PB98-963131
EPA 541-R98-135
March 1999
EPA Superfund
Explanation of Significant Difference
for the Record of Decision:
Cosden Chemical Coatings Corp.
Beverly, NJ
9/24/1998
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
SEP 2 A 1998 REdow „
DATE:
Explanation of Significant Differences for the
SUBJECT: Cosden Chemical Coatings Superfund Site
FROM-
Ricnar<*
Caspe, Director
Emergency and Remedial Response Division
TO: Jeanne M. Fox
Regional Administrator
Attached for your approval is an Explanation of Significant
Differences (ESD) for the Cosden Chemical Coatings Superfund site
located in the City of Beverly, Burlington County, New Jersey.
The differences between the remedy selected in the 1992 Record of
Decision (ROD) and the actions described in the ESD relate to the
on-site treatment of soil contaminated with inorganic compounds
and PCBs, and the natural flushing of soil contaminated with
volatile organic compounds (VOCs). The New Jersey Department of
Environmental Protection (NJDEP) has reviewed and concurred with
the ESD.
Extensive sampling performed during the remedial design has shown
that significantly less soil is contaminated than estimated in
the ROD, and that the contamination is distributed much more
sporadically. As a result, EPA has determined that
implementation of the in-situ treatment process called for in the
ROD would be significantly more complicated and costly than
originally anticipated and that off-site treatment and/or
disposal, which was supported by the community, is preferable.
EPA has also re-examined the cleanup goals which were established
in the ROD and has determined that the 500 parts per million
(ppm) concentration for lead is no longer protective. As a
result, the cleanup goal for lead is being changed to be
consistent with the current EPA and NJDEP cleanup goal of
400 ppm.
Finally, EPA is also modifying the approach to remediating the
VOC-contaminated soil which presents a source of ground water
contamination. A relatively small amount of shallow soil
contaminated with VOCs will also be excavated and transported off
site for appropriate treatment and disposal. In addition, a soil
vapor extraction system component will be added to enhance the
effectiveness of the ground water extraction and treatment remedy
currently being designed.
I recommend that you approve this ESD. My staff and I are
available to discuss this recommendation at your convenience.
Attachment
REGION II FORM 132O-1 (9/89)
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SEP-22-98 08. SB l-'KUn : Salic icemeut MA iui
Chrixlinr 'Imlil Whitman
Department of Environmental Protection
RnhrM C- Shinn, Jr.
Commissioner
SEP 18 199B
Mr. Richard Caspe
Director of Emergency Remedial Response Division
USEPA-Regionll
290 Broadway -Floor 19
New York, N.Y. 10007-1866
Subject: Cosden Chemical Coatings Corpootioa Supcrflmd Site
Explanation of Significant Difference (ESD)
Dear Mr. Caspc;
The Department or Environmental Protection has evaluated and concurs with the components of the
Explanation of Significant Differences (ESD) proposed by EPA for the Cosden Chemical Coating*
Corporation Superfand site. The difference! between the remedy (elected in the 1992 ROD and the actions
described in the E5H relate to the on-che treatment of soil contaminated with inorganic compounds and
PCBs and the treatment of VOCi. The changes include the following:
1. The original estimate of 8,000 cubic yards of toil contaminated with metals and PCBs wat reduced to
3.700 cubic yards of soil to be addressed.
2. The treatment technology of in-rim stabilization for soil contaminated with inorganic contaminants
and PCBs was changed to excavation, off-site stabilization. disposal and backfill.
3. Shallow soil contaminated with VOCs will now be excavated and transported off-site for treatment or
disposal since these toils represent a continuing source to ground water contamination. No active
remedial measures for VOC* woe selected in the ROD since VOCs did not post an unacceptable
dermal contact or ingestion risk and woe expected to flush out of the soils as part of the ground water
extraction and treatment remedy.
4. A soil vapor extraction system component will be added to the ground water extraction and
treatment remedy included in the ROD to address residual VOC contaminated aoilj.
5. The clean-up goal of 500 ppm far lead established in the ROD will be decreased to 400 ppm.
The State of New Jersey appreciates the opportunity to participate in (he decision making process and
looks forward to future cooperation with USEPA.
Poat-lt • brand (ax transmitlai momo 7671
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EXPLANATION OF SIGNIFICANT DIFFERENCES
COSDEN CHEMICAL COATINGS CORPORATION
Site Name and Location
Cosden Chemical Coatings Corporation
City of Beverly
Burlington County, New Jersey
Introduction
The United States Environmental Protection Agency (EPA) presents
this Explanation of Significant Differences (ESD) to explain a
change made to the remedy selected in the September 30, 1992
Record of Decision (ROD) for the Cosden Chemical Coatings
Corporation Superfund site. This change relates to that portion
of the remedy which addresses the treatment of soil and is the
result of information obtained and developed subsequent to the
1992 ROD.
This ESD is issued in accordance with Section 117(c) of the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, as amended (CERCLA), 42 U.S.C. 9617(c), and Section
300.435(c)(2)(i) of the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP), 40 CFR 300.435(c)(2)(i), which
contain provisions for addressing and documenting changes that
occur to a remedy after a ROD is signed. The ESD and documents
which form the basis for the decision to change the response
action will be incorporated into the Administrative Record for
the site in accordance with Section 300.825(a)(2) of the NCP.
The Administrative Record is available for review during normal
business hours at EPA Region II, 290 Broadway, New York, New York
10007, (212) 637-4308, and at the Municipal Building in the City
of Beverly, Burlington County, New Jersey.
Summary of Site History, Contamination Problems, and Selected
Remedy
The Cosden Chemical Coatings site is located in the southeastern
corner of the City of Beverly in Burlington County, New Jersey.
The 6.7-acre site is bounded on the north and east by residential
streets, on the south by Conrail tracks, and on the west by
undeveloped land. The Beverly Elementary School is located 0.2
miles to the northeast. The neighboring area is suburban with
some light industry. The Delaware River is approximately 4,000
feet to the north, and Rancocas Creek approximately 1.5 miles
southwest of the site. Approximately 3,000 people live within a
one-mile radius of the site.
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Cosden Chemical Coatings Corporation was a paint formulation and
manufacturing facility which produced coatings for industrial
applications. In the manufacturing process, pigments were
combined with resins and solvents and then placed into a mixing
tank where other ingredients were added to produce the final
coating products. The mixing tanks were then washed out with
solvents, and the material was transferred to drums. Organic
solvents used in the manufacturing process were recycled until
1974. After 1974, drums containing spent solvents were stored on
site; some of these drums leaked onto the ground and caused soil
and groundwater contamination. Solvents were also stored in
underground storage tanks, which have leaked.
A grass fire that occurred at the site on April 22, 1980 prompted
the Burlington County Department of Public Safety to report the
site conditions to the New Jersey Department of Environmental
Protection (NJDEP). Subsequent site visits by the NJDEP revealed
the presence of surface spills, and several hundred unsecured
drums. Various court actions and negotiations undertaken by
NJDEP against Cosden Chemical Coatings Corporation resulted in a
judicial consent order on February 5, 1985 that required Cosden
to clean up the site. Cosden initiated the cleanup in February
1985, but abandoned cleanup efforts after 88 of 695 drums were
removed. In January 1986, NJDEP undertook an emergency removal
of the drummed material, and cleanup of surface spills around the
drum storage areas.
The site was placed on the National Priorities List (NPL) of
Superfund Sites in July 1987 and EPA began a remedial
investigation and feasibility study (RI/FS) in April 1988. Cosden
ceased operating in May 1989. In June 1989, EPA initiated
emergency cleanup activities at the site by constructing a fence
around areas of soil contamination and began removing the
remaining drums, paint cans, pigment bags, mixing tanks, and
underground storage tank contents. On May 28, 1990, as the
removal action was nearly completed, a fire occurred inside the
process building which consumed a majority of the building. The
building was condemned by the Beverly City building inspector on
May 31.
The RI found that the soil was contaminated with volatile organic
compounds (VOCs), polynuclear aromatic hydrocarbons,
polychlorinated biphenyls (PCBs), and inorganic compounds; ground
water was contaminated with VOCs and inorganics; and the building
was contaminated with inorganics, PCBs, and asbestos. Based on
the results of the RI, EPA and NJDEP established remedial action
objectives for the site which called for prevention of exposures
to contaminant sources that present a significant human health
risk, and restoration of contaminated ground water to drinking
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water standards. To accomplish these objectives, EPA selected a
remedy in the ROD signed on September 30, 1992, which included
the following major elements:
• In-situ stabilization of approximately 8,000 cubic
yards of soil contaminated with inorganic compounds and
polychlorinated biphenyls;
• Decontamination and demolition of the building on the
site with disposal of the building debris at an
appropriate off-site facility; and
• Extraction of contaminated ground water with on-site
treatment and recharge to the underlying aquifer.
Because the levels of VOCs in the soil did not pose an
unacceptable dermal contact or ingestion risk, no active remedial
measures were selected in the ROD. The ROD recognized that the
VOCs in the soil represented a continuing source of ground water
contamination, but it expected that the VOCs would be gradually
reduced through natural soil flushing and the operation of the
ground water extraction and treatment system.
On-site activities related to the building decontamination,
demolition and disposal were initiated in July 1995 and were
completed in January 1996. The ground water remedy is currently
being designed. This BSD addresses differences to the remedy
selected for the soil cleanup.
Description of the Significant Differences and the Basis for
those Differences
The differences between the remedy selected in the 1992 ROD and
the actions described in this ESD relate to the on-site treatment
of soil contaminated with inorganic compounds and PCBs, and the
natural flushing of VOC-contaminated soil. The other components
of the remedy selected in the 1992 ROD remain unchanged.
In the ROD, EPA evaluated the following alternatives for
remediating the contaminated soil on the site: no action;
limited action; capping; excavation, off-site stabilization and
disposal, and backfill; excavation, on-site stabilization, and
on-site backfill; and in-situ stabilization. Each alternative
was evaluated with respect to a number of criteria including
overall protection of human health and the environment; long-term
effectiveness and permanence; reduction of toxicity, mobility, or
volume; and cost.
The ROD determined that the no action/limited action alternatives
would not offer adequate protection of human health and the
environment, would not achieve cleanup goals, and would not
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provide long-term effectiveness. It was determined that capping
would be protective of human health but would not meet applicable
or relevant and appropriate requirements (ARARs). It was
determined that the three remaining alternatives would satisfy
the majority of the evaluation criteria, and that the off-site
treatment and disposal alternative would provide the greatest
overall protection of human health and the environment, and long-
term effectiveness. Further, the off-site treatment and disposal
alternative was preferred by the community while the on-site
alternatives were not supported. The off-site treatment and
disposal alternative was not selected, however, because it was
estimated to cost more than twice as much as in-situ
stabilization and it was believed to be more difficult to
implement due to a limited availability of acceptable off-site
treatment and disposal facilities.
The ROD estimated that approximately 8,000 cubic yards (yd3) of
soil contaminated with inorganic compounds and PCBs would be
stabilized using in-situ solidification, and that soil and debris
contaminated with PCBs at a concentration greater than 50 parts
per million (ppm) would be transported off site for treatment and
disposal. This was based on an assumption that a large,
contiguous area was contaminated to a depth of four feet, and
that the majority of the material was located within the site
fence.
Extensive soil sampling was performed during the design of the
remedy. That sampling indicated that, rather than being one
large, contiguous area, the contamination is distributed in many
isolated locations. This resulted in a reduction in the
estimated volume of contaminated soil from 8,000 yd3 to less than
3,700 yd3. Additionally, the sporadic distribution of the
contamination, and the presence of a greater portion of the
contamination outside the site fence than originally believed,
indicated that implementation of an in-situ stabilization
treatment process and its subsequent monitoring would be
significantly more complicated and costly than originally
anticipated. Therefore, EPA reconsidered the off-site treatment
approach and determined that it could be implemented more easily
and cost effectively than an in-situ treatment remedy, and that
it was the approach originally supported by the community.
Further, analytical testing of the soil has indicated that much
of it will not likely need to be treated prior to disposal at a
permitted facility.
As a result, EPA has decided that off-site treatment and/or
disposal of the soil is preferable to in-situ treatment.
Utilizing off-site treatment and disposal will eliminate the need
for long-term monitoring of the effectiveness of the in-situ
treatment process, and likely eliminate the need for
institutional controls. Because no costs associated with
mobilizing and demobilizing a solidification/stabilization unit
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at the site will be incurred, and the estimated volume of
contaminated soil has been significantly reduced, the overall
cost of the remedy will also be decreased. The estimated present
worth cost to implement the original remedy is approximately $3.3
million, compared to about $2.1 million for this change to the
remedy.
EPA has also re-examined the cleanup goals which were established
in the ROD and has determined that the 500 ppm concentration for
lead is no longer protective. As a result, the cleanup goal for
lead has been changed to be consistent with the current EPA and
NJDEP cleanup goal of 400 ppm. The other soil cleanup goals for
the site (beryllium 1 ppm, chromium 390 ppm, and PCBs 1 ppm)
remain unchanged. However, as noted in the ROD, EPA recognizes
that NJDEP has requested that the soil be remediated to the
levels specified in its Soil Cleanup Criteria, but because those
criteria have not been promulgated they are not considered ARARs
under Section 121 (d) of CERCLA. The NJDEP may agree to fund the
incremental cost associated with any additional cleanup, or to
implement institutional controls. Further, because the NJDEP and
EPA cleanup goals for PCBs are not substantially different, the
soil remediation effort may actually achieve the NJDEP goal with
no additional cleanup activity or cost.
Finally, EPA has also modified the approach to remediating the
VOC-contaminated soil which presents a source of ground water
contamination. A relatively small amount of shallow soil
contaminated with VOCs will be excavated and transported off site
for appropriate treatment and disposal during the soil
remediation effort described above. In addition, a soil vapor
extraction system component will be added to the ground water
extraction and treatment remedy currently being designed. These
efforts are expected to significantly reduce the duration of the
ground water restoration and result in an overall cost savings.
Support Agency Comments
The State of New Jersey supports EPA's revision to the remedy and
decision to issue this BSD.
Affirmation of Statutory Determinations
Considering the new information that has been developed and the
changes that have been made to the selected remedy, EPA and NJDEP
believe that the modified remedy remains protective of human
health and the environment, complies with federal and state
requirements that were identified in the ROD and this ESD as
applicable or relevant and appropriate to this remedial action,
and is cost effective. In addition, the revised remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable for this site.
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Public Participation Activities
In accordance with the NCP, a formal public comment period is not
required when issuing an BSD. However, EPA will announce the
availability of this BSD in the Burlington County Times. This
BSD has been placed in the Administrative Record for the site.
Jeanne M .
Regional Admin
Date
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