8of6
0067 00*2 oon loie
e.iio iioo 05J5 soie
OOn 0470 O.M) 4ofO
0.110 0«M 0747 Jrf8
0.1JO 1.500 0470 5 of 8
^
OtOO 3000 1780 So>8
Impoundment 16
Mln | Max | Mean I Detects
0004 OOOS OOM 7<*8
0018 0140 0063 6rf8
000} 0018 OOM 4ol8
0009 0077 0018 3<<»
0007 0008 0004 3<*8
0004 0010 0007 3f*8
OOM 0170 0073 3<*«
OO40 0073 OOM 3aT8
0870 8100 3170 8al8
07)0 0830 0407 8ri8
0110 0700 0170 8<«8
0060 0700 0111 5d«
DIM 0400 0313 «t<«
0.110 0190 0113 4ol«
1900 8700 3683 60(8
Impoundment 17
Mln | Mai 1 Mean | Detect!
7600 7800 7800 1ol17
0047 8000 1777 11oM7
0004 1100 0471 8 1*17
037O 0370 0370 lot 17
007S 0075 0075 1 rf 17
03)0 500O 7387 «o(1J
0004 3400 1079 «oM7
0070 38000 15VM 7ol17
4000 180000 67491 11 oM7
7300 100000 33043 7<^17
4700 79000 11 608 7oM7
17000 1IUIOOO 575OO 17nl17
30DD 14000 8143 7ol17
19000 41000 78000 Srf17
6900 34000 16797 17of17
3700 15000 7171 7rf17
3300 300000 6307S 1}rf1J
4900 15000 9631 8c>11
8SOO 15000 11040 10 oT 17
Impoundment 18
Mln | Mai | Mean I Delects
0046 0048 0048 1470
0014 1SOOO 1087 16 or 70
0008 0430 0158 5<*70
0010 0010 0010 1i*70
0140 0500 0763 )c*70
0011 0011 0011 loTTO
0019 1800 0837 4470
7300 19000 7640 5ol70
3900 450000 119775 470
10000 37000 73500 8o>70
130000 140OOO 135000 7<*70
70OO 810 ODD 100083 16ol70
1.700 1700 1700 lot 70
4300 190000 88383 8<*70
17000 79000 73000 6ol70
3900 3900 3900 1 ot 70
m >numtwc ol aXrrtkint
-------
TABLE 1 (Cont'd)
AMERICAN CYANAMID COMPANY
BOUND BROOK. NEW JERSEY
GROUP N IMPOUNDMENTS
DATABASE SUMMARY FOR CONTAMINANT CONCENTRATIONS
IDF 2
Impoundment 19
mjlm
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Mln | Max 1 Mem I Detects
19« je» 777.90 6of6
r.n 70.40 17.77 eme
94.00 ram eei3 0are
4.70 630 5 SO 6 of 6
14.40 193 4932 8ol6
931 1210 768.17 Safe
37.70 4830 47.07 8 of 6
1030 4.49000 1.971.07 6 0*8
380.00000 987.00000 489.83333 8ol 8
104 779 187 8oT8
. «J90 1090 1090 1at8
1.790.00 1.74000 1.90000 8of6
791 1.89000 1.18817 8018
81 848 709.13 8018
19.30 19.30 1930 Id 6
8490 888 74487 6c»6
111 1 pOUl Nil! Wit lv
Mln I Max | Mean | Dried*
10400 79900 71800 6ol8
7.00 1890 ton «oie
9780 8300 0000 0ot8
480 770 977 6of6
690 790 740 7of6
7090 7490 3838 646
47900 1.07000 787 50 6 of 6
3200 4740 3747 8 o»6
1.04000 7.670.00 1.77167 6 of 6
437.00000 490.00000 487.33333 6ot6
1970 17400 9783 6of6
1.18000 1.93000 1.599 S3 8of6
70700 1.13000 89600 6(48
161.00 16100 161.00 1ol6
9890 97.80 7374 9oT6
7940 489.00 19777 6<*6
Impoundment 17
Mln | Max | Mean I Detects
47.60000 118.00000 96.33333 17 or 17
3070 4970 4793 3OM7
7790 16600 7117 17 of 17
3.83000 1550000 7.60167 17oM7
770 770 770 1oM7
160 570 396 11 of 17
17.70000 66.90000 75.77500 17(417
91500 19.70000 3.41875 170M7
980 7410 1569 17oM7
1.77000 3.64000 7.45750 17ori7
600 7070 1405 10oM7
74.40000 65.10000 48.35933 17oM7
1.30000 3.07000 7.35833 17ol17
18.00000 170.00000 96.08333 17oM7
695 OO 1.90000 1.19608 17<*17
7010 10100 76.18 17 of 17
6630 14500 9037 17oM7
09800 93500 91550 7<*17
19600 1.09000 54333 17 of 17
6100 11300 6396 17oM7
1.46000 3.75000 7.63167 11 of 11
trflpOmtQIftCflV • 9
Mln | Max 1 Mean I Detects
78.70000 173.00000 80.97900 TOo'TO
610 5600 3771 JOdTO
7730 577 17607 TOafTO
1.76000 14.10000 7.44950 70a>70
067 180 176 IQalTO
700 1000 453 TOoTTO
9.54000 183.00000 78.70750 TOofTO
40900 7.60000 1.68669 70 of 20
590 3760 1507 70 of 70
63600 3.67000 7.O96 40 TOoTTO
410 4970 1161 190170
73.70000 787.00000 99.96000 30 of 70
98500 3.37000 7.08550 70 of 70
3.73000 117.00000 77.59050 TO of 70
19700 1.65000 95310 TOofTO
3970 75400 17937 TOofTO
4890 39600 10796 TOofTO
44500 1.50000 70913 15ofTO
050 090 008 9 of 70
16600 81900 33400 TOofTO
3370 17500 7089 TO of 70
36700 4.38000 7.79970 70 of TO
not
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AMCWCAM CYANMWO COMPANY OMOUTI CMt
OMOUMMMATtlt QUALITY DATA
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Receptor
Population
On-Site
Production
Employees
On-Site
Maintenance
Employees
On-Site
Trespassers
Table 3-Record of Decision
Group II Impoundments (15, 16, 17 and 18)
Total Pathways Risk Characterization Summary
American Cyanamid. Bound Brook. NJ.
Exposure
Route
Incidental Ingestion
Derma! Contact
Inhalation
Incidental Ingestion
Dermal Contact
Inhalation
incidental Ingestion
Dermal Contact
Inhalation
Media
Production Area
Surface Soils
Production Area & West Yard
Surface Soils
Surface Soils South of Port
Reading Railroad Tracks
Summation of Risks
AH Pathways
Chemical- Chemical-
Specific Specific
Cancer Hazard
piste Indices
1.43E-04 2.49E-01
1.40E-04 &22E+00
324E-07 2B2E+00
On-Site
Trespassers
Incidental Ingestion Impoundment 15,16.17,18
Dermal Contact Solids
Inhalation
1.1QE-06 1.15E+00
On-Site
Trespassers
inhalation
Organic Vapors From
Impoundment 1 & 2 Water
Covers
4.80E-08 -
Off-Site Residents
Adult
Off-Site Residents
Adult
Incidental Ingestion Rarttan River Water via
Inhalation
Inhalation
Elizabethtown Water Company
Organic Vapors Prom
Impoundment 1 & 2 Water
Covers
e.ooe-oe 4,oeE-o3
Z40E-06 —
Off-Site Residents
Child
Off-Site
Recreational
Receptors
Incidental Ingestion Rarttan River Water via
Dermal Contact
Elizabethtown Water Company
t
Rarttan River Water
&50E-06 Z21E-03
1JOE-07 4.61E-05
3/ZH2
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ATTACHMENT 1
RESPONSIVENESS SUMMARY
AMERICAN CYANAMID SITE-RECORD OF DECISION
GROUP II IMPOUNDMENTS (15, 16,17 AND 18)
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Attachment 1
Am Cyanamid Site-Record of Decision
Responsiveness Summary
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
SITE REMEDIATION PROGRAM
PUBLIC MEETING TO DISCUSS A PROPOSED PLAN FOR
THE REMEDIATION OF THE GROUP II IMPOUNDMENTS
(15, 16, 17 & 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 & 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
New 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.
We 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 so, as we will use these lists for future
mailings. .
We are here tonight to both share information with
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-'i-*
submit written comments if you prefer. The comment pex^..
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 Haiyesh
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 Qere, consultants for
American Home Products, who will discuss the remedial
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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 Eaiyesh 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 Super fund in December of 1982. American Cyanamid
Company and the New Jersey DBP 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
€50,000 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.
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This ground water pumping has been in operation
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since 1982, and is affectively 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 Hill 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
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actions on impoundment* 6, 7, and 8. The remedial
investigation conducted at the Hill 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 Bill Property soils.
The site-wide remediation program has been divided
into three units. First unit is surface impoundments. The
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surface impoundments have been divided further into 'three
groups. Group I includes impoundments 11, 13, 19 and 24.
Group XX 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 I 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.
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
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completed in April of this year. The proposed plan we are
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discussing tonight, only addresses Group II impoundments and
the Bill 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 comment* 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 I go through the Group II impoundments, and the
remedial investigation for the Bill Property, I'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. Pour in which remediation has been
completed. Pive, 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 III impounds, which are the
remaining 8 impounds, in which the feasibility study will be
completed by April of this year.
I'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-11, 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
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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 SRVSA 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 Hill Property down to the main plant. The
other fundamental piece* of the overall remedial program/ at
this Bite, 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.
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I do -- just do an overview on the results of the
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remedial investigation, from the Hill Property. The Hill
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 Home 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 Hill 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
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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
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 endangennent 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 ingest ion, dermal and inhalation.
Again, in its existing stage before remediation. •
Next impound I'd like to 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
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 IJr"
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 5300,000 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 «oil cover, so
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 In-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
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.
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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 Z 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 sorry, excavated, solidified and
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placed in 8.
I'm sorry. And then impound 18, instead of no
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
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
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taking the largest impound we're dealing with, and putting it
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into the impound 8, waste management facility.
This* 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 the Bill Property soils, we are recommending
no further action, with ground water contamination recovery at
the main plant, and ground water monitoring of the Hill
Property.
We are recommending these alternatives because they
satisfy the CERCLA 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 I 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. LUZBCKY: Thank you Baiyesh. I'd also like to
recognize council President DeSensio.
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 II impoundments. He support
the proposed plan for the Hill Property, and we don't have any
real problem with that.
With respect to the Group II 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. From
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 Abater.
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 Z havq to give thanks to Haiyesh 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
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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 immobilizatidh 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 Gere 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 taking
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
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.
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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. LUZECKY: Thank you. Your comments are fairly
extensive, and I won't attempt to address them today, I do
share your concerns about the berms, 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. We 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. OERMINE: .Roman, if I might ask, in light of the
fact that we'll be getting hopefully a cost 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. LUZECKY: 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. QERMINE: Thank you and Z do have a written
version of the comments which I'll hand you.
MR. LUZECKY: Great, thank you.
MR. GERMXNE: 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 Finnderne 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
from impound 8.
The location of impound 8, has been known to flood,
there are pictures indicating during Hurricane Doria, that
area was under water. Impound 8 is on Polhemus Lane
approximately 50 feet from the road. Polhemus Lane is the
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only way you can reach the water company, sewerage authority,
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trash transfer, and recycling.
This 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, X 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. I 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 --
KR. 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 Finnderne and I know you're trying to
address them, and I know you're doing the.best, but --
MR. LUZECKY: 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
no exposure to the environment, from that impoundment.
MS . COWALL: Thank you.
MR. LUZECKY: Thank you for your comments. Yes.
MR. DeSENSIO: All right, my name is Frank DeSensio,
I'm a Bridgewater resident, I also happen to be a Councilman,
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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 Z make my comments.'
I wasn't going to say anything tonight, but after
listening to Mr. Germine 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 I worked there at the time, so my office
was under five feet of water, so I know that the problems they
had.
And I'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 I
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. LUZECKY: We 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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barms, and once the flood recedes, the water can then drain
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. HAMMERSLAQ: My name is Pete Bammerslag, and I'm
a Bridgewater resident. I'm also a member of Crisis. When
you responded to Frank 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. HAMMERSLAG: It will be implemented?
MR. LUZECKY: Correct.
MR. HAMMERSLAO: Okay, that's clear. I'd like to
follow up on the flooding aspect a little bit, I have two
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 Oeological Survey, in 1972, entitled Floods of August
and September 1971, in New Jersey.
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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: We 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 1 "
year flood plain, we would upgrade the berms,
impoundment 18, and 15, to withstand a 500 year flood.
MR. HAMMERS LAG: 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
I believe it was January 19th, flooding, which of course was
nothing like that. But --
MR. LUZECKY: Yes, I -- "
flood.
MR. HAMMERSLAG: -- is a fairly recent maybe small
MR. LUZECKY: Yes, those flooding conditions were
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monitored by I believe the township health department, Chris
Paulson, I believe was out there, during the worst times.
MR. SHAH: And Tim Farrell.
MR. LUZECKY: And Tim Parrell.
MR. SHAH: From American Home Products.
MR. HAMKERSLAG: 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: Mo, 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
soil borings would you have done in an area that large, to
satisfy yourselves that it's continuous?
MR. SHAH: Right, I mean we -- I forget the exact
numbers and -- and I 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. SHAH: Yes.
MR. HAMMERSLAG: -• group.
MR. SHAH: Previous consultant. Yes.
MR. HAMMERSLAG: Okay. .
MR. SHAH: I 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 I reviewed the information
and I think the numbers they used -- I wasn't involved, I did
not approve that, because X became Case Manager in 1990. And
this was done prior to that, but my Section Chief he was
project manager at that time, and subsequently to that, I
viewed the information, and I feel -- I 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
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 I missed something because I'm not
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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. HAMMERSLAG: 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. HAMMERSLAG: Okay. Somebody mentioned while
Mrs. Cowall mention mercury, and a few people said there's no
mercury there, I 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 impoundment 17 and 18.
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MR. HAMMERSLAG: Okay. Isn't 17 --
MR. SHAH: There is no mercury in Impoundment --
MR. HAMMERSLAG: -- going to be solidified and put
in 8?
MR. SHAH: Right.
MR. HAMMERSLAO: Okay, BO 17 having 101'parts per
million, of Mercury, maybe when it's solidified it'll be
harmless essentially?
MR. SHAH: Right;
MR. HAMMERSLAO: 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. LUZECKY: That would be my mistake. .When I
asked Haiyesh the question, I wasn't clear on his -- I didn't
understand his question, or his answer clearly. And I made
that statement incorrectly.
MR. HAMMERSLAG: Okay, I just wanted to clarify
that, to make sure Z have correct information and that Mrs.
Cowall understood the response to her question.
How does a cap avoid flood problems? Bow does a cap
that again, non technically, I 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
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flood plain, something about the cap insuring that what's
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underneath it, doesn't get flooded. Is it in the method of
securing to the ground?
MR. LUZECKY: Maybe --
MR. HAMMERSLAG: 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 maximum velocity,
such that there's minimal to no erosion associated with any
flood event.
MR. BAMMERSLAO: Okay, so it's erosion, by basically
water speed, rather than like infiltration of the flood waters
themselves? • .
MR. ROLAND: That's correct.
MR. HAMMERSLAO: 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 muc'i f-
MR. EAMMERSLAG: What does ground water impai_-
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
remediation, remedial alternatives.
MR. HAMMERSLAG: 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
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terms are you talking about?
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MR. LUZECKY: We 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. SEAS: Can I --
MR. LUZECKY: Sure.
MR. HAMMERSLAG: Okay, so it's -- oh, I'm sorry.
Did you want to add to that?
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. HAMMERSLAG: So 30 is the long term period?
MR. SHAH: Yeah, that's defined in their National
Contingency Plan, in Superfund.
MR. HAMMERSLAGt Thank you. I read something in the
paper about American Home Products wanting to sell the
property. I 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. LDZECKY: Pat Welsh from American Borne 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, I think that's all I have, thank you for your responses.
MR. LUZECKY: Well, thank you. '.Does anyone else
have any comments?
MR. SIMP SKY: My name is Greg Simp sky, and I'm a
resident of Finnderne, 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
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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. SIMFSKY: Okay, my next question would be based
on the condition of the property, below the Hill area, what --
it's current commercial viability, based on -• you know, the
contaminants and improvements that'll 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. He 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. LUZECKY: Well, 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.* 'He don't
look at its commercial viability, per se. I'm certain that if
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it coat a little bit acre to move or treat an impoundment
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differently, for a future development, that the company would
probably do that.
MR. SIMPSKY: Okay, thank you. •
MR. McKEOWN: Ei, ay name is Cameron McKeown, I'm a
neighbor of the Bite, 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 Super fund 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 18, we
chose to cap them, to minimize or eliminate the exposure to
airborne particles, and also to fence that area. It's the
best we can do to prevent off road vehicle use.
MR. McKEOWN: Well, just as one suggestion, the --
apparently DEP issued permits to the water company, t'o install
huge sewers, that run along the Raritan, between Bound Brook
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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 Finnderne
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 New Jersey Transit there was some
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flooding.
The flood in '73, which I think was larger than the
one in '71, was only an 80 year event, and in terms of our
local economy here, that was huge, 00 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. McKEOWN: All right, and just to follow up on
the last person's question about the effect of flood on these
berms, do I 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?
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 leacha'te.
What we have found through the studies, is that in
an open condition now, we found -- excuse me -- minimal to no
impact on ground water, which is where you would see that
potential leachate.
What we're proposing with this remediation, is to
basically create a situation where the flood 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 Z can tell you is that the situation now
has been identified to have minimal or no impact and then
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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. TUTKONI: John Tutroni, Bridgewater, I have one
question. Adjacent neighbor to this property is Zlizabethtown
Water, are they issued an opinion on the remediation of your
current plan?
MR. LUZECKY: No they have not.
MR. TUTRONI: 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
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. TDTRONI: Will you -- do you plan on soliciting
them for an opinion. •
MR. LtJZECKY: We can out reach to them one more time
to see if they have any comments on the proposed plan.
MR. SEAE: Right.
MR. TUTRONI: Thank you.
MR. SHAH: Welcome.
MR. SODEY: May I 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 Group. 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
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 meetings much
better informed of each other's positions and better able to
respond to them.
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And Z 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.
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 sitting
and listening to comments made in support of the plan's at
these public meetings, and this goes back to -the first one
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that Z think was held in 1991. Zf 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.
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Then we had the public meeting about two and a half
years ago, on the Oroup I 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 Superfund 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
I know you're not, that the material is not dangerous. This
concerns members of our Oroup. .
And it concerns us in terms of some things that come
my way, that I 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 I 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 EPA,
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.drv
substances, and that illnesses are resulting from these
exposures. This includes respiratory illnesses, cancers and
immune system effects, birth defects, reproductive disorders
and neurological problems." .
Now, I recognize that this is a blanket statement,
they're not talking about this site. This is covering all
contaminated waste sites apparently that EPA monitors, and to
that extent, it's a somewhat general statement.
But it also goes along the lines, and I believe this
particular clip was one that I both monitored in the Star
Ledger, April 23rd.
April 13th, 1993, and members of my Group, were
aware of this, and I believe one of them actually attended, it
was a US Senate Subcommittee hearing that was held in New
Jersey, in Trenton, was chaired by Senator Frank Lautenberg,
and at that witnesses presented testimony or I should say
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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, I believe X 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
want to represent it as such.
I -- I'm only bringing these things up now, to give
you better idea- why the Group 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 a* 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 Group I 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
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, I
believe it is.
There was also a suggestion made at that meeting,
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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 --
MR. 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: Well, 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. SODEY: 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,
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 Have been
raised on flooding. And potential effects on the impoundments
in Group ZZ.
Eas there been any recent delineation of -- Z 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. SHAH: 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 ZZ
impoundments, they included a history of flood events, and
then flood assessment was conducted.
Also the company is required to assess this flood
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 submi'tted
stream encroachment permit to DEP, and they had to re-evaluate
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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. SQDEY: So if Mr. Germine 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 Germine, 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, mo that it
depends on the extent of those comments, how long it will take
us to finalize the Record of Decision.
MR. SODEY: 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. GERMINE: 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. GERMINE: I don't see that's superfluous.
MR. SEAE: We won't sign the ROD, you know, without
giving you an opportunity.
MR. SODEY: You have nothing else to submit then?
MR. GERMINE: I don't have any problem with that.
MR. SODEY: Okay, all right, thank you.
MR. LUZECKY: Thank you. Any other comments?
. s
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,
•
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 Hall.
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 III impoundments,
when we move forward, move towards signing a third Record of
Decision for this site.
I do want to emphasize that your questions, and
comments are welcome throughout the remedial action process.
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Please -- please 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.
J & J COURT TRANSCRIBERS
BY: PATRICIA C. DUPRE
DATED: February 26, 1996
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ATTACHMENT 2
RESPONSIVENESS SUMMARY
AMERICAN CYANAMID SITE-RECORD OF DECISION
GROUP II IMPOUNDMENTS (15, 16, 17 AND 18)
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Attachment 2
Am Cyanamid Site-Record of Decision
Responsiveness Summary
TECHNICAL ADVISER'S RECOMMENDATIONS
TO CRISIS, INC., REGARDING
PROPOSED REMEDIATION PLAN FOR
GROUP II IMPOUNDMENTS,
AMERICAN CYANAMID SUPERFDND SITS,
BRICGEWATSR TOWNSHIP
Thomas J. Genuine, J.D., P.E,
January 23, 1996
The purpose of this report is to outline my
recommendations to CRISIS, as its Technical Adviser, regarding the
Proposed Plan for the remediation of the Group II Impoundments at
the American Cyanamid/American Home Products Superfund Site in
Bridgewater Township.
Background
The Group II Impoundments consist' of four Impoundments,
designated 15, 16, 17, and 18,. located immediately south of the
Reading Railroad tracks and immediately west of Cuckolds Brook (See
attached Site Map) . For the purposes of the' remediation plan, the
Group II Impoundments are .subdivided into two pairs, 15&16 and
17&18. In the course of the discussion which follows, I will refer
to data from the Group II Impoundments Corrective Measures
Study/Feasibility Study Report, as revised through May 1994 (the
"CMS/FS Report") and the Impoundment Characterization Program Final
Report, as amended through August 1990 (the "ICP Report") ..
Impoundments 15 and 16 contain -waste product from
Cyanamid's aniline production process, in which nitrobenzene was
reduced by reaction with iron filings using hydrochloric acid as a
catalyst. While the CMS/FS Report characterizes the contents of
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these two Impoundments as "iron oxide material", their contents
are, according to the ICP Report, significantly contaminated with
heavy metals, such as arsenic (80 ppm #15; 64 ppra #16), chromium
(1,210 ppm #15; 1,070 ppm #16), lead (229 ppm #15; 174 ppm #16),
copper (4,490 ppm #15; 2,620 ppm #16), and nickel (1,690 ppm #15;
1,130 ppm #16).
Impoundments 17 and 18 contain sludge waste from
Cyanamid's on-site wastewater treatment plant, which include
primarily inorganic heavy metal contaminants such as barium (15,500
ppm #17; 14,100 ppm #18), chromium (19,700 ppm #17; 2,600 ppm #18),
copper (3,640 ppm #17; 3,670 ppm #18), lead (3,070 ppm .#17; 3,320
ppm #18), and mercury (101 ppm #17,-. 254 ppm #18). Significant
levels of semi-volatile organic compounds are also present in these
Impoundments, including 2-chloronaphthalene (100 ppm #17), N-
nitrosodiphenylamine (180 ppm #17), 4-chloroaniline (780 ppm #18),
benzanthracene (41 ppm #17; 66 ppm #18) , dibehzofuran (15 ppm #17;
120 ppm #18), and naphthalene (300 ppm #17; 810 ppm #18).
Of primary .concern with respect to all four of these
Group II Impoundments is that they are located outside of the
confines of the plant's flood control dike and within the
floodplain of the Raritan River. Moreover, though these
Impoundments are surrounded by earthen berms, these berms are all
below the 100-year flood water surface elevation--i.e. in the event
of a 100-year or greater flood, the river water would wash over the
berms of all of these Impoundments and come into direct contact
with their: contents.
2 -
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Issues
In my initial review of the recommendations of the CMS/FS
Report (letter to Walt Sodie dated September 13, 1994),.1 agreed
with the proposal to solidify the contents of Impoundment 17 and
dispose of them in the on-site RCRA Impoundment 8 facility. I took
issue, however, with 'the Report's other recommendations for
Impoundments 15 and 16--which was consolidation into Impoundment 15
and capping--and for Impoundment 18--which was no action. As
detailed in my report of September, 1994, my objections to rv-
latter proposals were based upon the general princ- *
contaminated materials should not be maintained in a flooap^-.
and on monitoring data from the ICP Report indicating that
Impoundments 15, 16, and 18 were potentially impacting groundwater.
My .objections initiated a series -of exchanges of
information between myself and the NJDEP Case Manager Haiyesh Shah.
Mr. Shah, .cited data indicating that Impoundments 15 and. 18 are
underlain by continuous, low-permeability clay layers which
effectively isolate them from groundwater. Mr. Shah further
asserted that the groundwater impacts reflected in the monitoring
well data were attributable to the contents of Impoundments 16 and
17, which are in contact with groundwater, and hence that the
removal of these two Impoundments should effectively eliminate the
source of the impacts. •
In follow-up correspondence (letters to Walt Sodie dated
October 21, 1994, and June 19, 1995), I continued to express
• *
concern that the data does not unequivocally support the
- 3 -
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proposition that only Impoundments 16 and 17 are contributing to
the observed down-gradient groundwater contamination. Through Mr.
Shah, the Department's response has essentially been that post-
remedial groundwater monitoring would be imposed to verify the
efficacy of the source control, with the potential for further
remediation- should the . monitoring data indicate continued
groundwater impacts.
Remedial Alternatives
Impoundments 15 and 16
For Impoundments 15 and IS, the four alternatives
analyzed in the Proposed Plan consist of the following:
Alternative 1 - No-Action/Limited Action
both Impoundments remain in-place
Alternative 2 - In-Place Containment
. consolidation of Impoundment 16
contents into Impoundment 15
Alternative 3 - Solidification
in-situ solidification of the
contents of both Impoundments and
consolidation into Impoundment 15
Alternative 4 - Recycling
excavation of contents of both
Impoundments and off-site reuse of
• iron oxide • ' .
Impoundments 17 and 18
For Impoundments 17 and 18, the six alternatives analyzed
in the Proposed Plan consist of the following:
Alternative 1 - No-Action/Limited Action
both Impoundments remain 'in*place
Alternative 2 - Solidification of Impoundment 17 and
No-Action/Limited Action for
4 -
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Impoundment 18
solidification of contents of
Impoundment 17 and disposal of
material in Impoundment 8 facility
Alternative 2A - Solidification of Impoundment 17 and
Capping of Impoundment 18
Alternative 3 - Solidification of Impoundment 17 and
Consolidation' into Impoundment 18
with Capping
Alternative 3A - Solidification of both Impoundments
17 and 18 and Consolidation into
Impoundment 18 with Capping
Alternative 4 - Solidification of both Impoundments
17 and 18 and Disposal into
Impoundment 8 Facility
Evaluation of Alternatives
The Proposed Plan evaluates the remedial alternatives in
terms of nine criteria stipulated by the Superfund regulations:
l. Overall Protection of . Human Health and -the
Environment
2. Compliance with -Applicable Pollution Standards
("ARARs")
3. Long-term Effectiveness and Permanence
4. Reduction of Toxicity,. Mobility, or Volume Through
Treatment
5. Short-term Effectiveness
6. Implementability
7. Cost
8. USEPA Acceptance
9. Community Acceptance
Impoundments 15 and 16
Alternative 1 (No Action) is eliminated from
consideration because it is in conflict with Criteria #1,
protection of the environment, since it fails to address the Plan's
finding that both of these Impoundments "are a continuous source of
• • ^
i .
ground water contamination, which eventually discharges into the
- 5 -
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Raritan River" (p. 7) . Alternative 4 (Recycling) is also 'found to
be unacceptable because it is not implementable (Criteria #6), as
the Plan notes: "a recycling vendor has not been found despite
many years of pursuing this alternative" (p. 12) . "•
This leaves a choice between Alternatives 2 and 3, both
involving consolidation of Impoundment 16 into Impoundment 15, but
with Alternative 3 further requiring in-situ solidification of the
contents of both Impoundments before consolidation. The Proposed
Plan's evaluation of these two alternatives identifies the
following criteria for which Alternative 3 is superior:
2 . Compliance with ARARs.
3. Long-term effectiveness: "Alternative 3 would
provide better, long-term effectiveness than Alternative 2 because
Alternative 3 provides some level of treatment for inorganics,
while Alternative 2 relies on containment." (p.12)
4. Reduction of mobility of contaminants: "Alternative
3 would decrease the mobility of contaminants by binding them in a
solidified matrix while only slightly increasing the volume of
waste material." - •
With respect to short-term effectiveness (Criteria #5)
and Implementability (Criteria #6) , the Proposed Plan rates
Alternatives 2 and 3 as equal. Alternative 3 is the more expensive
of the two, with an estimated cost of $8..6 million as compared to
$2.7 million for Alternative 2.
Impoundments 17 and 18 . ,
Because Impoundment 18 supports over 15 acres of dense
- 6 -
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vegetation, including well-established trees, the Proposed Plan
finds the destruction, of this ecosystem, which would necessarily
result from the alternatives involving its capping arid/or
solidification (2A, 3, 3A, and 4), undesirable in terms of Criteria
#1, protection of the environment. The Plan finds that Impoundment
18 is not having an impact on groundwater, and proposes to confirm
•
this by instituting a program of long-term maintenance and
groundwater monitoring.
* .
The Preferred Alternatives
The Proposed Plan designates Alternative 2 as the
preferred alternative for Impoundments 15 and 16, i.e.
consolidation of the contents of Impoundment 16 into Impoundment 15
without^ prior solidification. For Impoundments 17 and 18,
Alternative 2, involving solidification and disposal of Impoundment
17 in Impoundment 8, and long-term monitoring of Impoundment 18 in-
place, is'the preferred alternative.
Recommendations
' Although my response to the proposals of the CMS/FS
Report was to urge solidification and disposal in Impoundment 8 fox-
all four of the Group. II Impoundments, I believe that a more
limited initial approach with respect to Impoundments 15, 16, and
18 may be appropriate with adequate provisions for long-term
monitoring and maintenance. Thus, while I initially recommended'
• ^
that the contents of Impoundment 18 be removed from the floodplain,
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its established ecosystem of some 15 acres may be worth preserving
if it can be done without further groundwater impacts. If a long-
term groundwater monitoring program is properly fashioned--and I
would strongly urge CRISIS to be involved in its formulation--it
could provide an effective safeguard, provided that the ROD sets
definite groundwater quality criteria to be achieved within the 5-
year monitoring program and imposes a contingent requirement of
capping and/or solidification in the event that the criteria are
exceeded.
With respect to Impoundments 15 and 16, here also my
initial reaction was to propose that the contents of both
Impoundments be solidified and removed out of the floodplain to
Impoundment 8. On the basis of information Mr. Shah has provided
on the low permeability of the clay/silt layer beneath. Impoundment
15, I am willing to go along with a more limited approach of
consolidation into Impoundment 15, but I think that the evaluation
in the Proposed Plan indicates that in-situ solidification of the
contents of both Impoundments prior to consolidation--i.e.
Alternative 3--is superior in terms of limiting the mobility of the.
contaminants. - I see no analysis in the Proposed Plan or elsewhere
indicating that this environmental benefit afforded by Alternative
3 does not justify its incremental cost.
Therefore, for Impoundments 15 and 16 I would recommend
that CRISIS take the position that Alternative 3 should be selected
instead of the preferred Alternative 2 identified in the^Proposed
Plan. With respect to Impoundments 17 and 18, as stated earlier,
8 -
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I recommend that CRISIS endorse the preferred Alternative 2, with
the proviso that a set of groundwater contaminant attenuation goals
be established, with which the 5-year monitoring program must
demonstrate compliance or else trigger further remedial steps for
impoundment 18, such as capping and/or solidification.
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JERSEY COLLECT..™
FLOODS OF
AUGUST AND SEPTEMBER 1971
IN NEW JERSEY
By .
STEPHEN J. STANKOWSKI
U.S. GEOLOGICAL SURVEY
With sections en
EFFECTS OF THE STORMS ON GROUND-WATER LEVELS
by HAROLD MEISLER, U.S. Geological Survey,
and
SUSPENDED-SEDIMENT TRANSPORT
by J.J. MURPHY, U.S. Geological Survey
SPECIAL REPORT 37
Prepared by the U.S. Geological Survey
in cooperation with
State of New Jersey
Department el Environmental Protection
Division of Water tetowrce* .
1972 SOMERSET COUNTS LIBRA" t
SOMERVILLE, N. J.
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co
Figure 15.—Flooding on the Raritan River between Somerville and Manville, looking east, August 1971
Photograph by Bob Collister.
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Figure 16.—American Cyanatnid Company plant in Brid^ewatcr flooded by Rarltan Rtver, August 1971,
Photograph by Bob Collister.
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5
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ATTACHMENT 3
RESPONSIVENESS SUMMARY
AMERICAN CYANAMID SITE-RECORD OF DECISION
GROUP II IMPOUNDMENTS (15, 16, 17 AND 18)
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Attachment 3
Am Cyaoamid Site-Record of Decision
Responsiveness Summary
Division of Responsible Party Site Remediation
Bureau of Federal Case Management
CN 028, Floor 5 West
401 East State Street, Trenton. NJ 08625-0028
*»hone: (609) 633-1455
Fax: (609) 633-1454
New Jersey Department of Environmental Protection
VIA FAX: Total Pages Including Cover (14 )
DATE: March 4, 1996
TO: Walt Sodie. CRISIS
FAX/PHONE: (609) 936-1942/(609) 799-1553
FROM: Roman Luzecky. Section Chief
SUBJECT: American Cyanamid/American Home Products Site
Bridgewater Township, Somerset County
Superfund Proposed Plan . .
Group II Impoundments (15, 16. 17 & 18) and Hill Property Soils
As requested by Thomas Germine, Technical Advisor to CRISIS, and you during the public meeting on
February 22, 1995, attached please find the following:
1. Impoundments 15 & 16: A cost-benefit analysis considering the remedial alternatives of in-place
containment (Impoundment 16 into Impoundment 15), cap and ground water monitoring vs.
solidification of Impoundments 15 & 16, consolidation of solidified Impoundment 16 into
Impoundment 15. cap and ground water monitoring.
2. Impoundment 8 Facility Uner System: A copy of the March 1994 Impoundment 8 Facility
Design Report Addendum, prepared by Blasland, Bouck & Lee. This report specifies the liner
system for the construction of Cell # 2 which includes Bentomat as part of the geosynthetic day
liners system. The construction of Cell # 2 is about 90% complete and 100% completion is'
expected to be achieved during this summer.
Please review the information provided here. If you have any comments, please forward your comments
to me on or before March 18, 1996 so that we can move forward towards preparing a Record of
Decision without delay, tf I do not hear from you before the due date, I win assume that you do not
have any comments and that the information provided here is acceptable to-you.. ..
We appreciate your a'me and interest in the on-going remediation at this site. If you have any questions.
please contact me. Thank you.
Attachment:
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AMERICAN HOME PRODUCTS/AMERICAN CYANAMID SITE
BRIDGEWATER TOWNSHIP, SOMERSET COUNTY, NEW JERSEY
IMPOUNDMENTS 15 & 16
BENEFITS ANALYSIS CONSIDERING COST, HUMAN HEALTH AND ENVIRONMENTAL
PROTECTION, LONG-TERM RELIABILITY (FLOOD IMPACTS AND RISING GROUND WATER
TABLE IMPACTS) AND RECYCLING
IN-PLACE CONTAINMENT (CONSOLIDATION OF IMPOUNDMENT 16 INTO IMPOUNDMENT
15, CAP, GROUND WATER MONITORING) VS. SOLIDIFICATION OF IMPOUNDMENTS 15 &
16, CONSOLIDATION OF SOLIDIFIED IMPOUNDMENT 16 INTO IMPOUNDMENT 15, CAP AND
GROUND WATER MONITORING
A: Cost:
• The cost for the In-Place Containment Alternative is about 52,700,000.
• The cost for Solidification, Consolidation and Cap Alternative is about $8,600,000.
The difference In cost is about $5.9 M.
B. Protection of Human Health and the Environment:
.• In-place Containment Alternative (includes consolidation of Impoundment 16 into Impoundment
15, capping and ground water monitoring):
This alternative provides protection of human health and the environment by; 1) eliminating direct
contact and inhalation exposure (dust) pathways through consolidation of Impoundment 16 into
Impoundment 15 and installation of a cap; and 2) minimizing rain water infiltration by cap
installation which would in turn minimize leaching of contaminants into the ground water and to
the Rarrtan River.
Ground water monitoring is a component of this alternative which would determine the
effectiveness of this proposal and would ensure that contaminants are not impacting the ground
water and the Raritan River.
This alternative prevents direct contact of human and environmental receptors with materials in
the impoundments.
If the ground water monitoring components shows that the irvplace containment alternative 'is
not affective the selected remedy will be re-evaluated.
• Solidification, Consolidation and Cap Alternative (includes solidification of the materials in
Impoundments 15 and 16, consolidation of Impoundments 16 materials into Impoundment 15,
capping and ground water monitoring): . . ' ' .
This alternative provides similar protection of human health and the environment by immobilizing
and containing the inorganic contaminants.
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Both alternatives provide similar protection of human health and the environment. There are no
incremental benefits for protection of human health and the environment at this time.
C. Long-Term Reliability (Impacts from Raritan River Hooding and Rising Ground Water): •
• ln-p)ace Containment Alternative:
A long-term maintenance and monitoring plan would be implemented including impermeable cap
maintenance and ground water monitoring. The maintenance requirements would require
' periodic inspection of the impermeable cap. The bottom of Impoundment 15 is underlain by a
very low permeability (range 4.4 x 10"6 cm/sec to 5.7 x 10"7 cm/sec) continuous silt and clay
layer (average thickness 2 feet-CMS/FS, Attachment 1) which would prevent the impact of rising
ground water from coming into contact with the material of Impoundment 15.
A Flood Plain Study for these impoundments was included in the Group II Impoundments
Corrective Measure Study/Feasibility Study (CMS/FS) report. This study concluded that berms
surrounding Impoundment 15 are susceptible to erosion in their present condition. As
recommended in the. Flood Study, measures to prevent erosion of the impoundment berms
(vegetative cover, stone, rip rap, etc.) would be developed during remedial design and
implemented during its construction. Additionally, to reduce the potential for this type of erosive
condition, a single low point or spillway would be constructed on one or more of the berms to
manage initial flood water inflow in a non-erosive manner. The base of the spillway would be
constructed at a pre-determined depth at the lowest elevation along the impoundment berms.
This spillway would be constructed to allow high velocity flow across it until the water levels on
both sides of the berm equalized. Once the berms are crested by the flood waters, the velocities
across the berms and impoundment should reduce to the non-erosive leveJs. Impoundment 16
would be consolidated into Impoundment 15 and a multi-layer cap would be installed on the
' consolidated impoundment. This cap would minimize the potential for river water to come into
contact with the contents of the impoundment in the event of river flooding.
It is expected that installation of a cap would minimize the infiltration of rain water and thus
minimizing leaching of contaminants and ultimately improving the ground water quality in this
area. To determine this, one should wait until the remedial activities are completed to see the
desired improvement. In addition, the proposed remedy would include a ground water
monitoring program which would indicate whether or not the desired improvement has been
achieved. If not, additional remedial action(s) would be considered. As added assurance, the
site-wide ground water remediation program will require compliance with the site-wide ground
water Applicable or Relevant and Appropriate Requirements (ARARs) which would include this
portion of the site.
> Solidification, Consolidation and Cap Alternative:
This alternative also provides long-term reliability in terms of possible impacts from river flooding
and a rising ground water table. Any impact from river flooding and rising ground water will b€
minimized by the solidification, consolidation and containment (cap) of the materials of the
Impoundments 15 and 16. . • '
Both of the alternatives provide similar protection against the possible impacts from river floodin.-
and rising ground water.
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D. Consideration for possible recycling/beneficial re-use of the Iron oxide materials in Imp
15 and 16:
• ln-p!ace Containment Alternative:
Over 99% of the materials of Impoundments 15 and 16 is non-hazardous irpnjDxide which has
recycling potential. This material has a potential for use in the manufacturing of magnetic tapes,
pigments, heavy media coal separation, sintered metal processing and iron recovery. American
Home Products continues to search for a potential user of this material. The proposed alternative
of placement of a cap and ground water monitoring would serve two purposes simultaneously;
protecting human hearth and the environment as well as leaving the option open for recycling
of this material if such a user is found in the future (if a user is found in the future, the material
can easily be accessed and removed by opening a cap).
• Solidification, Consolidation and Cap Alternative:
Under this alternative, an option for reuse/recycling of iron oxide in Impoundments 15 & 16 is
not possible because the material will be solidified.
Based on the above evaluation, the In-place Containment Alternative satisfies all of the criteria evaluated
(A, B, C, and D) while Solidification, Consolidation and Cap Alternative only satisfies Criteria B and C.
As such, In-place Containment Alternative is preferable over the Solidification, Consolidation and Cap
Alternative.
Relevant Discussion:
• As Part of the Impoundment Characterization Program, the materials of Impoundments 15 and
16 were analyzed to determine the teachability of the metals they contain by using Extraction
Procedure (EP) Toxicity method. All of the metals in the lechate were non detect except for
Barium which was detected in leachate at 0.05 mg/l, below the EP Toxicity criteria of 100 mg/l.
Subsequent to the EP Toxicity analysis, a new analytical method called Toxicity Characteristics
Leaching Procedure (TQLP) was promulgated. • •
The difference between EP Toxicity and TCLP extraction procedure is that the TCLP requires a
Zero-Headspaee Extraction Vessel (ZHEV) while EP Toxicity did not. This device is for use only
when the waste Is being tested lor the mobility of volatile organic compounds (VOCs). The
ZHEV allows for liquid/solid separation within the device, and effectively precludes headspace
for VOCs. This type of vessel allows for initial liquid/solid separation, extraction and final extract
filtration without opening the vessel. As such, the TCLP procedure would provide more accurate
data for organics (eliminating a potential for VOCs loss during procedure) compared to the old
EP Toxicity procedure. There is no difference.in extraction procedure between TCLP and EP
Toxicity for inorganics. Section 4.2.2 of the Toxicity Characteristics (TC) Rule states that when
the waste is being evaluated under TCLP using the non-VOCs extraction, headspace is allowed.
As such, there is no difference for extraction procedure and the use of vessel between EP
Toxicity and TCLP for inorganics.
Inorganics (arsenic, barium, chromium, lead and mercury) detected in Impoundments 15 and
16 have been analyzed individually by EP Toxicity and determined to be below the regulatory
thresholds even under the TCLP levels. Refer to Impoundment Characterization Program Rnal
Report (ICPPR) for these results and the TC Rule for regulatory levels. I forwarded you a copy
of the letter (with my 9/26/94 memo) dated December 23,1991 signed by Andrew Bellina, Chief
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of Hazardous Waste Facilities Branch at United States Environmental Protection Agency
(USEPA). This letter states that based on the information presented in American Cyanamid's
evaluation and information contained within the 1990 Impoundment Characterization Program
Final Report (ICPFR), USEPA believes that the wastes present in Impoundments 15 and 16
would not be Resource Conservation and Recovery (RCRA) hazardous if tested under TCLP,
because constituent levels are* below regulatory guidelines. The TC Ruls. (Federal Register,
Volume 55, No. 61, March 29,1991) developed in the context of the Resource Conservation and
Recovery Act (RCRA) does not require TCLP if a total analysis of the waste (using old EP
Toxicity) demonstrates that individual contaminants are not present in the waste, or that they are
present but at such low concentrations that the appropriate regulatory thresholds could not be
possibly exceeded. In this case, the TCLP need not be run.
This analysis demonstrates that the metals detected in the Impoundments 15 and 16 do not leach into
the ground water above the threshold regulatory criteria in their current state. The proposed In-situ
Containment and Cap alternative would minimize the rain water infiltration through the consolidated
materials of Impoundments 15 and 16 which would in turn minimize the leachate generation. The
additional step of solidification would not provide any incremental benefit in protection against leaching
into the ground water because the metals were not detected above the threshold criteria in the leachate
without any control. The proposed cap installation would eliminate any remote chance of metals
leaching into the ground water by minimizing rain water infiltration. As such, the additional step of
performing solidification is not justifiable.
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AMERICAN CYANAMID COMPANY
BOUND BROOK, NEW JERSEY
IMPOUND 8 FACILITY
DESIGN REPORT ADDENDUM
NOVEMBER 1993
Revised MARCH 1994
BLASLAND. BOUCK & LEE, INC
8 SOUTH RIVER ROAD
CRANBURY, NEW JERSEY
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SECTION 2 . MODIFICATION TO LINER DESIGN
?.1 General
The existing Impound 8-West linet system exceeds all NJDEPE an3 OSEPA
technical requirements for liner systems lor hazardous waste landfills. Although
•
the existing liner system is acceptable, a more effective system which Is more
protective of the environment can be installed with minimal change to the
original design. The remainder of this section describes the proposed system
end presents an evaluation of the system.
2.2 Proposed Impound B-East Liner System /"
The modified Impound 8-East liner system, will consist of a composite
primary and composite secondary liner system constructed of identical materials.
Both composite systems will consist of two synthetic liners: a 60 mil HOPE liner
will be installed in compressive contact with a geosynthetic clay liner. The
geosynthetic clay liner will be selected based on its compatibility with the waste
material that will be placed In the landfill. (The geosynthetic clay liner win}
^contain a~*minimum of 1 Ib. of bentonite per square loot of liner and exhibit ~e^
-* . , — \
, typical hydraulic conductivity of 1 x 10* cm/sj Examples of geosynthetic clav.*
liners Include Gundseat, manufactured by Gundle Lining Systems, Inc.; Bentomat,
\ manufactured by Colloid Environmental Technologies Co.; and Bentoliner.
' ._ , .. . . —
manufacturedjby SIT North America. IncJ Manufacturer's specifications for these
liners are included In Attachment 1. Determination of the epeelfic geosynthetic
«lay liner will be made concurrent with contractor selection for the project, and
the NJOEPE will be notified accordingly.
During the installation of the liner system, manufacturer^ recommended
specifications for installation, seaming, destructive and non-destructive testing.
etc.. will be followed. The seams of the 60 mil HOPE component of the liner
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tystem will be welded as proposed in the 1988 Design Report, whereat the
geosynthetic clay liners will be overlapped as specified by the manufacturer.
The geosynthetic clay liners will be used on the bottom of the landfill only; a
60 mil HOPE liner will replace the geosynthetic clay on the side slopes;
therefore, on the tide slopes, both the primary and secondary composite system
will consist of two 60 mil HOPE -liners. Figure. 2 shows •conceptual cross-
section of the proposed lining system with each component Identified.
The technical advantage of the proposed system is the system's ability to
sea! potential breaches in the liner system. This liner system Is designed to
prevent leachate from passing through a breach because the swelling of the
bentonite, once wet, would seal the liner at the breach.
2.2.1 Comparison of Liner Systems - Technical' Issues
The proposed modification of the primary liner, to be located below
the leachate collection system, consists of replacing the approved 80 mil
HOPE membrane with composite system comprised of a 60 mil HOPE
membrane and a geosynthetic eiay liner. This proposed primary liner
design will provide the added benefit of bentonite to seal any breaches,
minimizing the potential for liquid to enter the leachate detection system.
The proposed modification of the secondary liner system consists
of replacing the approved 80 mil HOPE/45 mil EPOM system with a
composlta system comprised of a 60 mil HOPE, membrane and a
geosynthatic clay liner placed over the existing 45 mil EPOM liner. The
secondary system, like the primary system, will provide the added benefit
of bentonite to seal any breaches in the liner aystam. The proposed
•
secondary system will be more effective In preventing liquids contained in
. *
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The selected thickness of the HOPE liners is dependent on design
criteria for puncture-resistance and •trength; the permeability of the HOPE
material is Independent of the thickness. A 60 mil HOPE liner can be
used in place of the approved 60 mil liner without sacrificing the liner
system's ability to isolate the waste material from the environment because
the liners are protected, on both aides, with a 16-ounce polypropylene,
continuous filament, needle-punched, non-woven geotextile. The geotextile
minimizes the puncture resistance required for the HOPE liners. In
addition, the 60 mil HOPE material exceeds strength requirements
necessary for the Impound 8-East facility, given the nature of the sludge
material to be landfilled, the alope of the berm, and the existing aubgrade
conditions. The 60 mil HOPE also exceeds regulatory standards And is -an
industry standard for hazardous waste landfills.
g.g.2 TComplianceL with Regulations
, *
The New Jersey State regulations for hazardous waste landfill
construction are presented in N.J.A.C. 7:26*10.8. The regulations state
that a new landfill must have a liner system consisting of two or more
liners. The primary liner thai) consist of a synthetic material, at least 40
mil thick, which is designed to prevent the flow of liquid through the liner.
in addition, • secondary liner system must consist of 5 feet of soil with
a maximum saturated hydraulic conductivity of 1 x 10"' cm/s or a 40 mil
synthetic material which is designed to prevent the flow of liquids through
the liner.
As stated in 40 CFR 264.301. the USEPA requires that new landfills
be designed with top and bottom liners. The top liner must prevent the
migration of hazardous constituents through the liner throughout its active
life and the post-closure period. The bottom liner must be a composite
system comprised of an upper component. . which must prevent the
-------
migration of hazardous constituents into the component, and a lower
component constructed of at least 3 feet of compacted •oil material with
a hydraulic conductivity of no more than 1 x 10*' em/t. ln_40 CPR
£64.301 (d) It is stated that alternative designs may be approved if the
alternative system will perform more effectively than the eystem apecified
in the regulations. The proposed liner system replaces the specified 3
feet of compacted soil material with a geosynthetic clay liner. This liner
will consist of 1 Ib. of bentonite per square foot of liner and exhibit a
maximum hydraulic conductivity no greater than 1 x 10'' cm/s. This
proposed liner will prevent the migration of hazardous constituents into the
environment as affectively as the 3 feet of compacted soil material.
The proposed double composite liner system meets or exceeds both
the NJDEPE and the USEPA requirements for liner systems, and the
proposed system will minimize flow through the liner more affectively than
the liner systems specified in the regulations.
-------
swcte LAYTH crotnrnc
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IMPOUND 8 CAST
-------
GUNDSEAL® HDPE/BENTONITE COMPOSITE LINER
Membrane Backing
Gundiine HO Membrane
»mi r 1 0
»Diia«o -«n 3 4J"Vi 0 *4 m-
•igxi» •>• •pe'OMittu Meet i'i
*y £•»«* Ml »n <»*'•« »Am
thfO»»»< »*+*•* » non-lot« •«•
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ID IMP
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If it needs Mng. I needs Gundle.*
19103 Gundle Road
Houston. Texas 77073 U.S.A.
Phone; (713) 4434564
ToU Free: (600) 435-2008
Telex: 166657 GundieHou
Fax: (713) 875-6010
-------
P»8« 3 of t
2.1 MATERIALS
The GCL shall have the properties necessary to achieve compliance with Sections A, B, and C
below. All values are minimum average roll values (MARVs) unless indicated otherwise.
A. Sodium Bentonite. The bentonite utilized in the manufacture of the GCL^as.well any
accessory bentonite provided for seaming and detail work, shall be Volclay* Wyoming-
grade sodium bentonite with the properties listed below.
Property
Montmorillonite Content
Particle Size
Free Swell
Moisture Content
Water Absorption
Test Method
Various Methods
ASTM D 421
USP-NF-XVn
ASTM 4643
ASTM E 946
Value
90% (Approximate)
20% maximum + #20 mesh
20% Maximum • #40 mesh
24 cc minimum
10% maximum as shipped
900% typical
B. The GCL shall be composed of geotextiles having the properties listed below.
Property
Composition
Thickness, typical (mm)
Mass/Area (oz/sy)
Grab Strength (Ibs)
Grab Elongation
Wide Width Sir. (Ibs/in)
Puncture Resistance (Ibs)
ASTM Method
N/A
D1777
.D 3776
D4632
D4632
D4595
D4833
Woven Geotextile
Slit Film PP
0.44 .
3.3
109
20
59
20
Nonwoven Geotextile
Needlepunched PP
2.0
6.0
67
100
7
35
C. The GCL itself shall have the physical properties listed below.
Property
Thickness, typical (mm)
Clay Mass/Area (psf)
Grab Strength flbs)
Grab Elongation
Wide Width Sir. (Ibs/in)
Puncture Resistance (Ibs)
Permeability (cm/sec)
ASTM Method
D1777
D 3776 (mod.)
D4632
D4632
D4595
D 4833
D 5084
Value
6.4 (dry)
1 (at 12% moisture)
88
20
35
102
5 x ID'9 cm/sec"
*At 5 psi maximum effective confining stress.
-------
BentoLiner DRY PHYSICAL PROPERTIES
Index Properties:
trapezoidal Tear (ASTM-D 4533)
Puncture Resistance (ASTM-D 4533)
Mullen Burst (ASTM-D 3786)
Intergeotextile Peel (ASTM-D 413)
Design Properties:
Grab Strength (ASTM-D 4632)
Grab Elongation (ASTM-D 4632)
Wide Width Tension Strength. (ASTM-D 4595)
Intergeotextile Shear (ASTM-D 3083)
Typical
55.0 Ibs
102 IDS
395.0 PSI
5.3 PPI
88 Ibs
20%
35 PPI
43.0 PPI
Standard Deviation
7.9 Ibs
24.7 Ibs
62.0 PSI
1.8 PPI
9.9 Ibs
2.1%
2.3 PPI
10.5 PPI
BentoLiner HYDRATED PHYSICAL PROPERTIES
Index Properties:
Trapezoidal Tear (ASTM-D 4533)
Puncture Resistance (ASTM-D 4533)
Mullen Burst (ASTM-D 3786)
Intergeotextile Peel (ASTM-D 413)
Design Properties:
Grab Strength (ASTM-D 4632)
Grab Elongation (ASTM-D 4632)
Wide Width Tension Strength. (ASTM-D 4595)
Intergeotextile Shear (ASTM-D 3083)
Typical
56.0 Ibs
37.2 Ibs
221.4 PSI
7.1 PPI
91.6 Ibs
17.6%
34.1 PPI
31.2 PPI
Standard Deviation
9.9 Ibs
2.8%
77.7 PSI
3.6 PPI
7.5 Ibs
5.9%
2JPPI
11.0 PPI
Teuint ptrtaintd by «n independent bborrefy mini BmoUntr VC 6J et. per tqum yttd Baft-woven: IjOfeperiquatlaai •odiwrn brraonhe: JiS at.
y»ri woven. Daifn Proprn* leuinf «m done in iht machine direnion «-hh tftcmeni h>«nied fo« lour days under • load of 90 prf le Mrwiiitt nint4o-tm*lvt mehe« cf
undeo\er.Sht»r& Peelwiu»«rcperfqnnfdusinf <.0inch«idt»feeimen». ASTM-DT«l4S»5tpplinaransumw*otti»«nfioi>(CREtMmilipccm«nfMi<«iiTw.A.Tal
itwli« »rr unu%iull.> te» dut «P >.lippaf * in fnj*. No rupwr occurred ASTM-D T«l 46J2 art'**a'commually memitmy Inad tenyiiuduully 10 the ipecinvrn and u*:? -J«i
ii ranied 10 nipiurr. ASTM-D TrM 4632 —idei(hit diu for mfoimj-. -j-
PUTOV« «"!i> and s««umcv no liabilii) in connection • hh the int of the data. Aeiual ten mtthj^v. (rrqiwnty end itrtnubk vilu»« are tubjrct lo the eonuaciual ifnr.- of
rc>r.jiiic
-------
Mar-20-96 O9:49A
COMMTRAN COMMUNICATIONS
Fax Memo
. 3/20/96
TO: Haiyesh Shah
NJ DEP
FAX NO. 609/633-1454
FROM. Walt Sodie
Coromtran Communications
116 Village Blvd.
Princeton, NJ 08540
Phone: 609/734-4312; Fax No. 609/734-7490
Number of pages, including this one - 4
The following pages are a report and analysis from Tom Genuine oh the DEP's cost/benefit
analysis that CRISIS requested at the public hearing of 2/22/96. Tom has serious problems with
the DEP document, and he presents some compelling logic in support of his conclusions. Unless
DEP can show where he is wrong, CRISIS is fully prepared to support his findings.
This is the first time since 1991 that DEP is giving Bridgewater what I consider to be extremely
short shrift on the cleanup. CRISIS has been very reasonable throughout this project. The group
has approached its task intelligently, and expects that its views will be given A least reasonable
consideration by DEP. Tom's report shows tilts clearly was not the case with the request we
made at the public meeting. Unless these circumstances are rectified, the organization is ready to
take its case to the public.
Please respond at your earliest convenience.
-------
THOMAS J. GERMINE
ATTORNEY-AT-LAW
V> SOUTH JEFFERSON ROAD
TELEPHONE WflPBWX NJ 07981 FACSIMILE.
(201) 515-5151 (201) 515-5154
March 12, 1996
VIA FAX AND R*EGULAR MAIL
Walt Sod ic
CRISIS, Inc.
116 Village Boulevard
Princeton, NJ 08540
RE: IMPOUNDMENTS 15 & 16
COST-BENEFIT ANALYSIS
Dear Walt:
1 have reviewed the "Cost-Benefit* analysis prepared by NJDEP with respect to the
comparison of remedial Alternatives 2 and 3 for Impoundments 15 and 16, and, quite frankly,
I find it locally inadequate.
First of ail, the Department has apparently misconstrued the point of CRISES' public
hearing comments on this issue. Our position, which I presented at the hearing and in writing.
is that the Proposed Plan's analyses of the two alternatives, applying the nine CERCLA
evaluation criteria, demonstrates the environmental superiority of Alternative 3. Hence it is
necessary that there be a weighing of the incremental environmental benefits of Alternative 3
versus its incremental cost as compared with Alternative 2.
The analysis presented by DEP does not contain anything which can be considered "cost-
benefit analysis', but rather it selectively revisits some of the nine CERCLA evaluation criteria
in an attempt to alter the Proposed Plan's finding that Alternative 3 is, on balance, more
environmentally beneficial than Alternative 2.
For the sake of clarity on this point, let me briefly review the conclusions of the
Proposed Plan vis-a-vis the 9 evaluation criteria:
Criteria Conclusion
1. Overall Protection Health and Environment Equal
2. Compliance with ARARs Equal
3. Long-term Effectiveness AIL 3 Better
4. Reduction of Toxicrty, Mobility, Volume Alt. 3 Better
S. Short-term Effectiveness Equal . ,
6. Inpkmentabiliry Equal
7. Cost ' Alt. 2 Le* Expensive
8. USEPA Acceptance Equal
9.. Community Acceptance [Deferred]
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Watt Sodie
March 12, 1996
Page 2
• ».
The Department's analysis flatly contradicts the finding of the Pi opened Plan with respect
to Criteria 3 and 4 above. Their report states that Alternatives 2 and 3 provide *similar
protection* with respect to Long-term Effectiveness, whereas the Proposed Plan unequivocally
concludes: • .
3 would provide better long-term effectiveness than
Alternative 2. because Alternative 3 provides tonne level of
treatment for inorganics while Alternative 2 relies on
containment.* pp. 11-12
Similarly, with respect to Criteria 4, the Proposed Plan (p. 12) finds that Alternative 3
would decrease the mobility of contaminants while Alternative 2 would not. Yet the
Department's analysis deals with this issue strictly on the basis of recycling option, which
constitutes a separate Alternative 4 in the Plan, which finds- it "not likely to be implementable*
(p. 12).
If the Department wanted to include the advantages of a recycling contingency in its
analysis, then the Proposed Plan should have presented an additional alternative calling for
temporary in-place containment and capping pending a well-defined period for evaluation of
recycling feasibility. But this is noj the way Alternative 2 was presented in the Proposed Plan.
Beyond the fact that DEP's analysis is transparently contrived and excludes the
consideration of those CERCLA evaluation criteria which do not buttress its position, from a
procedural standpoint, it is very disturbing to see the Department, alter the public hearing,
making major revisions-not to mention outright contradictions-to the Alternatives Analysis
presented in the Proposed Plan. This type of approach presents the public with a "moving
target' and tends to render the public hearing and comment process a meaningless ritual.
Even more disturbing, however, is the .section of the Department's report entitled
•Relevant Discussion', which advances the general proposition that, based on a non-hazardous
RCRA classification, the impact of impoundment wastes on groundwater may be discounted.
This position totally distorts the purpose of RCRA classification, which is only to determine die
applicable standards for treatment, storage, and disposal of wastes. It also contradicts the clear
finding of the Proposed Plan:
Qrpup 11 Impoundments (except Impoundment lift are %
cpntinuous source of proun^yyf f comrniftttioni which eventually
discharges into the Raritan River.* (p. 7)
* " •
This fallacious logic cannot go uncorreeted, because it has ominous implications for the
subsequent phases of this cleanup. Bear in mind that none of the wastes of this site have been
-------
WaltSodie
March 12, 1996
Page 3
Classified as RCRA hazardous, 10 if we accept the premise of the argument being advanced here
by DEP, in-puux containment with capping becomes the de-racto accepted remedy across the
board.
Once again, it is procedurally improper for the Department to inject a new remedial
evaluation criterion-^specially one as radical and questionable as this one-after the public
hearing process. If DEP truly wishes to justify its selection of Alternative 2 on the general
principle that non-hazardous wastes per sc do not significantly impact groundwaier, then they
should revise the Proposed Plan accordingly and reopen the public comment/hearing process.
Very jruly yours,
THOMAS J. GERMINE
-------
of ^cin .Ijcrscy
Christine Todd Whitman Department of Environment.il Protection Roln-n C Sli;nn. |r
Governor Cumm/.siri/icr
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
NO. -7.'..'.4l?.i
NO.
Walt Sodie, Executive Director
CRISIS
24 Madison Drive
Plainsboro, NJ 08536
Dear Mr. Sodie:
Re: American Cyanamid/ American Home Products Site
Bridgewater Township. Somerset County
Superfund Proposed Plan
Group 11 Impoundments (15, 16, 17 & 18) and Hill Property Soils
1 have received your fax on March 20, 1996 which includes a response report from Thomas
Germine dated March 12. 1996 concerning the additional information I sent you dated March 4.
1996.
Let me begin by saying that I was very disappointed by accusations from Mr. Germine and you
that the New Jersey Department of Environmental Protection (NJDEP) is not listening or
responding to concerns about the ongoing cleanup and that NJDEP is making major revisions and
outright contradictions to the Proposed Plan. NJDEP has been working very closely with
Bridgewater Township officials, CRISIS and other interested parties as remedial work has
progressed. NJDEP considers the views of each of these parties as pan of our community
outreach program for this site.
Specifically, we have made it a priority to work closely with you and your group throughout the
remedial process. We have attempted to identify the group's concerns and address them through
periodic written and verbal correspondence and provide copies of all approved documents to you
in addition to two local repositories. Finally, we take your comments seriously and afford thtm
ample review.
NJDEP committed at the recent February public meeting to provide CRISIS with more
information to address the group's concerns with NJDEP 's preferred alternative for
Impoundments 15 and 16. NJDEP stated that it would provide CRISIS with a cost benefit
analysis related to those impoundments, notably Alternatives 2 and 3. NJDEP also committed
New leafy a tn Equal Opportunity Employer
-------
o provide the response to CRISIS for comment before \ve signed a Record of Decision (ROD).
n his report, Mr. Germine states that the NJDEP apparently misconstrued the point of CRISIS's
Comment on the cost-benefit analysis. I believe the misunderstanding or difference of
nterpretation in what was asked for and what was produced is simply the distinction between a
qualitative and a quantitative cost benefit analysis. The first NJDEP can produce, the later
NJDEP believes c&nnot be and has not been performed at any Superfund site in New Jersey.
Before getting into a point by point explanation of how and why we prepared our response, I
want to emphasize that we are still open to comments and will use any information you provide
to help us make appropriate remedial decisions at this site as the ROD has not yet been prepared.
\nd, NJDEP appreciates your efforts to assist the Department and protect the community and
Environment around the American Cyanamid site.
Mr. Germine makes a general statement that because the analysis of the Proposed Plan
demonstrates the environmental superiority of Alternative 3, a weighing of the incremental
benefits of Alternative 3 versus its incremental cost as compared with Alternative 2 should be
performed. This is a quantitative cost benefit analysis and one NJDEP cannot perform for the
following reasons. It is not possible to determine an incremental environmental benefit by
spending a certain amount of additional money as it relates to Alternative 2 and 3 for
Impoundments 15 and 16 strictly in the context of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) and the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP-Section 300.430) dated March 8,1990. The two environmental
benefits presented in the Proposed Plan were reduction in mobility and better long-term
effectiveness. Numerical values for incremental environmental benefits related to reduction in
mobility and long-term effectiveness that correspond to a certain amount of additional money
spent cannot be determined in the context of CERCLA and the NCP. NJDEP has consulted
several environmental and economic professionals on this issue to ensure adequate consideration
was given to the CRISIS request.
NJDEP did prepare a qualitative cost-benefit analysis based pn the most significant comments
(i.e., impacts from Raritan River flooding and rising ground water as well as the recycling
potential for the iron oxide material) we received during the public comment period for the
preferred alternative for Impoundments 15 and 16. Since these issues came up during the public
comment period, we used them in the qualitative analysis. Please note that NJDEP did not
attempt to alter information presented in the Proposed Plan that Alternative 3 is better than
Alternative 2 for long-term effectiveness and reduction of toxicity, mobility and volume. The
information presented in the Proposed Plan is still valid.
In the analysis, we determined that Alternatives 2 and 3 are similar in providing long-term
reliability (and not long-term effectiveness as was presented in the Proposed Plan) only in
consideration with the impacts from Raritan River flooding and rising ground water. The
evaluation in the analysis was provided as a supplement to the Proposed Plan and not as a
replacement for the evaluation presented in the Proposed Plan. As such; Mr. Germine is incorrect
in stating that "NJDEP's analysis is transparently contrived and excludes the consideration of
those CERCLA evaluation criteria which do not buttress its position." Please note that NJDEP
-------
provided the additional evaluation based on the request by members of CKIMb ana
officials during the public comment period. Further, NJDEP did not make major revisions to the
alternatives analysis presented in the Proposed Plan after the public meeting and public comment
period.
American Home Products continues to search for potential users of the iron.oxide material in
Impoundments 15 and 16. As such, this evaluation was included in the analysis. Mr. Germine
suggested that KJDEP should have presented an additional alternative calling for temporary in-
place containment and capping pending a well-defined period for evaluation of recycling
feasibility. NJDEP did initially consider this as an additional alternative. However, by definition,
the temporary capping would have only included two feet of top clean fill material (soil) without
the impermeable synthetic liner. It did not satisfy the remedial objectives and, hence, was
eliminated from further consideration.
All of the information presented in the Proposed Plan and the analysis is independently accurate.
Even without using any of the information presented in the analysis, Alternative 2 is still
appropriate for Impoundment 15 and 16 because: 1) it satisfies the CERCLA threshold criteria
of protection of human health and the environment and compliance with Applicable or Relevant
and Appropriate Requirements (ARARs); and, 2) it is cost effective.
As specified in the NCP, nine evaluation criteria are used as follows for remedy selection: 1)
Threshold Criteria—protection of human health and the environment and compliance with ARARs;
2) Primary Balancing Criteria-long-term effectiveness and permanence, reduction of toxicity,
• mobility or volume through treatment, short-term effectiveness, implementability and cost; and.
3) Modifying Criteria-U.S. Environmental Protection Agency (USEP.A) and Community
acceptance. In accordance with the NCP, a remedy under consideration for selection must meet
the threshold criteria. Then a remedy must be cost-effective. This cost effectiveness is determined
by using the first 3 criteria under the Primary Balancing Criteria. And, finally USEPA and
community acceptance be considered for the remedy selection. Alternatives 2 and 3 are equal in
satisfying the NCP threshold criteria of protection of human health and the environment as well
as compliance with ARARs. Alternative 3 provides better long-term effectiveness and reduction
in mobility than Alternative 2 as presented in the Proposed Plan. But the cost of Alternative 3
compared to the cost of Alternative 2 is not proportional to its overall effectiveness. As such,
Alternative 3 is not considered cost-effective under the NCP remedy selection criteria. Compared
to the cost of Alternative 3, the cost for Alternative 2 is proportional to its overall effectiveness.
As such, Alternative 2 is cost-effective.
NJDEP prefers Alternative 2 for Impoundments 15 and 16. Qualitatively, NJDEP believes that
there are no incremental environmental benefits from Alternative 3 that are cost effective when
compared to Alternative 2. Because of this, the NJDEP does not have any legal authority to force
the responsible party to spend additional money for implementing Alternative 3.
-------
As stated above, NJDEP could not determine any quantitative incremental benefit for
implementing Alternative 3. If you can determine the quantitative incremental benefit, please
submit that information to NJDEP for consideration on or before April 9, 1996.
Also in his report, Mr. Germine states that NJDEP's analysis report contradicts the clear finding
of the Proposed Pten that the Group II Impoundments (except Impoundment 18) are a continuous
source of ground water contamination, which eventually discharges into the Raman River. The
statement in the Proposed Plan was made because contaminants were detected in the ground water
downgradiem of Impoundments 15 and 16 above the applicable regulatory standards. NJDEP
provided the Toxicity Characteristics Leaching Procedure (TCLP) information (which was pan
of the Corrective Measure Study/Feasibility Study report) to demonstrate that the metals detected
in Impoundments 15 and 16 do not leach into the ground water above the threshold criteria in
their current state. The proposed cap installation would minimize rain water infiltration and
leachate generation that would ultimately improve ground water quality. The intent of this
information was to demonstrate that the teachability and impact to ground water from the metals
detected in Impoundments 15 and 16 may be controlled by installing a cap without solidifying
them first. It was not NJDEP's intention to demonstrate that based on a non-hazardous RCRA
classification, the impact of impoundment wastes on ground water may be discounted. If that was
the case, NJDEP would have proposed a no action alternative for these impoundments if it was
solely based on waste classification and ground water contamination.
Mr. Germine also states that "none of the wastes on this site have been classified as RCRA
hazardous, so in-place containment with capping becomes the de-facto accepted remedy across
the board." In fact, the wastes in Impoundments 1,2, 3, 4, 5, 14, and 26 have been determined
to be Resource Conservation and Recovery Act (RCRA) hazardous and are being handled as such.
These impoundments are part of the Group III impoundments for which extensive treatability
studies are being performed, including biotreatment and thermal desorption treatment. Although
Impoundment 17 is not classified as hazardous, NJDEP proposed removal, solidification and
placement into. the Impoundment 8 as a remedy to eliminate the source of ground water
contamination. In contrast with Mr. Germine1 s statement, NJDEP did not propose in-place
containment with capping for Impoundment 17 as a de-facto accepted remedy across the board.
Group 1 Impoundments (11,13, 19 and 24) also are being handled as hazardous. Information on
the determination of RCRA hazardous waste characteristics for all Superfund impoundments at
the site was included in a letter dated December 23, 1991 from Andrew Bellina of USEPA to
Joel Jerome of American Cyanamid. A copy of this letter was forwarded to you with our fax
dated September 26,1994. In the Group II Impoundments Corrective Measure Study/Feasibility
Study (CMS/FS) report (Section 5.3, Page 5-28), it was also specified that Impoundments 1 and
2 are classified as characteristically RCRA hazardous. We forwarded a copy of this report to you
with our letter dated August 3, 1994. Since CRISIS has all this information about the site
impoundments RCRA waste classification, it was inappropriate to make a statement that "none
of the .wastes of this site have been classified as RCRA hazardous." This statement is not only
inaccurate but also misleading to a layperson to whom CRISIS is responsible to provide
information. •
-------
All of the information discussed here and in our pervious analysis has been provided in detail in
the documents listed in the Administrative Record Index. All of these documents have been made
available for public review at the two public repositories established for this site. A reference was
made in the Proposed Plan that NJDEP encourages the public to review the documents included
in the administrative record to gain a more comprehensive understanding of the facility. In his
response, it appears that Mr. Germine mostly references the Proposed Plan for findings and
conclusion. Please.note that the Proposed Plan does not find or conclude anything. As mentioned
in the Proposed Plan, it is a summary of the findings of the site studies and is provided as a
supplement to the reports included in the administrative record that should be consulted for more
detailed information. .NJDEP is not injecting any new information after the public participation
process. The information in the analysis was provided in response to questions by members of
CRISIS and Township Officials. NJDEP has made all relevant information available for public
review and comment. As such, there is no need to revise the Proposed Plan and re'open the
public meeting/comment period at this time. This process would result in an unnecessary waste
of resources and further delay the project.
If you have any questions, please contact me at (609) 63J-1455.
Sincerelv.
Roman Luzecky, Section Chief
Bureau of Federal Case Management
-------
COMMTRAN COMMUNICATIONS
Memo
4/10//96
TO:
FAX NO
FROM:
Phone: 609,734-4312; Fax No. 609/734-7490
Number of pages, including this one • 3
Jiaiyesh Shah
NJDEP
609'633-14$4
WahSodie
Commtran Communications
116 Village Blvd
The pages to follow art Tom Gerrniac's response to Roman Luzeclcy's communication to me of
3/26/96. . •
As you will see, Ton •would like to avoid a confrontation over this issue but he Still has some
basic policy differences with DEP on the proposed methodology for impoundments IS and 16.
Is there any way we can work out an accommodation with DEP on this matter?
-------
THOMAS J. GERMDJE
ATTPRNEY-AT.LAW
U SOUTH JEFFERSON ROAD
TO1FHOKE WWPFAN-Y. N] 07961 . FACSIMILE:
(201) 515-5151 . - £01) 51S-51S4
** . * — 5 .
• *
r . April 2, 1996 £ '."
.».-.-
-* • ' ••-.-•••
VIA FAX AND REGULAR MAIL
WaltSodie '
CRISIS. IK.
116 Village Boulevard
Princeton, NJ 08540
RE: IMPOUNDMENTS 15 & 16
COST-BENEFTT ANALYSIS
ROMAN LUZECKY LETTER OF M6-96
Dc»r Walt:
I have reviewed the letter of Roman Luzedcy of KJDEP dated March 26. 1996. which
•WLS wrracn in response to my comments regarding the cost-benefit analysis for impoundments
IS and 16 Getter to you of March 12, 1996).
First of all, let me uy that my strenuous objections to the manner in which this cost-
benefit analysis was performed are in no way intended to diminish or disparage the efforts of
Messrs. Luzecky, Shah, and other DEP officials who, on the whole, have done a very
commendable job with this complex remediation project. On the other hand, it is also our
charge, as the community's 'watchdog* over this effort, to scrutinize each step on this process
.aggressively and state our criticisms candidly.
That being aaid. the length and detail of Mr. Luzecky's response to my objections
regarding the cost-benefit analysis certainly indicate that the Department has taken our concerns
aeriously and made a good-faith effort to address them. If the equivalent effort had gone into
the original analysis, many of my objections might have been averted.
Unfortunately, however, Mr. Luzecky** after-the>fact rationalizations do not, hi my
mind, change the tact that the analysis be is attempting to defend is woefully inadequate. His
justification for limiting the criteria considered in the cost-benefit analysis ID impacts on Rarhan
River flooding and iron-oxide recycling potential, simply because these were prominent issues
in ihe public comments, quite frankly makes DO sense and has no basis in the CERCLA/NCP
regulations. .. . •
.• • * • • *^£
• *
Again, I recognize the level of effort reflected in Mr. Luzecky's response, bufhis basic
position in hopelessly self-contradictory: DEP finds the incremental cost of Alternative 3 to be
^disproportionate to its incremental effectiveness, jgi h offers no information, qualitative or
-------
Walt Sodie
April 2. 1996
2
4juanntanvt, is to what thai incremental effectiveness nay be. The suggestion (p. 1) that the
burden should fall on CRISIS to determine that incremental benefit conveniently ignores the fact
thai our TAG grant does not fund independent sampling and analysis. Moreover, it is the
responsibility of the regulatory agencies, not the community, to provide • complete analysis
justifying its selection among competing alternative remedies. • . • .
• • «
Perhaps in an effort to distract ifirntion from the teal issues of this discussion. Mr.
Luxtcky'i letter needlessly fuste* over a statement in my letter regarding RCRA hazardous
wanes on the site. My statement as to the absence of such wastes was made in the context of
the Croup 11 Impoundments which are the subject of the current ROD. I recognize, as Mr.
Luzecty points out, that the Group III Impoundments do contain RCRA hazardous wastes. Whai
1 objected to was the proposition advanced in the cost-benefit analysis that non-hazardous waste
classification somehow impliei insignificant impact on groundwater. In this regard, I am
satisfied thai Mr. Luzecky has set the record straight by stating (p. 4): "It was not NJDEP's
intention to demonstrate that, based on a non-hazardous RCRA classification, the impact of
impoundment wastes on grouodwater may be discounted."
Finally, the last paragraph of Mr. Luzecky's letter appears to suggest that the complete
Administrative Record, albeit not the Proposed Plan itself, contains the information justifying
the selection of Alternative 2 over Alternative 3. Again, I think the information gap which
needs to be filled in here concerns the efficacy of solidification as applied to the Impoundment
15/16 wastes. I have gone back over the record, most notably the Group II CMS/FS, and I do
sot see where this is addressed. As I see it, DEP simply cannot make a finding that the benefits
of such solidification are disproportionate to its cost without identifying those benefits and
assessing them, at least qualitatively.
Very truly yours,
-------
of
pristine Todd Whitman Department of Environmental Protection Robert C. Shinn, Jr.
Commissioner
CERTIFIED MAIL APR 2 3
RETURN RECEIPT REQUESTED
NO.
Walt Sodie, Executive Director
CRISIS
24 Madison Drive
Plainsboro, NJ 08536
Dear Mr. Sodie:
Re: American Cyanamid/American Home Products Site
Bridgewater Township, Somerset County
Superfund Proposed Plan
Group II Impoundments (15, 16, 17 & 18) and Hill Property Soils
1 have received your fax on April 10,1996 that includes a response report from Thomas Genuine
dated April 2, 1996 concerning my response letter to you dated March 26, 1996. Mr. Germine
still does not agree with the methodology New Jersey Department of Environmental Protection
(NJDEP) used to develop the Preferred Alterative 2 for Impoundments 15 and 16.
NJDEP has evaluated all of the remedial alternatives considered for Impoundments 15 and 16 in
accordance with the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
dated March 8, 1990. This detailed evaluation was presented in the Corrective Measure
Study/Feasibility Study (CMS/FS) for the Group II-Impoundments and was summarized in the
Proposed Plan.
This evaluation concluded that Alternative 3 is better in long-term effectiveness than Alternative
2 because it provides some level of treatment. The evaluation also concluded that Alternative 3
is better in reduction of mobility than Alternative 2 because it decreases the mobility of
contaminants by binding them in a solidified matrix. These are the qualitative incremental
benefits identified between Alternatives 2 and 3 that were already included in the CMS/FS and
presented in the Proposed Plan. Nevertheless, Alternative 2 satisfies the CERCLA'and NCP.
threshold criteria, protection of human health and the environment and compliance with
applicable or relevant and appropriate requirements (ARARs), by consolidation and capping of
the material of Impoundments 15 and 16 and ground water monitoring. Alternative 2 satisfies
Ntwfeneya on EgiuJ Oppornpuly Eofloyer
Rrcydtd P*per
-------
. these threshold criteria, without the qualitative incremental benefits afforded by Alternative 3, at
the lowest cost of all alternatives with the exception of the No Action Alternative.
Specifically, as Mr. Germine has been requesting, the incremental benefits provided by
Alternative 3 over Alternative 2 were identified and qualitatively assessed in the CMS/FS and
presented in the Proposed Plan. They are reduction in mobility and better long-term effectiveness.
NJDEP already provided the complete analysis of competing remedial alternatives for
Impoundments 15 and 16 in the CMS/FS and the Proposed Plan (summary of the evaluation)
together with a rational for the preferred alternative as required under CERCLA and the NCP.
Further qualitative assessment is not possible under CERCLA and the NCP. It is important to
note that both alternatives are non-permanent and both are expected to provide equal protection
of human health and the environment and improved ground water quality. As such, Alternative
2 remains NJDEP's preferred alternative under CERCLA and the NCP.
In his April 2, 1996 report, Mr. Germine incorrectly interpreted NJDEP's suggestion. He stated
that "NJDEP's suggestion that the burden should fall on CRISIS to determine that incremental
benefit conveniently ignores the fact that our TAG grant does not fund independent sampling and
analysis." NJDEP never suggested that CRISIS should perform independent sampling and
analysis. All sampling and analysis required for evaluating remedial alternatives for
Impoundments 15 and 16 have been performed. The results were included in the CMS/FS and
other relevant documents. NJDEP suggested that it could not determine any quantitative
incremental benefits for implementing Alternative 3, but if CRISIS could determine such values,
it should submit them to NJDEP for consideration. This determination, if possible to perform,
does not require any independent sampling and analysis by CRISIS. Mr: Germine's statement
about independent sampling and analysis by CRISIS maybe misleading to a layperson who may
think that sampling and analysis has never been performed. This is inappropriate and inaccurate.
In the future, NJDEP would appreciate CRISIS concentrating on the factual issues and analysis
instead of inaccurate and misleading statements and misinterpretation of the site information.
Furthermore, Mr. Germine clearly stated in his report dated March 12, 1996 that "none of the
wastes of this site have been classified as Resource Conservation and Recovery Act (RCRA)
hazardous" (pages 2 and 3). He also stated that, "This fallacious logic cannot go uncorrected,
because it has ominous implications for the subsequent phases of this cleanup." It is clear from
these statements that Mr. Germine was referring to the RCRA waste classification of all site
impoundments and not just Group II Impoundments as he is now trying to imply in his April 2,
1996 report. Since these statements were inaccurate and misleading, NJDEP had to provide
repeated information on the site impoundments' RCRA waste classification in its letter dated
March 26,1996. NJDEP did this to set the record straight and not in an effort to distract attention
from the real issues or to needlessly fuss over the statements in question.
-------
NJDEP has done everything it could to satisfy CRISIS's concerns as allowed under CERCLA,
the NCR and State of New Jersey requirements. As such, in order to keep the remediation
program at this site on schedule, N JDEP is proceeding with preparation of a Record of Decision
for the Group II Impoundments. Thank you for all your input in this case.
If you have any questions, please contact me at (609) 633-1455.
Sincerelv.
Roman Luzecky, Section Chief
Bureau of Federal Case Management
C: Honorable Mayor James Dowden. Bridgewater Township
Richard Martini. Health office-Bridgewater Township
-------
ATTACHMENT 4
RESPONSIVENESS SUMMARY
AMERICAN CYANAMID SITE-RECORD OF DECISION
GROUP II IMPOUNDMENTS (15, 16, 17 AND 18)
-------
Am Cyanamid Site-Record of Decision __
Responsiveness Summary
AM I €XPDS£D TO
HAZARDOUS WASTE?
These questions will help you find out if you were or are exposed to hazardous waste site contamina-
tion. If you need help with any of these questions, please call the New Jersey Department of Health,
Environmental Health Services. Telephone numbers are on the hack of this page.
' Do / live near a hazardous waste site? Have I ever lived near one?
If you don't know the answer to this, call your local health officer, or the local health officers of cities you lived
in. Their telephone numbers are in the blue pages of your telephone directory.
If you need more help in finding out about hazardous sites where you live, you can call the Department of
Environmental Protection's Bureau of Community Relations program.
Did the hazardous waste stay at the site, or did some of it go off-site? For example, did any
of the waste go into a stream, lake or river; or did it go into the drinking water; or did some
of it go into the air? .
Once you find out if you live near a sit*, you can also find out what government agency is in charge of its
cleanup (usually the New Jersey Department of Environmental Protection, or the federal Environmental
Protection Agency). The agency in charge usually has a Community Relations person who can give you help
with this question.'
If I find out that hazardous waste entered my drinking water, or that I might have come in
contact with it, will it make me sick?
That would depend on what it was, and how much contact you had with it. The Community Relations person
can tell you what was out there. To help you find out how much exposure you personally may have had, you
can call your local health officer, the New Jersey Department of Health Environmental Health Services, or the
federal Agency for Toxic Substances and Disease Registry. For some hazardous waste sites there have been
documents called Public Health Assessments written that have information on people's exposures to these sites.
Your health officer or the Environmental Health Services can explain how that information relates to you.
Once you know about your personal exposure to the chemicals at the hazardous waste rite, your medical
provider can help you figure out if you have health problems from the exposure.
What should I do if lam in contact with the waste?
Once you know where the waste is and how it might affect you, you will be better able to avoid any more
exposure to it There are many ways to avoid exposure, depending on where and what the waste is. For ex-
ample, if you find out that the dirt in your yard is contaminated with lead, you can avoid exposure by planting
some land of ground cover (such as grass), or adding clean fill dirt If your well water is contaminated, your
local health officer or the Department of Health's Environmental Health Services can help you find out if your
water is safe to drink or to use for showering, watering your lawn, or other purposes. .. , •
If I know what the chemicals are, but don't think I have any health problems, is there infor-
mation about them that I can look at before I talk to my medical care provider?
Your local health department might have what you're looking for, or the agency, in charge of the site clean-up.
You can also call the New Jersey Department of Health. The information which any government agency has is
almost always free. • • . ' •
-------
Directory of Government Agencies
New Jersey Department of Health
Environmental Health Services .
CN360
Trenton, N.J. 08625-0360
(609) 633-2043 or (609) 984-2193
• For information on the health effects from hazardous chemicals, or on health questions on
Superfund sites
Agency for Toxic Substances and Disease Registry, Region 11
290 Broadway Floor 18
New York, New York 10007
(212) 637-4305
For information on health questions about Superfund sites in New Jersey
New Jersey Department of Environmental Protection
Bureau of Community Relations
CN028 . -
401 East State Street, Floor 6
Trenton, N.J. 08625-0028
v
(609)984-3081
For information on locations of hazardous waste sites, and to find out whom you can con-
tact for more information about any of the sites .
United States Environmental Protection Agency, Region 11
290 Broadway
New York, New York 10278
(212)264-2657
For information on Superfund sites in New Jersey where EPA is in charge of the cleanup
This factsheet was supported In whole by fund* from the Comprehensive Environmental Response, Compensa-
tion and Liability Act trust fund through a cooperative agreement with the Agency for Toxic Substances' and
Disease Registry, Public Health Service, U.S. Department, of Health and Human Services.
Dtvttoe of EeMrmtoloc. EavtaxMMnul tot Orrnpitkmsl Hnhh Services » EaviroanwtiUl HMhh Services
Printed on Recycled Paper G4503"
-------
Site Review And Update
AMERICAN CYANAMTO COMPANY
BOUND BROOK, SOMERSET COUNTY, NEW JERSEY
CERCLIS NO. NJD002173276
AUGUST 11, 1993
U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
Public Health Service
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Atlanta, Georgia 30333
-------
Site Review and Update: A Note of Explanation
The purpose of the Site Review and Update is to discuss the current status of a hazardous
waste site and to identify future ATSDR activities planned for the site. The SRU is
generally reserved to update activities for those sites for which public health assessments
have been previously prepared (it is not intended to be an addendum to a public health
assessment). The SRU, in conjunction with the ATSDR Site Ranking Scheme, will be used
to determine relative priorities for future ATSDR public health actions.
-------
SITE REVIEW AND UPDATE
AMERICAN CYANAMID COMPANY
BOUND BROOK, SOMERSET COUNTY, NEW JERSEY
CERCLIS NO. NJD002173276
Prepared by:
New Jersey Department of Health
Under Cooperative Agreement with the
Agency for Toxic Substances and Disease Registry
-------
SUMMARY OF BACKGROUND AND HISTORY
The American Cyanamid Company (Cyanamid) is the owner and operator of an active industrial
facility in Bound Brook, New Jersey. The facility encompasses approximately 575 acres and
is bounded by NJ Route 28 to the north, the Raritan River to the south and west, and Interstate
287 to the east. Chemical manufacturing on the site has been continuous since 1915, with
Cyanamid's operations beginning in 1929. During approximately 64 years of operation, the
company has produced over 800 chemicals. These include pharmaceutical, dyes and textile
chemicals, organic pigments rubber compounds, and various intermediate chemicals.
Throughout Cyanamid's operations at the site, and until 1981, unlined lagoons were utilized for
waste storage. Approximately 800,000 tons of chemical waste were discharged to 27 of these
on-site lagoons and containment areas. These lagoons generally contain either organic tars or
waste water treatment sludges, and are the source of soil and surface water contamination. In
addition, the ground water under the site has been severely contaminated with numerous organic
chemicals and metals.
The groundwater contamination resulting from on-site lagoons and containment areas is well
documented, and the focus of extensive study and remedial efforts by American Cyanamid.
Remedial efforts have included the removal of unlined ditches and the initiation of a Remedial
investigation/Feasibility Study (RI/FS) which will, in fact, be a single RI and a separate FS's
for each of four "operable units". Each operable unit is composed of impoundments grouped
according to waste type, nature of contaminants, and geographical location on the site. At this
time, one FS has been completed for the first of three impoundment groups.
American Cyanamid was listed on the National Priorities List (NPL, a.k.a. Superfund) in
September of 1983. The company has signed two Administrative Consent Orders (ACOs). The
first AGO, signed in December 1981, required Cyanamid to access the contamination of the
underlying groundwater from the on-site impoundments and to design and enforce a remedial
plan. In addition, this ACO requires Cyanamid to pump and treat groundwater at the rate of
650,000 gallons per day. Water from these production wells is utilized by plant operations. A
second ACO signed on May 25,1988 assures approximately $63 Million dollars for ongoing site
remediation projects.
A Health Assessment for the Cyanamid Site was prepared for the Agency for Toxic Substances
and Disease Registry (ATSDR), by the New Jersey Department of Health (NJDOH), on August
3, 1990. The Health Assessment noted that contaminated groundwater, soil, and surface water
were the identifiable human exposure pathways associated with the site. It also concluded that
potential human exposure to contaminated well water may have occurred for approximately 45
years before a groundwater control program was initiated in 1982. Contaminants of concern at
the site consisted largely of volatile organic compounds and lesser amounts of semi-volatile
organic and inorganic compounds. Long term effects on residents could not be evaluated since
there was no data on well contaminants prior to 1981.
-------
The Health Assessment noted that although monitoring wells indicated substantial groundwater
contamination, off-site migration of contaminants had been minimized by pumping and treating
650,000 gallons per day drawn from perimeter production wells. This pumpjng has created a
cone of depression, of sufficient size and magnitude to restrict off-site groundwater
contamination. Site data reviewed indicated that any on-site groundwater contaminants that were
not captured by the production wells were ultimately discharged into the Raritan River.
Past public health and community concern about the Cyanamid site have focused on the
company's proposals to construct an on-site incinerator, rather than any concerns about past or
present exposure to contaminated groundwater.
In its final conclusion, ATSDR categorized the American Cyanamid site to be of potential public
health concern because human exposure to hazardous substances, at concentrations of concern,
may occur and have probably occurred in the past. ATSDR recommended that more site data
be collected and a revaluation of off-site groundwater quality be conducted to ensure the
effectiveness of the ongoing pumping program. The Health Assessment also recommended the
need for better security in the area south of the railroad tracks.
CURRENT SITE CONDITIONS
On April 29, 1993 personnel from New Jersey Department of Health, Bridgewater Health
Department, and the New Jersey Department of Environmental Protection and Energy (DEPE)
toured the American Cyanamid site with Cyanamid personnel and their environmental consulting
firm, Blasland, Bouck & Lee. The site visit included a formal presentation by Blasland, Bouck
& Lee staff, and an on-site tour of the 575 acre facility. The following observations were made
during the site visit:
• The site remains an active, but scaled down chemical manufacturing facility;
• Security in the main plant area, which includes the production area and west yard,
was very tight. This included perimeter fencing and security guards. Some of
the other contaminated areas were accessible to trespassers;
• Demolition of on-site structures was in progress;
• Evidence of recent trespasser activity was noted in the impoundment areas south
of the Port Reading railroad tracks. Specifically, fresh "All Terrain Vehicle"
(ATV)tracks were observed on impoundment 16. Also in this area shot gun
shells and beer cans were noted;
• The southern edge of impoundment 16 had been breached and lagoon contents
had apparently migrated to a small pond nearby. The vegetation in the runoff
area was stressed; and
-------
In the vicinity of lagoons 3,4, and 5 a strong hydrocarbon odor was detected.
Conditions at the American Cyanamid site, since the 1990 Health Assessment, have changed
physically, but the environmental conditions have remained constant. Physical changes noted
include: the initiation of the contaminant solidification process in impoundment #8; more
groundwater monitoring wells were added, there are now 501 monitoring wells on the site;
security in the area south of the Port Reading railroad tracks has been increased with the
addition of signs and a cable blocking the access road near the water plant; and there has been
further demolition of some of the old buildings on the site.
In light of current site conditions, the former conclusion in the original public health assessment
of a potential public health concern appear to have been partially addressed. As long as the site
remains secure from site trespassers, no exposure, resulting in adverse health effects, is likely
to occur. The dominant trespasser activity in the area south of the railroad tracks is ATV use.
No direct access to this area by standard vehicles is possible. Trespassers are generally
teenagers and adults, and it appears that the sites remoteness from population areas serves to
keep young children from the area. Site trespassers could be exposed to site contaminants at
levels of public health concern. Two of the four lagoons in the area (impoundments 18 and 19)1,
while less contaminated than the Main Plant area, contain wastewater sludges that are
contaminated with VOCs, SVOCs, and various metals. These two impoundments are heavily
overgrown with a vegetative cover and are, therefore, unlikely to be used by trespassers. The
other areas, which appear to be the most used areas by the site trespassers (impoundments 15
and 16), consist almost entirely of solid iron oxide waste. Iron oxide, in this form, is not
considered to be intrinsically hazardous material.
It remains a fact that, although it maybe assumed that groundwater contamination existed prior
to the groundwater control program, there is still no supporting data regarding groundwater
contamination levels. Therefore, no further action regarding past exposures can be taken.
There has been a considerable amount of additional site data collected which has further
characterized current contamination at the site. With the continuation of the groundwater
pumping from the production wells, however, there are no changes in exposure pathways or the
conditions of human exposure.
CURRENT ISSUES
Currently, the American Cyanamid Company is implementing the final remedial design for the
"group 1" impoundments, the first of four such operable units. Once in place, the selected
remedial alternatives (solidification) will prevent any further potential exposure. There are no
documented on-going exposures to site related contaminants.
-------
There is public health concern involving the continued evidence of trespassing near and/or on
the lagoons south of the Port Reading railroad tracks. Cyanamid has made some efforts to limit
unauthorized access to this area, but their efforts have not been totally successful.
The main concern of local residents is that, while they want the site cleaned up, they oppose any
remedy which would involve the use of an on-site incinerator. At this time, with the selection
of solidification of site contaminants as a final remedy, the incinerator issue appears to be moot.
According to local health officials, contaminated groundwater does not appear to be a concern
of area residents because they are not utilizing private residential wells. In addition, there are
no known community concerns regarding past exposures to site related contaminants or any other
concerns for adverse health effects.
CONCLUSIONS
Conclusions that were made in the 1990 ATSDR Health Assessment, regarding the site being
of potential public health concern, would only be partially true. As long as the site remains
secure from site trespassers, it is unlikely that exposure to contaminants, resulting in adverse
health effects, would occur. Site trespassers could be exposed to site contaminants at levels of
public health concern, but due to the nature of the contact with the site (ATV ridding) and type
of contaminants (mostly iron oxide) they would be exposed to, adverse health effects seem
unlikely. The iron oxide material did not appear to create dust, which further reduces its ability
to cause exposure.
Currently, there are no completed exposure pathways associated with the American Cyanamid
site as a result of the continued groundwater pumping from the production wells.
The original determination that human exposure to hazardous substances probably occurred in
the past remains valid. This conclusion was made because residents may have been exposed to
contaminants in the past. However, there are no monitoring data or other information available
to indicate if exposure to site contaminants has occurred in the past.
Conclusions in the ATSDR Health Assessment regarding a lack of sufficient data to characterize
the site contaminants on groundwater quality are unsupported in light of new data from the
remedial investigations.
The concern involving the continued evidence of trespassing near the lagoons south of the Port
Reading railroad tracks is still valid.
The final conclusion of the Health Assessment indicated that remedial actions taken at the
American Cyanamid Site minimize most of the human exposure to contaminants from the site.
This conclusion is still valid and will continue to be true until such time as site conditions or
remedial activities change.
-------
RECOMMENDATIONS
Recommendations made in the original health assessment concerning the need for better security
near the lagoons south of the Port Reading railroad tracks are still valid.
The recommendations made that would call for a reevaluation of the site's public health impact
following a change in environmental, lexicological, health outcome data, or changes in
conditions of the site, are still legitimate. This would include any changes in remedial activity,
in particular, if the concept of using on-site incineration as a remedy is reintroduced. Any
changes in conditions at the site may determine the need for additional actions by the ATSDR
and the NJDOH.
Remedial activities implemented at this site are sufficient to address concerns of the ATSDR,
the NJDOH, and the community regarding the site. The remedial actions are consistent with
protection of the public health.
After a review of the most recent documents and the current site conditions for the American
Cyanamid site, the ATSDR and the NJDOH have determined that no further action is required
at the site based on the following facts: (1) there are no known community health concerns about
past exposure to contaminants; (2) there are no monitoring data available to investigate levels
of past human exposure, if indeed it occurred; and (3) there are no current exposures at the site,
including trespassers, that are likely to result in adverse health effects.
The data and information developed in the Site Review and Update have been evaluated to
determine if follow-up actions may be indicated. No further public health actions are indicated
at this time.
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DOCUMENTS REVIEWED
1. Group 1 Impoundments Corrective Measures Study/Feasibility Study Report, American
Cyanamid Company, Bound Brook, New Jersey, Blasland, Bouck & Lee, May 1992.
2. Health Assessment for American Cyanamid Company, Bridgewater Township, Somerset
County, New Jersey, ATSDR, August 3, 1990.
3. Baseline Site-wide Endangerment Assessment, American Cyanamid Company, Bound
Brook, New Jersey, Blasland, Bouck & Lee , December 1990, Amended March 1992.
4. Superfund Proposed Plan, American Cyanamid Company, Bridgewater Township,
Somerset County, New Jersey, New Jersey Department of Environmental Protection
and Energy, November 1992.
PREPARER OF REPORT
Jeffrey J. Winegar
Program Specialist; ATSDR Health Assessment Project
Environmental Health Service
New Jersey Department of Health
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-------
LEGEND
^— — — FACILITY StOHCMT BOUMMUT
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MOUTH or emu. RAILMOAO
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AMERICAN CYANAMID COMPANY
BOUND BROOK, NEW JERSEY
CYANAMID FACILITY
FIGURE 3.
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ATTACHMENT 5
RESPONSIVENESS SUMMARY
AMERICAN CYANAMID SITE-RECORD OF DECISION
GROUP II IMPOUNDMENTS (15, 16, 17 AND 18)
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IU 35001 i«u«» otKOCl UtKMfM uncn i or ci<4 vmomvici* mi. r i\w i i_
COMPANY NAME American Cyanamtd Co. ANNUAL EMISSION STATEMENT
FORM A, PART 5 - TOTAL EMISSIONS FROM ALL SOURCES AT FACILr
EMISSION YEAR 94
'"'-'-'•-"• • ' • .1
I
•LEASE SEE INSTRUCTION BOOKLET (SECTION A) FOR INFORMATION ON FILLING OUT THIS FORM.
TOTAL FACILITY EMISSIONS (THE DEP WILL COMPLETE THIS FORM FOR YOU IF YOU REQUESTED DEP TO CALCULATE THE EMISSION RATES FROM ANY SOURCE
ON FORMS B THROUGH H).
TOTAL QUANTITY EMITTED IN EMISSIONS REPORTING YEAR (SUM OF EMISSIONS FROM FORMS A THROUGH P)
POLLUTANT
FORM A.
PART4 FQRMB FORMC FORM 0
FORME FORMF FORMG FORMH FORM I
ACTUAL TOTAL
FACILITY EMISSIONS
FORMP (TONS/YEAR)
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1 UtKMIM WICIt I
r l\vy I i_v» I lv_Mt
LAN! IU 35001 I-»U»»
OMPANY NAME American Cvanamld Co. ANNUAL EMISSION STATEMENT
FORM A, PART 5 - TOTAL EMISSIONS FROM ALL SOURCES AT FACILP
MISSION YEAR 9*
~ "
LEASE SEE INSTRUCTION BOOKLET (SECTION A) FOR INFORMATION ON FILLING OUT THIS FORM.
OF M A. • AN i a i AOE OF
TOTAL FACILITY EMISSIONS (THE DEP WILL COMPLETE THIS FORM FOR YOU IF YOU REQUESTED DEP TO CALCULATE THE EMISSION RATES FROM ANY SOURCE
ON FORMS B THROUGH H).
TOTAL QUANTITY EMITTED IN EMISSIONS REPORTING YEAR (SUM OF EMISSIONS FROM FORMS A THROUGH P)
POLLUTANT
FORM A.
PART 4 FORMS FORMC
FORMO FORME FORM F FORM O FORMH FORM I
ACTUAL TOTAL
FACILITY EMISSIONS
FORM P (TONS/YEAR)
VOC
(TONS)
NOx
(TONS)
CO
(TONS)
S02
(TONS)
TSP
(TONS)
PM10
(TONS)
Pb
(TONS)
A.t 3
O
.O
'
— —
*""""
•
0*30
t.6?
9.J/
~
O.O&
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r\ * ^^ ^/
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0. ?/
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0,03
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of
Christine Todd Whitman Department of Environmental Protection Robert C. Shmn. Jr.
Governor _ ««_ • • •» • • , • . -. . Commissioner
Bureau of Chemical Release Information and Prevention
CN405
Trenton, NJ 08625-0405
Phone: 609-984-3219
Fax: 609-633-7031
MEMORANDUM
April 8, 1996
TO: Fred Mumford, Community Relations Coordinator
Division of Publicly Funded Site Remediation
FROM: Shirlee Schiffman, Chief i-,1
Bureau of Chemical Release Information & Prevention
Division of Environmental Safety^ Health & Analytical
Programs
SUBJECT: Community Right to Know Information for American Cyanamid
This memo is in response to your request for information
regarding the American Cyanamid facility, East Main Street,
Bridgewater Township.
Attached for your information are computer-generated reports
of the facility's most current submissions: 1) the 1994 Community
Right to Know Survey (DEQ-094) that presents the facility's
hazardous substance inventory information and 2) the 1994 Release
and Pollution Prevention Report (RPPR or DEQ-114) data for
environmental releases, off-site . transfers and chemical
throughputs. ' ' -
The DEQ-094 is required of all manufacturing sector
facilities, as well as select non-manufacturing sector facilities
covered under the NJ Worker and Community Right to Know Act.
Employers are required to report all New Jersey Environmental
Hazardous Substances CEHS) that were present at the facility 500
pounds or more at any one time. Select EHSs may have a lower
federal thresholds. Additionally, under Section 312 of the federal
Emergency Planning and Community Right-to-Know Act of 1986' (EPCRA),
employers are required to report any other substances that were
stored above 10,000 pounds at any one time for which the employer
was required to maintain a material safety data sheet (MSDS)
pursuant to the Occupational Safety and Health Administration
(OSHA) Hazard Communication Standard.
New Jbxy a m Equi/ Opportunity Eapbftr
-------
The RPPR is required of all facilities that are subject to
reporting requirements under Section 313 of EPCRA. Section 313
requires facilities to submit the federal Toxic Chemical Release
Inventory Reporting Form (Form R) if they meet the following
criteria :
1. the facility is in the manufacturing sector (i.e. Standard
Industrial Classification codes 20 through 39);
2. the facility had ten or more full-time employees (i.e.
reporting year payroll of 20,000 or more work-.hours); and
3. the facility manufactured or processed a covered substance
in excess of 25,000 pounds or otherwise used a listed
substance in excess of 10,000 pounds during the reporting
year.
Also attached is a blank copy of Part 2 of the DEQ-094 to
assist your interpretation of the codes as presented on the
computer-generated report for the 1994 data.
I trust this information will be of use to you. Should you
have any questions, please call the Andy Opperman at 633-1154.
attachments
ao
-------
• NJSEP / DESHAP / COMMUNITY RIGHT TO KNOW 04/oi/i9»s
1994 COMMUNITY RIGHT TO KNOW DATA for AMERICAN CYANAMID. BOUND BROOK PACE: 1
report prepared tor Fred Mumford, RJDEP, Divi»ion of Publicly Funded Site Remediation
SUB! CAS NUMBER COMMON NAME OF SUBSTANCE
Pure Phy* Max Avg Dayi Container
Mixt State Daily Daily OnSite Code
090140!
0004
0006
0006
0006
0023
0103
0103
0343
0367
0766
0841
0«44
0844
2444
2461
2461
2360
1012
1012
1016
1222
1222
13-75
2651
1571
165S
1706
1706
1761
1166
1166
3C28
1001 • 2633
S966S
32S73S66
3156916
64197
67641
67641
67641
79107
1336216
1336216
471341
9003978
124389
7762505
77781
1417(6
64175
64175
10034932
7647010
7647010
67630
7487889
6761
67561
142461
7727379
1310583
7631869
1310733
1310732
540127
766493*
108813
108883
"
- 1806 AMERICAN CTAHAMID C
t. MAIN ST. (KASTON
2 ACETYLAMINO 134 TKIAD
2 ACETYLAMINO 5 KERCAPTO
2 CHLORODIBENZI B F
'ACETIC ACID
ACETONE
ACETONE
A-STONE
ACRLIC ACID.
AMMONIUM HYDROXIDE
AMMONIUM HYDROXIDE
CALCIUM CARBONATE
CALCIUM POLYCARBOPHIL
CARBON DIOXIDE
CHLORINE
DIMETHYL SULFATE
ETHYL ACETATE
ETHYL ALCOHOL
ETHYL ALCOHOL
FUEL OIL
HAZARDOUS HASTE
HAZARDOUS WASTE
HYDRAZXNE SULFATE
HYDROCHLORIC ACID
HYDROCHLORIC ACID
ISOPROPYL ALCOHOL
'MAGNESIUM SULFATE
METKANOL
METKANOL
0 N BISTHIOCARBAMYL HYDRA
NITROGEN
PARACHLOROBEHZYL CHLORIDE
PETROLEUM OIL
POTASSIUM HYDROXIDE
SILICA AMORPHOUS
SODIUM HYDROXIDE
SODIUM HYDROXIDE
SODIUM THIOCYAKATE
SULTURIC ACID
TOLUENE
TOLUENE
X SAMPLES OP UPORTKD SOB
0
TURNPIKE) ,B
M
M
M
P
P
P
P
P
P
P
P
M
P
P
P
P
P
P
P
M
M •
P
P
P
P
P
P
P
M
-P
P
P
P
P
M
M
9
f
M
P
RIDCE1
S
s
S
L
L
L
L
L
L
L
S
S
L
C
L
L
L
L
L
L
L
S
L
L
L
S
L
L
S
G
L
L
S
S
L
L
C
L
L
L .
L
*ATER
14
14
14
15
14
14
11
14
IS
13
14
15
14
13
13.
14
IS
14
19
IS
14
14
16
13
15
IS
13
12
14
is
14
14
14
14
17
13
14
14
ia
11
09
14
13
11
13
12
14
11
13
13
12
13
13
14
13
12
12
14
12
18
14
12
12
16
13
14
• 13
• 11
11
12
14
12
14
12
12
1C
11
12
13
13
11
09
365
365
365
365
365
120
365
365
365
36S
365
365
365
216
237
212
365
365
365
365
365
365
365
365
365
365
365
365
36S
365
365
365
36S
36S
3CS
3CS
315
344
36S
36S
3(5
' OF
DF
DF
DP
DS
TA
BG
DP
TA
DP.
BA
DP
TA
CY
CY
DS
TA
DS
TA
TA
DS
•DF
TA
DP
TA
BA
OS'
CM
DP
TA
• DS
DS
DS
BA
TA
DP
BA
OP
TA
CM
or
S«e attachment for codec.
-------
1_
PART 2
1W5 CHEMICAL INVENTORY REPORT
Reporting Period. January 1 -December31.1995
Photocopy Mt p*0» I you n
Mftuctiarw antuiy 6
rffa
SUBSTANCE DESCRIPTION
Name:
Substance Number:
CAS Number:
DOT Number
Pure ( ) or Mixture ( ) C/we*orM
Solid ( ) UquU ( ) or Gas{ ) Ctedkorw
Trade Secret: ( ) ctm*td*m*g Locattonfs)
( )Rre
( ) Sudden release of pressure
( ) Reactive
( ) Acute heath effects
( ) Chronic heath effect*
( JNoneperMSQS
CortaJrwType
Max. defy Inventory .
Avg. daly Invereory .
Deysonsae
Gturage pressure
Storage tempefaftjre.
Name:
Substance Number:
CAS Number:
DOT Number
Pure ( ) or Mixture ( ) Owe* CM
Solid ( ) Liquid ( ) or Gas ( )
Trade Secret: ( )
OFlre
( ) Sudden release of pressure
Container Type
Leesttonft)
(} Acute raatn-eflects
( ) Chronic heath effects
( ) None per OSOS
Name:
Substance Number
CAS Number
DOT Number
Pure ( } or Mixture ( ) Cte*on«
SoMd( ) Liquid () or Oas( ) Ctwckor* 4
Trade Secret: ( ) ow*f oMm*v LocatiorX*)
OFIre
( ) Sudden release of pressure
( ) Acute heath effects
() Chronic heath effects
() None per USDS
CortatwType
Max dMy Inventory
Avg. dftiy hventory
Oejysonste
Storage tenper
Name:
Substance Number
CAS Number
DOT Number
Pure () or Mixture ( ) Gtadrorw
SoW( ) Uquk*( ) or Qas( )
Trade Secret: ( )a*akid*mrg
Locadon(8)
OFlw
( ) Sudden release of pressure
( JReacfee
() Acute heath effects
()Chronfc heath effects
( )NoneperMSOS
Container Type.
Max. defy Inventory
Avg. defy Inventory
Deysoneee
Storage ternperekn
Name:
Substance Number
CAS Number
DOT Number
Pure ( ) or Mhture ( ) Ctaken*
Solid () Liquid {) or Qas( ) Cnei* one
Trade Secret ()a*t*rd*mbg Locetfon(e)
( ) Sudden release of pressure
(JReactfve
() Acute heath effects
( )Chronfcheath*
() None per USDS
ContaewType
Max. defy Invertory
Ayp. deiy Inventory .
Oeysonaee
-------
»f» / IWU* / COMMIT IIHH 10 UOU PtOUUH
1W iiiiMC t Mnunm ra«f*na> MMU mo-mi ««r MKIICU CIMUMIO, MM HOOK
report pr*P*r*roducti 0
fndln* Invenlonri 1,091
•• « ••
••cycled On tlUi 2,261
On-lllt (nerfy litineryi 0
tMiroyed On tltn 0
lolil On-Ill* •••tructloni 2.2A2
1
fuglllv* Mr lei til ami t
turlec* Uiter •iKliertni t
Creund Uiur Oledwreeti •
On-tlu lend •lepeiili •
leul On-Ill* ••IOMMI HD
••cycllnt Off lll*i
Inerty leceviry Oil Ilui
lr**la*M Ml Ilui
•lipeMl Ml lit*
OUwr Ml III* •euinnli
tout Off-Ill* Iremlern ' M.M4
-------
of • i ivttf i COMUHITI tiHi TO unu MOHAN
199* HUUi I MUUtlOU MtMlllOi ttrttU (KO-1U) f*r MKIICA* CVMNIIO. HUB MOM
r*p*rt pr»p*r*d for fr*d ftrtord, »lvl*lon *f ftMlcly fund«d lit* taHdUtl*n Oil dm It reported In
I. 19M
•*•*! I
(AM i oontaos OMIC*I •••: cani
flirtlnt Inventeryl l.in
Produced On II Ut 0
Or*u*t On tltii 1M.SM
••••* T.OIAL IWUli 1*9.171
«
ComiMd On tlUt 72,94)
tklppid In Products 11.140
(ndln( Inventory: 100
••cycled On flu: 0
On-fit* fnerfy Recovery: 0
OMtroyed On tlu: 16.2M
lot*! On-fit* 0*»tructlon: U.2M
tt*ck Air UUilom: 299
fugitive Air (•liilone: 1*4
furf*c* ll*Ur OlKharoii 0
Ground W*ur OlwlwrfMi 0
On-fit* lend tltpOMt: 0
Totil On-fit* lilee***: 441
lecycllnt Off III*: '
fnerty t*cov*ry Off SlUl
1r**t*«w Oft tlui
OIlfOMl Off tit*
Other Off tit* n«ii|i^il i .
letil Off-flu Irmier*;- • 0
XM«««*M IOIAI oUIPUIt 100,101
us*: oaoorrni OMBIUI •••: OIKII
ttcrtlni ln**ntory: 4,MO
rroduc*4 On f IWi 0
Ira*! On IIUi ».MO
••«•• TOIU. imnt 19,900
TI tmniE
ConHMd On til*: M.S4B
ttilpfMd In Product: 0
fndlnt InMntoryi J.5JO
«*cytl*d On Sit*: ' . 0
On-SIt* tn»rty l*cav*ry: 0
OMtroyvd On f It*: 0
Totil On-SIt* Pntructlon: 0
Stick Air falulm:
fugltlM Air iBlitlom:
furlM* U*t*r OlKkvgMi
Ground Utt*r Pltchirttti
On-fit* l*nd Oltpoul:
Total On-fit* **l**m: 2
lacrclln* Off tlt*i
(mrfy l*ca«*ry Off tit*:
Tr**ta*nt Off tlt*i
»l*po**l Off fit*
Olk*r Off tit* Hinimnti
T*t*l Off-tit* Tr«mf*r«i 0
>••••••••• TOlAi OUIWIt 29,900
CUfi I10DM9U OMBlc*! MB*: intAIlM SuXIATI
IWVIft
ttirtlni Inventory! 1,191
•roducid Oatlui 0
trougkl On Slt*i . 111.920
••••• TOIAl I*»UT: 120.111
OUIfUIS:
Conuwd On Sit*: 101.1M
Sklpp^ In Product: 0
fndlnt InMMoryi 14. WJ
lKycl*d On Sit*: 0
On-SII* Entrtv **co**ry: 0
0**troy*d On Sit*) 0
lotil On-slt* 0«ttructlon: 0
1
tuck Air {•Iwlont:
lugltlv* Air Evlnlom:
SurlK* Uitw Dltch*r«Hi
Ground IMUr Oltchirt**:
On-lit* l*nd DlipoMl:
lout On-SIU **Uu**: 2
t*cyclln« Off flu:
trariy l*co«*ry Off IIUi
Irwumt Off tlut
»l»(MHt Off lit*
Otkw Off flu mnm.intl
l*ul Off-fit* 1rin*f*r«i 0
•
-------
W Ol» / fSMT / OMUH1V IIOII TO UKM MOBUM
19*4 must I rouuiio* Mtwma UMMI t*r MCIICA* ctAWwio. tou* MODI
report prepared for Ired Mrford. Dlvlilon of *t*llcly tinted tit* loMdUtlon (oil d*t* I* reported In "poinb per year*)
April 1.
»••*! I
oontra»
•i itMncmoiic ACID
IWV)»1 • .
(Iwlln* Inxntoryt S9.7H
•routfil On tlMi MO.S7I
****- iDim imrti TO. Ail
ComiMd On »!«•: 4U.200
fndli* IdMMeryi 57.4U
••cycltd On Sift: ' •
Dwtropd On •!«•: 264,76*
total On- Sit* OMIructlan: 26*, 76*
1
ttack »lr lalulora: WO
Iur«*c* HM«r BUch*r«ni •
Croud IMttr OlKkwtwi 0
On-lit* l*nl •Itpouli •
l*t*l On-fit* I«|MM*I .. 761
»«•.
l*cyclli«0f( ilt*i
Eiwrflv l*cowrv Oft tlttl*
1r**UMt Off llt*i
BltpOMl Off tit*
Ottar Off lit* minjMinn
l*t*l Off-(lt*"lr*raf*r«i *
- - M
CAM: 007664*1* Ch*alc*.l
•I WlfWIC ACIO
IVUIIt
ttwttnt Imxntoryt 71
rroiijc*tl On fit*: 0
•row*t On tlt*l «0,«M
onniif:
CenttMd On fit*: B.ZM
fklppid In >roAKt: 0
Ending InMnteryt S.2V2
(•cycled On flu: . 0
On- SI I* Intrgy l*cov*ry: . 0
OMtro|«d On fit*: 470
lot*) On-ill* D«lt ruction: 470
I
tuck Air falulom: •
•uiltlv* Air (•Inleni: 0
Surfoco Uttor Dl«ch*rtni •
Crowd HM«r OltckM-fMi • •
On- fit* lend OltpoMl: •
lot*! On-IIU I*|*M«: •
-
••cycllna Off tlt*t
Imrn **cov*ry Off tlt*l
IrMMmt Off fit*:
•lipOMl Off SIM
Otiwr Off tit* •irninmt;
TM6I Off-tit* Tr*raf*ni 0
-------
ATTACHMENT 6
AMERICAN CYANAMID SITE-RECORD OF DECISION
GROUP II IMPOUNDMENTS (15,16,17 AND 18)
-------
ATTACHMENT 6
REGION B
290 BROADWAY
NEW YORK, NY 10007*1666
JUN 2B 1996
Robert C. Shinn, Jr., Commissioner
State of New Jersey
Department of Environmental Protection and Energy
401 East State Street, CN 402
Trenton, New Jersey 08625-0402
Re: Record of Decision
American Cyanamid Superfund Site
Bridgewater Township, Somerset County, New Jersey
Doar Commisaioner Shinn:
The United States Environmental Protection Agency (EPA),
Region II, h&d reviewed the two draft Records of Decision (RODS),
dated May 1996, for the American Cyanamid Buperfund site (Bite),
which ie located in Bridgewater Township, Somerset County, New
Jersey.
EPA concurs with the selected remedy for the Group II
Impoundments, which includes the in-pidue containment of waste
material from Impoundments 15 and 16, excavation, on-eite
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 Ho Action with
Monitoring for the Hill Property portion of the site. SPA 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. Thia finding shall not affect EPA1e 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
CSRCLA. EPA further reserves the right to take response and
enforcement actions pursuant tu Sections 104, 106 and 107 of CERCLA
with respect to the remedy and any additional future work at the
Site.
Sincerely,
etrator
PiMMl *IK Vfcgrtttto Of B«Md Mto o* 100% MMMM ftem «C* ft
------- |