United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R02-87/053
September 1987
&EPA
Superfund
Record of
Diamond Alkali, NJ
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TECHNICAL REPORT DATA
IF'least read tnttncttons on the rtvtnt btfore completingj
EPA/ROD/RO2-87/053
s ACCESSION NO
4. TITLE AND SUBTITLE
SUPERFUND RECORD OP DECISION
Diamond Alkali, NJ
First Remedial Action
7. AUTMORIS)
S. REPORT OATS
September 30, 1987
I. PERFORMING ORGANIZATION COOf
•. PERFORMING ORGANIZATION REPORT NO
I. PERFORMING OROANIZATION_NAME ANO ADDRESS
10. PROGRAM IlCME'Nf' NO:
1. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND AOORf S3
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE Of REPORT ANO PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY COOS
800/00
IS. SUPPLEMENTARY NOTIS
4.
The Diamond Alkali site, also referred to as Diamond Shamrock and the
80 Lister Avenue property, is located in the Ironbound section of Newark, New Jersey.
The 3.4-acre property is three miles upstream from the mouth of Newark Bay and is .'
surrounded by the former Sergeant Chemical Company site (subsequently purchased by t
Diamond Shamrock), the Duralac Company, a Sherwin-Williams Company property and .the
Passaic River. The site has been used for chemical manufacturing by numerous companies
for more than 100 years. The mid-1940s marked the beginning of the manufacturing
operations related to the current site conditions and included the production of DDT an
phenoxy herbicides. The Diamond Shamrock Company acquired the property in 1951 and
produced various chemicals and pesticides until 1969, when it was shut down. Subsequen
owners remained on the property until 1983, when EPA sampled the site and revealed high
levels of dioxin. The dioxin discovery led to the excavation and securing of the site.
All exposed soils were covered with geofabric to prevent potential migration of
contamination and guards were placed at the site. The primary contaminants of concern
affecting soil, structures, ground water, and air include dioxin and DDT.
The selected remedial action for this site includes: construction of a site slurry
wall and a 100-year flood wall; RCRA capping; disassembly and decontamination of
nonporous permanent structures for offsite reuse, recycling, or disposal; offsite .
(See Attached Sheet)
7.
KIV WORDS ANO DOCUMENT ANALYSIS
DESCRIPTORS
b.lOENTIPIERS/OPEN INOIO TiRMS C. COSATI Fwld/Croup
Record of Decision
Diamond Alkali, NJ
First Remedial Action
Contaminated Media: gw, soil, air, debris
Key contaminants: DDT, dioxin
S. DISTRIBUTION STATf MINT
19. SICURITY CLASS iTIm Rtporti
None
21. NO. Or PACES
202
20. SSCURiTY CLASS i Tint pat*i
22
EPA ftrm 2nO.I (••». 4-77) •niviout IOITION i»o«§OUtTi
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INSTRUCTIONS
1. MIPOMTNUMSIM
Insert >nc LPA report number as it appears on th* eovtr of tht puMKatton.
Z LIAVIKANK
J. MICIPIINTS ACCESSION NUMMM
Reserved for us* by raft npon reuparai.
4. TITLI AND SUtTITVI ~
Till* iliouM indxait clearly and briefly the subject comae* of ine report. and be vli«ptiyviJ prominently. S»M uibmk. it im-U. m MfPOMTOATI
Each report shall carrya daw indtcatinf at least month and year. Indurate the IMM» un »h*li 11 »j« tkxtcU /•• g Jtir •./ tw.Jttr ••/
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7. AUTMOMIS)
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•. •fMMWMINO OHOAMIZATIOM NI9ONT NUMMM
toaan tf parfarmini orpmanon «nhn to asufn inn number.
t. MMPOMMMO ONOANIIATtOM NAMf AND AOONUS
Cat HUH, unat. city, xaw. and ZIP code. Lui no men than two taffte or an urawti/viNNul hveanhy.
101 PftOONAM ILIMIMT NUMMN
UH the propM element number under which tht report wa» prepared. Subor4uui« number uuy be
11. CONTIUCT/OIUNT NUMMN
Intart contract or pint number under which report waa prepared.
1& SMNCONIMO AOIfeCV MAMI AMD AOOMUi
Indude ZIP code.
Ill TVff OPMVONTANOMIIIOOeOVIMO
Indicaie intcrun float, etc.. and if applicable, date* covered.
14. VOmOHIMO AOMUCV COM
Insert appropnatt cede.
it. sueviiMeurrAMv Norn
Enter information not included tliewhera but uatfal. weft a»: Prepared in wuopentHm with. InnstiiHxt ..i. l*nr«iiKiJ ji
''• To be pubtuhed ». Supenede*. Suppatmaata. etc.
It. AaVTHACr
Include a bnef/700 Mordk of/m; factual «unmary of tht me*u Mtniikint iniurmiimHi vunuimrU in UK-tv|mri. II ii
upiiftem btbUofjaphy or Uierature Minrey. mention it hem.
17. KIV WONOt AMD OOCUMflNT AMALV4M
(a) DESCRIPTORS • Select from ihe Thnaunu of bmjmeenn»
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EPA/ROD/R02-87/053
Diamond Alkali, NJ
First Remedial Action
16. ABSTRACT (continued)
transportation of drums containing hazardous substances with less than 1 ppb of dioxin
for treatment or disposal; demolition of all remaining onsite structures; onsite
security of all materials contaminated above 1 ug/kg with dioxin; stabilization and
immobilization of the contents of the remaining drums with dioxin contaminated
materials; onsite placement and capping of sludge from wastewater treatment until an
alternative method is identified; stabilization of dioxin contaminated chemicals in
drums; identification of the location of underground contaminant conduits with
subsequent plugging and rerouting of active systems; hauling, emptying, spreading, and
compaction of the contaminated materials stored at 120 Lister Avenue with
decontamination and shipping of containers for offsite reuse, recycling, or disposal;
installation, operation, and maintenance of a ground water withdrawal system;
installation, operation, and maintenance of a treatment system for ground water and
other aqueous liquids; implementation of monitoring, contingency, O&M, and site security
plans; and performance of a feasibility study every two years following the
implementation of the remedy. The estimated capital cost for this remedial action is
£8,068,000 with annual O&M of £261,000.
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RECORD OF DECISION
Remedial Alternative Selection
RECORD OF DECISION DECLARATION
Site: Diamond Shamrock Superfund Site
Remedial Alternative Selection for the Properties
Located at 80 and 120 Lister Avenue, City of Newark,
Essex County, Mew Jersey
Documents Reviewed or Relied Upon
Z am basing my decision concerning the appropriate remedial
alternative for the Diamond Shamrock Superfund Site (also
known as the Diamond Alkali Superfund Site) primarily on the
following documents:
1. 80 Lister Avenue Site Evaluation Report* (3 Volumes),
February 1985;
2. 120 Lister Avenue Site Evaluation Report* (2 Volumes),
May 1985;
*
3. 80 and 120 Lister Avenue Site Evaluation Report Addendum*
(1 Volume), February 1986;
4. 80 Lister Avenue Quality Assurance Data Review (By NUS
Corporation under contract to the New Jersey Department
of Environmental Protection (NJDEP)j
5. 80 Lister Avenue Feasibility Study*, October 1985;
6. 80 Lister Avenue Feasibility Study - Response to NJDEP
Comments*, June 1986;
7. 80 Lister Avenue Feasibility Study - Response to EPA
Comments*, June 1986;
8. Proposed Interim Remedial Action Plan - Diamond Shamrock
Superfund Site, EPA - Region II, July 1987; "
9. Public comments;
10. Responsiveness Summary.
•
A substantial number of additional documents are also,included
as part of the administrative record, which serves as the basis
of this Record of Decision (ROD).
* Documents prepared by contractors for Diamond Shamrock
Chemicals Company.
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ii
My decision is also based on a number of additional documents
which are published and generally available. These documents
include the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980, 42 U.S.C. Sections 9601 et Beg., as
amended by the Superfund Amendments and ReauthorizatTon Act of
1986; the National Oil and Hazardous Substances Pollution
Contingency Plan, 40 C.F*R. Part 300, and other documents cited
elsewhere in this ROD.
Description of the Selected Remedial Alternative
The components of the selected remedial alternative are
described below:
1. Construct a slurry wall encircling the site tying into
the silt layer underlying the site.
2. Construct a flood wall and appurtenances to protect the
site from the 100 year flood. Such flood wall shall conform
to the specifications and guidances of the U.S. Army Corps
of Engineers and the NJDEP and shall include as a design
consideration the impact of the proposed Passaic River
flood control project.
3. Disassemble and decontaminate all non-porous permanent
structures and materials to the maximum extent practicable
for off-site reuse, recycling or disposal.
4. Transport all drums containing hazardous substances but containing
less than 1 ppb of TCDD off-site for treatment or disposal.
5. Demolish all remaining structures on-site and secure all
materials contaminated above 1 ppb of TCDD on-site. Secured
materials shall be segregated to the maximum extent practi-
cable to afford access to and facilitate removal of the more
highly contaminated materials, should such removal be selected
as a remedy at a later date.
6. Stabilize and immobilize the contents of the remaining drums
of dioxin contaminated materials.
7. Locate and plug inactive underground conduits and reroute
active systems.
8. Haul, empty, spread and compact the contaminated materials
presently stored at 120 Lister Avenue; decontaminate the
shipping containers for off-site reuse, recycling or disposal.
9. Install, operate, and maintain a ground water withdrawal
system designed to maintain a hydraulic gradient preventing
the migration of ground water from the volume contained
within the slurry wall.
10. Install, operate, and maintain a treatment system for ground
water and other aqueous liquids.
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ill
11. Construct a surficial cap consisting of suitable materials
designed to meet the requirements of the Resource Conserva-
tion and Recovery Act.
12. Implement suitable monitoring, contingency, operation and
maintenance, and site security plans to ensure the protec-
tion of human health and the environment during and after
the installation of the selected alternative.
13. On-site placement and capping of all sludge generated from
the wastewater treatment processes until such time that an
alternative method of sludge management is approved.
14. Design, construct and operate the remedy to attain the clean-
up standards listed in Tables III, V, VII of Section VIII •
of this Record of Decision.
15. Perform a Feasibility Study every 24 months following the
installation of the selected interim remedy to develop,
screen and assess remedial alternatives and to assess the
performance of the selected remedy.
Consistent with Section 121(c) of CERCLA, which requires the
periodic reevaluation of containment remedies, the proposed plan
calls for the reevaluation of the remedy every two years. In
view of the periodic reevaluation process, EPA and NJDEP consider
the selected remedial alternative to be an interim remedy.
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iv
Declaration
Consistent with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA) as amended
by the Superfund Amendments and Reauthorization Act of 1986
(SARA), and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 C.F.R. Part 300, I have determined
that the remedial alternative selected for the Diamond Shamrock
Superfund Site is cost-effective, and provides adequate protec-
tion of public health and welfare and the environment.
I have also determined that the action being taken is consistent
with Section 121 of SARA and is appropriate when balanced
against the availability of Trust Fund monies for use at other
sites.
The State of New Jersey, Department of Environmental Protection
has been consulted and concurs with the selected remedial
alternative.
fin
Date •-- Regional AdmiMstrat^i
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v CONFORMED COPY
RECORD OF DECISION CONTENTS
PAGE NUMBER
Record of Decision Declaration ^
Contents v
Record of Decision Snmm&ry i"*'
I. Background Chronology 1
XI. Scope of this Record of Decision 2
III. Site Location and Description 3
IV. Remedial Investigation Findings 13
V. Risks Presented by the Site 22
VI. The Criteria for Remedy Selection 24
VII. Description and Evaluation of Remedial 26
Alternatives
VIII. Cleanup Standards 48
IX. Description of the Selected Alternative 77
X. Enforcement g0
XI. Community Relations 30
XII. Glossary of Tens and Acronyms 81
Appendix A. Responsiveness Summary
Appendix B. Site Evaluation Analytical Results
Figures
1. Site Location Hap 4
2. Site Vicinity Map 5
3. Site Plat Plan . g
4. Site Configuration '7
5. Conceptual Site Plan - Alternatives 2 & 4 29
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vi
RECORD OF DECISION CONTENTS cont. PAGE NUMBER
6.. Conceptual Cross Section - Alternative 2 30
7. Conceptual Site Plan - Alternative 3 33
8. Conceptual Cross Section - Alternative 3 34
9. Conceptual Cross Section - Alternative 4 36
10. Conceptual Site Plan - Alternative 5 40
11. Conceptual Cross Section - Alternative 5 41
Tables
I. Remedial Alternatives 27
II.- Cost Summary of Alternatives 28
III. Federal ARARs, That Will Be Attained 49
By The Selected Alternative
IV. Other Federal ARARs 55
V. State ARARs. That Will Be 60
Attained By The Selected Alternative
VI. State ARARs That Will Hot Be Attained 72
By The Selected Alternative
VII. Other Cleanup Standards 74
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RECORD OF DECISION SUMMARY
Z. Background Chronology Leading to this Record of Decision
The following chronology summarizes events leading to this Record of
Decision:
^.
3/51 - The Diamond Alkali Company (subsequently known as the Diamond
Shamrock Chemicals Company) purchased an existing chemicals
manufacturing facility at 80 Lister Avenue* Newark, NJ. The
company operated the facility from 1951 to 1969 manufacturing
2,4,5-trlchlorophenol; 2,4.5-T; 2,4-D; and other chemicals
and pesticides. From 1969 until 1977 when manufacturing
activities were halted, the facility was operated by other
companies.
5/83 - As a result of EPA's National Dioxln Strategy, which targeted
facilities which produced 2,4,5-trichlorophenol and/or its
pesticide derivatives for sampling, the site was sampled for
dloxln (i.e., 2,3,7,8-tetrachlorodibenzo-p-dioxin) and dloxin
was found in the samples. Subsequently dloxln and other
hazardous substances were also found at other properties in
the area and in biota and sediment samples from the Passaic
River, which borders the site. To address the off-site
contamination, EPA, under the removal authority of CERCLA,
and the NJDEP initiated a number of clean-up activities which
included . the vacuuming .of contaminated streets and the
excavation of contaminated soil.
9/83 - The site was proposed for the Superfund National Priorities
List.
3/84 - The NJDEP Issued an Administrative Consent Order (AGO I)
which required Diamond Shamrock to perform a Site Evaluation
and Feasibility Study for 80 Lister Avenue as well as other
response actions for the 80 Lister Avenue property.
9/84 - The site was added to the National Priorities List.
12/84 - The NJDEP Issued a second Administrative Consent Order (ACO
XI) to Diamond Shamrock requiring Diamond Shamrock to
complete the aforementioned cleanup actions which had been
initiated by EPA, under CERCLA removal authority, and NJDEP
for the t>ff-site properties. This Order also required
Diamond Shamrock to perform a Site Evaluation for 120 Lister
Avenue and expanded the scope of the Feasibility Study to
include the hazardous substances stored at 120 Lister
Avenue. This Feasibility Study addresses the 120 and 80
Lister Avenue sites as a source control operable unit.
Additional areas of concern include off-site studies of the
Passaic River and bedrock aquifer. These will result in
additional operable units at some time in the future.
1/85 - EPA and Diamond Shamrock signed a voluntary cost
reimbursement agreement which resulted in the recovery of
nearly 2 million dollars which EPA had spent for the site.
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2/85 - Diamond Shamrock submitted a three volume Site
Evaluation Report for 80 Lister Avenue. (Using Superfund
terminology, this would be a Remedial Investigation Report).
The report quantified the extent of hazardous substance
contamination in soils, wastes, ground water, and structures
at the site.
5/85 • Diamond Shamrock submitted a two volume Site Evaluation
Report for 120 Lister Avenue, which is adjacent to the former
Diamond Alkali plant and is currently used to store the
dioxin wastes resulting from the off-site removal actions.
10/85 - NJDEP released a report entitled "A Study of Dioxin in
Aquatic Animals and Sediments" which presented data showing
dioxin contamination of fish and crustaceans collected in the
vicinity of the site.
12/85 - Diamond Shamrock submitted the Feasibility Study (FS) for 80
. 120 Lister Avenue.
2/86 - Diamond Shamrock Submitted an addendum to the Site
Evaluation Reports addressing NJDEP comments.
2/86 - A Public Meeting on FS was held on 2/86.
3/86 • Diamond Shamrock submitted a two volume report entitled
"Passaic River Sediment Study", which further defined the
extent . of the dioxin contamination of the Passaic River
sediments.
4/86 • NJDEP and EPA comments on the Feasibility Study were
transmitted to Diamond Shamrock.
6/86 - Diamond Shamrock responded to the NJDEP and EPA comments
on the Feasibility Study.
7/87 - The Proposed Interim Remedial Action Plan (PIRAP) explaining
the Remedial Alternative preferred by NJDEP and EPA was made
public.
8/87 - A Public Meeting on the PIRAP was held.
II. Scope of this Record of Decision
As indicated in the .background chronology provided above, the Site
Evaluations and Feasibility Study, which are a chief basis for this Record
of Decision, are for the properties at 80 and 120 Lister -Avenue. Other
properties that were contaminated by releases of hazardous substances from
the 60 Lister Avenue property are not addressed by the Feasibility Study or
by this Record of Decision. The cleanup of these other properties is being
addressed separately from this Record of Decision, as outlined in the
background chronology above (12/84) and will be addressed as subsequent
operable units.
In addition, the existing contamination of the Passaic River is being
addressed by a separate study. The cleanup of the River sediments is not
addressed in this Record of Decision. While the remedy selected by this
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Record of Decision will have a beneficial effect on the Passaic River,
ground water and other properties by abating releases from 80 and 120 Lister
Avenue, it is not intended to clean up the existing contamination of the
River or other properties. Other actions have been and will be taken by EPA
and NJDEP to address off-site problems resulting from hazardous substances
released from 80 Lister Avenue.
Thus, this Record of Decision has a limited scope and is not intended to
address all contamination related to the site. Section 300.68(c) of the NCP
specifically authorizes a response action to be conducted in discrete parts
(referred to as operable units), each having a limited scope.
III. Site Location and Description
The 80 Lister Avenue property is located in the Ironbound section of Newark,
New Jersey. The property occupies approximately 3.4 acres on the north side
of Lister Avenue. It is nearly rectangular in shape, extending about 375
feet in an east-west direction and 405 feet north-south. The property is
bounded on the north by the Passaic River, on the east by the former
Sergeant Chemical Company (120 Lister Avenue) site subsequently purchased by
Diamond Shamrock, at the southeast corner by the Duralac Company property,
and on the south and west by Sherwin-Williams Company property. Vehicular
access to the property is via a common right-of-way shared with Duralac
entering the southeast corner of the property. The property is formally
described as Lots 58 and 59 in Block 2438 on the Newark tax maps .
The location of the site within Newark and the Ironbound section is shown on
the accompanying maps (Figures 1 thru 3).
Geology
The site is situated in the Piedmont Lowland section of the Piedmont
Physiographic Province. This province is located between the Atlantic
Coastal Plain and the Valley and Ridge Province.
In New Jersey, the Piedmont Lowland section is underlain by igneous and
sedimentary rocks of Trlassie-Jurassic Age. The igneous rocks in the
section are generally more resistant and form hills and ridges while the
sedimentary rocks occur in the low areas. The section is characterized by
rounded ridges separated by wide valleys and isolated hills which rise
abruptly above the surrounding landscape. The general surface of the
section slopes from around Elevation 400 feet mean sea level (HSL) in the
northwest to .sea level at Newark Bay.
As an Industrial area that has been occupied for over 100 years, the entire
site has been built up with fill. Approximately 6 to 8 feet of cinders,
bricks, sand, and rubble have been placed over natural materials. In this
process, the site has been Intentionally leveled. Total relief across the
site is approximately 3 feet with the lowest point along the railroad tracks
at the southern boundary. Elevations vary between approximately 7 and 10
feet HSL. Much of the site has been covered with either pavement or gravel.
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ROAD CLASSIFICATION-
HEAVY DUTY
MEDIUM DUTY
LIGHT DUTY
FIGURE 1
SITE LOCATION MAP
80 LISTER AVENUE
MtPAMKO POM
STATE ROUTE
INTERSTATE
DIAMOND SHAMROCK
DALLAS tTEXAS
U.S. ROUTE
f 1964 ft CORPORATION
ALL COPYRIGHTS RESERV
... Creating a Sai«i Tomorrow
"Do Net Seal* Tfut Drawing'
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7.5 MINUTE US OS TOPOGRAPHIC OUADftANOLE
MAPS OF: ELIZABETH AND JERSEY CITY, N.J.-N.Y.
DATED: l»67, PHOTOREVISED' 1981, SCALE: I «tOOO.
« 19M IT CORPORATION """ i
ALL COPYRIGHTS RESERVED-
VICINITY MAP
•0 LISTER AVENUE
PREPARED FOR
DIAMOND SHAMROCK
DALLAS, TEXAS
... Creating a Safer Tomorrow
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- 6 -
i
0
*
M
<0
*
0
*
Is
60 L/sfer Avenue
SERGEANT
CHEMICAL CO
THOMASETTE
DIAMOND ALKALI/CO
120 LISTER AVE.
SHE R WIN
WILLIAMS CO
.TRIPLEX CO.
DURALAC
MONTROSE
ACCESS RIGHT OP WAY
LISTER AVE.
APPROXIMATE SCALE
too
400 FEET
REFERENCE:
DIAMOND ALKALI COMPANY
OWO. NO. 2NS-SS3-
TITLED'REAL ESTATE PROPERTY
FIGURE 3
^
PLAT PLAN FOR 60 LISTER AVE.
AND ADJACENT PROPERTIES
MIPAfttO
» 19M IT CORPORATION
ALL COPYRIGHTS RESERVED
DIAMOND SHAMROCK
DALLAS , TEXAS
.. Creating a Safer Tomorrow
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- 7 -
N
f
if
H
I
I
ft
UUU I
FIVE STORY-OFFICE/ ^
PROCESSING BUILDING O
TANK FARM
APPROXIMATE SCALE
=^==
60 120 FEET
LEGEND
60 LISTER AVENUE
PROPERTY BOUNDARY
* 1964 IT CORPORATION
ALL COPYRIGHTS RESERVED
FIGURE .4
60 LISTER AVENUE
FACILITY LAYOUT
PRIOR TO EXPLOSION
FEBRUARY, I960
MCMMD r'OM
DIAMOND SHAMROCK
DALLAS , TEXAS
... Creating a Safor Tomorrow
•Do Net Seal* Th* Drawing"
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Surface Water
The site is located in the Lower Valley portion of the Passaic River
drainage basin. The Lower Valley is the southeasterly portion of the basin
lying between the Central Basin and the mouth of Newark Bay. It is
characterized as a flat relatively narrow floodplain of 1,000 to 2,000 feet
in width, abutting low rolling hills. From Dundee Dam tq^the mouth of
Newark Bay, the river is a tidal estuary and is navigable. The site is
approximately three miles upstream from the mouth of Newark Bay.
The closest known surface water gaging station on the Passaic River is at
Little Falls, New Jersey, which is approximately twenty-six river miles
upstream from the site. The gaging station is also upstream from the Dundee
Dam, and therefore, river elevations at this station are much higher than
river elevations at the site, and thus are not representative of site
conditions. Tidal elevations for the Passaic River at Newark are reported
by the National Oceanic and Atmospheric Administration (NOAA, 1972). The
mean tidal range (difference in height between mean high water and mean
lower water) is reported by NOAA as 5.1 feet. The spring range (average
semidiurnal) range occurring semimonthly as a result of the moon being New
or Full is reported by NOAA as 6.1 feet with the mean tide level (midway
between mean low water and mean high water) at 2.5 feet.
The Passaic River basin lies in the tracks of most east coast storms and is
consequently subject to occasional rainfalls of great intensity. The types
of storms producing damaging floods on the Passaic Include late summer
storms originating over the ocean to the south (such as 1881, 1903, 1945);
fall or hurricane storms (such as 1810, 1919, 1938, and 1955); spring storms
originating over the continent to the west and southwest (such as 1819,
1843, 1865). Of these storms, the greatest flood of record was due to the
storm of 1903 which, in the reach from Dundee Dam to the Newark Bay,
inundated an area of 1,520 acres to a maximum depth of 14.5 feet. The most
recent severe floods occurred in 1936, 1945, 1955, and 1968.
Unlike upstream areas where flooding is controlled by rainfall events,
flooding of the Passaic River at the site is controlled mainly by tidal
influences. The greatest potential for Inundation in the Lower Valley comes
from the storm surge and tidal flooding associated with a major storm. The
cross-sectional area of the channel in the tidal zone of the river is so
great in relation to the discharge that any rise in water level as a result
of rainfall is minimal when compared to elevation changes due to tides.
According to the U.S. Army Corps of Engineers flood Insurance study for the
region, flood elevations for the 10-, 50-, 100-, and 500-year tides are 7.5,
9.3, 10.2, and 12.8 feet above MSL, respectively. Partial inundation of the
site from the Passaic River was reported in 1983.
Flooding occurs in the Lower Valley (and at the site) due to a relatively
narrow flood channel that is constricted by many bridges, heavy urban
development along the river banks, and generally flat slopes that are
constrained by rock outcrops. The natural storage in the Central Basin
reduces the contributing flood flows into the Lower Valley from the
flash-flood susceptible highland tributaries (the Ramapo, Vanaque,
Pequannock, Rockaway, and Vhippany Rivers).
Ground Water
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The source of ground water recharge at the site is precipitation that does
not run off the land surface to streams or return to the atmosphere through
evapotrinspiration. This precipitation infiltrates the ground and moves
through and is stored in geologic formations. The regional aquifers in the
vicinity of the site are .the bedrock of the Brunswick Formation of Triassic
age and the unconsolldated glaclo-fluvlal sands and gravel deposits of
Pleistocene age.
The principal source of ground water in the area is the rock of the
Brunswick Formation. The shales and sandstones are generally capable of
sustaining moderate to large yield wells, but the Orange Mountain Basalt is
capable of only small to moderate yields. The unconsolldated Pleistocene
•and and gravel deposits, although capable of sustaining large yields, are
of somewhat limited extent in the vicinity of the site.
Vater in the rock of the Brunswick Formation occurs under both unconfined
and confined conditions. In the upland areas, the aquifer is generally
unconfined. In the lowlands of the Hackensack Meadows, the aquifer is
generally confined or semiconfined by glacio-lacustrine clay. Where the
aquifer is confined by relatively impermeable layers, it is commonly under
artesian pressure. The area around Newark has been subjected to heavy
pumping, however, and the artesian pressure has been reduced. In part of
Newark, extensive pumping has actually dewatered parts of the aquifer such
N that it no longer behaves as a confined aquifer.
Ground water moves in the bedrock both vertically and horizontally from
cones of secondary porosity through systems of interconnected joints and
fractures. Most wells that are screened in this interval draw from more
than one water-bearing zone, but the boundaries of the zones have not been
accurately defined. Some wells penetrate from 400 to 600 feet below ground
surface to reach these zones. The best producing wells, however are 300 to
400 feet deep.
The glacio-fluvial sands and gravels constitute an aquifer of limited
extent. In the site area, these materials occur as valley fill deposits
occupying buried bedrock valleys. The sands and gravels are generally
interlayered with till and clays which reduce their total permeability.
However, where layers of coarse sand and gravel are encountered, wells
yielding 175 to 600 gallons per minute (gpm) have been developed.
Unfortunately, pumping from this aquifer has also been in excess 'of fresh
water recharge and, as a result, salt water intrusion has been known to
occur.
Ground water.yields from the Brunswick Formation range from 35 to 820 gpm
for the shales and sandstones and from 7 to 400 gpm for the Orange Mountain
Basalt. Specific capacities of the wells in the shales and sandstones
ranged from 0.2 to 70 gpm per foot of drawdown (averaging 11.1 gpm per foot
of drawdown). Specific capacities of wells in the basalt range from 0.05 to
5.66 gpm per foot of drawdown (averaging 1.74 gpm per foot of drawdown).
Although the water quality of the bedrock aquifer is generally considered to
be good, salt water intrusion in the vicinity of the site has occurred as a
result of the heavy pumping in this industrialized area. In 1879, analysis
of a ground water sample from this vicinity showed 6.2 ppm chloride. In
1948, a ground water sample showed 1900 ppm chloride.
The heavy pumping has greatly lowered water levels in the area over the last
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100 years. In eastern Newark adjacent to Newark Bay and the Passaic River,
the water levels by the year 1900 had been pumped from 40 to 130 feet below
ground surface. Continued pumping in the 1900*s has lowered the water level
even further. In 1679, evaluation of wells in the vicinity •bowed ground
water levels from a few feet above to 25 feet below the ground surface. The
heavy pumping has reversed the natural gradients in this vicinity and the
dredging of the shipping channels in Newark Bay and the Passaic River has
exacerbated the salt water intrusion problem by removing part<«f the barrier
between the ground and surface waters.
Site History
Industrial development on the site is reported to date from the 1870's.
Drawings from 1914, revised in 1922, show the site to be part of the Lister
Agricultural Chemical Company property which extended for some distance
•long the Passaic River. This plant site also included most of the other
nearby industrial sites.
It was during the period of ownership by Lister that the site reached its
present dimensions following filling along the south shore of the Passaic
River to form the northernmost 30 percent of the property. Much of the
remainder of the site is also filled with the granular material reportedly
used to fill the marsh land that existed in the natural state. Several
buildings were on the site including the Lister power plant, which remains
today as the chemical manufacturing building.
When Lister Agricultural Chemical Company ceased operations the property was
subdivided largely along the lines that form the present property boundaries
and was sold. A 1.8-acre parcel (the northeast portion of the present site)
was eventually acquired by the Kolker Chemical Works, Inc., which, by the
•id-1940's, was operating an agricultural chemicals plant on the site. This
was the beginning of the manufacturing operations that are related to the
-cuwent conditions at the site.
_Kolker_was an_early producer of both dichlorodlphenyl trichloroethane (DDT)
and the phenoxy herbicides. The exact dates when manufacture started is not
known, but It is believed that DDT production was underway before the end of
World War II and that herbicide production started by 1948. In addition to
DDT and the phenoxy herbicides, other products of interest produced on the
•ite included hexachlorobenzene (HCB), ovex (a miticlde), Lindane and low
gamma-benzene hexachloride (low gamma-BHC). Several derivatives of benzene
•ulfonyl chloride and sulfonates were also made, but these were all low
volume products. In all cases, manufacture started with readily available
raw materials and the principal intermediates were made on the site.
• _ •
The principal products made on the site by Kolker were DDT and the phenoxy
herbicides. Ownership by Kolker ceased in .March 1951 when the Kolker
Chemical Works was acquired by Diamond Alkali Company (Diamond Shamrock
Chemicals Company).
During this period the manufacture of several products was either
transferred to other locations or discontinued, leaving the phenoxy
herbicides as the only products of the plant. A major impetus for this
change was an explosion in February 1960 which destroyed several plant
processes. When rebuilt the plant only included processes for the
manufacture of the phenoxy herbicides and their intermediates.
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Modernization and expansion continued during the I960*a, more than doubling
total phenoxy capacity, to 15 Billion pounds per year.
The changes started in 1955 with the transfer of Lindane manufacture to
another location. Production of low gamma-BBC continued until 1957 or 1958
when it also was relocated. The biggest change, however, was the transfer
of DDT production, which was moved to Texas in late 1958 or early 1959.
During the late 1950's several process changes were instituted to improve
the operating efficiency of the plant. Among these was a change instituted
around 1956 to the trichlorophenol (TCP) process effluent with the
installation of an Industrial sewer connecting to the Passaic Valley
Sewerage Commission (PVSC) Lister Avenue line. Following installation of
that connection, most of the plant process wastes were discharged through
the PVSC treatment plant.
An explosion in the TCP unit during February 1960 destroyed the large
five-story building in which it and several other plant processes had been
located. Following the explosion, a decision was made to limit future
production to the phenoxy herbicides, ending output of HCB, ovex and the
benzene sulfonyl chloride derivatives.
A larger site was required for rebuilding the plant on the scale desired, so
an adjacent 1.6-acre parcel (consisting of the southwest portion of the
present site) was leased from the Triplex Oil and Refining Company (later
Walter Ray Holding Company). This site, which had been used for reclaiming
oil, contained several buildings and large tanks which were razed to permit
installation of a new laboratory and office building, a maintenance
•hop/warehouse building, and a tank farm for flammable raw materials along
the west side of the property.
Following demolition of the remains of the damaged building, a new process
building devoted to the manufacture of sodium trichlorophenol (NaTCP),
2,4-dichlorophenol (2,4-DCP), monochloroacetic acid (HCA), and by-product
hydrochloric acid (RC1) was erected along the river near what had been the
north end of the old building. Following this construction, the manufacture
of the intermediates was carried out in the new buildings, leaving the old
but undamaged chemical manufacturing building for the production of
2,4-dichlorophenoxyacetic acid (2,4-D), 2,4,5,-trichlorophenoxyacetic acid
(2,4,5-T), and their esters and amines.
The process building remains largely unchanged to this day. The only
addition was equipment installed in 1967 to purify the NaTCP by removing
dioxin. The period 1963 to 1967 saw several major projects in the 2,4-D and
2,4,5-T manufacturing areas which were designed to improve working
conditions, improve product quality, and expand capacity. Host significant
among these changes were:
t
° 1963 - The 2,4-D acid process was rehabilitated. The roof was
raised permitting installation of new ventilating ducts to carry
process fumes to a new caustic scrubber.
0 1965 - The melt, washing, and drying process for the production of
dry, flaked 2,4-D was installed, with a 40 percent increase in
capacity. These changes also reduced personnel contact with the
2,4-D.
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- 12 -
0 1967 - The final plant expansion saw the construction of a new and
larger 2,4-D unit and the conversion of the former 2,4-D unit to the
•anufacture of 2,4,5-T. The TCP purification process for dioxin
removal via carbon filtration was added as part of this same
expansion.
Operation at the plant continued until August 1969 when it vas shut down.
The production units were cleaned out as they were shut down,, and between
September and December the remaining raw materials and products were sold
and shipped. The plant was listed for sale and remained idle throughout
1970 until It was purchased by Chemicaland Corporation in March 1971. It is
noted that Chemicaland actually purchased the 1.8 acres and improvements
owned by Diamond Shamrock, which then assigned rights to the 1.6 acres it
had leased from Valter Ray Holding Company to Chemicaland.
Following purchase of the property by Chemicaland, equipment was installed
for the manufacture of benzyl alcohol which was to be made and sold by
Cloray NJ Corporation, an affiliate of Chemicaland. Production of benzyl
alcohol was not profitable, so an attempt was made to expand their product
line by manufacturing on a toll basis. These efforts were all unsuccessful
and production ceased during the summer of 1973.
In September 1973, Chemicaland contracted with Diamond Shamrock to produce
2,4-D on a toll basis and started rehabilitating the plant so that it could
again make 2,4-D. Rehabilitation of the plant was completed sometime during
the spring of 1974 and production of 2,4-D resumed. Limited quantities of
2,4-D were produced during the summer of 1974, but none was delivered to
Diamond Shamrock under the contract. Operations were suspended and the
plant staff was laid off in September 1974.
Arrangements were then made by Chemicaland to produce 2,4-D on a toll basis
for a second time and work resumed in February 1975. Limited quantities of
2,4-D were being produced by April 1975. Production of 2,4-D continued for
the next 22 months, but output varied widely. Chemicaland scavenged
equipment from unused processes such as TCP purification and 2,4,5-T for use
in their 2,4-D unit and made temporary repairs to bypass failed equipment.
The only major addition to the process known to have been made by
Chemicaland was the installation of a second 2,4-D reactor during May 1976.
However, this addition was soon negated by the failure of the original
reactor. The maximum monthly output of 2,4-D by Chemicaland was reported to.
be about 500,000 pounds.
In November 1976, while they were considering acquisition of Chemicaland,
Occidental Chemical Company assumed control of the management of the plant
and continued to manage the plant until February 24, 1977, when they
returned control of the plant to Chemicaland. Because Chemicaland did not
have the resources to continue operating without the support, of Occidental,
they laid off all plant personnel and shut down the plant on February 24,
1977.
The property remained idle through 1980, but the ownership changed as
William Leckie (the successor to Walter Ray Holding Company) purchased the
1.8 acres owned by Chemicaland in a tax sale, consolidating ownership in his
name. In March 1981 Leckie sold the site to Marisol, Inc.
Little is known of the use of the property by Marisol, but eventually this
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company started cleaning and clearing the site. Concerning the cleanup, it
is known that:
0 The product left in the equipment when the plant was shut down on
February 24, 1977, was removed and placed in drums, of which 570
remain on site today.
0 Some equipment known to be on the site following the shutdown was
removed.
* Warehouse space and tankage was leased to 8CA Corporation which used
it in conjunction with waste disposal operations at their
neighboring plant. The date that SCA started to use the site is not
exactly known, but was prior to the summer of 1982.
During the spring of 1983, SCA continued to lease and use a portion of the
site, while Harisol was working to prepare the office building' for
occupancy. This was the situation in Hay 1983 when results of samples taken
in April by the USEPA showed high levels of dioxin on the site and NJDEP
moved to control access to the property.
Present Status
Upon the discovery of the presence of high concentrations of TCDD in Hay of
1983, the site was evacuated and secured. All exposed soils were covered
with geofabric to prevent potential migration of contamination by surface
runoff and wind blown participates. In addition, the site is guarded 24
hours per day. These provisions have been maintained and are currently in
place.
IV. Remedial Investigation Findings
A. 80 Lister Avenue
A comprehensive field investigation and sampling program was developed for
the remedial investigation. All activities conducted on the site were
completed in accordance with a site specific workplan and health and safety
plan, reviewed and approved by NJDEP. All activities were also completed
under direct supervision and direction of NJDEP.
A variety of sampling activities was performed to characterize the levels of
chemical contamination at the site. These included:
0 Ambient air samples
• .
0 Industrial hygiene samples
0 Chip, wipe, and bulk samples from existing buildings, tanks, piping,
equipment, and sewers
0 Samples of soil
0 Samples of ground water
0 Samples of Passaic River water and sediments
0 Samples of background soil
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0 Samples of on-site drums
A more detailed discussion of the remedial investigation results follows.
Ambient Air Sampling and Results
Ten sets of ambient air samples were subjected to detailed chemical
analysis. As requested by the NJDEP, those sets of samples having the ten
highest iron and manganese concentrations were analyzed.
The total suspended particulate matter (TSP) concentrations ranged from 85
to 254 micrograms per cubic meter (ug/m*) with five days recording
concentrations in excess of 150 ug/m1. The inhalable particulate matter
(IPH) concentrations ranged from 56 to 196 ug/m*; the maximum value occurred
on the.same day as the maximum TSP concentration. The concentration of all
metals except iron were less than 1 ug/m* on all days. The iron
concentrations ranged from 0.682 to 1.259 ug/m*, with the maximum occurring
on the day of maximum TSP and IPH concentrations.
On only two of the days chosen for analysis was any concentration of dioxin
recorded. The observed concentrations were 86 picograms per cubic meter
(pg/n*) and 286 pg/m*. Vinyl chloride was found on only five of the ten
days chosen for analysis. The observed vinyl chloride concentrations ranged
from 0.15 to 0.33 ug/m*. Nine samples were analyzed for volatile organic
compounds (VOC). Total VOC concentrations ranged from 71 to 182 ug/m*.
The asbestos fiber counts were all less than 0.01 fibers per cubic
centimeter. The concentrations of pesticides and polynuclear aromatics
(PNA) for the samples analyzed are provided in the attached Appendix. The
observed pesticide and PNA concentrations were all less than their
permissible exposure levels.
All air volumes utilized in calculation of concentrations reflect
calibration correction. Analytical results were used as prepared by the
laboratory with adjustments for recoveries, breakthrough, or blanks.
Building and Structures Sampling and Results
*
Wipe, chip, and bulk samples were collected to evaluate the buildings and
structures for potential contamination. Wipe samples were collected from
coated floors, walls, fixtures, and air ducts. Chip samples were collected
whenever possible from exposed concrete floors and building exterior or
brick surfaces. All wipe and chip samples were analyzed for dioxin only.
Bulk samples were taken to determine the possible presence of asbestos in
insulation and other building materials. Selected bulk samples were also
analyzed for dioxin. , '•
a. Office and Laboratory Building
Of the 40 samples collected in this building, dioxin was detected in 32 and
one sample was voided. Dioxin concentrations of the first floor wipe
samples ranged from 38 to 1,100 ng/m*. Dioxin concentrations of first floor
chip samples ranged from 2.0 to 69.3 ppb. Fifteen of 15 first floor samples
were Identified as containing dioxin. Dioxin concentrations of the wipe
samples taken on the second floor ranged from 10 to 14,000 ng/m1 with 11 of
the 11 valid samples having dioxin identified. The dioxin concentrations of
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chip samples from the exterior of the building ranged from 0.57 to 2.4 ppb
with 5 of 11 samples having dioxin identified. One exterior wipe sample had
a dioxin concentration of 168 ng/m1; the other showed no dioxin present.
b. Warehouse
Of the 24 samples collected, 21 samples showed detectable levels of dioxin.
The dioxin concentrations of interior wipe and chip samples ranged from 130
to 19,000 ng/m* and from 48.7 to 192 ppb, respectively. All 11 interior
samples had positive dioxin results. The dioxin concentrations of exterior
chip samples ranged from 1.0 to 16.5 ppb with 9 of 12 samples having
positive results. The single exterior wipe sample showed dioxin present at
13
c. Manufacture "ft Buildf"ff
Positive dioxin results were obtained for 27 of the 28 samples collected.
The dioxin concentrations of Interior chip samples ranged from 1.0 to 1,280
ppb; 14 of 14 samples collected showed positive results. The concentration
range for interior wipe samples was 233 to 7,000 ng/m*, with all four
samples having dioxin identified. The dioxin concentrations of exterior
chip samples ranged from 0.93 to 203 ppb, with 9 of 9 samples having
positive results. Dioxin was not detected in the exterior wipe sample.
d. Process Bui Id f "ft
All 29 samples collected had identifiable dioxin concentrations. The dioxin
levels detected for the 12 interior wipe samples ranged from 60 to 41,600
ng/m*. The dioxin concentrations of the three interior chip samples ranged
from 43.2 to 696 ppb. Dioxin concentrations for the seven exterior chip
samples ranged from 2.7 to 1,580 ppb. The two exterior wipe samples showed
dioxin levels of 6.4 and 12 ng/m*. The bulk samples collected ranged from
3.0 to 128 ppb with-five of five samples- having potitlve-dimMn fMnlt.li. -
e. Other Structures (Stack. Solvent Shed, pump house)
All six chip samples collected had detectable levels of dioxin ranging from
1.2 to 50.0 ppb. Dioxin was detected at 0.17 ppb in the bulk sample
collected.
f. Tanks
Tank samples were taken from chemical process vessels and outside storage
tanks. A total of 140 tank samples were collected with 12 being designated
for dioxin analysis. Nine samples (75 percent) had positive dioxin results,
with concentrations ranging from 5.0 to 60,800 ppb.
g. Sewers and S"mps S'^pling and Results
Four sewer and eight sump samples were collected for dioxin analysis. Of
the 12 samples taken all showed positive dioxin results, with concentrations
ranging from 105-9,160 ppb.
Near Surface Soils
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Twenty-one geotechnical borings were drilled on or near the Bite.
Split -spoon and Shelby tube samples from the borings were logged according
to both the USGS and Burmister classification system. Fill ranging in
thickness from 8 to 15 feet is present at the surface. The fill is
underlain by an organic .silt which is in turn underlain by glaclo-f luvlal
sands. On the southern portion of the site, the silt consists of an upper
organic layer and a lower layer with lenses of clay and sand.
«^.
Near-surface soil samples were obtained to a depth of 60 inches. Samples
from depth intervals of zero to 6 inches, 6 to 12 inches, and 12 to 24
inches were collected for the chemical analyses designated in the Work
Plan. Below a depth of 24 inches, near-surface locations were continuously
sampled at 12-inch intervals to a depth of 60 inches. Of the 63
near-surface soil samples analyzed for dioxin, all had Identifiable dioxin
concentrations ranging from 0.39 to 19,500 ppb. Forty-two near-surface soil
samples were analyzed for priority pollutants. Of the 69 semi-volatile
compounds, 28 were identified one or store times in the depth intervals of
zero to 6 and 12 to 24 inches. At zero to 6 inches, 24 compounds were
identified. For 12 to 24 inches, 26 compounds were identified excluding
•ethylene chloride and acetone. Toluene was detected at highest
concentrations (2,000,000 ppb) followed by xylenes (310,000 ppb) and
chlorobenzene (84,000 ppb). Of the 38 volatile organic compounds, 13 were
identified one or more times. Of the 35 herbicide, pesticide, and PCB
compounds, seven were identified one or more times. DDT was detected most
frequently and in highest concentration (620-5,090,000 ppb), followed by ODD
(1,200-164,000 ppb), and 2,4, 5-T (490-86,000 ppb). Of the 13 metals, 12
were identified one or more times. Thallium was not identified in the
near-surface samples.
Soil 8<|t"ples
Boring soil samples were also collected at thirteen locations on site. Five
were •obtained for designated analyses at each of seven locations.
_D£_the_3i boring soil samples analyzed for dioxin, at depths of zero to 6
inches, the.dioxin concentrations ranged from 19.7 ppb to 2,700 ppb. At 6
to 12 inches, the dioxin concentrations ranged from 7.5 ppb to 3510 ppb, and
at 12 to 24 inches, the dioxin concentration ranged from 4.7 ppb to 830
ppb. Samples from directly above the silt had dioxin concentrations ranging
from 0.36 ppb to 71.8 ppb. Samples from the silt zone had dioxin
concentrations ranging from 0.49 ppb to 2.8 ppb with three of seven samples
not having detectable concentrations of dioxin. Twenty-four boring soil
samples above the silt were analyzed for priority pollutants, but samples in
the silt layer were not.
•
Of the 69 semi-volatile compounds, 27 were identified one or more times in
the samples from zero to 6 inches, 12 to 24 inches, or above' the silt. At
zero to 6 inches, 20 compounds were identified; at 12 to 24 inches, 27
compounds were Identified. In the soil samples taken from above the silt,
17 compounds were observed. Compounds detected most frequently and at
highest concentration were 2,4-D (1,400,000 ppb), 2,4,5-T (270,000 ppb), and
hexachlorobenzene (84,000 ppb). Of the 38 volatile organic compounds, 10
were identified one or more times in the samples from zero to 6 inches, 12
to 24 inches and above the silt. At zero to 6 inches, three compounds were
Identified; at 12 to 24 inches, eight compounds were identified. For
samples from above silt, seven compounds were identified.
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Excluding methylene chloride and acetone, only toluene (7-2,400 ppb) and
chlorobenzene (49-20,000 ppb) were detected in more than 50% of the samples
analyzed.
Of the 35 herbicides, pesticides, and PCB compounds, 10 were identified one
or more times in the samples from zero to 6 inches, 12 toJ24 inches and
above the silt. At zero to 6 inches, nine compounds were identified; at 12
to 24 inches, nine compounds were identified; and in the samples from above
the silt, eight compounds were identified.
Ground Water 8<>mpliiut *"d Results
The results of the ground water investigation at the site are presented in
the following discussion.
Ground water flow rates were calculated based on the calculated hydraulic
conductivities and the gradients (change in head per unit distance)
determined. An effective porosity of 0.30 was used for the fill. From the
center of the site northward to the river, the computed ground water flow
rate ranged from 0.6 to 4.0 feet per day. From the center of the site to
the south, the range was 0.5 to 1.3 feet per day.
Two sets of ground water samples were collected from each of the eight
original on-site monitoring wells. Based on these preliminary dioxln
results, the ground water from monitoring well MW-2A was sampled a third
time.
The first two rounds of ground water samples from all eight wells were
analyzed for full priority pollutants plus 40 and dioxln. The third ground
water sample from HW-2A was analyzed only for dioxln.
Of the 17 ground water samples analyzed for dioxln, 15 had dioxln
concentrations up to 10.4 ppb. For the three ground water samples collected
from MW-2A, reanalysis of 5 to 1 dilutions was required to provide results
in the Instrument linear calibration range. Sixteen ground water samples
were analyzed for full priority pollutants. Of the 69 semi-volatile
compounds, 19 were Identified in the initial round of samples, 24 compounds
were identified in the second round of samples. Compounds detected most
frequently and at highest concentration were 2,4-D (58,000 ppb), 2,4,5,-T
(26,000 ppb), and 2,4,6-TCP (11,000 ppb). Of the 38 volatile organic
compounds, 18 were identified one or more times in each of the two rounds of
sampling. Compounds detected most frequently and at highest concentration
were chlorobenzene (23,000 ppb), benzene (7,900 ppb), and toluene (3,300
ppb).
Of the 35 possible herbicides, pesticides and PCB compounds, eight were
identified one or more times in the first round samples and six compounds
were identified in the second round samples. Compounds detected most
frequently and at highest concentration were 2,4-D (27,000 ppb), DDT (22,000
ppb), and 2,4,5-T (5,600 ppb). Of the 13 metals, 11 were identified one or
more times in the first round samples and 12 metals were identified in the
second round samples.
Passalc River Water and Sediment Sampling and Results
Two Passalc River water samples were collected concurrent with the ground
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- 18 -
water sampling for the eight on-site wells. Both samples were analyzed for
dioxin and full priority pollutants. Both samples had non detectable (ND)
results for dioxin at 0.004 ppb and 0.007 ppb detection limits respectively.
Of the 38 volatile organic compounds, six were detected in the first sample
and five were detected in the second. Only two of the 69 semi-volatile
compounds were detected in the first sample and one semivolatile compound in
the second sample. Only two of the 35 total herbicide/pesticJ.de/PCB's were
detected in the first water sample, none were detected in the second. Of a
possible 13 metals, four were detected in both Passaic River water samples.
Sediment samples were taken at twenty-three locations in the Passaic River
in the vicinity of the site. In total, 36 samples were collected for
dioxin—23 samples at depths of zero to 12 inches and 13 samples at depths
of 12 to 24 inches. Fifteen priority pollutant samples were taken, 10
samples at depths of zero to 12 inches and five samples at depths of 12 to
24 Inches.
Of the 36 Passaic River sediment samples analyzed for dioxin, 26 samples had
identifiable dioxin concentrations. At zero to 12 inches, the dioxin
concentrations ranged from 0.53 to 10.8 ppb with six samples having non
detectable dioxin concentrations at a detection limit of 0.78 ppb. At 12 to
24 inches, the dioxin concentrations ranged from 0.63 to 130 ppb with four
samples having non detectable dioxin concentrations at the 0.78 ppb
detection limit.
Of the 69 semi-volatile compounds, 17 were identified one or more times in
the zero to 12 inch or 12 to 24 inch samples. Fourteen compounds were
.identified at zero to 12 inches. Seventeen compounds were identified at 12
to 24 inches.
Of the. 38'volatile organic compounds, 10 were identified in one or more
samples at the zero to 12 inch or 12 to 24 inch depths. Eight compounds
were identified at depths of zero to 6 inches. Ten compounds were
identified at depths of 12 to 24 inches.
Of the 35 herbicide, pesticide, and PCB compounds, 11 were Identified one or
more times in the zero to 12 inch or 12 to 24 inch samples. Ten compounds
were identified at depths of zero to 12 inches. Eight compounds were
identified at 12 to 24 inches. Of the 13 metals, 11 were identified one or
•ore times in the zero to 12 inch or 12 to 24 inch samples.
Background Sf'ples and Results
Samples were taken and analyzed for priority pollutant and dioxin analysis
at four locations off the site. Three samples were taken at Harrison
Avenue, Raymond Boulevard, and Roanoke Avenue in Newark,, New Jersey.
Samples from Boring B-14 on the adjoining Sherwin-Williams property used for
the installation of a monitoring well were also used to establish background
levels of dioxin and priority pollutants.
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Sherwin-Williams
Five samples were taken from the Sherwin-Williams property for analysis.
Samples collected at depths from zero to 6 inches, 6 to 12 inches, 12 to 24
inches, immediately above the silt rone, and in the silt cone were analyzed
for dioxin. Samples from depths of zero to 6 inches, 12 to 24 inches, and
immediately above the silt were analyzed for dioxin and priority
pollutants. Three of the five samples taken had detectable-concentrations
of dioxin. Of the 69 acid/base/neutral compounds, 20 were reported one or
•ore times in the three samples analyzed. Of the 98 volatile organic
compounds, three were reported one or more times; of the 35 herbicide,
pesticide, and PCB compounds, two were reported one or more times; and of
the 13 metals, 11 were reported all three times.
Newark
Samples collected at Harrison Avenue, Raymond Boulevard, and Roanoke Avenue
were taken to establish a background for the area. These areas were
considered to be representative of conditions prevalent within the city of
Newark. Three samples were collected at depths of zero to 6 inches and
analyzed for priority pollutants and dioxin.
Of the 69 semi-volatile compounds, 16 were identified in the Newark
background samples one or more times. Compounds detected most frequently
and at highest concentration were hexachlorobenzene (620,000 ppb), chrysene
(3,700 ppb) and fluorene (2,800 ppb). Of the 35 herbicide, pesticide, and
PCB compounds, three were detected one or more times with PCB being
detected. Of the 11 metals, 11 were identified one or more times. Positive
total cyanide and phenol results were reported for four of the six samples
analyzed.
On-Site Drums Sampling and Results (Waste Categorization)
Subsequent to sampling and initial field testing of each drum,
individual samples were composited for further waste categorization
testing. Composites were limited to six drums per composite grouping
and were based on such similarities as pH, drum content, and physical
appearance. The major purpose of compositing drum samples was to
survey the drums for dioxin contamination and to categorize their
preliminary waste and hazard characteristics.
Composite drum samples and certain individual drums were tested for
gross physical properties or waste categorization parameters.
Ten parameters were.examined in the drum sampling program. They were:
Water reactivity - solubility
Water reactivity - temperature change
Percent lower explosive limit (LEL)
PH
Presence of oxidizable materials (OX)
Presence of peroxides (peroxide)
Sample type
Open cup ignitability
Open cup flashpoint
Presence of halogens (halogens).
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The results of this sampling event will be used to determine disposal
alternatives and methodology. All drums are currently secured on site and
monitored.
* Dioxin Analysis
Dioxin analysis was performed on 22 selected drum samples^ Drums to be
tested were selected by one of two criteria— either the drum was
representative of a major group of drums or it had some particular.
association with the manufacturing process. Of the 22 drums analyzed,
15 showed positive results, ranging from a low of 1.5 ppb to a high of
12,200 ppb. Seven of the 22 samples had no detectable quantity of
dioxin present. If the result for a particular drum was positive for
dioxin, all the drums in its associated composite were also considered
contaminated. ,
A summary of the results of the remedial investigation is presented in
tabular form as an Appendix.
B. 120 Lister Avenue
Similar to 80 Lister Avenue, a comprehensive field investigation and
sampling program was developed for the remedial investigation of the 120
Lister Avenue property. All activities conducted at the site were completed
in accordance with a site specific work plan and health and safety plan,
reviewed and approved by NJDEP. All activities were also completed under
direct supervision and direction of NJDEP.
A variety of sampling activities was performed to characterize the levels of
chemicals contamination at the .site. These included:
* Ambient air samples
0 Industrial hygiene samples
0 Chip, wipe, and bulk samples from existing buildings, tanks,
trailers and equipment
0 Soil samples
0 Ground water samples
0 Surface water samples
0 Drum samples
A more detailed discussion of the remedial investigation result follows.
Air Sampling and Results
Eighty-six ambient air samples were collected on the 120 Lister Avenue
site. Of the 86 samples, 18 (21 percent) were analyzed for dioxin only. Of
the 18, 5 were not reported due to laboratory complications. Of the 13
reported ambient air results, 12 had non-detected dioxin concentrations.
One sample had an identified dioxin concentration of 33.5 pg/m , however,
due to matrix inter ference(s), analysis did not meet all of the
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- 21 -
Identification criteria for dioxin, and therefore the identification was
considered tentative.
Building and Structures
Chip and wipe samples were collected from the buildings and structures at
the 120 Lister Avenue site to evaluate potential contamination. Chip
samples were collected from the interior walls, exterior walls, floor, and
roof of each of the three buildings. Vipe samples were collected from the
tanks, trailers, equipment, and assorted hardware and supplies.
a. Buildings
Of the 18 chip samples collected from the three buildings on the 120 Lister
Avenue site, positive dioxin results were obtained for half (9) of these
samples, however, none of the results exceeded the action level of 7.0 'ppb.
Dioxin concentration In the 9 chip samples ranged from 0.13 ppb to 6.3 ppm.
b. Tank. Trailers, and Equipment
Sixteen wipe samples were collected from the tanks, trailers, and equipment
located at the 120 Lister Avenue site. Two of the 16 samples were positive
for dioxin with concentrations of 7.9 ng/m and 11.0 ng/m .
A total of 23 geotechnical borings were drilled at the site. Split spoon
and Shelby tube samples from the borings were logged according to both the
US6S and 'Burmeister Classification Systems, similar to the Investigation
completed for 80 Lister Avenue .
Of the 72 samples__analyzed for TCDD to a 'depth of 60 inches, 54 had
identifiable 'concentrations ranging~from u.is to 490 "ppbT Of the 15 lamp IBB
analyzed for TCDD from 60 to 132 Inches, 10 had identifiable concentrations
of TCDD ranging from 0.23-to $3.7 ppb. —
A total of 42 soil samples from the 120 Lister Avenue site were analyzed for
full priority pollutant parameters and dioxin. Samples were collected and
analyzed for depths ranging from 0 to 11 feet.
Of the 69 semi-volatile compounds, 13 were identified one or more times.
Bis(2-ethylhexyl) phathalate was detected most often and at highest
concentration (up to 90,000 ppb), followed by pyrene (up to 39,000 ppb). Of
the 38 volatile organic compounds, 3 were identified one or more times.
Me thy 1 en e chloride (up to 750 ppb) and chlorobenzene and benzene (up to 120
ppb) were the volatile organics identified. Of the 35 herbicide, pesticide,
and PCB compounds, five were identified one or more times', with 4,4-DDT
being detected at the highest concentration (up to 480,000 ppb) followed by
alpha-BHC (up to 50,000 ppb).
Ground Water Sampling and Results
Based upon the ground water level measurements and slug tests performed in
the six monitor wells on 120. Lister Avenue, estimates of the ground water
flow directions and associated rates were calculated. Estimates of the
vertical flow of ground water from the fill material through the silt to the
glacio-fluvial sand deposit were also determined.
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- 22 -
Ground water flow velocities in the surficial fill at 120 Lister Avenue were
computed from the gradients (piezooetric head divided by distance) and the
hydraulic conductivities. Computed horizontal ground water velocities
ranging from 2.2 to 3.1 feet per day from the center of the site north
towards the river and from 0.3 to 0.6 feet per day form the center of the
site to the southern boundary.
The vertical hydraulic gradient and an estimate of the vertical hydraulic
conductivity of the silt layer were used to calculate the ground water
velocities from the fill through the silt into the underlying sand unit.
Assuming an average, silt layer thickness of 8.5 feet, the average computed
velocity is 1.6x10 feet per day.
Hydraulic conductivity testing in the glacio-fluvial sand indicated an
average value of 2.32 feet per day in the upper sand unit and 0.23 feet per
day in the lower sand unit.
Five ground water samples were collected from the 120 Lister Avenue site and
analyzed for full priority pollutants and dioxin.
Dioxin was not detected in any of the five ground water samples taken from
the 120 Lister Avenue site. A total of 23 organic compounds were detected
at least once. Of these 23, benzene, chlorobenzene, and 4,4-DDT were
detected with the highest frequency. Concentrations of the detected
organics ranged from 0.3 ppb for B-BHC to 790 ppb for 2,4,-Dlchlorophenol.
Of the 14 inorganic compounds analyzed for, 14 were identified ranging in
concentration from 0.01 ppb for total phenol to 36 ppb for Zinc.
Surface Vater S^T*! ^**B *m\ Results
Prior to disposal of water used on site during the investigation, sampling
-van—conducted to determine if dioxin was present. In addition, several
other parameters, including COD, BOD, TOG, and IDS were analyzed.
Of the two samples analyzed, one had a detectable concentration of 0.013 ppb
TCDD. The other sample was non-detect at a detection limit of 0.0019 ppb.
and Results
Eighteen drums samples were analyzed for hazardous waste characterization,
EP toxicity and PCBs. Samples were also taken for TCDD analysis and have
been placed in archieve for possible future analysis.
V. Risks Presented by the Site
As previously reported in earlier sections of this , ROD, the 'results of the
remedial investigation indicate that the site is contaminated by a large
number of hazardous substances. Chemicals presenting especially great risks
because of their toxicities and concentrations are TCDD and DDT. The
contamination at the site is widespread, affecting most media including
soils, structures, ground water and air. Routes for exposure to these
hazardous substances are discussed below.
Direct On-Site Contact
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- 23 -
The following measures have been taken to lessen the risk of direct on-site
exposure of humans to hazardous substancesr
0 Access to the site is controlled by fencing and by a 24-hour
security service _
0 Those persons authorized for site access are required to wear
protective clothing and equipment —•
0 A geotextile fabric covering the site minimizes the potential for
direct contact with soil
As a result of these measures, the risk of on-site exposure is currently not
a concern.
Migration of Hazardous Substances to the Passale River
The remedial investigation indicates that hazardous substances are being
released from the site to the Passaic River through the routes of ground
water migration and surface runoff of stormwater. The remedial
Investigation also identified TCDD and other hazardous substance in Passaic
River sediments. A separate study of the contamination of Passaic River
sediments is being conducted by Diamond Shamrock. Results of that study
show that the more recent sediments contain relatively little TCDD compared
to older sediments. The data suggests that releases of TCDD to the Passaic
River were much greater in the past during the period of pesticide
production at the site than at the present. TCDD has also been found in
biota from the Passaic River and nearby water.
•
The releases of hazardous substances from the site to the Passaic River
present a continuing risk to the environment and to humans who may ingest
contaminated fish and shellfish. The latter risk has been reduced by
NJDEP's advisories against fish consumption and ban on commercial fishing.
Migration of Hazardous Substances to Deeper Aquifers
A component of the contaminated ground water in the fill layer flows
downward into the lower aquifers which are influenced by industrial wells in
the area. Since there are no potable wells in the area, Ingestion of
contaminated ground water is not a great concern at this time. ' However,
there is still some risk of exposure via the industrial wells pumping from
the deeper aquifers. The fact that the migration of TCDD and DDT in ground
water is attenuated by adsorption of these compound on soil substantially
reduces this risk.
Migration of Airborne Hazardous Substances
Hazardous substances can be released from the site into the air by
volatilization and by dust generation. While the geotextile fabric reduces
dust generation form the soil, the buildings and structures at the site are
a potential source of airborne dust. As previously reported in this ROD,
TCDD and other hazardous substances were measured in ambient air samples
taken on-site. Inhalation of airborne hazardous substances migrating
off-site is an exposure route. Control of air emissions from the site will
be a prime concern during remedial activities since the remedial activities
can be expected to generate dust and expose volatile chemicals to the air.
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- 24 -
Chapter 3 of the Feasibility Study Report quantifies tone of the risks
discussed about and provides a more detailed analysis.
VI. The Criteria for Remedy Selection
1. The Law and Regulations that Govern this ROD
EPA's selection of a remedial alternative Bust be in accordance with the
requirements of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), 42 U.S.C. Sees. 9601 et sea., as amended
by the Superfund Amendments and Reauthorizatlon Act (SARA) (enacted October
17, 1986), and the requirements of its governing regulations, the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 C.F.R.
Part 300. Accordingly, the Agency has selected a remedy that is consistent
with its governing statute.
2. The Substantive Legal Requirements
Under its legal authorities, EPA's responsibility at Superfund .sites is to
undertake remedial actions that are necessary in order to protect the public
health and welfare and the environment. In Section 121 of SARA, Congress
provides guidelines which the Agency must follow in selecting remedies which
assure protection of human health and the environment. These guidelines are
discussed below.
First, in Section 121(b), Congress creates a statutory preference for
remedial actions in which treatment permanently and significantly reduces
the volume, toxicity or mobility of the hazardous substance, pollutants or
contaminants. In assessing various permanent solutions, EPA must
specifically address the long-term effectiveness of the different
alternatives. EPA shall, at a minimum, take into account:
(A) the long-term uncertainties associated with land disposal;
(B) the goals and requirements of the Resource Conservation and
Recovery Act (RCRA);
(C) the persistence, toxicity, mobility and propensities of the
hazardous substances and constituents to bioaccumulate;
(D) the short and long-term potential for adverse health effects from
human exposure;
(E) long-term maintenance costs;
(F) the potential for future remedial action costs if the alternative
remedial action in question were to fail;
(6) the potential threat to human health and the environment
associated with excavation, transportation, and redisposal, or
containment.
Congress prescribes that in choosing its final remedy, EPA'must select a
remedial action that uses permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent
practicable.
Second, pursuant to Section 121(c), if EPA selects a remedial action that
results in any hazardous substance, pollutants or contaminants remaining at
the site, EPA must review such remedial action at least every 5 years after
the initiation of such remedial action to assure that human health and the
environment are being protected by the remedial action being Implemented.
In addition, if upon such review it is the judgement of EPA that action.is
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- 25 -
appropriate at such site in accordance with Section 104 or 106, EPA must
take or require such action.
Third, in Section 121(d)(2), Congress provides that EPA's remedial action,
when . conducted on-site, oust comply with applicable or relevant and
appropriate environmental standards established under Federal and State
environmental laws (such applicable or relevant and appropriate requirements
sometimes will be referred to as ARARs). However, Section 121(d)(4) allows
EPA to select a remedy that does not comply with all ARARs, if EPA finds
that:
(A) the remedial action selected is only part of a total remedial
action that will attain such level or standard of control when
completed;
. (B) when compliance with such requirement at that facility will
resultin greater risk to human health and the environment than
alternative options;
(C) compliance with such requirements is technically impracticable from
an engineering perspective;
(D) the remedial action selected will attain a standard of performance
. that is equivalent to that required under the otherwise applicable
standard, requirement, criteria, or limitation, through use of
another method or approach;
(E) with respect to a State standard, requirement, criteria, or
limitation, the State has not consistently applied (or demonstrated
the intention to consistently apply) the standard requirement,
criteria, or limitation in similar circumstances at other remedial
actions within the State; or
(F) in the case of a remedial action to be undertaken solely under
Section 104 using the Fund, selection of a remedial action that
attains such level or standard of control will not provide a
balance between the need for protection of public health and
welfare and the environment at the facility under consideration,
and the availability of amounts from the Fund to respond to other
sites which present or may present a threat to public health or
welfare or the environment, taking into consideration the relative
immediacy of such threats.
Fourth, in Section 121(d)(3), Congress established requirements for actions
involving the transfer of any hazardous substance or pollutant or
contaminant off•site (e.g., to an off-site commercial treatment or disposal
facility). This Section requires that the off-site facility'be operating in
compliance with Section 3004 and 3005 of RCRA (or, where applicable in
compliance with other applicable Federal law) and with all State
requirements. In addition, this Section provides further restrictions
regarding the use of off-site land disposal facilities that are releasing
hazardous waste or hazardous waste constituents to ground water, surface
water or soil. .
In addition, Section 121 (a)' requires the selection of a remedy which, in
addition to meeting all other criteria of Section 121, provides for
cost-effective response. In evaluating cost-effectiveness of remedial
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- 26 -
alternatives, EPA oust take into account the short-term and long-term costs
of these alternatives including the costs of operation and maintenance for
the entire period during which such activities will be required.
VII. Description and Evaluation of Remedial Alternatives
The remedial alternatives which were developed in detail in the Feasibility
Study are listed and briefly described in Table 1= Cost estimates for these
remedial alternatives are presented in Table II. A detailed description of
the process for screening remedial technologies and developing remedial
alternatives is found in the Feasibility Study report. For each remedial
alternative, a description and evaluation follows.
Alternative 1 - No Action
The. no-action alternative Includes the maintenance of the site fence,
geotextlle fabric, security systems, and the establishment of an ongoing
monitoring program. The site would essentially remain as it currently
exists except that all materials remaining on 120 Lister Avenue (east of the
fence separating 80 Lister Avenue from 120 Lister Avenue) with dioxin
concentrations in excess of 7 ppb will be transferred to 80 Lister Avenue
for storage.
The risks presented by the site after Implementing Alternative 1 would be
essentially the same as those discussed previously in Section V of this
ROD. In view of these risks, Alternative 1 (no action ) does not assure
protection of the environment or of human health. Since Section 121 (d) (1)
of CERCLA requires that the selected remedy assure such protection,
Alternative 1 cannot be selected.
Alternative 2 - On-Site Containment with Cap and Slurry.Vail
This alternative would rely on the on-site containment of wastes by the
construction of an impermeable barrier (slurry wall) and a cap meeting RCRA
requirements (see Figures 5 and 6). Only a portion of 120 Lister Avenue
where soil concentrations of dioxin are less than 7 ppb would be outside of
the containment area.
There are a number of additional components of this remedial alternative.
The buildings would be demolished and the rubble spread and compacted over
the site. The contents of shipping containers currently on 120 Lister
Avenue would be emptied, spread and compacted over the site. Underground
conduits, including utility lines and sewer systems which have not already
been sealed, would be located by perimeter excavation, plugged at the
exterior of the site, and completely filled within the Interior of the site
with grout. Several tanks and major structural steel components would be
cleaned and hauled off-site for .reclamation, resale, or disposal as
non-hazardous waste. A new bulkhead would be installed to Increase the
stability of the river bank. Drummed liquids and process wastes would be
stabilized and immobilized. A monitoring program would be established and
maintained.
The underlying design principle of this alternative is to substantially
reduce the movement of chemical contaminants, especially dioxin and DDT, by
containment of the waste. The site geologic and hydrogeologic conditions
coupled with the geochemical characteristics of dioxin and DDT make this
alternative a possible remedial option for the • containment of these
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- 27 -
Table !_
Remedial Alternatives
Alternative 1 - NO ACTION ~.
Alternative 2 - Slurry wall and Cap - Demolition of
structures, decontamination, grading, and
ih-situ containment of all waste with a
slurry wall and cap.
Alternative 3 -» Slurry wall and Cap, Groundwater
treatment - Demolition of structures,
decontamination, grading, and in-situ
containment of all waste with a slurry
wall and cap, with continued pumping and
treatment of the groundwater.
Alternative 4 - Excavation and On-Site Thermal Treatment -»
Demolition of structures, decontamination,
grading, excavation, on-.site treatment of
groundwater, and thermal treatment of all
site wastes and soils containing dioxin
above 7 ppb with in-situ containment of
the remaining site soils and treated
materials with a slurry wall and cap.
Alternative 5 - Excavation .and OntSite Vault » Demolition
of structures, decontamination, grading,
_ _ excAvatioiv, — ftn*-gitg trttitmgnt of
groundwater, and vault encapsulation of
all site wastes and soils containing
""dioxin above 7 ppb" with in-situ
containment of the remaining soils with a
slurry wall and the vault.
Alternative 6A •* Excavation and OffnSite Disposal -
Demolition of structures, decontamination,
grading, excavation, on-site treatment of
groundwater, and hauling of waste and
soils containing dioxin above 7 ppb to an
offtsite facility for landfill disposal;
soils remaining with dioxin levels below 7
ppb would be contained by a slurry wall.
Alternative 6B -
Demolition of structures, decontamination,
grading, excavation, on-site treatment of
groundwater, and hauling of waste and
soils containing dioxin above 7 ppb to an
off-site facility for "thermal
treatment."Soils remaining with dioxin
levels below 7 ppb would be contained by a
slurry wall.
-------
Alternative
1
2
3
4
5
6A
6B
Capital Coat
Bat irate
1
- 28 -
Table It,
Coat' Suemry of Altacnatlvaa
i
Capital Coat
Rang*
1422,000 9380,000«464 ,OOO
$•.013,000 16, 4 10,000*9 ,616 ,OOO
$0.061 ,OOO 96,469,000*9,703,000
$60,O96,OOO 954.O86.OOOa7S.120.O90
$16.879.000 $13, 503.000*20.254,000
$51.272.000 946,145,000*66.653,000
$247,808,000 9223,027,0004322,150,000
Coat Praaant
Valaa
92,600,000
98,350,000
99,320,000
946,620,000
914,180,000
839,460,000
9188,460,000
Animal Operating
and Maintenance Costa
9237,000
9163,000
9261,000
9112,000
9116,000
962,000
962,000
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- 29 -
TOP Of
CONTAIUMINTCL. l».0
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FINCE(TTK)
THIS PLAN IS CONCEPTUAL AND THE
DETAILS OP THE OESION WILL IE
FINALIZED PMIOK iTO IMPLEMENTATION.
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ALL COPYRIGHTS RESERVED
•Do Not Sc»it'
FIGURE 5
X
CONCEPTUAL SITE PLAN
ALTERNATIVES 2 B 4
•0 LISTER AVENUE
PREPARED FOR
DIAMOND SHAMROCK
DALLAS,TEXAS
... Creating a Sal»r Tomorrow
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- 30 -
o
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CONCEPTUAL CROSS SECTION
LOOK MO EAST
ALTERNATIVE f
tO LISTf • •vtwut
DIAMOND SHAMROCK
DALLAS, TEXAS
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- 31 -
contaminants on site. A low-permeability silt layer with an average
thickness of about nine feet underlies the fill and mitigates the downward
migration of the chemical constituents. Furthermore, dioxin is strongly
absorbed by media with organic and clay content (such as the silt layer) and
its rate of migration in .such media would be greatly retarded. The behavior
of DDT in the silt layer would be similar. Therefore, the silt layer
provides a natural barrier to mitigate downward migration of dioxin and
DDT. Testing indicated that the permeability of the silt ir approximately
10 centimeters per second (cm/sec).
The slurry vail would provide a lateral barrier and, with the cap, would
encapsulate the wastes. The slurry wall, would be constructed of clay and
bentonite and have a permeability of 10* cm/sec or less. The cap, which
would include a layer of compacted clay (permeability of 10" cm/sec) and
a nearly impermeable synthetic membrane liner, would virtually eliminate
downward seepage of surface water into the contained volume.
After installation of Alternative 2, the RCRA cap would adequately control
the risks resulting from direct on-site contact and from airborne migration
of hazardous substances. The risk of further contamination of the Passaic
River by the site would also be adequately controlled. Surface runoff from
the site to the Pass lac River would be uncontaminated because the cap will
eliminate stormwater contact with hazardous substances. Downward migration
of contaminated ground water through the silt layer to deeper aquifers would
continue but would be reduced with time as the water level within the
contained volume is gradually lowered by the downward flow. Eventually the
rate of downward groundwater migration through the silt layer would be
reduced to the rate of water infiltration through the nearly Impermeable cap
and slurry wall. When this condition occurs, the flow of groundwater
through the slurry wall will be into the contained volume due to the lowered
water level within the contained volume. Therefore, there would be no
•igration of groundwater from the contained volume through the fill layer to
the Passaic River. Alternative 2 should assure substantial protection of
human health and the environment, although it would allow some continued
release of hazardous substances to the groundwater.
Alternative 2 does not involve substantial treatment of hazardous
substances, although the drummed process wastes would be treated to reduce
the mobility of hazardous substances prior to the burial of these wastes.
Therefore, Alternative 2 does not satisfy the preference for 'treatment
expressed in Section 121(b) of CERCLA.
Alternative 2 would require minimal routine operation and maintenance
activities. The cap would need to be inspected for erosion or cracking and
repairs made as needed. . However, with the passage of time the permeability
of the cap and slurry wall may increase due to deterioration of materials
with age or as a result of chemical attack. This condition would not result
in a sudden failure of the remedy but to a gradual reduction in
effectiveness. Should monitoring show this to be the case, repairs could be
made such as installation of another slurry wall or reconstruction of the
cap. Alternatively, a different remedy could be implemented at that time.
Alternative 2 would not comply with the land disposal ban of Section 3004(e)
of RCRA and the associated regulations (40 CFR Sec. 268.31 - see page 40642
of the November 7, 1986 Federal Register), which prohibit the land disposal
of listed dioxin wastes after November 8, 1988. Alternative 2 would also
not comply with the RCRA standards for landfill design (see 40 CFR Part 264,
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- 32 -
Subpart N) which require a double liner and double leachate collection
system. The landfill proposed in Alternative 2 for disposal of stosed
wastes and demolition debris has no bottom liners or leachate collection
systems .
Vith the exception of the no action alternative, Alternative 2 is the least
costly of the alternatives. This would be the case even if it is assumed
that the remedial alternatives involving containment would have to be
periodically reconstructed to maintain their effectiveness. It can also be
implemented quickly (construction would take approximately 2 years) and is
without any anticipated implementation problems.
Alternative 3 - On-Site Containment with Cap. Slurry Vai
en
This alternative is similar to Alternative 2 except that purge wells would
be installed in the containment area to pump ground water for treatment. A
wastewater treatment plant would be constructed on-site to treat the pumped
ground water prior to discharging it either to the Passaic River or to the
local publicly owned treatment works. The conceptual design for this
alternative is shown in Figures 7 and 8.
After installation of Alternative 3, the RCRA cap would adequately control
the risks resulting from direct on-site contact and from airborne migration
of hazardous substances. The risk of further contamination of the Passaic
River by the site would be greatly reduced. Surface runoff from the site to
the Passaic River would be uncontaminated because the cap will eliminate
.stormwater contact with hazardous substances. The pumping of . groundwater
would lower the water level in the contained volume toward the top of the
silt layer. Since the water table within the contained volume would then be
lower than the water table outside the slurry wall, any lateral migration of
groundwater through the slurry wall would be into the contained volume.
Because the potentlometric surface of the sand unit below the silt layer is,
on the average, two feet above the top of the silt layer, the groundwater
pumping would cause an upward flow of groundwater from the sand unit
through the silt layer into the contained volume. This would virtually
eliminate releases from the contained volume to the groundwater. There
would be a discharge of treated groundwater to the Passaic River as a result
of the implementation of this remedy. The treatment system would be
designed to meet the effluent limitations specified in Section VIII of this
ROD. As described in Section VIZI, the level of treatment provided to
achieve these effluent limitations will result in adequate protection of the
Passaic River. Therefore, Alternative 3 would assure protection of human
health and the environment.
•
Alternative 3 does not rely primarily on the treatment of hazardous
substances, although some treatment would be required. Specifically, the
drummed process wastes would be treated to reduce the mobility of hazardous
substances prior to the burial of these wastes and the pumped groundwater
would be treated to achieve the effluent limitations specified in Section
VIII. Therefore, Alternative 3 does not fully satisfy the preference for
treatment expressed in Section 121(b) of CERCLA.
Alternative 3 would require operation and maintenance of the groundwater
pumping and treatment system for the foreseeable future. In addition, the
cap would need to be inspected for erosion or cracking and repairs made as
needed. However, with the passage of time, the permeability of the cap and
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- 33 -
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LISTER AVENUE
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• 0
' 1964 IT CORPORATION
ALL COPYRIGHTS RESERVED^
DIAMOND SHAMROCK
DALLAS, TEXAS
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•Do Not Suit Thi» Df««m-
-------
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ALTERNATIVE S
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DALLAS, TEXAS
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- 35 -
slurry wall Bay increase due to deterioration of materials with age or as a
result of chemical attack. This would gradually result in greater influx of
groundwater into the contained volume and greater flow of groundwater to the
treatment system. Since the treatment system would be designed to
accommodate • increased flows and still achieve the required effluent
limitations, the effectiveness of the remedy would be maintained (although
operating costs would increase with greater volumes of_ water being
treated). Should a significant Increase in groundwater influx occur,
repairs could be made such as Installation of another slurry wall or
reconstruction of the cap. Alternatively, a different remedy could be
implemented at that time.
Alternative 3 would 'not comply with the land disposal ban of Section 3004(e)
of RCRA.and the associated regulations (40 CFR Sec. 268.31 • see page 40642
of the November 7, 1966 Federal Register), which prohibit the land disposal
of listed dioxin wastes after November 8, 1988. Alternative 3 would also
not comply with the RCRA standards for landfill design (see 40 CFR Part 264,
Subpart N) which require a double-liner and double leachate collection
systems. The containment system proposed in Alternative 3 for disposal of
stored wastes, demolition debris and wastewater treatment sludge has no
bottom liner and only a single leachate collection system.
Alternative 3, while more costly .than Alternative 1 and 2, is less costly
than the other alternatives considered: This would be the case even if it
is assumed that the remedial alternatives involving containment would have
to be periodically reconstructed to maintain their effectiveness. It can
also be implemented quickly (construction would take approximately 2 years)
and is without any anticipated implementation problems.
Alternative 4 - Excavation and On-Site Thermal Treatment of Waste
This alternative includes the excavation and on-site thermal treatment of
all soils and site waste containing dioxin above 7ppb (Figures 5 and 9).
This includes building rubble, contents of shipping containers, excavated
soil and burled piling, and other miscellaneous site waste. Several tanks
and major structural steel components from the on-site buildings would be
cleaned and either disposed of off-site as non-hazardous waste or
salvaged. Crushing/grinding would be required to reduce debris to a size
suitable for treatment. A slurry wall would be installed prior to
excavation. The thermally treated material would be placed back onto the
site and a cap meeting RCRA requirements would be constructed over the
treated material. A new bulkhead would be Installed to increase the
stability of the river bank and a monitoring program would be established
and maintained during the post-implementation period. To implement this
alternative, the fill and underlying sand unit would be dewatered and the
resulting wastewater treated during remediation.
*
To clean the site to a 7 ppb dioxin level, most of the fill above the silt
layer must be excavated. To dewater the excavation, the slurry wall would
extend at least to the silt layer. The slurry wall may be required to
extend to rock adjacent to the river to reduce inflow of ground water. The
slurry wall would reduce the horizontal ground water flow into the
excavation pit. However, because of the high potentiometric surface in the
glacio-fluvial sand unit, especially adjacent to the Passaic River, the
removal of the fill material, without adequate control, would be expected to
cause disturbance (heave) of the silt layer. This phenomenon will affect
the integrity of the silt layer which has been acting as a barrier against
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- 36 -
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DALLAS. TEXAS
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- 37 -
the downward migration of the dioxin. To control this phenomenon, the
potentiometric head within the glacio-fluvial sand unit Bust be lowered
below the level of the silt layer. This would require extensive dewatering
of the sand unit and treatment of the pumped groundwater prior to discharge.
After excavation of the fill to the 7 ppb dioxin level, dioxin and DDT would
still be present in the silt layer and ground water seeping_into the sand
unit would still contain these chemicals. The downward seepage would be
similar to Alternative 2, although the mass of dioxin and DDT would be
substantially less than Alternatives 2 because of the treatment of the fill
layer.
The highest ranking method of thermal treatment Indicated in the Feasibility
Study is a mobile incinerator. Mobile thermal treatment systems have been
used successfully to treat dioxin wastes, the most notable example being the
use of the EPA mobile incinerator at the Denny Farm Superfund Site in
Missouri. Pilot scale mobile thermal treatment systems developed by J.M.
Huber Corp. and Shirco Infrared Systems, Inc. have also been successfully
tested on small quantities of dioxin wastes. Larger versions of the Huber
and Shirco mobile systems have been constructed but have not been tested on
dioxin wastes. In addition, a number of other companies have developed
mobile thermal treatment systems in the last few years. Although these
systems have not been tested on dioxin wastes, most of these systems are
potentially applicable to treating the type of waste found at the Diamond
Shamrock Site. Because these mobile thermal treatment systems are newly
developed, there is little data available on the performance of many of
these units and on their reliability for extended periods of operation.
The EPA mobile incinerator is the largest mobile unit tested on dioxin waste
and the only one which has burned dioxin waste over an extended period of
time; The unit has demonstrated that it can achieve the required 99.9999X
destruction and removal efficiency for dioxin. However, the unit
experienced operating problems at Denny Farm which required that it be shut
down for repair and maintenance more than half of the time. The EPA mobile
incinerator was recently modified to correct past operating problems.
However, the modified unit had not been used to burn dioxin wastes as of
July 1987. Another trial burn at Denny Farm is planned for the modified
unit.
The use of a single mobile incinerator like the EPA unit, operating at the
rate achieved at Denny Farm (about 12 tons per day), would take about 20
years to burn the amount of waste present at the Diamond Shamrock Site.
Although a number of these units could be constructed, brought to the site
and operated simultaneously, there would be difficulty in locating a large
number of small incinerators on a relatively small site. It also would not
be cost effective to use small incinerators for a large project. Therefore,
it would be preferable to use one or two larger thermal treatment units,
although such units have not yet been tested on dioxin waste. Since one or
more mobile thermal treatment unit may have to be designed, constructed, and
tested prior to operation to clean up the Diamond Shamrock Site,- it is
expected to take at least six years to complete this remedy.
For thermal treatment to be considered fully successful, the treatment would
need to be sufficient to allow delisting of the treated materials as
hazardous wastes. If thermal treatment does not allow delisting of the
treated_waste, the treated waste may have to be managed in a more protective
manner than described above.
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- 38 -
After implementation of Alternative 4, the quantity of hazardous substances
remaining at the site would be greatly reduced as a result of the thermal
treatment of wastes. There would, however, be some remaining hazardous
substances in the treated waste and in the silt layer. If necessary, more
protective variations of-Alternative 4 could be selected (e.g. adding a
groundwater pumping and treatment system similar to the one described in
Alternative 3, off-site disposal of the treated waste). Once Alternative 4,
(with any more protective variations needed) has been implemented, further
releases from the site would not significantly affect health or the
environment* However, there would continue to be significant releases of
hazardous substances during the period of time prior to the complete
implementation of this remedy. The remedy will require an estimated six
years to implement because of the need for a detailed incinerator design, a
test burn, major excavation activities, the time required to treat more than
70,000 cubic yards of waste material, and the final disposition and capping
of the treated materials. During the period of implementation the releases
from the site will vary depending on the status of the remedial activities.
During the design phase there would be a continuation of the current
releases from the site. During the excavation activities dusts and volatile
chemicals would be released to the air. There would also be a discharge of
treated groundwater resulting from groundwater pumping during the remedial
activities. Lastly, there will be emissions from the incinerator stack.
Because the incinerator would be designed to achieve the RCRA standards for
incinerators (see 40 CFR Part 264, Subpart 0), the air emissions from the
incinerator will contain very low concentrations of hazardous substances.
For example, the standards require 99.9999 percent destruction and removal
efficiency for dioxin. As a result, the air emissions from the incinerator
would release less than 0.0001 Ibs (0.05 g) of dioxin during the entire
period of operation. Although a large population would be exposed to the
incinerator emissions, the level of treatment required would provide
adequate protection of health and the environment.
As previously discussed for Alternative 3, a high level of treatment can be
provided for groundwater pumped from the site. While quantities of treated
groundwater would be much greater during the implementation of Alternative 4
than for Alternative 3, proper design and the operation of the treatment
facilities would provide adequate protection of the Passaic River.
The most significant releases expected from the implementation of
Alternative 4 would be the air emissions resulting from the excavation
activities. These emissions would result both from dust generation and from
volatilization of chemicals exposed to air. A risk assessment performed by
an EPA contractor for another site with high dioxin concentrations (Risks
from Chemical Releases Associated with Proposed Excavation of the Hyde Park
Landfill. Environ Corporation, November 1985) , concluded that dioxin
contaminated dusts generated from the proposed excavation would result in
cancer risks greater than 10* at properties as far as 1200 meters from
that site. While this assessment assumed conventional dust suppression
methods, alternatives such as construction under an inflatable dome have not
been demonstrated at hazardous waste sites.. In the absence of new
information, the remedial alternatives involving excavation of the fill
layer cannot be determined to be adequately protective of health and the
environment.
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- 39 -
Alternative 4 requires minimal operation and maintenance once it has been
implemented. The cap will need to be maintained and the site monitored.
Alternative 4 would, upon completion, comply with all applicable or relevant
and appropriate requirements (ARARs) of State and Federal environmental laws.
Alternative 4, with a present value cost estimate of $46,600,000 is more
costly than the alternatives based on on-site containment. "*'
Alternative 5 • Excavation *"<< Pisposal of All Vaate Above 7 oob *" p
Secure On-Site Isolation Vault
This alternative includes the excavation of all soil containing dioxin above
7 ppb and disposing of this soil in an on-site, above grade vault (Figures
10 and 11).
The difficulties associated with excavation discussed for Alternative 4
apply to this alternative also. The vault would be constructed so that the
bottom of the vault is one foot above the 100-year flood level (Elevation
10.2 feet). A lateral barrier (slurry wall) would be constructed along the
site perimeter.
The construction of a slurry wall would be necessary to reduce the volume of
water infiltrating during excavation and requiring treatment. In addition,
the sand unit would be dewatered to reduce the piezometric pressures in the
glaciofluvial sand to minimize potential disturbance of the silt layer.
On-site contaminated building demolition material, material stored in
containers, and other site wastes would also be disposed of in the vault.
Some tanks and major structural steel components would be decontaminated and
•ither disposed of off -site as non-hazardous waste or salvaged. The vault
would be lined (top, sides, and bottom) to meet RCRA requirements.
Clean fill would be purchased and placed in the excavation to return the
excavated fill layer to existing ground surface. Because-excavation would
proceed to the 7 ppb level in the fill and dioxin is present in the silt
layer, ground water seeping from the site will still contain dioxin, but at
reduced levels from present conditions. The excavation, stockpiling, and
backfilling would need to be finished before the vault could be complete;
therefore, this alternative is extremely difficult, if at all feasible, due
to the limited size of the site and the fact that the vault would be
expected to cover most of the site.
To raise the vault above the 100-year flood elevation, an additional 4.5
feet of soil would be required above the existing grade. Coupled with the
excavation backfilling, this represents the purchase and hauling of
approximately 77,000 cubic yards of clean fill.
After implementation of Alternative 5, nearly all of the hazardous
substances at the Site would be contained within the vault. However, some
hazardous substances would remain in the silt layer. More protective
variations of Alternative 5 could also be selected (e.g., adding a
groundwater pumping and treatment system similar to the one described in
Alternative. 3). Portions of -this remedy (e.g., the cap, landfill bottom
liners, etc.) may gradually deteriorate with the passage of time. As
discussed for Alternative 3,,portions of the remedy such as the cap may need
to be rebuilt or replaced periodically to maintain the effectiveness of this
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.-•40 -
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ALTERNATIVE S
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-42-
reoedy. Once Alternative 5 (with protective modifications aa needed) has
been implemented, further releases from the site would not significantly
affect health or the environment, provided that the remedy is properly
operated and maintained.
Similar to Alternative 4, there will be continued releases of hazardous
substances during the period of remedy implementation. There would be
continuation of current releases during the design phase. The period for
design is likely to be lengthy considering the construction difficulties
previously noted. These difficulties could be reduced if an off-site
storage area can be found where the materials to be contained can be stored
during excavation and vault construction. However, the siting of such a
storage area may not be possible given the storage restriction of Section
3004(J) of RCRA in conjunction with the likely hood of opposition from the
community near any storage site.
Air emissions resulting from excavation activities would be similar to those
described for Alternative 4, as would the discharge of treated ground water
resulting from ground water pumping.
Alternative 5 will not rely, primarily on treatment although some wastes
would be stabilized prior to containment and leachate from the vault would
be treated. Therefore, this alternative does not satisfy the treatment
preference of CERCLA Section 121(b).
Alternative 5 will require continued operation and maintenance including the
possible need to rebuild portions of the remedy should they deteriorate with
time. Vastevater treatment needs for Alternative 5 would be less than
Alternative 3 since there would be less Infiltration of water into the
contained volume.
Alternative 5 would not comply with the land disposal ban of RCRA Section
3004(e) and the implementing regulations (40 CFR Part 268, Subpart C - see
page 40641 of the November 7, 1986, Federal Register).
Alternative 5, with a cost present value of $14,180,000 is the most costly
of the on-site containment remedies but is less costly than the remedies
which rely on thermal treatment.
Alternative 6 - TTnn«t>r»yt and Off "Site Disposal or Treatment
At present, permitted facilities do not currently exist which can accept
RCRA regulated dioxin wastes from the site. However, permitted facilities
may become available in the future.
•~
The basic premise of Alternative 6 is that all materials containing dioxin
levels above 7 ppb would be excavated and transported off-site. The
shipping containers from 120 Lister Avenue would be shipped as is because
they are presently sealed and the exteriors are not contaminated. Drummed
wastes would be shipped as is, or in overpack drums for existing
deteriorated drums, Building debris would be reduced to an adequate size
for shipment and the excavated soils and subsurface debris would be
shipped. The difficulties associated with excavation discussed for
Alternative 4 apply to this alternative also. All shipments would be in
sealed carriers.
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-,43-
The alternative also considers that the materials transported from the site
would be disposed of by thermal treatment (eg. incineration) or by
landfllling. Candidate sites for determining cost and transport method were
•elected on the basis of disposal or treatment facilities that would accept
materials containing PCBs. A facility near Houston, Texas was identified
for potential thermal treatment allowing transport by truck, rail, or
barge. A landfill was identified near Emelle, Alabama which limits
transport to trucking. ^
The cost for the landfilling or thermal treatment of dioxin-containing waste
was assumed to be at least 30 percent greater than for PCBs. The actual
cost 1* unknown.
Alternative 6A (Excavation with Off-site Disposal) is clearly not a viable
alternative because it will be prohibited in the United States by the land
disposal ban of Section 3004(e) of RCRA and the implementing regulations (40
CFR Part 268, Subpart C • see page 40641 of the November 7, 1986 Federal
Register). 40 CFR Sec. 268.31 bans the land disposal of RCRA dloxin wastes
after November 8, 1988. While CERCLA gives EPA the authority to waive
applicable legal requirements at Superfund sites under certain conditions
(see Section 121(d)(4) of CERCLA), CERCLA does not give EPA the authority to
waive applicable requirements at off-site facilities. Efforts to locate
treatment and disposal sites in other countries have, thus far, been
unsuccessful. Therefore, Alternative 6A cannot be selected.
After the implementation of Alternative 6B (Excavation with Off-site Thermal
Treatment), the quantity of hazardous substances remaining at the site would
be gr.eatly reduced. . There would still be tome remaining hazardous
substances in the silt layer. If necessary, more protective variations of
Alternative 6B could be selected (e.g. adding a groundwater pumping and
treatment system similar to that described for Alternative 3). Once
Alternative 6B (with any more protective variations needed) has been
implemented, further releases from the site would not significantly affect
health or the environment.
Compared to Alternative 4, Alternative 6B would have the advantage that a
site could be selected with ample space to locate the thermal treatment
equipment and with a buffer zone separting the facility from its neighbors.
As in the case of Alternative 4, there would continue to be significant
releases of hazardous substances during the time prior to the. complete
implementation of this remedy. Since at the present time there are no
off-site incinerators of adequate capacity which are permitted for dioxin
wastes and none with pending applications for permits, EPA must assume that
one or more off-site incinerators would have to be designed, sited,
permitted and constructed in order to implement this remedy. Because of
potential siting problems, this remedy could take longer to implement than
Alternative 4, which itself would take at least six years. Siting treatment
disposal locations for waste from CERCLA cleanups'has delayed cleanups in
the past and would be expected to be especially difficult for a dloxin
incinerator. With the exception of the fact that there would be no
incinerator stack emissions at the site, the releases of hazardous
substances at the site during implementation would be similar to Alternative
4. .'....• .
Alternative 6B relies primarily on treatment and satisfies the preference
for treatment of Section 121(b) of CERCLA.
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- 44 -
Alternative 6B requires minimal operation and maintenance once it has been
implemented. Continued monitoring would be required.
Alternative 6B would, upon completion, comply with all applicable or
relevant and appropriate .requirements (ARARs) of State and Federal
environmental laws.
Alternative 6B is the most costly of all the alternatives with an estimated
present value cost of $188,460,000.
Comparison Of Alternatives
As previously noted, Alternative 1 is not protective of health and the
environment and Alternative 6A cannot be implemented given the RCRA land
disposal ban and the lack of availability disposal facilities in other
Countries. Therefore, these alternatives will not be considered further^.
Alternative 2 and 3 are similar but Alternative 3 has several advantages
over Alternative 2:
1. Alternative 2 would allow a continued, but reduced, release of
contaminated ground water downward from the contained volume.
Eventually, the quantity of ground water migrating downward would
equal the quantity of water infiltrating the contained volume. For
Alternative 3, the pumping of ground water from the contained
volume would reverse the direction of ground water flow, causing an
influx of ground water into the contained volume from the lower
sand unit. This ground water flow reversal would provide
additional protection of the ground water in the sand and bedrock
below the site.
2. Alternative 3 is more reliable than Alternative 2 because the
ground water pumping system provides a backup should the
effectiveness of the slurry wall and cap be reduced with time.
Therefore, the effectiveness of Alternative 3 can be maintained
over time more readily than the effectiveness of Alternative 2.
3. The ground water pumping and treatment system of Alternative 3 will
remove the more mobile hazardous substances from the .contained
volume and provide appropriate treatment. Since the remaining
hazardous substances will be less mobile, the quality of the ground
water in the contained volume should gradually improved with time.
For Alternative 2, any Improvement of ground water quality in the
contained volume would be at the expense of the downward migration
of mobile hazardous substances toward the deeper sand and bedrock
aquifers, which are tapped by industrial water supply, wells.
- /•
The advantages of Alternative 2 over Alternative 3 are that Alternative 2
would not result in a discharge of treated wastewater to the Passaic River
and a relatively small difference in cost. However, by meeting the cleanup
standards in Section VIII, the discharge of highly treated wastewater for
Alternative 3 would be fully protective of the.Passaic River.
Based on the above comparisons, Alternative 3 is preferred over Alternative
2.
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- 45 -
As previously discussed, Alternatives 3, 4, 5, and 6B each would, after
Implementation, assure adequate protection of human health and the
environment. However, Alternative 3 can be implemented much more quickly
and would achieve its objectives much sooner than any of the other three
alternatives. In addition, Alternatives 4, 5, and 6B each would involve
extensive and difficult excavation activities expected to generate
significant releases of hazardous substances to the air. The "implementation
of Alternative 3 would release a much smaller quantity of hazardous
•ubstances to the air during construction. • . "
In the near term, it is clear that Alternative 3 presents less risk than
Alternatives 4, 5, and 6B because it will bring the site under adequate
control much more quickly than the other alternatives. In the long term,
Alternatives 4 and 6B, which rely on thermal treatment to destroy hazardous
substances, are more reliable than Alternatives 3 and 5 since once hazardous
substances have been destroyed there is no further risk of their release.
However, the short term releases and exposures to hazardous substances
resulting from the excavation of contaminated material associated with the
implementation of Alternatives 4, 5, and 6B cannot be eliminated once they
have occurred (i.e., once a person or the environment has been exposed to
hazardous substances, it is impossible to go back in time and change this
fact; irreparable harm may have been done). If Alternative 3 is
implemented, short-term risk will be adequately controlled and it will still
be possible to take future actions to control long-term risks. In fact.
Section 121(c) of CERCLA requires that, if a remedial action that results in
any hazardous substances remaining at the site is selected, such remedial
action must be reviewed at least every five years to assure protection of
human health and the environment. If at the time of review, further
remedial action is appropriate in accordance with Section 104 or 106 of
CERCLA, EPA must take or require such action. As noted previously,
Alternative 3 would hot Tail suddenly, but "may "gradually become less
affective with the passage of time. Therefore, the remedy could be
reevaluated and supplemented by additional remedial —action--without
appreciable damage resulting from loss of remedy effectiveness. In view of
EPA's obligation to reevaluate containment remedies under Section 121(c) of
CERCLA, Alternative 3 assures adequate long-term protection of health and
the environment, as would Alternative 5 for the same reasons. Based on the
currently available information, EPA has determined that Alternative 3
presents less risk at this time and is more protective than the other
Alternatives when both short-term and long-term risks are considered.
Additional Considerations Regarding Alternative 3
• ' .
For the reasons given In the previous section of this , ROD, EPA has
determined that Alternative 3 is more protective than the other Alternatives
considered in the Feasibility Study. Before Alternative 3 can be selected,
EPA must first take into account the factors listed in Section 121(b)(l) of
CERCLA. As summarized below, EPA has taken these factors into account:
(A) The long-term uncertainties associated with land disposal -
As previously acknowledged in this ROD, it is expected that Alternative
3, which relies primarily on containment of hazardous substances, will
require perpetual operation, maintenance, monitoring and reevaluation;
and, if necessary, additional remedial action. EPA recognizes the need
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- 46-
for continued care of the lite and is obligated by Section 121(c) of
CERCLA to ensure that the remedy remains protective in the long-term.
(B) The goals and requirements of RCRA -
As previously noted, Alternative 3 would not comply vith the land
disposal ban of Section 3004(e) of RCRA and the associated regulations,
which prohibit the land disposal of listed dioxin wastes after November
8, 1988. Alternative 3 would also not comply with the RCRA standards
for landfill design (see 40 CFR Part 264, Subpart N) which require a
double-liner and double leachate collection systems.
Section 121(d)(4)(B) of CERCLA provides that EPA may select a remedy
that does not comply with all applicable or relevant and appropriate
requirements of Federal and State environmental law if compliance with
all requirements will result in greater risk than alternative options.
EPA has previously determined that Alternatives 4 and 6, which comply
with the RCRA land disposal ban, will result in greater risk than
Alternative 3 due to the potential exposure to hazardous substances
resulting from excavation of contaminated material. Alternative 5,
which would comply with RCRA landfill standards but not with the land
disposal ban, would also result in greater risk than Alternative 3.
Variants of Alternative 3 are also possible which would contain the
wastes presently in the ground in the same manner as Alternative 3, but
utilize Incineration or a double-lined on-site landfill to manage the
wastes presently stored at the site as well as the demolition debris.
The advantage of this approach is that a solution with greater
long-term reliability can be used for some of the waste, without
extensive excavation and the associated risks. This approach can also
be more consistent with RCRA requirements than Alternative 3. However,
these .variants would offer no significant reduction in long-term risk
compared to Alternative 3 because the wastes presently in the ground
contain a much greater quantity of hazardous substances than the stored
wa~ste and" demo lit ion debris. Specifically, the material above ground
contains relatively low concentrations of contaminants. Removing this
material, while reducing the volume of waste, would remove only a small
percentage of the mass of total contaminants. Therefore, the long term
risk would remain essentially unchanged. These variants would also be
more difficult and time consuming to implement than Alternative 3
(especially if incinerator siting, design and testing is involved) and
would not bring the site under adequate control as expeditiously as
Alternative 3. Therefore, Alternative 3 is preferable to these
variants of Alternative 3.
•
Based on the above considerations, Alternative 3 may be selected
although it will not comply with the RCRA land disposal ban or RCRA
landfill design standards.
(C) The persistence, toxicity, mobility and propensities to bioaccumulate
the hazardous substances and constituents -
The extreme toxicity and propensity to bioaccumulate and persistence of
dioxin and other hazardous substance was taken into account in the
remedy selection process. The fact that the hazardous substances would
have greatly reduced mobility under the conditions which Alternative 3
would establish was also taken into account, as was the fact that
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- 47-
excavatlon activities could greatly increase the mobility of hazardous
substances such as dioxin, which would otherwise be relatively immobile.
(D) The short and long-term potential for adverse health effects from human
exposure •
As previously discussed, Alternative 3 presents less potential for
adverse health effects at this time than all other1 Alternatives
considered when both short and long-term risks of exposure are
considered. Specifically, the potential exposure to hazardous
substances resulting from the excavation of contaminated material which
is an essential component of Alternative 4, 5, 6A and 6B is determined
to be too great a risk at this time.
(E) Long-term maintenance costs •
The long-term maintenance costs associated with Alternative 3 are
recognized. The selection of Alternative 3 would be based on its
greater protectiveness and not on its lower initial cost when compared
to the other Alternatives.
(F) The potential for future remedial action costs if the alternative
remedial action in question were to fail •
It is recognized that the performance of Alternative 3 could
deteriorate with time and that costly additional remedial action may be
necessary. However, the selection of Alternative 3 would be based on
its greater protectiveness and not on its lower initial cost when
compared to the other Alternatives.
(G) The potential threat to human health and the environment associated
with excavation, transportation, and redisposal, or containment •
Future excavation, if required after implementation of Alternative 3,
. could have substantial risks. However, these risks would be no greater
than the risks presented by the excavation activities associated with
Alternatives 4, 5, and 6. As previously discussed, any deterioration
of performances of Alternative 3 would be gradual and could be
mitigated by additional response action when the initial sign of
deterioration (such as an Increased Influx of ground water 'into the
contained .volume) is observed. The appropriate corrective action for
remedy deterioration might be to rebuild the containment system rather
than excavate. Rebuilding the containment system would involve far
less risk of. construction related releases than would actions involving
excavation.
Section 121(b) of CERCLA creates a preference f or, remedies 'which utilize
treatment by ensuring that the long-term disadvantages of remedial
alternatives are taken into account in the remedy selection process. Since
treatment alternatives tend to minimize long-term disadvantages, treatment
is favored by taking these disadvantages into account. However, Section
121(b) also takes short-term risks into account. Section 121(b) is not
Intended to establish treatment as an end in itself, but to use treatment,
to the extent practicable, as a means for ensuring protection of health and
the environment. Since, for this site, the remedial alternatives which have
a greater reliance on treatment are less protective than Alternative 3,
Alternative 3 utilizes treatment technologies to the maximum extent
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- 48 -
practicable for achieving CERCLA1a primary goal of protecting health and the
environment.
VIII. .Cleanup Standards
Section 121(d)(2) of CERCLA provides that EPA's remedial action, when
conducted on-eite, must comply with applicable or relevant and appropriate
environmental standards established under Federal and State environmental
lavs except as provided by Section 121(d)(4). Such applicable or relevant
and appropriate requirements sometimes will be referred to as ARARs. It is
EPA's position is that on-site response actions need comply only with the
substantive requirements of other environmental lavs, not the procedural and
administrative requirements of other environmental lavs (e.g., requirements
to obtain permits, prepare environmental Impact statements, prepare planning
documents, maintain records and submit reports). Bovever, CERCLA actions
vill utilize procedural and administrative safeguards similar to those
provided by other environmental lavs. Since ARARs may not alvays provide an
adequate level of protection (for example, there may not be an ARAR for a
particular hazardous substance), cleanup standards may also be established
based on risk assessment, guidance or other available Information.
The five tables in this section list the ARARs and other cleanup standards
vhich pertain to one-or more remedial alternatives for the site. Table III
lists Federal ARARs that vlll be attained by the selected clternative while
Table IV lists the Federal ARARs that vlll not be attained by the selected
alternative as veil as Federal ARARs that are not pertinent to the
selected remedy but are pertinent to other remedial alternatives. For each
requirement, the tables provide a summary of the requirement, a description
of the legal prerequisites vhich make the ARAR applicable and a legal
citation vhlcb can be used to obtain further information on the ARAR.
Unless otherwise specified by a footnote, each of the listed ARARs pertains
to all the remedial alternatives. Footnotes are also provided to give site
specific interpretations and other explanatory Information. Tables V and VI
provide similar information for State ARARs. However, States ARARs that do
not pertain to the selected alternative (but may pertain to other
alternatives) have not been included. Table VII lists other cleanup
standards (e.g., those based on guidance or advisories, but not on
promulgated legal requirements). In the event that there are several ARARs
vhich pertain to the same hazardous substances, action or circumstance, the
selected alternative must attain the most stringent of these ARARs, except
as provided by Section 121(d)(4) of CZRCLA.
It should be noted that the ARAR summaries provided in Tables III through VI
are abbreviated versions of promulgated legal requirements. For a more
complete understanding of these requirements, it is necessary to refer to
the cited sources, vhich are too lengthy to reprint in this; ROD in their
entirety. It should also be noted that where administrative requirements
(e.g., the need to obtain permits or submit planning documents) are listed
in Tables III through VI, the substantive technical requirements of such
permits or planning documents are ARARs. However, the administrative
requirements themselves are not ARARs.
Except as provided by Section. 121 (d) (4) of CERCLA, ARARs must be attained
upon completion of the remedial action as required by Section 121(d)(2).
However, some ARARs are pertinent during the remedial action. For example,
a newly installed ground water treatment facility, vhich could Include tanks
and a container storage area, generally should be designed and operated to
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- 49 -
Table 111
Federal ARARs That Mill 8* Attained By. the Selected Alternative •
Summary
Facility moat be designed,
operated, and Maintained
to avoid waahout.
Prereguiaite
RCRA haiacdoua wastes treatment,
atorage, or diapoaal within the
1OO year flood plain
Citation
40 CFR 264.18(b)
footnotea
1
Action to avoid adveree
effects, minimiie potential
harm, reatoce and preserve
natural and beneficial
values.
Action will occur in s flood.
plain* i.e.* lowlands and
flat areaa adjoining inland
and coaatal waters and other
flood prone areaa
Executive Order 119M,
Protection of flood* .
plaina, 40 CPU 6 App. A
Placement of a cap over
waste (e.g., closing a land*
fill* or cloaing a surface
impoundment) requirea a
cover designed tot
o Provide long term minimisation
of migration of liquida through
the capped area}
o Function with minimum maintenance}
o Promote drainage and minimise
eroaion or abraaion of the cover}
o Accomodate settling and subsidence
so that the cover'a integrity ia
maintained} and
o Have a permeability less than or equal
to the permeability of any bottom
liner ayatem or natural aub-aoils
present.
Hasardous waste land disposal
unit capping
40 cm 264.310fa)
Restrict poat*cloaure use
of the property as necessary
to prevent damage to the
cover.
Nasardoua waate facility closure
40 CPR 264.117(c)
-------
-50 -
Summary
Prevent run-on and run-off
from damaging the cover
Prerequisite
Haiardous waste landfill closure
Citation
40 CFR 264.310(b)
Footnotes
Protect and maintain surveyed
benchmarks used to locate
waste cells 1landfills) •
I • I I ...!•,
Installation of ifinal cover to
provide long*term minimisation
of infiltration.
Post^closure care and
groundwater monitoting.
40 CPR 264.310(b)
40 CPR 264.310
40 CPR 264.310
3.4
Install two liners or more
that prevent waate migration
into the liner, and a bottom
liner that prevents w.aate
migration through the liner.
Install leachate collection
systems above and between the
liners.
Construct run»on and run-off
control systems capable of
handling the peak discharge of
a 25 year atorm.
v
Control wind dispersal of
particulates.
Prevent run-on and control end.
collect run-off from a 24*hour
2S«year storm. .
Inspect liners end covers
during and after installation.
Inapect facility weekly and
after storms to detect
malfunction of control systems or the
presence of liquids in the leachate
collection and leak detection systems.
Maintain records of the exact
location, dimensions, and contents
waste cell.
Hasardous waste currently being
placed in a landfill
40 CPR 264.301
40 CPR 264.302
40 CPR 264.303
40 CPR 264.304
-------
Summary
Close each cell with • final
cover after the last waste has
been received.
No bulk or non-contalnerited
hazardous waste
containing free liquids may be
disposed of in landfills.
- 51 -
Prerequisite
! I
Citation
40 CPR 264.310
40 CFR 264.314
footnotes
3
Containers of hazardous
waste must bet
o Haintalned In good condition}
o Compatible with hazardous waste
to be stored}
o Closed during storage (except
to add or remove waste)|
Inspect container storage areas
weekly for deterioration.
Place containers on a sloped,
crackfree base, and protect from
contact with accumulated liquid.
Provide containment system with
a capacity of lot of the volume of
containers of free liquids.
Remove spilled or leaked waste
in a timely manner to prevent
overflow of the containment system.
Keep containers of ignitable or
reactive waste at least SO feet
from the facilities property line*
Keep incompatible materials
separate. Separate incompatible
materials stored near each other
by a dike or other barrier.
Hazardous waste storage in
containers
40 CPR 264.171
40 CPR 264.172
40 CPR 264.173
40 CPR 264.174
40 CPR 264.175
40 CPR 264.176
40 CPR 264.177
-------
Summary
At closure, remove all hazardous
waste and residues ftosi the
containment system, and
decontaminate or remove all
containers, liners.
Prohibition on long-tens
storage of listed dioxin wastes
Prereqi isit«
- 52 -
Storage] after Nov. I, 1981
Citation
40 CPR 264.171
40 cm 268.50
footnotes
5
Tanks must have sufficient shell Tanks
strength (thickness), and, for
closed tanks, pressure controls, to
assure that they do not collapse
or rupture.
Waste must not be incompatible
with the tank material unless the
tank is protected by • liner or
by other means.
Tanks must be provided with controls
to prevent overfilling, and sufficient
freeboard maintained in open
tanks to prevent overtopping by
wave action or precipitation.
Inspect the following!
overfilling controls, control
equipment, monitoring data, wast*
level (for uncovered tanks), tank
condition, above*ground portion
of tanks, and the areas surrounding
tanks.
Repair any corrosion, crack or
leak.
At closure, remove all hazardous
waste and hasardous waste residues
from tanks, discharge control
equipment, and discharge confinement
structures.
40 CPR 264.190
40 CPR 264.191
40 CPR 264.194
40 CPR 264.195
40 CPR 264.196
40 CPR 264.19?
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- 53 ^
Su
ry
Prerequisite
Compliance with effluent
limitations requiring the
application of best avalable
technology (BAT) to control
toxic and nonconventional
pollutants and best conventional
pollutant control technology M ( .
(BCT) ,to control,conventional pollutants.
Compliance with water quality
based effluent limitations.
Discharge must be monitored
to assure compliance.
Discharge will monitors
o The mass of each pollutant
o The volume of effluent
o Frequency of discharge
and other measurements as
appropriate.
Approved test methods for
waste constituents to be
monitored must be followed.
Detailed requirements for
analytical procedures and
quality controls are provided.
Discharge of treatment systesi
effluent to navigable waters
(e.g. Passaic River)
Citation
b
40 CFH 122.44(a)
Footnotes
40 CPU 122.44 (d)(2)
«*•
40 CPU 122.44 (i)
Pollutants thst pass through the
POTM without treatment, inter*
fere with POTM operation* or con*
taminate POTM sludge are prohibited.
Specific prohibitions preclude the
dischsrge of pollutants to POTNs
thatt
o Create a fire or eiplosion
haxard in the POTWj
o Are corrosive (pH<5.0)f
o Are discharged at a flow rate
and/or concentration that will
result in interference} and
Discharge to publicly
owned treatment works.
4O CPU 4O3.3
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- 54-
Sui
iry
Prerequisite
Citation
Footnotes
o increase the temperature of Haste-
water entering the treatment plant
that would result in interference*
but in no case raise the POTW
influent temperature above 104
degree Fahrenheit
(4O degree Celsius).
o Discharge smst cosiply with local
POTW pretreataent program. Includ-
ing POTWospecific pollutant limitation
spill prevention program requirements, and
reporting and monitoring requirements.
40 CFR 403.S
and local POTW
regulations
-------
- 55 - •
Table) W
Other Federal ARARs
Table 1VA Federal ARARs For Incineration
Summary : Prerequisite Citation ;, footnote*
Analyse the waste feed. Incineration of RCRA 4O CfR 264.341 10
hazardous waste
Remove all hazardous waste and . 4O CPR 264.351 10
residues, including ash, scrubber <
water, and scrubber sludge upon
closure. . • .
Performance standards for
incinerators*
o Achieve a destruction and removal 4O CPR 264.343 10
efficiency of. 99.99% for each
principal organic hazardous
constituent in the waste feed
and 99.9999% for dioiins} and
o Reduce hydrogen chloride emissions 4O CPR 264.342 10
to l.O kg/hr or 1% of the HC1 in
the stack gases.
Monitoring of various parameters 4O CPR 264.343 10
during operation of the incinerator
is required. These parameters includes
o Combustion temperature}
o Waste feed rate}
I
o An indicator of combustion '
gas velocity} and
o Carbon monoxide.
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-56 -
Table IVB Pederal M*Ba That Mill Mot Be Attained By the Selected alternative
8u«»aty Pr«cequl«it« Citation ' Footnotes
Tteataent by Beit De«on«tr«t«d PlaceiMnt after Nov. 8, 1981 of 40 CPR 268 (Subpact D) 3
Available Treatnent before liated dioiin waates
placeMent.
Prohibition on land dispoaal 40 CPR 268 (Subpart C| 3
of liated dioiin waatea.
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- 57-
Footnotes for Tables III and IV
1« All alternatives require remedial action in a floodplain since
the site is located within a floodplain. All alternatives except
Alternative 1 can be designed to prevent washout.
2. All alternatives except Alternative 1 can be^ designed to
minimize adverse effects from flooding. Alternative 2 through
6 would all significantly restore natural and beneficial values
of«the floodplain by reducing the risk of contact with hazardous
substances. Changes in flooding patterns which would result from
the U.S. Army Corps of Engineers flood control project for the
upper Passaic River would also be factored into the remedial
design.
3. This ARAR pertains to Alternatives 2, 3, 4 and 5 only.
4« The cited groundwater monitoring requirements do not pertain
to this action. This action addresses only 80 and 120 Lister
Avenue and is not intended to address off-site groundwater
monitoring or restoration (see Section II, Scope of this Record
of Decision).
• . •
5. This ARAR pertains to Alternatives 1, 3, 4, 5 and 6 only.
6. This ARAR pertains to Alternatives 3, 4, 5 and € only.
7. For the State of New Jersey, the authority to issue National
Pollutant Discharge Elimination System permits, which contain
technology-based effluent limitations, has been delegated by
the Federal government to the State of New Jersey. This dele-
gation was based on the finding that the State requirements for
such permits are at least as stringent as' 'the Federal require-
ments. Therefore, the attainment of the State effluent
limitation ARARs ~of-Table V will ensure—compliance- with ^he
corresponding Federal requirements.
8. Water quality based effluent limitations are established by
modeling the impact of the proposed discharge on the. receiving
water. While it is not within the scope of this ROD to clean
up the existing contamination in the Passaic River or to abate
other sources of pollution which are currently impacting the
river, it is within the scope of this ROD to ensure that dis-
charges from the site do not contribute to violations of state
water quality standards or Federal Water Quality Criteria which
are ARARs. Therefore, water quality standards are not ARARs for
this ROD but water quality based effluent limitations are ARARs.
Federal Water Quality Criteria were developed to assist States
in establishing State water quality standards. While the
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- 58-
criteria are not applicable requirements, Section 121(b)(2)(A)
of CERCLA makes it clear that the Water Quality Criteria which
are relevant and appropriate are ARARs. The Water Quality
Criteria can be found in the Quality Criteria for Mater
1986, US EPA, May 1, 1986. The criteria from this document
which EPA considers relevant and appropriate to the Passaic River
are:" • . ' '. . .
a) The criteria for the protection of saltwater "aquatic
life.
t>) The criteria for the protection of human health from
exposure through ingestion of contaminated aquatic organisms
(the Passaic River near the site is not a source of potable
water but is a potential source of aquatic organisms for
. human consumption). For carcinogens, the criteria will be
based on a level of protection corresponding to a- 10~6
increased cancer risk.
The relevant and appropriate criteria for dioxin, DDT and
hexachlorobenzene and the corresponding effluent limitation
ARARs are:
Pollutant Criterion Effluent Limitation ARAR
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^M^MMMi^^V •
Dioxin 1.4 x 10-5 ng/L 1.0 x lO"8 Ibs/day
DDT 2.4 x 10-2 ng/L j.6 x ID'S Ibs/day
Hexachlorobenzene 7.4 x 10"* ng/L 5.4 x 10"* Ibs/day
These effluent limitations were calculated using the formula
EL - 0 x 8.33 x 10-6 x c
re EC ~is the effluent limitation in Ibs/day, C is the water
quality criterion in ng/L and Q is the flow of the Passaic River
-in-million gallons per day.
This formula is based on a number of assumptions!
- Steady state behavior
- Conservative behavior of substances (e.g. no biodegrada-
tion, volatilization, etc.)
- Complete mixing
*
- Background concentrations are zero
t
The flow of the Passaic River used for the calculations is
89 million gallons per day, which is the seven day average
low flow expected once in ten years (the 7Q10 flow). While
a number of conservative assumptions (e.g. use of the 7Q10 flow,
assumption that substances behave conservatively) were made which
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- 59 _
result in the calculated limitations being more protective, the
assumption of zero background concentrations is not a conservative
assumption. Although dioxin has not been found in Passaic River
water samples taken near the site, the water quality criterion
for dioxin is below-the current detection limit. Therefore,
there may be non-zero background concentrations of dioxin which
•have not been detected due to analytical limitations. Improved
analytical methods are becoming available which may succeed in
measuring very low concentrations of dioxin in Passaic River
water. The presence of dioxin, DDT and hexachlorobenzene in
Passaic River water will be studied further and the effluent
limitation ARARs may be reconsidered based on new data that
becomes available.
Effluent limitations based on the Federal Water Quality Criteria
for pollutants other than dioxin, DDT and hexachlorobenzene' are
less stringent than the State effluent limitation ARARs in Table
V.
9. An option for Alternatives 3 through 6 is to discharge the
treated wastewater to the Passaic Valley Sewerage Commision
(PVSC) treatment plant instead of direct discharge to the
river. The viability of this option will depend on the PVSC's
willingness to accept this discharge for treatment.
the PVSC's Rules and Regulations Concerning Discharges to the
Passaic Valley Sewerage Commisioners Treatment Works contains
applicable Federal ARARs since these rules and regulations
were developed pursuant to the requirements of the Federal Clean
Water Act. These rules and regulations are available for review
in the administrative record. In addition, the Federal pretreatment
program has been delegated to the State of New Jersey based on
the finding that the State program requirements are at least as
stringent as the Federal requirements. Therefore, the attainment
of the State pretreatment ARARs in Table V will also ensure that
the corresponding Federal pretreatment requirements are attained.
The PVSC treatment plant is designed to treat conventional pollut-
ants as well certain as toxic and non-conventional pollutants.
For dioxin, DDT, and hexachlorobenzene, which are not specifically
addressed by the PVSC rules and regulations, the direct discharge
water quality criteria based effluent limitations will be
considered relevant and appropriate to the pretreated effluent.
10. This ARAR pertains to Alternatives IV and VIB only.
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-60-
Requirement Summary
Table V , .
New Jersey State AHAHs That Mill Be Attained By. the Selected Alternative
Prerequisite/Application Regulatory Citation
A facility located in the
1OO year Cloodplain "uat
be designed, operated and
maintained, *p prevent, wa,i
of any, hazardous waste. ,un,le»p ,
the owner or operator can snow
that the waate can be removed
safely, before floodwatars
reach the facility.
Location Standards for New Hazardous 7s26«lO.3(a)l
Haste Pacilitiea - Construction Mlthin
the'1OO year floodplain
footnote
1,2.3
Container storage area* Must
have a containment eystesi
that is capable of collecting
and holding spills, leaks,
and precipitation.
All hatardons waste and
hazardous waste residues Bust be
resioved froa the containsient systt
at closure.
Unless the owner or operator can
demonstrate that the solid waste
removed from the containment syst
at cloaure is not a hazardoua
waste* the owner or operator bee
a generator of hazardous wast*.
Os«
•nd Management of Containers
I
7s2f*10.4(b)l et. seq.
7s26«*lo.4(c)l
7t26»10.4fc)2
2.3
Tanks shall have sufficient shell Tan
strength and, for closed tanks*
pressure controls to ensure thet they
do not rupture or collapse.
General operating requirements for •
tanks include the following!
o Hastes and other material that are
incompatible with tank material shall
not be placed in the tank.
'he owner or operator shall use appropriate
trola to prevent overfilling.
is
I
7t2C«lO.S(b) et. seq.
7!26*10.5(c) et. seq.
2.3
-------
Requirement Summary
Above ground storage tank* Must have
a containment system comparable to
containment ayatema Cor containers.
The owner or operator aha11 inspect i
overfilling control equipment, data I
gathered from monitoring devices,
monitoring equipment* tank construction
materials, and the general condition of
areas surrounding tanka at leaat once a day.
At closure, remove.all hazardous waste from
tanka, discharge control equipment, and
discharge confinement atructurea.
Repair any leak, crack or wall thinning.
- 61 -
erequiaite/Application
Regulatoiy Citation.
7t26«10.5(d)l at. aeq.
7t26»10.S(e)l et.
Footnote
7t26*10.S(e)6(h)l
7i26alO.S(eH
A groundwater monitoring ayatern ahall be
established to prevent the contamination
of groundwater.
Cover or otherwise manage the hasardoua
waate landfill so that wind diapersal of
hazardous waate ia eliminated.
Ignitable, corrosive and reactive waste shall
not be placed in a hasardoua waste landfill
unless the waate is first treated to render
it nonignitable, noncorrosive and/or
nonreactive.
Incompatible waates shall not be placed
in the aame cell of a hasardous waate
landfill.
Bulk liquids* non-containerised liquids,
waatea containing free liquida and acute
hasardoua waate ahall not be placed in
a hasardous waate landfill.
Liquid waste of small quantity may be
placed in a hasardous waate landfill.
All empty containera ahall be crushed
flat, shredded or reduced In volume prior
to disposal.
Hasardous Waste Landfills
7s26410.8(e) et. aeq.
7(26*10.8(e) et. seq.
7t26«10.8(e)8
*
7t26«10.8(e)9
I
7t26*10.8(e)10
7t26*10.8fe)11
7t26-10.8(e)12
2.3
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- 62 -
Requirement Summary
Mo odor* shall be detectable off-*site.
Liquid wastes miied with absorbent
siater ial may be placed in a hazardous
waste landfill.
,The .owner. 4>r operator of • hasardous
waste landfill shall supplyt a siap showing
the locations* dimensions, snd depth of
each eelIf contents of each cell, and the
approximate locations of each hasardous
waste in each celL.
Liners and final covers shall be inspected
for uniformity, damages* etc..
Prerequisite/Application
Regulatory.Citatton
7126^10.I(e)17
7t26-10.l(e)20
7t26il0.8(f) et.
Footnote
7t26«10.l|h) et. seq.
The owner or operator shall close the
hasardous waste facility in a manner
that minimises further maintenance and
controls.
General Closure Requirements
The owner or operator shall have a written
closure plan.
The closure plan shall identify the steps
necessary to close the facility.
7s2«*9.l(b)
7t2C.9.f(c)
7I264«.f(e) et.
2.3
At final closure of a hasardous wast*
landfill or any cell therein* the owner
or operator shall place final cover
to provide longterm minimisation
of migration of liquids into
the landfill.
The final cover shsllt
o consist of a vegegative top cover
o consist of a drainage layer
o consist of a liner system
ccomodate aettling
Specific Closure Requirements
7t2€sl0.t(i) et. seq.
I
7t26«lO.1(1)2
2,3
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- 63 -
Requirement Summary
Prerequisite/Application
The owner or operator shall consider as part
of closure st least the following!
o the type and amount of waste
o the mobility of the wsste constituents
o site location, topography, and surrounding
land uae
o Climste
o Characteristics of cover material
o Geologic and soils profiles
o Surface and subsurfsce hydrology
Regulatory Citation
7s26*l0.t(i)4
footnote
Post closure care shall continue
for 3O years after the date of
completing the closure.
General Post Closure Requirements
712«.9.9 (a) et seq.
2.3
A owner or operstor must
establish financial assurance.
Financial Requirements for
Facility Post Closure Care.
7s26at.ll(a) et seq.
2,3
Naintain the function
of the final cover, continue to
operate the lea'chate collection
system, maintain and monitor the
leak detection system, prevent
run-on and run-off, maintain gas
collection system, maintain and
monitor groundwater monitoring
system, protect and maintain benchmarks,
restrict access.
Specific Post Closure
Requirements
7i26-10.1(1)5 et seq.
2,3
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- '64-
Requirement Summary
Permits to construct and
certificate to operate required
for .new or altered air pollution
control appuratu* and equipment.
Requirement* for the storage,
tranafer and use of toiic
volatile organic substance*.
Requirements for toiic substance
emissions from control apparatus.
*
Toiic Volatile Organic Compound*
must be discharged from a point source
at least 4O feet above grade and
at least 2O feet higher than
the nearest human use occupancy.
Prerequisite/Application
Mew or Altered Air Pollution
Control Devices
Use of Listed Toiic Substances
Discharge off Toiic Volatile
Organic Substances
Regulatory* Citation
7s27«l et. seq.
7s27*17 et. seq.
7i27.1C et. seq.
7t27*17 et.seq
7t27*17.4 et,
Footnote
A permit shall be obtained for
the construction or alteration of
any structure or permanent fill
along, in, or across the channel
or flood plain of any stream.
A permit must be obtained prior
to the development of waterfront
upon any navigable waterway.
waterfront development means docks,
wharves, piers, bulkheads, bridges,
pipelines and dredging operation*.
Construction Within •
Flood Plain
7ta«3.13
Those person* who presently
discharge or plan to discharge to
the surface water* of the State •
must apply for a NJPOBS permit
which grants spproval for such
discharge. Pec*ittees currently
holding a Federal NPDBS permit are
exempt but must apply for a State
NJPOES permit within sii
months of expiration.
Discharge to Surface
Water
7sl«A«l et. seq.
§,10,11,12
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-65'-
Peouireaent 8
Prerequisite/Application
Persons who plan to discharge to
surface waters of the state aust
first appy for and receive • discharge
allocation certificate which allocates
the effluent limitations that the
facility must Meet initially.
Regulatory Citation Footnote
""•^•"^•^"•"^^^^ "^•'•^•••""•"^ . ^_m^_^_^M_
7sl4A*2.1(n
!•• ' I •• I ., I..- I I. . , 1 f . I .4i -.
Those persons who presently
discharge or plan to discharge
to the land or groundwater of
the atate siust apply for a NJPDE8
perait which grants approval.
Discharge to Land/
Groundwater
7sl4A<*l et. sea.
13,14
Persons diverting aore than.
10O,OOO gallons of wster per
day (7O gpa) frost surface or
groundWaters shall obtain a
water supply allocation
petalt.
Mater Diversion
7tlf et, sea.
15,11
Certain sewer systeas are
prohibited from accepting new
tievins to sewer, lines.
Sewerage Facility Tie«ins
7t9»13.1 et seq.
17
Penlts aust be obtained for
the drilling, boring, coring
or excavation of any well. All
abandoned wells aust be sealed.
Neil Drilling snd Sealing
7tlO.ll
II
Owners or operators of new and
existing aajor facilities and
cleanup organisations aust file
with the NJDEP. Hajor facilities
include but are not Halted to any
appurtenance that is used or
capable of being used to
refine, produce, store, handle,
transfer, process or transport
petroleua or other hazardous
substances.
Storage and Transfer of
Petroleua snd Other
Hasardous Substances
7tlB et seq.
19
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- 66 -
Footnotes for Table V
1. All New Jersey State ARARs are for the selected alternative
only. In come cases, administrative requirements,-* auch as
permitting requirements are cited above. Although these are
not considered ARARs, the technical requirements
associated with the permits are. For additional specific
requirements, the reader is refered to the regulations cited
below.
2. Statutory citation: N.J.S.A. 13;1E*1 et seq.. Also known as
the Solid Waste Management Act.
3. Additional specific requirements may be found at N.J.A.C.
7:26«1 et seq.
4. Statutory citation: N.J.S.A. 26:2C-»9.2 et seq.. Also known as
the Air Pollution Control Act.
5. Additional specific requirements may be found at N.J.A.C.
7:27 et. seq.
6. Statutory citation: N.J.S.A. 58:16A-50 et seq.. Also known
as the Flood Hazard Area Control Act.
7. Additional specific requirements may be found at N.J.A.C.
7:8*3.5.
8. Statutory Citation:
9. Statutory Citation: N.J.S.A. 58:10A-»1 et seq.. Al«o_Jcnown as
the New Jersey Water Pollution Control Act.
10. Additional specific requirements may be found at N.J.A.C.
7:14A«1 et seq.
11. NJPDES Toxic Effluent Limitations for discharge to the
surface waters of the State of New Jersey * N.J.A.C. 7:14A?
1 et. seq.. Appendix F. These limitations are promulgated
regulations for the discharge of toxic substances to surface
water. The regulation outlines the criteria for developing
the chemical specific limitations listed below. These
limitations are therefore applicable. Where two numbers
appear in the column, the limitation on the left indicates a
maximum weekly limitation, with the number on the right
indicating a monthly limitation.
BASE/NEUTRAL-ACID EXTRACTABLES NJPDES Toxic Effluent
Limitation (ug/1)
2,4,6«,Trichlorophenol 115/260
2«Chlorophenol 35/125
2,4*Dichlorophenol 23/150
Phenol 17/40
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- 67 -
BASE/NEUTRAL*ACID EXTRACTABLES NJPDES Toxic Effluent
continued Limitation (ug/1)
Benzoic Acid
2«Methylphenol
4«Methylphenol
2,4,5«Tr ichlorophenol
Acenaphthene
l,2,4tfTrichlorobenzene 45/90
Hexachlorobenzene 20/40
2<4Chloronaphthalene
l,2<*Dichlorobenzene . 40/110
l,3«Dichlorobenzene 25/35
l,4nDichlorobenzene 18/45
Fluoranthene 16
Naphthalene 35/105
Bis(2-rethylhexyl)phthalate
Di*N«butylphthalate
Benzo(a)anthracene
Anthracene
Fluorene
Phenanthrene 35/105
Pyrene
Benzyl alcohol
2«Methylnaphthalene
VOLATILE ORGANICS
"Benzene" 21/57
Chlorobenzene 23/45
l,2«Dichloroethane 30/85
l,l,l«Trichloroethane 25/65
lfl4Dichloroethane 25/65
Chloroform 20/40
1vluDichloroethene
trans*il,2*Dichlorethene 25/65
Ethylbenzene 430
Methylene Chloride .
Tetrachloroethene
Toluene 18/35
Trichloroethene 25/65
Vinyl Chloride 25/65
Acetone
2tButanone
Carbon Disulfide
4«Methyl-2*pentanone
Total xylenes
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- 68 -
HERBICIDES, PESTICIDES,
AND PCBs
NJPDES Toxic Effluent
Limitation (ug/1)
4,4fDDT
4,4iDDE
4,4nDDD
Alpha-endosulfan
2,4*D
2,4,5-T
2,4«DB
Dinoseb (DNBP)
2,3,7,8-TCDD
INORGANIC PARAMETERS
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selinium
Silver
Zinc
Total Cyanide
Total Phenol
Nitrate Nitrogen
OTHER PARAMETERS
Total Organic Carbon (TOO
Total Suspended Solids
pH (standard units)
Petroleum Hydrocarbons
Total Toxic Organics-
Total Volatile Organics
Total Dissolved Solids
Suspended Particulates
* BMDL means below minimum detection limit. Minimum detection
limit for 2,3,7,8«TCDD as defined by 40 CFR 136 is
0.002 ppb.
0.001
14.0
32/90
1500/3300
14/25
420/790
BMDL *
200/305
50/115
5.3
0.012
44 tri
0.29 hex
4.0
0.75
O.O0057
7.1
0.12
47
3.5
/40,000
30,000/50,000
6-9
10,000/15,000
12. Treatment of
limitations
waters. In
are based
Limitations
Wastewaters * NJAC 7:14A*1 et seq., defines
for discharges of toxic substances to surface
some cases, limitations of individual compounds
on and similiar to NJPDES Toxic Effluent
(see reference(11)). Other limitations are
dc.,.ved based-on Nat/.ono? Categorical Pretreatment standards
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- 69 -
(40 CFR 413, 415, and 433), as required by the Clean Water
Act of 1977. Development of some chemical class limitations
are derived from Pesticide Chemicals Point Source
Pretreatment Standards and Best Available Technology (BAT),
which are considered appropriate and relevant.
BASE/NEUTRAL4ACXD EXTRACTABLE COMPOUND
Treatment of waste
water limitation (ug/1)
2,4,€*Trichlorophenol
2*Chlorophenol
2, 4
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- 70 -
2«Butanone
Carbon Disulfide
4*Methyl-«2-»pentanone
Total xylenes
0.012 ++
0.004 ++
0.0011 ++
32/90
1500/3300
790/1900
14/25
420/790
0.002 +•»•
HERBICIDES, PESTICIDES,
AND PCBS
4,4*DDT
4,4-DDE
4,4*DDD
Alpha«endosulfan
2,4*D
2,4,5«T
2,4*DB
Dinoseb (DNBP)
2,3,7,8«.TCDD
INORGANIC PARAMETERS
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selinium
Silver
Zinc
Total Cyanide
Total Phenol
Nitrate Nitrogen
OTHER PARAMETERS
Total Organic Carbon- (TOO
Total Suspended Solids
pH (standard units)
Petroleum Hydrocarbons
Total Toxic Organics
Total Volatile Organics
Total Dissolved Solids
Suspended Particulates
4 concentrations noted -to be in TTO limitation.
++ minimum detection limit as defined by 40 CFR 136.
+++ toxic volatile organic substances. Mass limit shall be 0.1
Ib/hr for individual compounds and 0.5 Ib/hr for the sum total,
13. Statutory Citation: N.J.S.A. 58:10A-1 et se£.. Also known, as
1000/3000
260/690
120/230
360/1100
400/600
48/110
170/360
660/2200
6«9
100,000/150,000
2,130/2,130
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- 71-
14. Additional specific requirements nay be found at N.J.A.C.
7:14A«1 ct seq.. *>
15. Statutory citation: N.J.S.A. 58A:1 ct seg.. Also known as
the*Water Supply Management Act.
16. Additional specific requirements may be found at N.J.A.C.
7:19 et seg..
17. Statutory citation: N.J.S.A. 58:10A«1 et seg.. Also known as
the Water and Sewer Laws.
18. Statutory citation: N.J.S.A. 58:4A-14. Also known as the Well
Drilling and Pump Installers Licensing Act.
19. Statutory citation: N.J.S.A. 58:10-23.11 et al.. Also known
as the Spill Compensation and Control Act.
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- 72 -
Table VI.
Mew Jeraey State HUM a That Mill Mot Be Attained BV the Selected alternative
I
Requirement Suawary Prerequisite/application Hequlatory Citation footnote
A landfill that is uaed for, . Haaacdoos Naato Landfills 7t2C«lO.t(e) at.
the disposal of hazardous
waste shall have a liner !
ayste« designed to prevent
any Migration of wastes out
of the landfill.
Landfilla used for the diapoaal ' 7t2C«10.t(d) at. aeq.
hatardoua waste ahall have a
leachate collection ayatern.
No waate diapoaal ahall occur
'within ZOO feet of the property
boundary.
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- 73 -
Footnotes for Table VI -
1. Statutory citation: N.J.S.A. 13:1E-1 et. seq.(At»o known
as the Solid Waste Management Act). Additional information
regarding the requirements for hazardous waste landfills.
.may be found at N.J.A.C. 7:26«tl et. seq.. Since the Solid
Waste Management Act encompassess the requirements set by
the Federal Resource Conservation and Recovery Act (RCRA),
Federal RCRA ARARs that are waived will have state
equivalents that will also be waived.
2. Although leachate will be collected as a result of pumping
and treating groundwater within the proposed sluury wall,
the leachate collection system will not attain the minimum
RCRA requirements including a leachate collection system
above and between liners.
3. Buffer zone is a state ARAR which will be waived since the
site conditions, i.e., size, does not allow 200 feet of
setback.
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- 74 -
Table VII
Other Cleanup Standards
BASE/NEUTRAL.ACID EXTRACTABLES
Health
Advisories(1)
(ppb)
Soil
Cleanup(3)
(ppb)
2,4,6-Tr ichlorophenol
2<*Chlorophenol
2,4f*Dichlorophenol
Phenol
Benzoic Acid
2«Methylphenol
4*Methylphenol
2,4,5*Trichlorophenol
Acenaphthene
l,2,4«Trichlorobenzene
Hexachlorobenzene
2#Chlor©naphthalene
l,2«»Dichlorobenzene
l,3«Dichlorobenzene
1,4«Dichlorobenzene
Fluoranthene
Naphthalene
Bis(2«ethylhexyl)phthalate
DifN^butylphthalate
Benzo (a)anthracene
Anthracene
Fluorene
Phenanthrene
Pyrene
Benzyl alcohol
2<»Methylnaphthalene
VOLATILE ORGANICS
Benzene
Chlorobenzene
1, 2f»Dichloroethane
l,lrlnTrichloroethane
lfl«Dichloroethane
Chloroform
1,l^Dichloroethene
trans-.!,2-.Dichlorethene
Ethylbenzene
Hethylene Chloride
Tetrachloroethene
Toluene
Trichloroethene
Vinyl Chloride
Acetone
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
1,000
1,000
1,000
1,000
1«000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
.r,ooo
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- 75 -
VOLATILE ORGANICS continued
Health
Advisories(1)
(ppb)
Soil
Cleanup(2)
(ppb)
2i»Butanone
Carbon Disulfide
4«Methyl*2«pentanone
Total xylenes
1,000
1,000
1,000
1,000
HERBICIDES, PESTICIDES,
AND PCBS
4,4*DDT
4,4«DDE
4,4*DDD
Alpha^endosulfan
2,4«D
2,4,5#T
2,4*DB
Dinoseb (DNBP)
2,3,7,8-TCDD
INORGANIC PARAMETERS
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selinium
Silver
Zinc
Total Cyanide
Total Phenol
Nitrate Nitrogen
OTHER PARAMETERS
Tt>tal Organic Carbon (TOO
Total Suspended Solids
Petroleum Hydrocarbons
Total Toxic Organics
Total Volatile Organics
1.0
20,000
3,000
100,000
170,000
400,000
1,OOO
100,000
4,000
5,000
350,000
12,000
100,000
1,000
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- 76 -
Footnotes for Table VII .
1. Health Advisories *» Guidance received from appropriate health
agencies such as the Center for Disease Control (CDC) and the
New Jersey Department of Health (NJDOH). Considered as other
guidance to be employed in the implementation of the selected
alternative.
The concentration of 1.0 ppb of dioxin is a soil concentration
that was developed by the CDC and has been applied
consistently at cleanups throughout New Jersey.
A risk based 2,3,7,8-TCDD concentration of 500 nanograms per
square meter has been developed by the NJDEP to be employed
during cleanup of surfaces contaminated with dioxin. (e.g.,
trucks, backhoes, etc.). This concentration of dioxin has been
employed in the • past to assess the performance of
decontamination procedures.
• i
2. Soil Cleanup Standards •* These standards are not yet
promulgated, but have been accepted and used by the NJDEP.
They are therefore presented here for consideration as
appropriate and relevant requirements.
•
The concentration noted in each organic category are for each
compound individually or the total sum concentration of that
class of compound, e.g., the total concentration of base
neutral compounds cannot exceed 10,000 ppb. Inorganic
concentrations are for individual elements. Concentrations
given are based on best professional judgement, risk
assessment, best available technology (detection limits), or
known average background concentrations.
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- 77 -
•eet the ARARs for tanks, containers and effluent quality during the
remedial action. As a general rule, the remedial action should not result
in any new Instances of non-attainment of ARARs, except as provided by
Section 121(d)(4). In contrast, instances of non-attainment of ARARs which
exist prior to the commencement of remedial action generally cannot be
corrected until the remedial action (or a portion of the remedial action)
has been completed. The timing of the attainment of ARARs listed in Tables
III and V will be in accordance with the above principles.
The selected remedial alternative described in Section IX of this ROD will
be designed to meet all pertinent ARARs and other cleanup standards except
those listed in Table IVB and VI:
The RCRA land disposal ban
The RCRA standards for landfill design
The New Jersey Solid Waste Management Act requirements for landfill
design, requiring a liner system and a 200 foot buffer cone
For the reasons given in item (B) under Additional Considerations Concerning
Alternative 3 in Section VII of this ROD, Section 121(d)(4)(B) of CERCLA
allows the selection of the chosen remedy despite the fact that it does not
comply with the RCRA land disposal ban or landfill design standards.
Similarly, Section 121(d)(4)(B) also allows for selection of the chosen
alternative despite the fact that it does not comply with the New Jersey
Solid Vaste Management Act requirements for landfill design. In addition,
the 200 foot buffer cone requirement (no disposal within 200 feet of the
property line) is technically impracticable given the site dimensions and
would provide no significant added protection given the presence of
hazardous substances already in the ground near the property' line. These
circumstances allow for the selection of the chosen alternative pursuant to
Sections 121 (d)(4)(C) and (D) despite the fact that it will not comply with
the buffer cone requirement.
IX. Description of the Selected Alternative
The evaluation of remedial alternatives presented in Section VIII of this
document determined that Alternative 3 is the most protective of the
alternatives considered in the Feasibility Study. However, several
modifications of Alternative 3 would make it more protective including:
1. The remedy shall be designed to attain the cleanup standards listed
in Tables III, V, and VII of Section VIII, which include a more
stringent soil, cleanup standard for dioxin as well as more
stringent requirements for flood control.
f
2. Drums containing hazardous substances but containing less than 1
ppb of dioxin shall be transported off-site for treatment or
disposal.
3. A Feasibility Study shall be performed at least every two (2) years
following the installation of the remedy to develop, screen and
assess remedial alternatives. These Feasibility Studies will
evaluate the performance of the remedy as well as new and
alternative technologies.
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- 78-
Tbe components of Alternative 3 with the above Modifications axe described
below:
1. Construct a slurry wall encircling the site tying into the silt layer
underlying the site._
2. Construct a flood wall and appurtenances to protect the site from the
100 year flood. Such flood wall shall conform to the "Specifications
and guidances of the U.S. Army Corps of Engineers and the NJDEP and
•hall include as a design consideration the impact of the proposed
Passaic River flood control project.
3. Disassemble and decontaminate all non-porous permanent structures and
•aterials to the maximum extent practicable for off-site reuse, recycle
or disposal.
4. Transport all drums containing hazardous substances but containing less
than 1 ppb of TCDO off site for treatment or disposal.
5. Demolish all remaining structures on site and secure all materials
contaminated above 1 ppb of TCDD on site. Secured materials shall be
segregated to the maximum extent practicable to afford access to and
facilitate removal of more highly contaminated materials, should such
removal be selected as a remedy at a later date.
6. Stabilize and Immobilize the contents of the remaining drums of dioxin
contaminated materials.
7. Locate and plug underground conduits and re-route active systems.
8. Haul, empty, spread and compact the contaminated materials presently
stored at 120 Lister Avenue; decontaminate the shipping containers for
off-site reuse7~xecyclB or disposal.
9.- Install, operate, -And. maintain a ground water withdrawal _system
designed to maintain a hydraulic gradient preventing the migration of
ground water from the volume contained within the slurry wall.
10. Install, operate, and maintain a treatment system for ground water and
other aqueous liquids. - '
11. Construct a surflcial cap consisting of suitable materials designed to
meet the requirements of the Resource Conservation and Recovery Act.
12. Implement suitable •monitoring, contingency, operation and maintenance
and site security plans to ensure the protection of human health and
the environment during and after the installation o'f the selected
alternative.
13. On-site placement and capping of the sludge generated from all
wastewater treatment processes until such time that an alternative
method of sludge management is approved.
14. Design, construct and operate the remedy to attain the cleanup
standards listed in Tables III, V, and VII of Section VIII of the
Record of Decision.
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- 79 -
15. Perform a Feasibility Study every 24 months following the installation
of the selected interim remedy to develop, screen and assess remedial
alternatives and to assess the performance of the selected remedy.
It should be noted that, although the cap described in the Feasibility Study
includes a layer of concrete at the surface, the RCRA regulations do not
specifically require the cap to have a concrete component. Since the
proposed concrete portion of the cap could Interfere- with future
modifications of the remedy which may be needed, the alternative described
above does not specifically call for a concrete cap.
The remedial alternative described above is consistent with the requirements
of the Comprehensive Environmental Response, Compensation, and Liability Act
of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization
Act of 1986 (SARA), and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 C.F.R Part 300. This remedial alternative, has
been determined to be consistent with Section 121 of SARA. In particular,
this alternative has been determined to provide adequate protection of
public health and welfare and the environment, to be cost-effective and to
be appropriate when balanced against the availability of Trust Fund monies
for use at other sites.
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- 80 -
X. Enforcement
As noted in the previous section concerning the background chronology, the
NJDEP has issued two Administrative Consent Order for the Diamond Shamrock
Site and EPA entered into a voluntary cost reimbursement agreement with
Diamond Shamrock.
EPA and NJDEP plan to negotiate with Diamond Shamrock for "the design and
implementation of the selected remedy. EPA intends that any agreement for
Diamond Shamrock to design and implement the remedy would be In the form of
a Consent Decree entered into pursuant to Section 122(d) of CERCLA.
XI. Cofinninity Relations
The discovery of 2,3,7,8-TCDD in the Ironbound Community in 1983 caused
grave concerns by the residents in the vicinity over the habitability of the
area, as well as fears related to the potential long term health effects of
the presence of TCDD in the environment.
Total or partial excavation and removal of contaminants from the site has
been encouraged by the public, however, it is noted that there is currently
no facility in the United States that can accept dioxin contaminated
materials from the site, nor is one anticipated in the near future. Lacking
the ability to implement an off-site removal in the near future, it is
believed that the community would accept, grudgingly, a containment
alternative that would minimize potential health and safety concerns until
such time that removal or treatment of contaminant materials becomes
realistically achievable. It therefore appears that the selected
alternative would satisfy those concerns. Specific comments from community
representatives are addressed In the Responsiveness Summary, which is
included as an attachment to this document.
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- 81 -
XIII.
Glossary of Terms and Acronyms
ARARs
CERCLA
DDT
Dloxln
EPA
Feasibility Study
NCP
NJDEP
Off-Site
PIRAP
RCRA
- applicable or relevant and appropriate
requirements of Federal and State
environmental laws
• the Comprehensive Environmental Response
Compensation and Liability Act*, as amended
by the Superfund Amendments and
Reauthorization Act of 1986
• Dichlorodiphenyl Trichloroethane
- 2,3,7,8-tetrachloredibenzo-p-dioxin, also
referred to as TCDD or 2,3,7,8-TCDD
• the U.S. Environmental Protection Agency '
- as used herein, "the Feasibility Study"
refers to the feasibility study performed by
Diamond Shamrock Chemicals Company for the
properties at 80 and 120 Lister Avenue
pursuant to two Administrative Consent
Orders issued by NJDEP
- the National Oil and Hazardous Substances
Pollution Contingency Plan (40 CFR Part 300)
• the New Jersey Department of Environmental
Protection
- as used herein, "off-site" refers to all
other areas than 80 and 120 Lister Avenue,
Newark, NJ
• Proposed Interim Remedial Action Plan
- the Resource Conservation .and Recovery Act,
as amended
Remedial Investigation
ROD
SARA
• as used herein, "the Remedial
Investigation" refers to the site
evaluations performed by Diamond Shamrock
Chemicals Company for the properties at
80 and 120 Lister Avenue pursuant to two
Administrative Consent Orders issued by
NJDEP
• Record of Decision
• the Superfund Amendments and Reauthorization
Act of 1986
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- 82-
Site - The Diamond Shamrock Superfund Site (also
known as the Diamond Alkali Superfund site) in
its broadest sense, is the former pesticides
manufacturing facility at 80 Lister Avenue and
the surrounding areas which have been
.contaminated by hazardous substances which
originated at 80 Lister Avenue. However, "the
site," as used in this Record^ of Decision,
refers only to the portions of the Diamond
Shamrock Superfund Site located at 80 and 120
Lister Avenue.
-------
APPENDIX A
RMpons !?•&••• Suonary
-------
RESPONSIVENESS SUMMARY
This Responsiveness Summary is divided into two parts.
Part I is the Responsiveness Summary for comments received at
the February 20, 1986 public hearing on the Feasibility Study
(FS) and for written comments on the FS. Part I was prepared
by the New Jersey Department of Environmental Protection
(NJDEP) with input from the U.S. Environmental Protection
Agency (EPA).
Part II in the Responsiveness Summary for comments received
at the August 11, 1987, public meeting on the Proposed Interim
Remedial Action Plan (PIRAP) and for written comments on the
PIRAP. Part XI was prepared jointly by EPA and NJDEP and the
responses represent the positions of both Agencies.
In both Parts I and II, similar comments from different
persons have been consolidated to reduce the need for
repetitious responses.
-------
CONFORMED COPY
Appendix A - Part I
Diamond Sbaaroek Sitt
80 and 120 Lifter Avenue
Newark, Eaaex County
Rev Jeraey
leaponaiyenesa Sunnary
for the
On-Slte Feasibility Study
February 1986
-------
•This community relations responsiveness summary, prepared as part of
the Record of Decision (ROD) is divided into the following sections:
I. Background of Community Involvement and Concerns
This is • brief history of community interest is the Diamond
Shamrock site and a chronology of community relation* activities
conducted by the Hew Jersey Department of Environmental Protection
(HJDEP) and the United States Environmental Protection Agency
(USEPA) prior to and during the Remedial Investigation/Feasibility
Study (RI/FS).
XI. Summary of Major Questions and Comments received during the
P*ublic Comment Period and NJDEP'a Responses
This is a summary of major questions and comments directed to
HJDEP and Diamond Shamrock during the February 20, 1986 Public
Bearing regarding the results of the Feaaibility Study and aent to
RJDEP during the public comment period. RJDEP'a responses are
included in this section.
*
III. Remaining Concerns
Discussion of remaining community concerns of which RJDEP, USEPA,
and Diaaond Shamrock should be aware in conducting the remedial
design and remedial actions at the Diamond Shamrock aite.
Attachments
A. Agenda and Fact Sheet distributed at the 2/20/86 Public Bearing.
B. List of Attendees at the 2/20/86 Public Bearing.
C. _List el Speakers at the 3/30/86 Public-Bearing.
D. Letters aent to NJDEP during the public comment period.
-------
I. Background of Community Involvement and Concerns
The discovery of dloxin contamination at the Diamond Shamrock site
stimulated active community involvement, especially among
reaidenta of the- Ironbound section of Newark. An organized
citizen group, Ironbound Reaidenta Againat Toxlca, ia •ppriaed of
•11 aignificant activities and included in all informal briefings
for local officials related to the Diamond Shamrock site. The
initiation of reaidential sampling and aubeequent remedial action
created increaaed awareneaa and involvement'on behalf of citizens
with respect to the activities of the New Jereey Department of
Environmental Protection (NJDEP) and the United States
Environmental Protection Agency (CSEPA) at Diamond Shamrock. On
several occasions the Department has consulted with this group
regarding atrategles for disseminating information to and
communicating with reaidenta regarding the sensitive iesue
concerning sampling and remediation of their propertiea.
Following is a chronology outlining community relations activities
over the pact aeveral years.
Chronology of Community Relations Activitiea
Event
•NJDEP released fishing advisories for reduced consumption of
White Catfish in the Paaaaic River. The River abutting 80
Lister Ave. vas closed for commercial fishing of American
Eels and atrlped bass.
6/2/83 •Briefing with NJDEP, USEPA, and New Jersey Department of
Health (NJDOH) for Newark officials.
- -Press conference during which time the Governor offered
alternate housing to affected residents.
^Commissioners Bughey (NJDEP) and Goldstein (NJDOH) met with
residents in Newark. Fact sheets were distributed.
6/8/83 -Public meeting (sponsored by Mayor Gibson) with NJDEP
(Tyler, Berkovitz), USEFA, NJDOH at Roosevelt Housing
Development.
6/10/83 -USEPA latter to residents re: dioxin sampling during week
of 6/13/83.
6/20/83 •Public meeting to discuss current findings with residents
(Governor Kean).
•/
6/83 -USEPA held several informal briefings with D. Cherot (Newark
Dept. of Health and Welfare) 4 Staff.
•USEPA initiated numerous door-to-door contacts re: ongoing
activities (L. Johnson 4 R. Cahill).
6/3/84 -NJDEP and USEPA officials met with residents re:
•tart of habitability •ampling.
-------
-NJDOH brought a mobile van to the Xronbound section to
provide resident* with information about dioxin.
-Command pott with State workers aet up at 17 Riverview
Court.
6/6/84 -State officials attended a meeting at Che Rooaevelt
Housing Project.
-HJDEP and MJDOB vent door-to-door to discuss residential
•sapling results. The Governor and other state officials
held a press conference in Newark and a •eating at a local
tavern to discuss these results.
6/8/84 -Public Meeting organised by Mayor Gibson at Roosevelt
Bousing Project (NJDEP officials in attendance).
6/13/84 -HJDEP cosnmmity relations visit and latter distribution to
residents re: stabilisation and containment action at Brady
Iron ft Metals, Inc.
6/18/84 -Press conference with Dr. Devling (USEPA).
-Press avent re: Federal Investigation Team (PIT)
demonstration at Hayes Park Eaat.
6/84 -HJDOH distributed fact sheets, questionnaires and addreaaed
questions re: health concerns in Ironbound.
8/9-11/84 -NJDEP aponaored Dioxin Public Information Open Bouse.
1/10/85 -NJDEP latter to residents re: eff-aite cleanup (AGO II)
and aampling activities (beginning 1/14/85).
2/18/85 -NJDEP informal briefing for Newark officials and community
representatives re: ACO's I ft II.
3/12/85 -NJDEP meeting in Newark to diacuss traffic logistics with
police department* fire department* and emergency response
coordinator.
3/14/85 -USEPA distribution of letters and consent forma to 17
residents re: residential aampling on 3/19/85.
4/2/85 -NJDEP letter (English and Spanish) to residents re:
parkway median remediation achedule on 3/19/85.
«.
6/19/85 -NJDEP Informal briefing with Newark officials and community
, repreaentatives re: atatus of the dioxin cleanup.
8/9/85 -NJDEP hand delivered lettera to residents and explained
sampling results from their property.
9/9/85 -NJDEP hand delivered letters to residents requesting their
cooperation for USEPAfs residential sampling during
September 1985.
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1/8/86 -NJDEP distribution of letter* (English and Spsnish) to
residents regarding January 11-16, 1986 street cleaning
activities.
2/20/86 -NJDEP Public Bearing (in Newark) to present results of
Feasibility Study and receive comments.
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II. Summary of major questions/and comments received during the
public comment period and NJDEP's responses
In December 1985, the Feasibility Study vas placed in the
following repositories for review: Newark Public Library* 5
Washington Street; Newark Public Library, 140 Van Buren Street;
Newark City Clerk's Office, 920 Broad Street; and HJBEP, 432 E.
State Street, Trenton. NJDEP issued press ralaasas and contacted
local officials, as veil as community representatives regarding
the availability of the Feasibility Study at these repositories.
/ •
On February 20, 1986 NJDEP held a public bearing to present tbe
results of, and raeaiva comments/questions regarding, tbe
Feasibility Study. (See Attachment A: agenda and fact sheet
distributed at the hearing). The hearing was held at St. Aloys.ius
Theater, 89 Fleming Avenue in Newark. In order to select the most
appropriate and accessible meeting location, St. Aloysius Theater
vas chosen in consultation with Mr. Arnold Cohen (Ironbound
Residents Against Toxica-IRAT), Mr. Michael Gordon (Attorney for
IRAT), as veil as local officiala (E. Bill, D. Cherot, B.
Martinez). Notification of the public hearing vas accomplished
through press releases and direct mailing of notices to local,
state and federal officials, as veil as concerned citizens.
Approximately 150 people attended although only approximately 80
people signed the attendance sheet (See Attachment B), and 11
people commented during the hearing (See Attachment C). Responses
to questions and comments, for the most part* vere not stated at
the hearing. The public comment period vas held from February 20,
1986 through March 21, 1986. In addition to the comments made
during the public hearing five letters vere received by the
Department during this period. (Sea Attachment D).
During the public bearing Mr. Button, Director of Environmental
Affairs for Diamond Shamrock, gave a presentation of six remedial
action alternatives that vare considered in the Feasibility
Study. These are:
1. No action;
2. In-situ slurry vail vith cap;
3. Ground vatsr pumping and treatment, vith in-situ slurry vail
and cap;
4. Excavation".with thermal treatment of materials vith over 7
parts per billion (ppb) dioxin coupled vith in-situ slurry
vail and cap;
5. Excavation and construction of an on-site landfill for the
materials vith over 7 ppb dioxin coupled vith a slurry vail
and cap; and
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6. Excavation* loading, and transportation of contaminated
on-site material* and off-site commercial disposal, a slurry
vail built for stability and ground water control during
excavation, and mitigation of migration of remaining dioxin
below the 7 ppb level after remediation.
Mr. Button then discussed Diamond Shamrock*a proposed remedial
•alternative which Includes a ground water pumping and treatment
system, in-sltu slurry wall* and capping.
Following is • summary, organised by subject* of all major
questIons/comments received by HJDEP at the public hearing and
during the comment period. Major subjects include:
* Permanent Removal;
* Efforts to Secure an Off-Site Disposal Facility;
* Development of a Licensed Dioxin Disposal Facility;
* Adequacy of Proposed Site Cleanup;
* Consideration of Technologies for Safe Excavation;
* Applicability of State Laws for Hazardous Site Remediation;
* Long-Term Site Maintenance;
* Containment Option;
* Proposed Alternative Vis a Vis the Passaic River; and
* Other Issues.
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8
Permanent Removal
Tht overriding and recurring theme expressed by the speaker* at the
.hearing vas that the. only acceptable remedial alternatives vould entail
the total removal of hazardous waste from the Diamond Shamrock site at
80 and 120 Lister Avenue. Community representatives appealed to NJDEP
to protect the interests of the Ironbound residents aad businesses who
have already experienced the hardships and stigma associated with
dioxin contamination in their neighborhood. The alternative proposed
by Diamound Shamrock is perceived by some residents and others aa a
continuation of the problem* rather than a remedy.
1.+ A disposal aits cannot be in Easex County. Total removal is
the only acceptable option.
Response: If implemented at the present time, the total removal option
would result in greater risk to community residents than
would the proposed remedial action plan. The disadvantages
of the total removal alternatives are discussed below:
The option of off-site land disposal without treatment is not
a viable one. There are currently no land diapoaal
facilitiea permitted for disposal of dioxin wastes, and
affective on Hovember 8, 1988, regulations promulgated under
the Federal Reaource Conservation and Recovery Act (RCRA)
will ban the land disposal and long-term storage of dioxin
waatea unless the waatea meet treatment standards, which are
achievable by incineration. A waiver from the land disposal
ban is available under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) (Superfund
law) authority for land disposal at the Diamond Shamrock site
- becauii^the alternatives "which comply* with' tne ban are less
protective than the proposed plan. However, CERCLA does not
.give-authority for auch a waiver for off-site-disposal or — -
storage.
Since there are no existing off-site commercial hazardous
waate thermal treatment units of adequate capacity for the
cleanup of the Diamond Shamrock site which are permitted to
treat dioxin or have pending applications to treat dioxin, an
eff-aite thermal treatment unit would have to be designed,
constructed and tested. In addition, the unit would have to
• be aited, another atep in the time consuming process of
implementing this remedy. Siting treatment and disposal
locations 'for wastes from CERCLA cleanups has delayed
cleanups in the past and would be expected to be especially
difficult for an incinerator capable of destroying dioxins.
It would take at least six years and possibly much longer to
implement a remedy which relies on off-site treatment.
+ All comments and questions are numbered for the purpose of cross
referencing the text.
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In addition* the excavation necessary for total removal
present* significant risks. The hazardous substances to be
•zcavated are far more concentrated than those substances
which were excavated at off-site properties. Of particular
concern would be the risk resulting from airborne releases of
hazardous substance*. While it has been suggested that
•xcavation could take place under a dome with th~e airborne
hazardous substances vented through carbon filters* this
technology has yet to be demonstrated in an application
similar to its possible use at this site.
By contrast, the proposed remedial action plan can be
implemented in approximately two years with minimal risks
during implementation. The proposed plan will provide
adequate protection of health and the environment much sooner
than alternatives involving total removal and it can be
supplemented by additional remedial actions in the future.if
feasible.
2.+ Ve understand that the cleanup plan proposes to place
dioxin-laden soils in a landfill on their property in this
area. ...All landfills will eventually fail. ...Have other
treatment technologies been considered here? ...The only
advantage seems to be a cheap and convenient way for Diamond
Shamrock to dispose of these wastes. This is not in the best
interests of the community. DEP'a fir*t priority should be
to provide maximum protection of public health and the
environment and not to make life "easy" for industry. Ve
hope NJDEP will not spprove this proposed plan but rather
consider cleanup options that will remove permanently,
destroy or detoxify the dioxin-laden soils.
Response: Diamond Shamrock and their contractor* IT Corporation, have
.considered the full range of potentially viable alternatives
in the Feasibility Study submitted to RJDEF and USEPA in
October of 1985. This document summarized the findings
of an extensive Remedial Investigation conducted in 1984
and 1985. Both of these documents were placed in public
repositories for review in December 1985.
The findings of the Feasibility Study Indicate that treatment
technologies for large quantities of dloxin-contaminated
materials are not sufficiently developed to warrant
recommendation at thia time. Additionally, there are
currently *m> approved disposal facilities available to accept
these wastes. Consequently, MJDEP is recommending securing
+ Paraphrased comment, received from Stephen Lester and Lois Gibbs.
Refer to Attachment D for letter.
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10
contaminated materiala on site. It is the position of HJDEP
that thia on-aite containment ia an interim aolution, and ia
recommended in order to atop the migration of hazardoua
materiala. Provisions will bs made to periodically review
the status~of available technologies in order to conduct
environmentally safe destruction of on-site materiala in the
future. **
The HJDEP believes that the propossd remedy is more
protsetivs of health and environment than total removal at
this time. With regard to any engineered aolution,
operational difflcultiea may develop at any time.
Accordingly, sufficient proviaona for proper operation and
maintenance of the remedy muat be included. In accordance
with Section 121 (e) of CERCLA, additional remedial actions
would be taken should the remedy prove to be ineffective;
however, HJDEP regsrds this as a remote possibility.
More speciflcslly, ths proposed remedy would require
operation and maintenance of a ground water pumping and
treatment system for the forseesble future. The pumping
would reveres ths pressnt direction of ground water flow and
would result in a net influx of groundwater into the
contained volume. In addition, the cap would be inspected
for erosion or crscking and rspairs would be made as needed.
Should a significant increaae in groundwater infiltration
occur, it would Immediately be detected, and rspairs could bs
made at that time.
Thermal treatment, which la currently the moat developed and
affective of treatment altemativea, waa found leaa
protective than the propoaed containment plan if implemented
at the preaent time (ass ths response to comment 11).
3.+ I fundamentally agree with the sixth remedial alternative
considered (i.e., excavation, loading and transportation of
contaminated on-aite materials for off-alts commercial
diapoaal). Since the decisions made here will be an
accommodation of existing law for any of the alternatives,
... perhaps an arrangement between HJDEP and USEPA to have
already established "dioxln-qualified" out-of-stste landfills
accept our dioxin waate... until Hew Jeraey has ita own
facility. Additionally, we both know there are ways and
means to excavate safsly without further contaminating air,
water, and"land, however coatly to Diamond Shamrock. ++
•f Paraphraaed comment received from Maria Del Tufo, R.T.. Refer to
Attachment D for letter.
++ Thia iaaue ia addressed later in thia Responsiveness Summary.
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11
Response: There are BO commercial facilities, either currently or in
the near future, available for the treatment or disposal
of dioxin-contaalnated wastes. We therefore believe
that the only viable alternative available is to secure
and contain all contaminated materials on site until an
appropriate technology becomes available. There are
questions to be answered regarding aafe methods~bf
excavation, identify areas most likely to be impacted,
and the means for addressing those potential impacts.
The NJDEP ia committed to a comprehensive study of
excavation risks and a means for controlling those
risks by requiring a feasibility atudy to be performed
•very two years.
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12
Effort* to Secure an Off-Sitt Disposal Facility
4.+ Diamond Shamrock ha* failad to comply with 7:26-1.4 by not
exploring all alternatives and failing to list detailed
reasons why off-site disposal is not available.
Response: Dlaaond Shamrock has, in fact, explored the possibility of
off-site disposal as evidenced by the development of
Alternative No. 6 which explored the possibility of off-site
disposal at • hyppthetically approved landfill and
incineration facility. This alternative baa been
rejected due to the reality that there are no currently
approved disposal facilities available in the United
States as noted in the response to comment II. Although
treatment or disposal sites may become available in the
future, ve cannot predict when or if thia will occur.
. RJDEP recognizes the need to respond to the situation aa
it is currently preaented. In addition, it la the
position of RJDEP that all potentially viable
alternatives have been investigated and evaluated by
Diamond Shamrock.
5. Diamond Shamrock has failed to fulfill ita obligation to
provide communications regarding the availability of off-site
options for disposal. The Feasibility Study does not contain
documentation of communication with hazardous vasta disposal
facilities. Thia prevents « meaningful evaluation of
available alternatives. Remember RJDEP especially requested
that this information be contained in the study back in
Auguat 1985.
Response: Although Diamond Shamrock did not preaent communications
regarding off-site disposal options vithin the Feasibility
Study, a response has been received by RJDEP subsequent to
the completion of the Feasibility Study. Although it la
. . known that there are no approved disposal facilities which
can accept the TCDD-contaminated reaidues from the Diamond
Shamrock site. Diamond Shamrock*! contractor, XT Corporation,
made Inquires at twelve facilities that accept waatea
containing PCB-contaminated residues. These disposal
facilities were selected aince PCB disposal facilities would
be most likely to accept TCDD wastes. All indicated that
waatea containing TCDD residues would not be accepted. USEPA
has confirmed the fact that there are no commercial treatment
or disposal-facilities that are permitted in the.United
States. This information was reviewed 'by RJDEP and forwarded
to Michael Cordon, Esq. contaminated soils at concentrations
up to 80 ppb. Facilities such as this offer promise for
future treatment options. -
One of eeveral comments received from Michael Gordon, Eaq. Refer to
Attachment D for letter. .
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6.
13
Diamond Shamrock baa not avaluattd the diapoaal of dioxin-
contaminattd aoil at licensed international diapoaal aitea.
.Response: NJDEP requested the evaluation of this alternative in our
reaponae to the Draft Feasibility Study. Diamond Shamrock'a
raaponae indicates that although dloxin-contamlnated soil
may be diapoaed of at one European facility* the
political and inatitutlonal conatrainta are such chat a
timely resolution would be unrealistic aince thia
facility baa been aatabliahed for local diapoaal
purposes. While MJDEP recognixea the benefita that vould be
realised by such overseaa diapoaal, we queation several
factore Including: Diamond Shamrock'a ability to
participate in such s plan; the time that vould
undoubtedly be required for implementation; the
appropriateness of such an extreme remedy in terms of
disposing of more than 70,000 cubic yarda of contaminated
materiala; and compliance with all regulations imposed
by the receiving country.
7.4- The City of Newark received correapondence from Veat
Germany'a Department of Environmental Protection indicating
that there ia a regiatered landfill for dioxin-contaainated
waste in Kaaael, Veat Germany. Director Alvin Zach, Newark
Department of Engineering, urged NJDEP to require Diamond
Shamrock to assess thia facility, aa well aa other
appropriate international diapoaal facilitiea.
Reaponaet At the requeat of NJDEP, Diamond Shamrock has investigated
Che possibility of such disposal of dioxin-contaminated
materiala. As indicated by the tone of the response, the
facility referred to in Vest Germany doea not aeek the
disposal of foreign TCDD-vaete materiala, citing political
conatrainta and local uaage preference. In addition, for
reaaona detailed in the previous response, we question the
viability and practicality of such a disposal option.
8.++ Request via correspondence from Mayor Gibson that NJDEP
require Diamond Shamrock to explore the use of USEPA'a firat
registered disposal site for dloxin in the united Statea.
The J.M. Buber Corporation in Texaa waa recently permitted to
accept dioxin wastes. Presuming that such a disposal
facility is available, storage of dloxin should not be
permitted in Newark.
•»• Comment received from Director Alvin Zach. Refer to Attachment
D for letter.
++ Comment received from Mayor Gibaon. Refer to Attachment D for
letter.
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14
Response: Investigation by NJDEP technical staff baa determined that
the Texaa facility referred to, at present* doea not have the
necesaary USEPA permit to treat dioxin. However* thia
facility *ay accept dioxin vaatea for raaeareh and future
engineering design purposes. The inapproprlatanaaa of thia
facility ia indicated by the fact that it will process a
maximum of only 0.5 pound/hour* and that it ia affective on
contaminated aoila at concentration up to 80 ppb.
Facilitiaa auch aa thia offer promise for future treatment
optiona.
9. Have you tried to locate any off-aita facliltlea where thia
material could ba taaporarily stored?
Reaponaes There are currently no facilities available in the United .
States that accept TCDD-contaminated wastes for aither
storage or diapoaal purposes. Section 3004(a) of the
Resources Conservation and Recovery Act (RCRA) prohibita land
diapoaal of TCDD materiala, affective November 8, 19880
further* Section 3004 (J) of RCRA reatrlcta storage of vaatea
prohibited from land diapoaal under most circumstances (ace
pagea 40641 - 40643 of the November 7, 1986 Federal Regiater
for the specific regulations). Evan if storage of these
vaatea vere poesible, such a facility doaa not axiat. aa
indicated previoualy.
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15
Development of a Licensed Dioxin Disposal Facility
10. Diamond Shamrock has not evaluated the aiting, permitting,
construction, operation, and maintenance of a new dioxin
disposal facility within New Jersey or anywhere else la the
world.
Response: Realistically* BJDEP recognizes the difficulties of
siting and permitting a new hazardous waste disposal facility.
for TCDD. Ve also recognize the desirability of ultimately
treating or removing the contamination from this site. This
is why the Record of Decision (ROD) will contain provisions
for periodically evaluating the feasibility of doing so.
Zn addition* as described previously in the response to
comment II, this option was evaluated and found to be less
protective than the proposed plan.
11. Entombment only prolongs the process; it does not solve the
cleanup problem. Diamond Shamrock should be required to
develop a licensed facility for the disposal of
dioxin-contemlnated soil.
Response: It is the responsibility of HJDEP to protect human health and
the environment. It la our position that the proposed plan
provides the greatest protection of ell the alternatives. In
addition* the containment alternative is considered an
interim measure until such time as the feasibility of other
treatment or disposal methods is proven.
12. The recommended alternative does not evaluate the cost and
legal constraints of seeking to become a licensed, permitted,
•olid waste or hazardous waste disposal facility within New
Jersey. This is what is being recommended by Diamond
Shamrock.
Response: Section 121(e) of CERCLA eliminates the need for any
federal, state and local permits for CERCLA remedial
actions. In addition. Section 121(d)(4) of CERCLA allows for
waivers of the applicable or relevant and appropriate
requirements of federal and state environmental laws under
certain circumstances. The ROD will include the
justification of such waivsrs. Finally, this site is not
considered to be a disposal facility in the sense that waste
materials from locations other than those originating at
the site wi,ll not be accepted.
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16
Adequacy of Proposed Site Cleanup
13. Diamond Shamrock has failed to evaluate the iapacta of Judge
Stanton'a order and opinion. These require the site
remediation to achieve the higheat level of cleanup that the
boundaries of our known technology will allow. —
Response: Judge 8teuton*a order requires the cleanup "to the greatest
extent feasible within the bounds of known technology."
Similarly* section 121(b) of CERCLA requires the selection
of a remedy that uses permanent solutions and alternative
treatment technologies or resource recovery technologies to
the maTlmum extent practicable. It is the position of
HJDEP that neither Judge Stanton'a order nor section
121(b) of CERCLA were intended to maximize the use of
technology as an end in itself* but as a meens for ensuring
the protection of health and the environment. Since the
alternatives which have a greater reliance on technology are
less protective than the proposed remedial action plan at the
present time, the proposed plan doee utilise known
technologies to the extent practicable or feasible for
protecting health and the environment.
14. This site produced chemicals for 63 years. There are
probably a lot more chemicals than Diamond Shamrock la
willing to deal with. Geologic and major engineering
judgements are being made baeed on two chemicals (dioxin and
DDT). "Vhat about the other chemicals at this site thet have
very different characteristics from dioxin and DDT?
Response: The risk assessment developed by Diamond Shamrock and their
contractor, XT Corporation, evaluated risks posed by all
chemicals detected in significant concentrations on site.
The evaluation was less detailed for chemicals which have a
minor contribution to the total riak.
15. Diamond Shamrock baa improperly developed a ground water
decontamination program based on the chemical characteristics
of two compounds when there are a hundred compounds
contaminating the site. The likelihood of success of any
ground water program must evaluate the mobility, toxicity,
etc. of all compounds present above the Mew Jeraey standard
of 100 ppb being used for ground water cleanups at industrial
sites. The Feasibility Study does not recognize the proper
cleenup goal of remediation until all contaminants are below
the 10 ppb standard.
Response: The recommended remedial alternative includes a ground water
pumping plen to reverse the downward flow of ground water
through the sand unit. The purpose of the pumping is to
prevent the migration of the contaminants beneath the cap and
within the slurry wall from moving off site. The pumped
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17
ground vater will then bt treated to remove all contaainanta
to level* appropriate for discharge to the Paaaaie River or
to a vaatevater treatment facility.
The proposed plan is not intended aa a ground water
decontamination program. It ia intended only Co prevent the
release of pollutants from the 80 and 120 Liater Avenue
propertiea to the ground vater. The cleanup of all ground
water contamination attributable to the Diamond Shamrock
aite ia outside of the aeope of the Remedial Investigation
and Feasibility Study. RJDEP ia committed to further
investigate ground vater contamination in the vicinity of 80
and 120 Lister Avenue and to implement additional remedial
actions, aa appropriate.
New Jeraey does not have a atandard of 10 ppb for ground
vater cleanups at industrial sites. Hew Jersey's Interim
ground vater criteria are established on a "per chemical"
basis. For volatile organic compounds, the levels
astabliahed are 5 ppb for aach carcinogenic compound and a
total of 50 ppb for noncarcinogenic compounds vhich do sot
have a federal Maximum Contaminant Level. Nonvolatile
organic compounds have individual criteria that can be
obtained from the Department*a Division of Vatar Resources.
It is NJDEP'a plan to satisfy the requirements for affluent
dischargee.
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18
Consideration of Technologies for Safe Excavation
16. Diamond Shamrock has failed to evaluate the impacts of known
cleanup and construction methodologies on the optiona
requiring excavation of materials, i.e. reverae preasure
• within a covered vork area. Thia means the evaluation of
alternatives presented is clearly misleading. Diamond
Shamrock relies on thia misinformation to eliminate any
optiona containing excavation of soils.
•espouse: As indicated, excavation of contaminated materials ia not
conaidered to be a viable option at thia time. When disposal
•itea or satlafactory technologies for treatment are
sufficiently developed, safe excavation methods will be
evaluated and implemented to the maximum extent
practicable. (See response to comments II and 13).
17. There are safe engineering technologies for the excavation of
contaminated soils. A structure can be built with negative
preasure to draw air in rather than out, thereby reducing the
emission of dioxln-contaainated particulatea into the
atmosphere.
Response: KJDEP ia cognisant of special techniques for such
construction. However, there are currently no available
treatment or diaposal facilities in use in the United
Statea for such contaminated materials. (See response to
comments II and 13).
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19
Applicability of State Lavs for Hazardous Site Remediation-^
18. Diamond Shamrock haa failed to evaluate the legal
requlrementa applied by NJDEP to ait« cleanups in New
Jersey. Thia prevents the evaluation of what lava will be
broken by the cleanup option aelected by Diamond Shamrock.
Reaponae: Under the Comprehenaive Environmental Response,
Compensation, and Liability Act (CERCLA) (Superfund Lav)
authority•.which allova for an on-site remedy that doea
mot attain all applicable or relevant and appropriate
requirementa of federal and atate lava* NJDEP ia proposing
implementation of a modified veraion of the alternative
that vaa propoaed by Diamond Shamrock. Furthermore,
justification will be provided in the Record of Declalon •
(ROD) under Section 121(d)(4) of CERCLA for thoae
requirementa which will not be met.
19.
The Feasibility Study ia incomplete and cannot be properly
evaluated (e.g.* there ia no llating/diacuaaion of atate lavs
that are applicable to the recommended alternative).
Reaponae: Although NJDEP notea that the Feaaibility Study doea not
diacuas relevant atate or federal regulationa, it ia the
responsibility of NJDEP to identify and evaluate
applicable or relevant and appropriate requirementa in any
enforcement action to ensure that the aelected alternative is
in compliance with relevant regulations. As indicated above,
the aelected remedy is being implemented under CERCLA
authority, which controls the legal requirementa. Although
CERCLA doea not require obtaining permlta prior to initiation
of remedial actlvitiea, CERCLA doea require that these
actions meet the substantive requirements of such permits.
20. Diamond Shamrock haa failed to evaluate the Nev Jersey
requirements for thickness and permeability of linera at nev
waate diapoaal locations. Diamond Shamrock's reliance on the
preaent silt layer is illegal.
Response: CERCLA allovs for the selection of a remedy which may not
meet all requirements under the circumstances described
in Section 121(d)(4). (Refer to response for comments 118
and 119 for further discussion).
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20
Long-Term Site Maintenance
21. Regardless of the selected remedial alternative* a long-term
monitoring program is necessary during and after the remedial
work to ensure environmental safety. The monitoring program
must provide data/information that is raadilj useable by
officials to assess damage to health and the environment.
The monitoring program should be paar reviewed by appropriate
scientists within and outside of government. The Essex
County Office of Environmental Health is available for
assistance in this regard.
Basponsa: RJDEP has the responsibility and capabilities to
establish a long-term monitoring plan. Indeed* thia is a
requirement of the selected remedy. HJDEF routinely
seeks the expertise of outside health agencies* as
neededt and informs them of programa established to protect
public health and safety. Toward this end we appreciate the
interest of the Essex County Office of Environmental Health.
•
22. It is difficult to comprehend maintaining this site in
perpetuity* which will ultimately happen if we do aot remove
it. Diamond Shamrock will be able to abandon this site after
30 yeara and the community will be left with the
responsibility of maintaining the aite forever. What is the
longest documented experience in operating a pumping system
of this kind? This is a temporary solution to a permanent
problem.
Response: Financial aaaurancea will be required of Diamond Shamrock
for continual maintenance of the site until auch time ae the
-contaminants -are -either removed or-no-longer pete A threat
to human health or the environment. There will be ao
"abandonment" of the site after 30 years* although-RJDEP
hopes that a permanent resolution will be realised
before that time. If subsequent negotiations with Diamond
Shamrock fail, NJDEP is committed to providing the
necessary financial assurances to implement the remedy.
•
Pumping systems are capable of indefinite operation.
Although pieces of equipment do wear out* all that is
required is component replacement. The same is true for many
. water treatment technologies that are currently in use by
weter companies throughout the stste and nation, such as air
•tripping tod activated carbon for the removal of certain
organic compounds, as well as filtration* flocculation,
aedlmentation* and ion exchange for other contaminants.
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21
23. Presently* the lav it written so that tht Resource
Conservation and Recovery Act (RCRA) requirements for a cite
cap terminate after 30 years. Diamond Shamrock can walk avay
"scot free" after 30 years. It is highly unlikely to operate
the proposed pumping system for 30 years. Diamond Shamrock
plans to leave this site after 30 yeara. «..
Response: These actions are being taken under the authority of CERCLA
which provides for operation and maintenance at Superfund
sites for an indefinite period. RCRA is being used to
provide technical guidance for evaluating and developing the
containment system requirements only. The proposed remedy
includes provisions for continual operation and maintenance*
aa well as monitoring* until contamination is removed or
treated to completion. These provisions will be specifled'in
a Federal Judicial Consent Decree* a legally binding document.
24. Diamond Shamrock has failed to properly evaluate the impact
to the environment and public health of their abandonment of
the site once the 30-year period of aite maintenance ends.
This failure is critical since Hew Jersey law requires
remedial activity until the site has been remediated.
Response: Aa previously noted* Diamond Shamrock cannot abandon the
aite after 30 yeara* Even if the Corporation goea bankrupt*
its financial guarantees would remain in affect.
25. It is misleading to aay that there ia an upward hydraulic
gradient at the aite. When the cap deteriorates and the pump
falia apart the natural hydraulic gradient will be downward
and .into the Passaic River. Diamond Shamrock ia propoaing a
temporary non-solution to a permanent problem.
-Response:-The selected remedy will be implemented with the approval
and proper financial assurance from Diamond Shamrock. Aa
such, maintenance of pumps and all structures will be
ensured, including monitoring activities to sustain their
affectlveness indefinitely. (See response to comments. 922
and 123 for further discussion).
-------
22
Containment Option
26. Major concern was expressed regarding the permanency of
Diamond Shamrock's recommended cleanup alternative. The City
of Newark (per D. Cherot) presumes that Diamond Shamrock's
recommended alternative is an interim meaaure and that the
NJDEP will not allow the aite to become a permanent hazardous
waste facility in Newark.
Response: The recommended remedy is considered to be an interim
measure. The recommendation is made because NJDEP
wishes to initiate alte remediation meesures now to reduce
the risks possd by ths aits. Sines no dispose} facilities or
treatment technologies are currently acceptable, any
recommendation other than some form of on-eite
containment would delay the initiation of remediation
until auch facilities become available or technologiea are
sufficiently developed. The duration of the proposed
containment remedy will depend on a number of factora
including the performance of the remedy, development of
meesures to minimize excavation risks, the development of new
technologies, and the availability of existing technologies
auch as incineration for dioxin wastes.
27. Where has containment of dioxin been permitted?
Response: Containment has been implemented at sites in Arkansas and
Ssvsso, Italy. Containment remedies for dioxin westes have
been selected by OSEPA for the Love Canal site and Hyde
Park Landfill in New York State.
28. Are you making a business decision, i.e., choosing an
alternative that will cost 95Z lees by storing it on site
rather than getting rid of it?
Response: NJDEP does not make "business decisions" regarding
cases that are being addressed by responsible parties. . The
propossd containment remedy is advocated by RJDEP because it
is presently the most protective alternative. NJDEP is
committed to recommending trestmsnt or removal when theee
can be reliably implemented. As indicsted in the
previous response, containment of dioxin wastss la being
implemented elsewhere.
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23
Proposed Alternative Via a Vit the Paaaaic River
29. Diamond Shamrock baa failed to avaluatc tha impact of
flooding upon the project and the propoaed use of thia area
for flood control by the U.S. Army Corpa of Engineerao
Reaponae: NJDEP ie aware of thia potential impact. Ve bare
tranamitted our concerna to Diamond Shamrock, and have
subsequently received their reaponae to our concerna,
•,--•"" indicating their willlngneae to cooperate with KJDEP, USEPA,
and the U.S. Army Corpa of Engineera. However, due to the
•agnitude of the Army Corpa project, the reaolution to thia
aapect of the selected alternative will be accompliahed
through coordination on the part of Diamond Shamrock with the
U.S. Army Corpa during the remedial deaign phaae of the
selected alternative. EPA ia.working with the U.S. Army
Corpa of Engineera to enaure that the flood control project
baa no aignlflcant adverse impact on the Diamond Shamrock
alte or other Superfund aitea on the Paaaaic liver.
30.
Diamond Shamrock baa not evaluated the current Paaaaic River
dioxin and DDT contamination and bow that relatea to moving
forward with thia recommended alternative.
Recponae: HJDEP baa received the reaulta of a Remedial Investigation of
the Paaaaic River conducted by Diamond Shamrock during
the summer of 1985. HJDEP ia currently evaluating the
findings of that study snd will requeat additional
studies, if neceaaary. Upon completion of our review,
and any additional investigatlona that are deemed
neceaaary, we will be requesting that Diamond Shamrock
proceed to prepare an additional Feaaibility Study to
develop remedial alternativea for the detected
contamination.
The remediation of the Paaaaic River sediments is outside of
the scope of the proposed remedial action plan, and will be
addreaaed through another Record of Deciaion.
31. The Paaaaic River flood project preaenta a aerioua conflict
to the encapsulation alternative. Thia iaaue needa to be
addreaaed. Proper operation and maintenance (O&M) ia alao a
critical concern.
Response: NJDEP ia avare of the Paaaaic River flood control project, as
well aa the need to secure the site from 100-year flood
conditions. Theee considerations will be addreaaed by
Diamond Shamrock in their remedial deaign. Diamond Shamrock
will consult with the U.S. Army Corpa of Engineers
regarding acceptable engineering deaign considerations.
Operation and maintenance of the propoaed remedy will be
addressed. .
-------
Other Issues
32. This 2/20/66 public hearing ia not fair in that the public
doea not have tbe advantage of knowing the position of
HJDEP. A bearing ahould be held after NJDEP makaa a deciaion
regarding the aite remedy. • ^
Raaponae: A public meeting vaa held on August 11, 1967 at vhich time
tbe Proposed Remedial Action Plan vaa presented to tbe public.
33. The recommended cancer riak factor aet by Diamond Shamrock is
not acceptable. DEP baa the responsibility to "get in on the
act". It ia Inappropriate for Diamond Shamrock to aet thia
standard.
Response: HJDEP agrees. The excess cancer riak typically *
employed by NJDEP for riak assessments ia 1 x 10 (a
one in one million riak factor). In addition, the cleanup
atandarda to be used for the aite vill be developed by
NJDEP and vill not be based on the acceptable riak
recommendations made by Diamond Shamrock.
34. What la the permeability of the ailt?
Raaponae: Permeability of the.allt at tbe aite baa been taated and is
on tbe order of 10 centimeters per second. Thia ia
•quivalent to a clay-type material. Additional teating
vill be performed to reconfirm thia in tbe design
phase. Monitoring vill be aatabliahed to anaure the
effectiveness of the remedy.
35. What ia NJDEP'a achedule for responding to Diamond Shamrock's
recommended alternative?
Raaponae: Late September, 1987.
-------
25
III. Remaining Concerns
The residents of the Zronbound community are disturbed by the
presence of hazardous wastes* especially dioxin, in their
community. As auch, sampling and cleanup activities conducted by
NJDEP and USEFA have not been veil received* and have generated
considerable fears and anxiety on the part of the cosssunity. It
is essential to maintain a strong community relations program
throughout subsequent cleanup aetivitiea in order to minimize
unfounded concerns. It is essential to emphasize that HJDEP views
the proposed remedy as an interim action, and that when
technologies for cafe removal or destruction become available,
they will be implemented.
-------
26
Attachment
A. Agenda and Fact Sheet distributed at the 2/20/86 Public Meeting.
B. List of Attendees at the 2/20/86 Public Meeting
C. List of Speakers at the 2/20/86 Public Bearing
D. Letters sent to NJDEP during the public comment period
-------
RV JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OP VASTE MANAGEMENT
BAZARDOUS SITE HZTZCAnON ADMINISTRATION
Public Buriai to lacaiva Coanaat on Feasibility Study
ragardinft
•0 and 120 tifttr Avanut, Vavark 9
Thursday* Pabruary 20* 1986
TsOO p.».
St. Aloyilua Thaatar
•9 Flavins Avanua
Vavark, «J
AGENDA
Opaaiag Rraarka
and Xatroductioas
Miehaal Catania. Daauty
Coaaiaaioaar* WDEP
2) Ovarriav of Projtct Status
Dr. Jorga Barkovits, Adviaiatrater
Hazardous Sita Mitigation Administrstion,
VJDEP
3) Vraaaatatioas Paasibility Study Mr. Villiaa Button, Diraeter
and Off-Sitt BaitadUl Action laTiroimantal Af/aira
Diasoad Shamrock Corporation
4) CooBtnts and Quaatiena
-------
STATE or Vcw .f«a*rr
or £vvnK»mic*TAi Paorjccrio*
FACT SHEET
•a
Feaaibility ftody
for
•0 and 120 Lieter Avenue
Vevark. KJ
Saeex County
Thursday, February 20. 1986
Site Deaeription* Tbt 10 Lifter Aveooe site occupies approximately 9.5 acres' in
the Zronbound aectioa of lewark. Zt ia bounded en tb« north by the Passaic
ftlver, en tbt east by th« foxvtr Strfttnt Otmleal Company (120 titttr
ATtnu<» aov evntd by Dlcaond fbanrock Corporation) • at tbt aootbtatt aorntr
by tbt Ouralae Company, and en tb« aoutb and vast by tha Sbanrin-ViUiau
Covpany. Altbougb praaantly inaetira* tba aita «•• oaad for •amifaetoring
varioua afrieultoral and apaeialty organic efeaaicala from 19U-1977. Xha
•oat aignifieant period ralatlra to contamination- ebaanrad at tba aitt la
from tba and ef Vorld War XZ to tba «id-1970a. During tbia ti»a. pasticidta
aad fbanozj barbleidaa vara tba priaary produeta amnvfaetttrad. Pioxin ajay
eccnr aa a coataainaat la thaaa produeta.
lacktrotmdt Coneam about tba potential anrironaantal lapaet ef dloxin in tbia
area daralopad aa information became arailabla regarding aonufacturing
procaaaaa vhicb bad tba potential to produce onvanted toxie by-producta
including dioxin. Zn tba Spring ef 1983 a comprehensive aampling program
vaa implemanted by tbt lev Jaraey Department ef Itnrironmtntal Protection
(KJ9EP) te ivrtacigate facilities which eight b*re produced elioxia. Tbe
preatnct ef dioxin at tbt 80 Lister Avenue aita vaa identified in May 1983.
Subsequent to tbia finding* dioxin vas also discovered in aevaral areaa
throughout tba Zronbound auction ef Hevark. Based en tba results ef initial
investigations* Diamond Shamrock entered into aa Administrative Consent
Order (ACO) with the RJDCP en March 13, 1984. Tbe* AGO requiraa that Diamond
Shamrock aacura tbe aita, prevent axpoaure to contamlnanta, determine the
extant ef chemical contamination, and complete a aite evaluation and a
feasibility atudy ef remedial alternatives. On December 20, 1984, Diamond
Shamrock entered into a aeeond ACO (ACO ZZ) with VJDFP vhicb requires the
investigation and cleanup ef all affected eff*site areas ef contamination in
the Zronbound section of Newark.
-------
-2-
Status: Almost all of the requirements af both ACO X and ACO XX bava bean
fulfilled by Diamond Shamrock. To data. Diamond Shamrock baa moated a
letter af credit for approximately $16 Billion in order to conduct the verk
outlined la both ACOa. Off-eite araaa bava bean remediated {eee attached
aummary af off*eite remediation)* contaminated aoila bava been traaaportad
mae* containerized, aad are being atored temporarily at 120 Liatar Avenue.
The Draft Feaalbility Study for SO Liater Avenue vaa completed, in December.
198rand placed in the following repoeitoriee for public revievx
(1) Vevark Public Library, VJ Befareace, S Washington Street. Vevark;
(2) Vavark Public Library, 140 van Suren Street, Vevark;
(3) Vavark City Clerk*a Office, 920 Breed Street, Vevark; aad
(4) VJDEP, 432 E. State Street, Trenton.
Written cemmenta regarding the Taaaibility Study ahould be aubmitted to the
Department prior to March 21, 1986 and forwarded tot
Crace Singer
Vev Jeraey Department of Environmental Protection
Batardoue Site Mitigation Administration
Office af Community Relations
CM 028
Trenton, VJ 08625
Summary ef temedial Alternatives Conaldered in the Feasibility Study
• i
An extanalva ecreening af available technologlea raaultad in the cenaideration ef
aix remedial action elternativaa. Thaae ara:
• Vo action;
* Xn-eitu alurry vail vith cap;
• Crowd vatar pumping aad treatment, vith ia-aitu alurry vail vith cap;
• Excavation vith thermal treatment af materiala vith aver 7 parta per
billion (ppb) dioxia coupled vith in-aitu flurry vail aad cap;
• Excavation and development af an en-alte vault for the materials vith
aver 7 ppb dioxin coupled vith a alurry vail aad cap; and
• Excavation, leading, and transportation ef contaminated en-alte
materials and off-aite commercial diapoaal, if available; a alurry vail
built for atabllity and ground vater control during excavation, end
mitigation ef migration of remaining diexin btlow the 7 ppb level after
remediation.
-------
-3-
tummarv of Off-Site laaadiation
According to tbe December 20, 1984 Administrative Conaant Order (ACO XX) batvaan
Diaaoad Shamrock aad tbe VJDEP,- tbe following areaa in tbe Xronbouad aection of
Vevark bare beea reaediated. '.•••.
_• Cenrail Trackst teaediated aad Conrail ia currently preparing the
•" *•- track for resumption of aerrice.
- . .'••'' ' ' g^.
9 *" fhervin Williams Spur at. teaediated aad service baa %eea raatored.
• leaideneeet Beaediatioa ia coaplete where acceaa baa beea granted.
9 Severe and Catch lasine: Severe and cateb baaina on Bayaond Boulevard
and Euclid Avenue have been.cleaned in accordance with tbe AGO.
* Brady Iron and Metala/Hildemann PropertyfMerria Canalt Excavation and
backfilling ia complete. All poet aamplea have baan taken; results
indicate ao contamination reaaina above 1.0 ppb. The aite vill ba
returned to ita original contour. Demobilisation of aquipaant aad
officaa ia ia progreaa. At tbe concluaion of remedial activities tbe
•ite vill be fenced. ' '
9 120 lister Avenue: Approximately 1,000 containers with contaminated
•oil have bean placed at tola aite (20,000 cubic yards) for temporary
storage. Approximately 800 of tbeae contain material froa tbe Brady
site.
Trailerat Decontamination of tbe mine trailers containing
aquipmant froa tbe SCA warehouse ia complete.*
itreat Vacuumings Tbia operation vaa completed in mid-January* 1986.
2/86
•JDD
-------
JERSEY DEPARTMENT OF ENVIRONMENTAL nOTECTZOM
PIVISION OF WASTE MANAGEMENT
•A2ARDOUS SITE MITIGATION ADMINISTRATION
FUBLIC HEARING TO RECEIVE COMMENT
FEASIBILITY ITDDT
AT
•0 AND 120 LISTER AVENUE
THURSDAY, DECEMBER 20, 1106 ;
7lOO p.a.
ST. ALOYSIUS THEATER
•9 FLEMING AVENUE
KEUARK, KJ
KAME
AITXLXATION
ADDRESS
v
•** . . - •
5-^V? -r
I
;.-i«W
•jif tLtJii \jJJiv
\,.\l$b~$ fart)
-------
MEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
•AZARDOUS' SITE MITIGATION ADMINISTRATION
PUBLIC BEARING TO RECEIVE COMMENT
FEASIBILITY STUDY
AT
tO AND 120 LISTER AVENUE
THURSDAY. DECEMBER 20, 1106 '
7iOO p.*.
ST. ALOYSIUS THEATER
•9 FLEMING AVENUE
•EVARX, *J
HAKE
AirauTioN
ADDRESS
r.-.f / £
• *
* •• '-•'
A/ j
"
v /
L*JLtf°1 (. U /!•/
' '
, i
•vca
-------
MME
AFFILIATION
ADDRESS
. I Y^
A M. \
I
V
-------
IKV JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
PUBLIC EARING TO RECEIVE COMMENT
FEASIBILITY STUDY
AT
•0 AND 120 LISTER AVENUE
THUUDAY, DECEMBER 20, 1966 *
7iOO p.«.
ST. ALOTSIUS THEATER
•9 FLEMING AVENUE
VEUARK, *J
HAKE
AFFILIATION
ADDRESS
4K
¥
-------
NAME
AFFILIATION
ADDRESS
7.
j:
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s /q .r///266 /^Sffig V. iT^NJ»
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-------
JERSEY DEPARTMENT 07 ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
PUBLIC BEARING TO RECEIVE COMMENT
FEASIBILITY STUDY
AT
•0 AMD 120 LISTER AVENUE
THURSDAY, DECEMBER 20, 1986 i
7tOO p.».
ST. ALOYSIUS THEATER
•9 FLEMING AVENUE
NEWARK, RJ
MAME
tfntuTioii
ADDRESS
Jrt *v~
JT
'•: f~?.»*~
- *?, V J
&
**,
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-------
BEV JERSEY DEFARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
•AEARDOUS SITE MITIGATION ADMINISTRATION •
PUBLIC BEARING TO RECEIVE COMMENT
FEASIBILITY STUDY
AT
•0 AND 120 LISTER AVENUE
THURSDAY, DECEMBER 20, 1986
7tOOp.«.
ST. ALOYSIUS THEATER
•9 FLEMING AVENUE
BEHARK, BJ
NAME AFFILIATION ADDRESS
Tl
.1 (
C/M
t
•
-------
tp«ak«ra at tht 2/20/66 Piaaend Shamrock Public B«ariat
Mr. Baaaia 6. Caarot, Director. Bavark Dapartaaat of Baalth and Vclfar*
Mr. Baary Martiaa** Couaeilaaa. City of Itevark
Mr. Alfia Zaeb* Director* Vtvmrk D«ptrt»«Bt of taglafttrlag
• • .._.-'••;
Mf. lAtKryn Sera, for lasts Couaty baeutiva Fatar Shapiro ^~
Mr. Miehaal Cordon, Attonty, Xroobound Comittat Agaiaat Toxic*
Mr. Arnold Cohaa* Zroabovad CovBltt** Agaiaat Toxic*
Mr. Victor Daloea* Adalaiatrator* Zroabouad Coagniaity Corporation
Ma. taaa Kopyataaaki, BxaevtiTa Diractor, Agtat Oraaga Vietisa of Vav Jaraay
Mr. Patar Montagu*, Coaaultaat
Ma. Juaa Kmattvaki, Xroabouad Coanittaa Agaiaat Toxica
Ma. faadra King, Baportar* *«* Jaraay Hatwork Vava
-------
-------
•
Newark
SOIf»iMO
•
• • •
^ •* •• '•
• • *
•
• . ••
February 21, 1»C
Mr. Michael P. Catania
Dtputy Commissioner .
N.J. Dept. of Environmental Protection
CN 402 .
Trenton, New Jersey 0862S . .-3 . tr
a* ft
RE: Public Hearing • Feasibility Study Per Pinal ftemediatioh
of the Diexin Csataaination at 80 Lister Avenue
Dear Mr. Cataniat
As a follow up to my testimony last night, concerning the above,
Z received a letter this morning from Wast Germany's Department
of Environmental Protection, dated February 18, 1916 (copy
attached), in response to my cablegram of January 29, 1986.
The letter indicates that there is a registered landfill for
dioxia contaminated debris in Kassel West Germany.
Z -would urge that you move to require that Diamond Chamrocfc
realistically assess not only this noted West German disposal
site, but, also other international disposal sites that are
properly designed and constructed to properly dispose of such dabris
•
The tipping fee at Xasse> is DM 211 per metric tonne, which trans-
lates at today's exchange of $91.IS per metric ton of waste
that would be landfilled.
Newark
-------
Niehatl F. Catania
latter
pabruary 21, 1116
taga 2
Pltaae aJviae «t, at «~"" *--*-• ——
vhtt atapa you plan to .- .:*...
"tba propar diapoaal at s-i«- cst.24...
Ah aarly iraaponst trould ba aioat a^r.-tcj.ai
Vary trulyvpura,
I«ch, P. I., Director
of Knginaariag
ALZsaa • .
•• •*••.'.' J ' i'
CCt Kannath A. Cibaon/* Mayer r
Hanry Mar tint z, Councilman* Caat Ward
Elton Hill, Busir.tit Administrator
Richard Dawtllin;. DEP, Conuniaaier.tr
-------
cmtirs cicMinoMOusi to* NMMBOUS u*ms. MC.
March*, 1986
Me. Grace Singer
lev Jeraey Department of Environmental
Protection
Haxardoua Mitigation Administration
CM 028
Treatoa, U 08625
Dear Ma. Singer:
Tba Citixtaa Clearinghouse la a national grassroots ergaaicatioa that
worka with community groups aeroaa the country conctrntd with problems cauatd
by haxardoua and toxic cheaicala. Vt arc coacaraad and troubled by tbt plan
proposed by Diamond Shamrock to clean up aoila contaminated with diozins in
the Zronbound neighborhood of Newark, la ire understand the cleanup plan,
Diamond Shamrock proposes to place dioxin laden aolls in • landfill on their
property la this area.
Given the growing acientific evidence documenting the failures of
landfills, «t are eurprieed. and disappointed that D£P ia even considering
thia aa an alternative.
Ve would expect that PEP is familiar with atndlea conducted at both
Princeton University and Texaa AIM Universities, aa well aa reports
prepared by the Congreaslonal Office of Technology Assessment and the
National Academy of Sciences (aea attached reference Hat). These atudies
and others have come to the aame general conclusions all landfilla will
eventually fail. The Natioaal Academy Beport farther stated that laadfilliag
should only be considered aa "the laat alternative alter all waate treatment
technologies...have been explored." Have all ether treatment technologies
been considered hare? . .
• •
Landfilla built with .even the beat available engineering design are
•till destined to fail. It ia only a matter of time.' Permitting Diamond
Shamrock to landfill these waatea in a community ia only asking for trouble.
The only advantage to the plan seems to be a cheap and convenient way for
Diamond Shamrock to diapoae of these wastes. This ia aot la the beat -
Interest of the local community. DEP'a flrat priority should be to provide
maximum protection of public health and the environment and mot Bake life
"easy" for industry.
-------
Fate 2
Ma. Grace Singer
Kerch 4. 1986
Ve hopt DIP will HOT apporove this proposed plan, bat rather consider
cleanup options that will sjore permanently destroy or detoxify tha diozin
4adaa soil*. Landfilllat tha vaataa ia not a solution. It would ba a
•iatafce*
Shank you for consideration of thaaa coaotata.
• •
Sincerely,
Stephen 0. Lester
Science Director
>is Marie Cibbs
Executive Director
SUL:LMC/gfa
-------
STUDIES POClJMEmNG FAILURES OF LANDFILLS
1) Technologies tnd Management Strategies for Hazardous Waste Control.
Congress of the United States* Office of Technology Assessment, Washington, •
D.C..March. 1983.
..».''
2) Management of Hazardous Industrial Wastes. Research and Development Needs,
National Materials Advisory Board, National Research Council of the National
..~ Academy of Sciences. March. .1943.
3) Vtlliam Sanjour. U.S. EPA and Kirk W. Brown. Texas A ft M University
Testimony before the House Subcomnlttee on Natural Resources. Agriculture
Research and Environment of the Committee on Science and Technology.
November 30, 1982. (Comments on CPA proposed regulations for the land
disposal of hazardous wastes).
4) Alternatives to the Land Disposal of Hazardous Wastes. An Assessment for
California. Prepared by the Toxic Waste Assessment Group, Governor's
Office of Appropriate Technology. State of California, 1981. Available
from Publications and Information, OAT. 1600 Ninth St.. Sacramento. CA
95814. Phone: 916/323-8133.
5) Hazardous Waste Landfills • Can Clay Liners Prevent Migration of Toxic .
Ltachate? Allen Morrison. Civil Engineering • ASCE. July, 1981.
* •
6) Organic Leachate Effects on the Permeability of Clay Liners. D.C. Anderson,
K.W. Brown, J.O. Green appeared 1n the proceedings of the national Confer*
tnce on Management of Uncontrolled Hazardous Waste Sites. October 28-30.
1981.
7) The Interaction of Clay-Soil with Water and Organic Solvents^ Implications
for the Disposal of H»z»rdous-W«tes.- William J. Green,-
R. Anne Jones. Accepted for publication J. Cnv. Sc1. and Techn. 1982.
8) Performance Difficulties of"Secure" Landfillsfor;~ehem1cerwa$te a~nd~
Available Mitigation Measures. Peter N. Skinner; Appeared 1n The Hazardous
Waste Dilemma: Issues and Solutions. 1980 Conference of Environmental
Engineering Division of the American Society of Civil Engineers. 1981.
9) Pour Secure Landfills 1n New Jersey-A Study of the State of the Art in
Shallow Burial Waste Disposal Technology, Draft of February 1, 1981. Dr.
Peter Montague, Dept. of Chemical Engineering and Center for Energy and
Env. Studies, Sch. of Eng./Applied Sci., Princeton Univ., Prlncton. N.J.,
1981. .-.
•
10) Discussion Paper: State Action to Reduce Land Disposal of Toxic Wastes.
Prepared by the Interagency Task Force for Reduction of Land Disposal of
Toxic Wastes. State of California, Dept. of Health Services. January,
1982. '.. •
11) Hazardous Waste Disposal Methods: Major Problems With Their Use. Report
by the Comptroller General of the United States. U.S. General Accounting
Office, Report No. CED-81-21. November 19, 1980.
-------
TANT M PMRONdENTAL SSMCES AIO OCCUPATONAI. HEALTHCARE
March 12, 1986
Ms" Crace Singer
New Jersey Department of Environmental Protection
site Mitigation Administration
Of flee of Gomunity Relations
CN028
Trenton, New Jersey 08625
Dear Ms. Singer,
As an environmentalist and someone with family concerns in
the Xronbound connunityof Newark, X would like to take this opportunity
to cement on the Feasibility Study done by Diamond Shamrock Corp.
with regard to the '^Clean-up and/or remediation of contaminants at
80 and 120 lister Avenue, Newark.
Xt was ny understanding at the Public Hearing held on this
subject on February 20, 1986, that excavation and off-site transport-
ation and disposal of the dioadn contaminated materials is NOT an
alternative since; f
- 1. Dioxin is not accepted at any established out-of-state
landfill in this country from an out-of-state source, and
2.~Excavation of said contaminants would innately produce
'bore" air pollution and contamination of the environment.
As outlined in the FACT SHEET on the Feasibility Study for 80
and 120 Lister Avenue, Newark, N.J., X fundamentally agree with the
sixth Remedial Alternative considered:
"Excavation, loading and transportation of contaminated
en-site materials and off-site coranercial disposal, if
available; a slurry wall built for stability and Round
water control during excavation, and mitigation of migra-
tion of remaining dioadn below the 7 ppb level after
remediation." • •
Since the decisions made here will be an accomodation of existing
law for any of the alternatives, it seems to me perhaps an "arrangement
could be made between the (NJ)DEP and (FEDERAL)EPA to have already
established "Dioxin-Qualified" out-of-state landfills accept our dioxin
waste, at least temporarily until New Jersey has it's own such facility.
K\ ~ flt l">«-^A1 Tl Tit f
-------
Ms. Grace Singer Much 12, 1986
New Jersey Department of fhvironnental Protection Page
As for the excavation further contaninatine the environment, we
both know there are ways and means to excavate safely and without further
contaminating the surrounding air, water and land, however costly to
X thank you for this opportunity to coment on this situation
ana hope you can arrive at a remedial alternative that is agreeable to
all concerned.
Xf X can be of help in any way, please feel free to contact oe.
Yours truly.
Maria A. Del lufo, K.T.
cc: Councilman Henry Martinez
East Ward, Newark, N.J.
-------
KENNETH A. GIBBON
.KKW JUISBY
-•-•.. ©7101
March 18, 1986
Honorable Ric^avc V. i
Commissioner
N. J. Department of Environmental
Protection
CN 402
Trenton, New Jersey 0862S
Dear Commissioner Dewling:
Zn addition to exploring the use of registered sites ..outside
of the United States far-the safe and proper storage'of'the
dioxin contaminated waste as noted in Mr. Zach's letter to
Mr. Catania of February 21, 1986 (copy attached), I would
like to suggest that you require Diamond Shamrock to explore
the use of EPA1* first registered disposal site for dioxin in
the United States. The J. M. Huber Corporation has recently
been permitted by EPA for dioxin disposal in Texas. I am
attaching a copy of ten articles printed in the March issue of
"World Waste," which describes the dioxin disposal process.
i
In that disposal facilities are available, the dioxin from
the Diamond Shamrock property and other contaminated sites in
Newark »1y»plg/iiot be permitted to be stored in Newark.
Sincer
Ke/jreth A. Gibson
Mayor . ...
XAC:pa
Attachments
cc: Mr. Alvin L. 2ach, P.E., L.S., Director, Newark Dept. of
Engineering
Honorable Michael F. Catania, Deputy Comaissioner, N. J.
Dept. of Environmental Protection
Newark
-------
OFFICES
CORDON AND CORDON
- AMOmilOMALCMfOMnOM
aOMAINSTJIHT
. .
AMACOMJO,
March IB, 1935
: '.. : RS
Gerard Burke, Esq. A0
Director of Regulatory Services * °*
Stste ef New Jersey ^
Bepartaent of Environmental Protection ,-V,
Office ef Regulatory Services utT
RE: Disaond Shaarock Feasibility
Study Conaents
Trenton, New Jersey 08625
)ear Mr. Burke:
The following ccaaents are subaitted on behalf ef the
Xronbound Health Rights Advisory Coaaission' and Arnold Cohen.
These written eoaaents are in .addition and adept the oral
eomaenta Bade by ayself, Dr. Feter Montague and Arnold Cohen at
the"' public »etting held by BEF on the feasibility study.
The aain areas ef concern and deficiencies found in the
feasibility study are the following:
1. Biaaond has failed to comply with 7:25-1.* by net
. •• ' •
f
asploring all alternatives and failing to list detailed reasons
why off-site disposal is not available. .
2. Biaaond has failed to fulfill its obligation to furnish
-------
communication* regarding the availability of off-lite options for
disposal. This prevents a meaningful evaluation of available
alternatives r'eaenber DEP specifically requested this information
.
be Contained in the study in August of 1935.
C. <•
"3. Diaaond bas failed to evaluate the legal requireaents
applied by PSP to site cleanups in V.J. This prevents the
evaluation of what laws will be broken by the cleanup option
selected by Diaaond.
4. Diaaond bas failed to evaluate the iapacts of Judge
Stanton's order and opinion (copies atachedK These require that
the cleanup achieve the highest level of cleanup that the
boundaries of our known technology would allow.
5. Diaaond bas failed to evaluate the impacts of known
cleanup and construction aetbodelogies upon the options requiring
excavation of materials, ie. reverse pressure within a covered
work area. This a)eans the evaluation of alterntives presented is
clearly misleading. Diaaond relies on this misinformation to
.?.. .'• ' . • • • •
eliminate any options containing excavation of aoils.
6. Diaaond bas failed to properly evaluate the impact -upon
the environment and public health of abandonaent of the site by
Diaaond once the 30 yeer'tiae fraae of aaintenance of the site
s
envisioned by Diamond's feasbility study ends. This failure is
critical for New Jersey law requires remedial activity until the
site bas been cleaned and responsibility for ongoing cleanup
-------
activity Is riot ended by* the aere passage of tine.
7. Diamond has improperly developed • groundwater
• . - *•'_'' . \.
decontamination program based upon the chemical characteristics
™ • •. •
of two 'compounds when we know literally a hundred compounds are
&-
contaminating the site. The likelihood of success of any
groundwater program Bust evaluate the Mobility, toxicity, etc. of
all eoapounds present above the New Jersey standard of 10 ppb
being used for ground water cleanups at industrial sites. The
feasibility study does not recognize the proper cleanup foal ef
remediation until all contaminants are below the 10 ppb.
•
standard.
8. Diamond has failed to evaluate the iapact ef flooding
upon the project and the proposed use ef this area fer flood
control by the Aray Corps. .
9. Diamond bas failed to evaluate the Mew Jersey
requirements for thickness and peraeability as to liners at new
waste disposal locations. Diamond's reliance en the present silt
layer is illegal.'
10. Diamond has not evaluated the siting, permitting
construction operation, and aaintenance ef a new Diamond dioxin
• .
disposal facility, within New Jersey or anywhere else in the
/
world.
11. Diaaond has not evaluated the disposal ef dioxin
contaminated soil at licensed International disposal sites.
-------
12.. Diamond has not evaluated tht currtnt Passaio River
dioiin and DDT eontaaination and how that ralatts to moving
* ' • '
forward with ibis rtcommtndtd alttrnativt.
13* Tbt reeoaaended alttrnativt dots not tvaluatt the eoat
and legal constraints of seeking to bteoae a licensed peraitted
solid waste or hazardous waste disposal facility within New
Jersey. This is what is being recoaaended by Diamond.
The Xronbound Health Advisory Commission is adaaent that the
objectives outlined by Diaaond in its executive summary are
illegal in part and do not Beet the cleanup requireaents as
•andated by the judicial decision of Judge Stanton. Judge
Stanten has deterained that Diamond Shamrock is legally
responsible to cleanup these sites to the extent peraitted by
known technology. This does not Btan Barely contain
oonntaainants on site, or Barely reduce the aass transport of DDT
—and -Dioxin—in -the ground water, er Barely eliainate the Bass
transport of chtmicals from the site to the Passaic tiver, er
titan imdue concern for 'the ajost cost effective atthod when that
Bethod does not represent a total cleanup. Judge Stanton's
ruling Beans the iapleaentation of cleanup and reaoval to a
secure facility and... the coaaentors will pursue this
• . •
interpretation in court if necessary in order to prevail upon DEP
to require a real cleanup. Diamond's current study is incoaplett
and the Xronbound Health Rights Advisory Commission requests a
-------
foraal bearing be held by DEP once the feasibility study bas been
deeaed complete and DEP bas selected an alternativt and issued
Its ratiensle necessary to support it.
Respectfully ..submitted,
MICHAEL CORDON
NC:pc
Enclosure
ec: Arnold Coben
-------
SUPERIOR COURT OF NEW JERSEY
COWCTHOUSE
Morten, tow Jm*y 07960
00US29-IQ39
HORBS AND SUSSEX COUNTIES
February 3, 1986
Michael Gordon, Esq.
Gordon and Gordon
•0 Main Street
Vest Orange, Mew Jaraay 07052
Francis E. P. McCarter, Bag.
McCartar and English
550 Broad Street
Vavark, Maw Jaraay 07102
Ithonda S. Birnbaun, Esq.
Hoagland, Longo, Oropollo ft Koran
P.O. Box 480
Haw Brunsviek, Waw Jarsay 08903
Philip L. GuarinOf Esq.
Lowtntttin, Sandlar* Brochin, lohl, Fishar, t
Boylan t Maanor
•5 Livingston Avanut
Itosaland* Vav Jarsay 07068
Kenneth S. Rasper* Esq.
Shanlay ft Pishar
131 Madison Avenue
Morris town, Hew Jarsay 07960
Patricia Massa Bass, Esq.
Dughi ft Bawit
340 North Avenue
Cranford, Maw Jarsay 07016
.•••
Dwyer, Connall ft Lisbon*'
427 Bloomfiald Avenue
Montclair, Maw Jarsay 07042
Richard P. Engel, Esq.
Daputy Attorney General
Hughes Justice Complex
|CN 112
Trenton, Hew Jarsay 08625
Re: Ironbound Health Riohtt Advisory Commission, et al. v
Diamond Shamrock Chemical* Co., at al.r
-------
page 2
5/3/86
Chancery Division* Essex County;
Docktt NO. C-3190-I3E — LETTER OPINION
.Dear Counsels
• • ' / '
On January t, 1986, an Order Granting Final Equitable^lelief
and Transferring Damage Claims to Law Division vas entered by
me in this action. The Order acted as a final judgment with
respect to plaintiffs' claims for equitable relief. On
February 24, 1986, I received notice that the defendants New
Jarsey Department of Environmental Protection and Maw Jersey
Department of Health appeal from a portion of the Order. This
Letter Opinion is issued pursuant to £. 2:5-Kb) and mutt be
made part of the record on appeal.
Over a period of years, the defendant Diamond Shamrock Chemical
Company, or a corporate entity to which it was related, s»anu-
factured a chemical herbicide in a factory at 10 Lister Avenue
in the Zronbound section of Newark, New Jersey. Under the name
•Agent Orange* this herbicide was widely used as a defoliant
during the Vietnam War. A by-product of the herbicide is an
extremely troublesome dioxin.
Tests on many standard species of laboratory animals have shown
that the dioxin involved here is highly toxic. Indeed, for
some standard species, the dioxin is super toxic, with extremely
amall quantities producing quick death. Experience with standard
species of test animals would lead one to suspect that exposure
to dioxin might produce devastating results in humans.
Before the dioxin in question was perceived as being as potentially
dangerous as we now suspect it may be* many human beings were
•xposed to it in one way or another. Nevertheless, the devas-
tating results for humans which might have been predicted from
the test results we now have on laboratory animals do not seem
to have occurred. The evidence in .this ease indicates that
most human beings exposed to this dioxin have not yet experienced
any adverse results, at least none which can be presently detected.
When exposed humans have experienced detectable adverse results,
the problems seem to be-relatively minor.
Zt may be that the human organism has an ability to withstand
exposure to this dioxin which the standard apecies of test animals
do not share, or it may be that exposed humans have received
damage which is slow in manifesting itself. All of us hope,-
of course, that the dioxin is not seriously harmful to humans.
-------
3
3/3/86
But our experience with ethtr chemicals forces us to be cautious*
because we know that we are sometines seriously damaged by a
chemical without being aware of it until Bany years have passed
after the exposure. In this regard* one cannot help thinking
about ^ synthetic estrogen (DCS), an approved therapeutic drug
which was routinely administered to many pregnant women to prevent
sUsearriages. The women taking DCS did not appear to be hurt
by it, the babies they produced appeared to be healthy* and
' grew into healthy young children. However* as those children
passed through puberty into adolescence, vastly disproportionate
numbers of them developed serious cancers. The human reality
and the human decency of our present situation require us to
regard persons exposed to dioxin as being at apecial risk.
They will remain at special risk for many years to come. Zt
is imperative that responsible public agencies operate carefully
designed programs to test, monitor and, if necessary, «treat
persons exposed to dioxin.
*
Many years ago, defendant Diamond Shamrock Chemical Company
ased the factory at 10 Lister Avenue to manufacture herbicide.
All of the persons who worked in the factory during that manu-
facturing process were exposed in a substantial way to dioxin.
The families of those workers were exposed to the dioxin in
a different, but potentially significant, way. After Diamond
Shamrock stopped using the factory at to Lister Avenue, other
businesses used the premises for different manufacturing processes.
By that time there were relatively large amounts of dioxin in
the soil and materials at 80 Lister Avenue, and these workers
were exposed. Their families have had a derivative exposure
to dioxin. Over the years, dioxin has been carried from 80
Lister Avenue into the surrounding neighborhood, neighborhood
factory workers and residents have been exposed to varying amounts
of dioxin. Xn short, over the years, various categories of
persons have been exposed in different ways, for different lengths
of time, to varying amounts of dioxin. On the face of it, some
of the exposure is potentially very dangerous, tome is potentially
moderately dangerous in some degree or other* and some is probably
not dangerous. But nobody really knows.
The fact that there was'-substantial diexin contamination at
80 Lister Avenue and its environs came to public attention in
1982. Shortly thereafter, this action was instituted. Plaintiffs
have sought a wide range of injunctive relief. Some of the
relief was aimed at physical cleaning of 80 Lister Avenue and
surrounding areas; some of it was aimed at identifying, testing,
monitoring and treating the various categories of persons ex-
-------
« 4
3/3/86
posed to the dioxin. There were also claims for substantial
•oney damages. At the outset, I determined (without any serious
obAction from any of tht parties or their attorneys) that top
priority had to be given to physical sbatement and cleaning
of the environment and to helping to g«t appropriate htalth
programs in plae«. Financial liability problems were^f decidedly
secondary importance. 2 did not vant to see the energy and
resources of public officials and the parties diverted from
the need to-solve existing environmental and health problems.
Accordingly* Z stayed all proceedings with respect to damage
claims* and Z prohibited any discovery on the damage claims.
Although ve have never had and never will have a plenary trial
en the equitable relief claims in this case* we have had ex-
tensive interlocutory proceedings dealing with the equitable
relief claims. There have been many fortunate aspects to this
case. The executive branch of our State government has given
extensive attention to the problems at and around 80 Lister
Avenue. The attention has often been at the highest level*
vith the Commissioner of Health* the Commissioner of the De-
Krtment of Environmental Protection and the Governor himself
coming personally involved in some of the executive branch
decision-making. Diamond Shamrock has exhibited an enlightened
social conscience with respect to the environmental problems
and has entered into consent administrative orders with the
Department of Environmental Protection which'have committed
•any millions-of- dollars **a trm«
-------
page S
3/3/86
By the summer of 1985, it appeared to me that the Department
of Environmental Protection and the Department of Health had
the real-life problems of this ease well in hand. That is not
to «ay that the problems were solved. Far from it. Many future
'years pf .work are involved here. The environmental cleanup
plan-and the health plan will require ongoing revision and updating
as work progresses and as more facts become known. However*
it seemed to me that the Commissioner of the Department of Environmental
Frotection and the Commissioner of the Department of Health
were addressing all of the problems with vigor .and with expertise
that the Court did not possess. Accordingly, Z suggested to
the parties that perhaps the Court should terminate the equitable
relief portion of the ease and transfer the damage claims to
the Law Division for further proceedings. Z invited the parties
to submit written argument. After receiving the arguments of
the parties, Z entered the January I, 1986 Order Granting Final
Equitable Relief and Transferring Damage Claims to the Law Division.
So far as equitable relief claims are concerned, the January 8
Order provides as followss
•ZT ZS FURTHER ORDERED that the Commissioner
of Department of Health shall implement (with
federal technical assistance and financial aid,
if available; but without them,if they are not available)
the medical testing and monitoring program previously
approved by the Court* and the Commissioner of Department
~ of Environmental Frotection shall continue to
enforce the cleanup of dioxin contamination at
~an(d) la the environs of 80 Lister Avenue,
Newark, New Jersey to the greatest extent feasible
within the bounds of known technology. ...
•The Court is satisfied that the Commissioner
pf the Department of Health and the Commissioner
of the Department of Environmental Frotection will
continue in an active and vigorous fashion to
discharge their responsibilities in this matter.
Other than what is granted above, no additional
equitable judicial relief is necessary. This
Order constitutes a final judgment on the
claims asserted herein for equitable relief.*
-------
Z realise that when the Commissioner of the Department of Health
submitted his testing and monitoring plan to the Court he an-
ticipated that substantial financial and technical assistance
la carrying out the plan would be forthcoming from the federal
government. . Z gather that federal funding has not yet been
'obtained in anything approaching the needed amount, and that
it is'doubtful that full federal funding will aver beTgranted.
That lack of federal funding is regrettable, and Z recognise
it poses substantial practical problems for the Mew Jersey De-
partment of Health. However* the lack of federal funding does
aot alter the basic realities of this ease, and it does aot
and should aot relieve any Mew Jersey official of his responsibilities
in this vatter.
Perhaps the most basic reality of this ease is that there is
a fundamental human need to be Bet. Heal people, innocent people,
whose identities are known, have been exposed to dioxin and
?ut at special risk. They have to be tested, monitored and,
f necessary, treated. This is a responsibility of government. .
Zn view of the fact that the testing and monitoring Bay yield
data of general scientific significance in addition to helping
the individual people involved, one would have hoped that the
federal government would be a major funder. However,if the
federal government is unwilling or unable to help, that does
not excuse Mew Jersey from meeting its responsibility. Me in
Mew Jersey have our own special traditions of earing, eoneern
and decency, and they Bust be upheld. /
The Commissioner of the Department of Health has appealed from
that portion of the January I Order which requires him to •im-
plement (with federal technical assistance and financial aid,
if available; but without them, if they are aot available) the
medical testing and monitoring program previously approved by
the Court. ..." Z point out that the program in question was
net something proposed by the plaintiffs, or oven fully accept-
able to them. Zt was not something devised by the Court. The
program was proposed to the Court by the Commissioner. Zt rep-
resented his evaluation of what needed to be done to Beet the
human health needs of this situation. Z accepted it because
it appeared to be a well-designtd, well-reasoned response to
the health problem confronting all of us. The hoped-for federal
funding Bay have disappeared, but the problem has not.- Given
the importance of the problem, 2 do not think It represents
inappropriate judicial activism or an inapproriate judicial
intrusion into the affairs of the ether branches of government
to require the Commissioner of the Department of Health to implement
-------
page 7
3/3/86
his own program of ••dical tatting and monitoring, •van though
ha did not gat tha fadaral halp ha anticipated. Underbill of
the eireunstaneas of thii case, Z think it is right for tha
Court to axpact tha Governor and tha Legislature to figure out
a way to provide the several Billion dollars needed *£ imp lament
the siedical testing and monitoring program.
Very truly yours*
leginaXd Stanton, A.J.S.C.
Copies tot
• Clerk of the Appellate Division IS copies)
• Case file
-------
Prepared by the Court- after
receiving draft Ordtr from
plaintiffs* attorntys
XRONBOUND HEALTH RIGHTS
ADVISORY COMMISSION* et al.*
Plaintiffs '
DIAMOND SHAMROCK CHEMICAL
COMPANY* et al.,
•
Defendants.
s
s
s
s
s
I
FILED
JAN 08 BBS
SUPERIOR COURT OF HEW JERSEY
CHANCERY DIVISION
ESSEX COUNTY
DOCKET MO. C-3190-83E '
Civil Action .
ORDER GRANTING FINAL EQUITABLE
BELIEF AND TRANSFERRING DAMAGE
CLAIMS TO LAW DIVISION
This natter cant before tht Court on tht notion of
Cordon and Gordon, P.A., attorntys for plaintiffs* for
an Ordtr for Additional Interim rtlitf la .tht prtstnct .
*• •
of Messrs. Cordon and Gordon* F.A. by: Michael Cordon*
•
Esq. and Timothy S. Etlty* Esq.* Attorntys for Plaintiffs;
Mtssrs. Boegland* Longo* Oropello t Koran* byt Rhonda
S. Birnbaum* Esquire* Attorneys for Defendant* Aetna Casualty;
Messrs, tovenstein. Sandier* Brpchin* Kohl, Fisher* Boyland
•
S Meaner* by: Philip L. Guarino, Esq.* Attorneys for Defendant*
S.E.A. Services* Znc'.* Mtssrs. McCarter 'ft English* by:
, *
Francis E.P. McCarter* Esquire, Attorneys for Defendant*
-------
Diamond Shamrock Chemicals Company; Mtssrs. Shanley ft Fisher,
byt Kenneth 8. Xasper, Esquire, Attorneys for Defendant*
Richard F. Engel* Esquire, Deputy Attorney General* Attorney
for Defendant* Department of environmental Protectioni
'Messrs. Dughi • Hewit* bys fatrieia Massa Bass* Esquire,
Attorneys for Defendant* Dr. Roger Brodkin. The question
• • •
of making final the equitable relief granted in this ease
came before the Court on its own motion, after all counsel
were given the oppportunity to comment thereon.
ZT IS HEREBY ORDERED, on this *£^ day of January,
• *
1986, that Plaintiffsanction for Additional Interim Relief.
is denied.
ZT ZS FURTHER ORDERED that the Commissioner of Department
of Health shall implement (with federal technical assistance
and financial aid, if available; but without them, if they
t
are not available) the medical testing and monitoring program
'previously approved by the Court, and the Commissioner of
Department of Environmental Protection ahall continue to
•nforce the cleanup of dioxin contamination at an in the
environs of 10 Lister Avenue, Vevark, Mew Jersey to the
«.
greatest extent feasible within the bounds of known technology.
See below. * . '
•*
ZT ZS FURTHER ORDERED that the matter is 'hereby transferred
- 2 -
-------
to tht Law Division, tasex County for. .all ^further proceedings
•
en the damage claims asserted htrtin.
XT IS FURTHER ORDERED that the stay on discovery it
hereby lifted. .
"it ia roeoamtndad to tha lonorabla John A. Marsufii,
<
A.J.S.C. that this Batter be specially assigned to a singla
judga for easa aanagamant.
flaintiffs* attorneys shall sand eopias of this Order
•
to all counsel of raeord within 7 days of tha.data hereof.
•REGINALD STANTON
Judge of tha Superior Court
Assignment Judga
• Tha Court is satisfiad that the Commissioner of tha
Department of Health and tha Commissioner of ,the Department
•
of Environmental Protection will continue in an active
and vigorous fashion to discharge their rasponsibilitias
in this natter. Other than what is grantad above, no additional
equitable judicial relief is. necessary. This Order constitutes
a final judgment on the claims asserted herein for equitable
relief. •
- 3 -
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CONFORMED COPY
Appendix A - Part II
Diamond Shamrock Site
80 and 120 Lister Avenue
Newark, Essex County
New Jersey
Responsiveness Summary
for the
Proposed Interim
Remedial Action Plan
August 1987
-------
DIAMOND SHAMROCK SITE
RESPONSIVENESS SUMMARY
FOR THE
- PROPOSED INTERIM
REMEDIAL PLAN
TABLE OF CONTENTS
SECTION I. Selection of a Remedial Alternative . . 2
A. The Proposed Remedy 2
B. Excavation and Thermal Treatment 7
C. Alternative VI 10
SECTION II. General Comments and Questions . . , . 14
A. Health . 14
B. Diamond Shamrock 14
C. Conditions at the Site . . 15
D. Other Concerns ° . 16
SECTION III. Summary of Written Comments 18
-------
RESPONSIVENESS SUMMARY
PROPOSED INTERIM REMEDIAL ACTION PLAN FOR
THE DIAMOND SHAMROCK SUPERFUND SITE
_ NEWARK, NEW JERSEY
PUBLIC COMMENT PERIOD
July 31, 1987 to August 31, 1987
Sections I and ZI below present a summary of the questions
and comment's expressed by the public at the August 11, 1987,
meeting on the Proposed Interim Remedial Action Plan for the
Diamond Shamrock Superfund site. The questions and comments
are grouped into general categories or subjects. Section III
is a summary of additional comments received in writing during
the public comment period. All comments or questions are
followed by responses representing the joint position of EPA
and NJDEP.
I. Selection of a Remedial Alternative
A. The Proposed Interim Remedy - On-site containment with
ground-water pumping and treatment.
1. Community members stated concern that this "interim"
solution would be permanent and that the site would
become a hazardous waste disposal facility.
EPA and NJDEP do not believe that the proposed remedy will
be a permanent solution for the contamination at the
Diamond "Shamrock sife~H ~is "hoped that future studies of
the means for excavation will show that excavation can be
-done in a safe manner-with an acceptable impact-writhe - —
community. Both Agencies believe that siting problems for
a hazardous waste thermal treatment unit can be resolved,
given enough time. It is expected that that larger thermal
treatment units capable of properly treating dioxin wastes
will be proven effective and will become available for the
treatment of waste from this site. This expectation is
based on the rapid progress in thermal treatment technology
which is currently being made.
Excavation and treatment options are not preferred at this
time, in part, because they cannot be implemented in an
expeditious manner. Once the site is adequately controlled
by the proposed remedy, however, the need to remedy the
site expeditiously will no longer exist and more complex
remedies such as excavation and thermal treatment can be
considered in the necessary detail.
-1-
-------
2. Peter Montague expressed concern about whether a
remedy similar to that proposed had been used on
similar vastes. If so, where has this solution been
used before?
Containment remedies have been utilized at hazardous waste
sites numerous times in the past, although the composition
of the waste, especially with respect to the dioxin
contamination, at the Diamond Shamrock site is unique. A
noteworthy example of the successful implementation of
containment at a site with wastes similar to those at
Diamond Shamrock is the Love Canal site in New York State.
As with Diamond Shamrock, Love Canal is a setting in which
pesticides and dioxin-contaminated materials were
disposed.
A new cap was placed on the Love Canal site in 1984 and
ground-water pumping and treatment have been initiated.
Extensive monitoring has subsequently been conducted and
the results indicate the effectiveness of the cap and
ground-water pumping and treatment in controlling off-site
migration of contaminants.
3. Frank Sudol, representing Mayor Sharpe James, said
that the proposed remedy does not adequately address
the following :
a - detailed description of the FS to be conducted
every two years (what will be done to meet CERCLA
..The Agency is currently developing guidance that will
explain procedures for conducting evaluations required
by Section 121(c). After this guidance is available,
~it will be used in developing plans for the biennial
Feasibility Studies called for by the Proposed Plan.
Existing EPA guidance for conducting a Feasibility
Study, entitled Guidance on Feasibility Studies under
CERCLA, June 1985, provides much information that will
still be relevant when the first re-evaluation is
performed.
b - detailed proposal for public participation in the
biennial FS;
.* • '
Current EPA regulations require that, there be a public
comment period on all Feasibility Studies developed
under the Super fund program. Therefore, the public
will have an opportunity to review and comment on each
biennial re-evaluation report. Additionally, NJDEP
and EPA will be willing to meet with an advisory
committee composed of officials and community
-2-
-------
representatives in order to obtain input from this
committee and to keep the committee apprised of site
status.
c - details- concerning the conditions which vould
trigger additional studies;
«^.
Since re-evaluation studies are to be completed every
two years, such studies will be in progress almost
continually. NJDEP and EPA, therefore, do not
anticipate the need- for additional studies. The
Agencies have the discretion, however, to conduct or
reguire such studies should the need arise.
d - the possibility of Newark receiving compensation
for accepting dioxin, as there is a precedent for
this;
EPA and NJDEP are aware of no existing statutory
authority to compensate Newark for storing dioxin.
Thus, the Agencies cannot consider compensation at
this time.
e - detailed proposal for air monitoring;
Item 14 on page A-2 of the Proposed Interim Remedial
Action Plan (the Proposed Plan) addresses the need for
suitable monitoring activities: "Implement suitable
monitoring, contingency, operation and maintenance...
to ensure the protection of human health and the
environment during and after the installation of the
selected alternative, including a ground water
monitoring program." Detailed plans for this
monitoring will be included in the Remedial Design
document, including specific actions for air
monitoring. That document will be made available for
public review and comment, prior to the initiation of
any on-site work.
f - details concerning how the carbon will be treated
after it has cleansed the ground water;
Item 13 on page A-l of the Proposed Plan specifies how
the spent carbon and other sludges generated by
wastewater treatment will be handled. It states that
actions taken as part of the remedy .will "place
on-site and cap the sludge generated from the
wastewater treatment process until such time that an
alternative method of sludge management is approved."
Spent carbon and sludges will probably be placed in a
separate on-site landfill cell to minimize potential
release of other on-site waste under the cap. Future
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options for these ground-water treatment wastes may
involve treatment at an off-site permitted facility.
g - plan for a bulkhead which could withstand the
500-year flood;
The securing of the hazardous materials from, flooding
will not be achieved solely by rebuilding the
bulkhead. The integrity of the site will also be
maintained by the construction of the cap, which will
be designed to meet the rigorous requirements of
RCRA. He anticipate that the cap will be several feet
thick and will contain highly impermeable materials
which will not be penetrated by flooding or other
weather conditions. Although it is possible that the
outermost part of the cap may be damaged in the
500-year flood, the contents under the cap would not
be threatened. The 100-year flood is used as the
design basis for flood protection in a number of
applicable Federal and State regulations.
b - plans for additional security during the times
when the site will be unattended;
Item 14 on page A-2 of the Proposed Plan addresses the
need for "site security measures to ensure the
protection of human health and the environment during
and after the installation of the selected
alternative..." The site will be especially hazardous
during implementation of the remedy and there will be
much construction equipment on the site. Security
measures, therefore, will be quite stringent during
the implementation phase. Following completion of the
selected remedy, the site will be much less hazardous
to trespassers than is currently the case, and the
site will need less security. A detailed plan will be
prepared later as part of the Remedial Design. The
security plan will be available for review and comment
by local citizens and officials.
i - details concerning the specific type of industry
which might use the site once it is capped;
Although the. Feasibility Study explored the
possibility,-'EPA and NJDEP have no intention that
industry should be located at this site. Building on
the cap would interfere with further remediation.
j - details concerning the contents of the S70 drums
mentioned in the FS;
Details concerning the contents of these drums are
located in Section 5.10 of the document entitled "Site
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Evaluation for 80 Lister Avenue/' dated February
1985. This document may be found in the
administrative record* for the site. Information
currently available indicates that more than half of
the drums contain dioxin, which makes off-site
disposal of most drums impossible at this time.
k - details on the Feasibility Study plane for dust
control, as well as air, ground-water and
neteorological monitoring while the buildings are
being demolished.
EPA and NJDEP agree that air, water and meteorological
monitoring are necessary. These detailed plans will
be developed during the Remedial Design phase and will
be made available for public review and comment prior
to the initiation of on-site work. EPA and NJDEP are
confident that this work can be done safely. Possible
approaches for dust control would include removal of
contaminants whenever possible prior to dismantling
buildings, use of chemical dust suppressants and use
of a fabric fence around the site.
4. Several of those who spoke said they believed that the
proposed remedy was chosen because it is cheapest or
easiest for Diamond Shamrock to implement.
The reasons for proposing this remedy are outlined in the
Proposed Plan. After careful consideration, it was
determined by EPA and NJDEP that the proposed remedy is the
most protective action available at this time. It was also
•Repositiories for the administrative record are:
United States Environmental Protection Agency
Region II
26 Federal Plaza
New York, NY 10278
(Contact Lenore Berman at 212-264-2649)
New Jersey Department of Environmental Protection
Division of Hazardous Site Mitigation
401 East State Street'--
Trenton, NJ 08625
(Contact Janice Haveson at 609-984-3081)
Newark Public Library
5 Washington Street
Newark, NJ 07101
(NJ Reference Section, 201-733-7800)
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the most cost-effective. The more costly alternatives had
major implementation difficulties which would require a
great deal of time, study and effort to resolve (refer to
sections B. and C. below for further discussion). The
delays this would require are inconsistent with the need to
remedy the site in a timely manner.
5. One community member wanted to know the construction
Materials of the cap.
The cap is expected to be composed of several layers,
including clay, a synthetic membrane liner, a flow zone
(containing coarse sand and/or gravel) and a top layer of
topsoil and vegetation, as recommended by RCRA guidance
documents. Other materials such as a geotextile may also
be used to protect areas especially subject to erosion.
Detailed plans will be developed in the Remedial Design
phase and will be made available for public review and
comment. The concrete top layer originally proposed in the
Feasibility Study has not been selected because it could
unnecessarily interfere with possible further remedial
action.
B. Excavation and Thermal Treatment
1. Mr. Montague expressed concern that incineration was
being turned down for insufficient reasons:
a - If the lack of a large incinerator is the
problem, use several small ones;
The lack of a large incinerator to treat site waste
was, and is, a factor in the decision to recommend the
proposed remedy, but it is one of many. The
incinerator roost successful at burning dioxin-
contaminated waste was the EPA mobile incinerator used
at the Denny Farm site in Missouri. That unit
demonstrated that it can achieve the required 99.9999%
destruction and removal efficiency for dioxin. But,
the use of a single mobile incinerator like the EPA
unit, operating at the rate achieved at Denny Farm
(about 12 tons per day), would take about 20 years to
burn the amount of waste present at the Diamond
Shamrock site. Although a number of these units could
be constructed, brought to the site and operated
simultaneously, there would be difficulty in locating
a large number of small incinerators on a relatively
small site. It also would not be cost effective to
use small incinerators for a large project.
Therefore, it would be preferable to use one or two
larger thermal treatment units, although such units
have not yet been tested on dioxin waste. Since one
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or more mobile thermal treatment units may have to be
designed, constructed, and tested prior to operation
to clean up the Diamond Shamrock site, it is expected
to take at least six years to complete this remedy.
b - If airborne releases are a concern, we have clean
room technology on a scale large enough to begin
the excavation. Mr. Montague also wanted to know
why it vas all right to risk excavation in
Milsonville, XL, but not in Newark. He asked for
a list pf communities where excavation has taken
place. '
Further study is needed to address the concern of
airborne releases during excavation. The application
of existing technology (e.g., "clean room" or dome -
technology) at this site would take a great deal of
study and method design. There are no precedents for
applying these technologies to situations similar to
the possible excavation of the Diamond Shamrock site.
Clean room technology (i.e., a room under negative
pressure, the air exhaust filtered with activated
carbon) has been used in a stationary building at the
Denny Farm site in Missouri. This building is used
for shredding and blending dioxin waste prior to
incineration. However, this technology is not
designed to be.moved around a site being excavated.
Although it may be possible to transfer the existing
stationary technology to a mobile application at
Diamond Shamrock, it would require lengthy study and
design to do so.
- The chief-difference-between tlu» excavation being
considered for the Diamond Shamrock site and the
excavation conducted at Wilsonville, -IL, is-the4evel
of toxicity of the wastes involved. Dioxin is orders
of magnitude more toxic than the substances at
Wilsonville. The dioxin contained in air emissions
resulting from the excavation of the Diamond Shamrock
Site would be the controlling factor in the level of
risk. A risk assessment performed for another site
with high dioxin concentrations concluded that
dioxin-contaminated dusts generated from possible
excavation would result in cancer risks greater than
10~2 (i.e., cine in one hundred) at properties as far
away as one-half mile from that site. The calculated
risk resulting from high concentrations of other toxic
chemicals was negligible compared to the risk from
dioxin.
A list of communities where excavation has taken place
would require an exhaustive search. Furthermore, a
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complete list of locations where excavation has been
conducted is not germane to the selection of a remedy
at the Diamond Shamrock site. Therefore, there are no
plans to conduct a search and develop a list at this
time. There 'are, however, numerous examples of
excavation, some with dioxin contamination, including
Newark, NJ. ~
e - What are EPA's and KJDEP's reasons for thinking
technology will advance to make Alternatives IV,
V or VI feasible in the future, as indicated at
the top of page 4 of the Proposed Plan?
The section of the Proposed Plan, cited above, states
that the implementation problems associated with
Alternatives IV, V and VI may be resolved in the
future. This resolution is not dependent solely upon
technological advancement. Numerous factors,
including political decisions, siting, permits or
other actions, may help solve problems that have led
to the rejection of Alternatives IV, V and VI at the
present time. Technology is, however, a significant
part of the decision not to select these alternatives.
Prior to the 1985 trial burn of the EPA mobile
incinerator at the Denny Farm site, the successful
incineration of dioxin waste in accordance with RCRA
requirements had not been demonstrated. .Since that
time, successful trial burns have been conducted by
two thermal treatment units developed by the private
sector. A number of companies have recently developed
- -mobile incinerators inspired by the success of the EPA
unit. Some of these newly developed units have
greater capacity than the EPA mobile unit and include
modifications intended to improve performance. Recent
government initiatives (the land disposal ban
regulations being phased in under RCRA and the
implementation of the 1986 Superfund Amendments, with
its preference for treatment alternatives) should
continue to increase the demand for incineration
capacity and provide a continued economic incentive
for development of new treatment technology.
Therefore, thermal treatment technology should
continue to progress and to become more available in
the future. • '
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2. One citizen said that the community would oppose
on-site incineration.
At the present time, EPA and NJDEP have no intention of
selecting on-site-incineration. However, it has not been
ruled out for the future. Refer to the response to comment
I.e.9. below. ~
C. Alternative VI - Off-site Treatment or Disposal
1. Several community members and officials preferred
Alternative VI to Alternative III because they feel
that the dioxin is being "dumped" in Hewark.
According to then, the only solution is to move it.
There are currently no existing permitted facilities at
which to dispose of the waste, either in the Unites States
or elsewhere. This does not mean that there will be none
available in the future. A large factor in the Proposed
Plan was the need to find a solution that can be
implemented expeditiously; off-site disposal or
incineration would take a very long time to develop and
implement, during which time the site would continue to
present a hazard to public health and the environment.
2. These people feel that Diamond Shamrock should come
and get the waste and store it on some other property
owned by the company.
The difficulties in implementing off-site management
options are discussed in other responses in this section.
These same difficulties would apply if off-site management
were to occur on property owned by Haxus Energy Corporation
• (successor to Diamond Shamrock). Off-site management
options were evaluated and found less protective than the
proposed remedy at this time. To limit off-site management
options to property owned by one company would make
off-site management even more difficult by excluding other
properties which may be better suited for managing the
waste.
3. These same people fear that the site will be useless
as long as contaminants remain on site.
•
•
•
EPA and NJDEP do not currently anticipate any use for the
site while the proposed remedy is in place.
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4. Two speakers felt that EPA/HJDEP were not really
considering the option of sending the diozin to an
off-site location.
There has been an'intensive search for sites in the United
States and abroad for a treatment, storage and disposal
facility that would accept waste from the Diamond Shamrock
site. No promising opportunities at existing facilities
have been found. EPA and NJDEP have also looked into
constructing a facility primarily for the purposes of
receiving site wastes, but have determined that this cannot
be accomplished in a timely manner.
5. Mr. Sudol noted that if the waste were to be
transported somewhere, EPA/NJDEP should take
transportation risk-reduction measures.
i
EPA and NJDEP agree that transportation risk reduction
measures should be taken, if such a remedy is selected in
the future.
6. Mr. Montague asked that if Missouri accepts diozin,
why not send the contamination there?
Missouri has not accepted, and currently does not accept,
diozin wastes from outside the State.
7. Mr. Sudol cited technical advances in thermal
treatment and the fact that EPA did not adequately
assess the possibility of shipping to Europe as
reasons for revising the Feasibility Study to examine
Alternative VI more carefully.
It is true that there have been significant advances in
thermal treatment technology since the Feasibility Study
was completed in 1985. These advances were considered by
EPA and NJDEP in developing the Proposed Plan. It should
be noted that the Record of Decision is based not only on
the Feasibility Study, but on the entire administrative
record, which includes information that was not available
at the time the FS was prepared.
EPA and NJDEP have also explored the option of shipping
site wastes abroad.. As a result, it has been concluded
that shipment of -wastes from the Diamond Shamrock site to
another country for treatment or disposal has not been
demonstrated to be a viable option at this time. No
foreign facility which could accept the waste has been
identified.
\
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EPA'6 Office of International Activities, to which exports
of hazardous waste from the United States must be reported,
has indicated that dioxin wastes have not previously been
exported from the.United States. A West German landfill
which reportedly has disposed of dioxin wastes and received
hazardous wastes from other countries was contacted by IT
Corporation and by EPA. Both contacts indicated that
approval to dispose of dioxin wastes from the U.S. at this
West German facility is very unlikely.
The extreme difficulty in getting approval to export dioxin
waste to other countries is illustrated by experiences with
Canada, which receives a substantial quantity of hazardous
wastes, including Superfund wastes, from the U.S. The
Canadian government has opposed containment remedies at
U.S. Superfund sites located near the Niagara River, which
is a source of Canadian drinking water. One of these sites
is Love Canal, which is a dioxin site. A proposal was made
by the New York State Department of Environmental
Conservation (NYSDEC) to conduct a trial burn for Love
Canal waste at an innovative thermal treatment unit (a
plasma arc pyrolysis unit) developed and located in
Kingston, Ontario, Canada. Despite the fact that a
successful trial burn would be a step toward the Canadian
government's wish for a permanent solution for the Love
Canal site, the Canadian government refused permission for
shipment of a relatively small quantity of Love Canal waste
to Canada for the trial burn. Canada maintains that if the
Love Canal trial burn is conducted, the thermal treatment
unit will have to be relocated in the United States. Given
this failure to obtain export approval to Canada under
relatively promising circumstances, the prospect for
approval of export of Newark dioxin wastes does not appear
promising at this time.
Should the prospects for export of Newark dioxin wastes
change in the future, removal of the waste to another
country could be a viable option at that time.
S« Mr. Sudol also said that the fact that there is no
licensed facility should not be Newark's problem.
Section 121 of CERCLA requires that short-term risks be
taken into account in evaluating remedial alternatives.
The fact that there are no licensed off-site facilities
which could accept wastes from the site does lessen the
effectiveness of off-site treatment or disposal options in
controlling short-term risks. Unfortunately, this is one
factor which makes the alternative preferred by the City of
Newark less protective than the proposed remedy.
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9. Mr. Michael Gordon, Esq., attorney for the Ironbound
Health Advisory Commission, stated that off-site
incineration is the only alternative which meets Judge
Stanton's order.
It is the position of EPA and NJDEP that the selected
remedy meets, for the present, the State's obligation under
Judge Stanton's order. Judge Stanton's order requires the
cleanup "to the greatest extent feasible within the bounds
of known technology." Similarly, Section 12l(b) of CERCLA
requires the selection of a remedy that uses permanent
solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent
practicable. It is the position of EPA and NJDEP that
neither Judge Stanton's order nor Section 121(b) of CERCLA
were intended to maximize the use of technology as an end
in itself, but as a means for ensuring the protection of
health and the environment. Since the alternatives which
have a greater reliance on technology are less protective
than the Proposed Interim Remedial Action Plan at the
present time, the Proposed.Plan does utilize known
technologies to the extent practicable or feasible for
protecting health and the environment.
10. Mr. Montague asked whether the Proposed Interim
Remedial Action Plan adequately outlines the reasons
supporting the rejection of Alternative VI.
The Proposed Plan adequately summarizes the reasons for the
remedial selection, including germane reasons for the
rejection of Alternative VI. The Record of Decision will
provide a more detailed discussion of the selection
rationale. Additional supporting information is contained
in the administrative record.
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II. General Comments and Questions
A. Health
i. Members of the community urged additional health
screening and medical testing. One community member
described illnesses occurring in the neighborhood.
The New Jersey Department of Health did conduct a health
survey of Ironbound residents in June 1984. Current health
problems or questions that may be related to the Diamond
Shamrock site may be brought to the attention of Dr.
Liveright at Mew Jersey Department of Health, Division of
Occupational and Environmental Health, at 609*984-1863.
The Hew Jersey Department of Health has expressed a
willingness to continue to investigate health problems that
may be related to the site, and to assist the Essex County
Department of Environmental Health in its efforts.
B. Diamond Shamrock
1. A number of comment or s maintained that Diamond
Shamrock is not doing enough to clean up the site.
Diamond Shamrock has complied with the requirements imposed
on it by the State and Federal environmental agencies in
addressing site cleanup.
i • •
2. One person vas concerned that no penalties had been
assessed against Diamond Shamrock.
The «uperfufid~IegisIatl5H~dbes~ not provide "E5>A with the
authority to impose penalties for past actions which
resulted in the -creation of uncontrolled hazardous-waste —
sites. It does, however, impose financial liability on
responsible parties for the costs of the cleanup efforts at
Superfund sites. Diamond Shamrock has spent millions of
dollars on work it has done to clean up the site and
surrounding areas and has reimbursed EPA for almost
$2 million of the Agency's costs.
3. Mr. Sudol stated his belief that violations of ECRA
may have occurred when Diamond Shamrock transferred
property to a. separately incorporated holding company.
Since ECRA is a State lav and falls within State
jurisdiction, the matter has been referred to NJDEP for
investigation. The alleged ECRA violations, however, are
unrelated to the selection of a remedy for the site.
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C. Conditions at the Site
1. A few people questioned what would happen to the 570
drums and the cargo containers. One woman wanted to
know the condition of these drums and cargo containers
and whether they would be checked before the next
Feasibility Study. Another speaker believes-that
burying the drums will cause new problems.
The drums and storage containers that remain on the site
are inspected on a regular basis. Currently, they are in
acceptable condition to prevent releases of containerized
materials to the environment. Any drum found to be leaking
or whose integrity is otherwise impaired is quickly
repaired. Waste from the drums will be stabilized (i.e., -
the liquids will be solidified) before burial and will not
add significantly to the contamination. Those drums which
are found not to be dioxin-contaminated will be disposed of
off-site.
2. A few local residents spoke of concern about the
guards at the site. One person said that he had gone
to the site at various times and had seen no guard.
The site is visited periodically by NJDEP. To date, a
guard has always been found to be on duty. These periodic
checks will continue to ensure that the 24-hour security
service continues to provide adequate site protection.
3. One community member said he felt that the cleanup of
the Passaic River should not be left unaddressed.
Contamination in the Passaic River is beyond the stated
scope of_the Feasibility Study and Proposed Plan for 80 and
120"Lister Avenue. A separate study has commenced and a
Feasibility Study will be conducted to determine possible
clean up alternatives for the River. A public involvement
program will be implemented for that activity to inform the
local community of site activities and conditions and •
provide opportunity for public comment.
4. Mr. Montague wanted to know exactly what, and how
many, chemicals are contaminating the site.
The list of chemicals identified to be present at the site
is extensive. This information can be obtained in the
documents "Site Evaluation for 80 Lister Avenue" (February
1985) and "Site Evaluation for 120 Lister Avenue" (May
1985), which are part of the administrative record for this
site.
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D. Other Concerns
1. Mr. Victor DeLuca, from the Ironbound Comnunity
Corporation, felt that the response to the need for
cleanup in Montclair. NJ vas more rapid than the
response at Diamond Shamrock and wanted to know why.
The problem in Montclair, although not without considerable
difficulties, is less complicated than the problem at the
Diamond Shamrock cite. As a result, the solution there
should be easier to complete. It should be noted that
NJDEP and EPA have responded rapidly to the problems
associated with the Diamond Shamrock site and that much has
been accomplished since dioxin was discovered in 1983.
However, this highly complex situation is not amenable to- a
quick solution.
2. City Councilman Martinez expressed his concern that
Newark is being penalized for its "not in my backyard"
sentiments.
This was not a consideration in the decision-making process
for the site. The available alternatives were evaluated,
and the remedy selected, strictly on the basis of site
characteristics and technical factors.
3. Mr. Montague expressed the opinion that the meeting
would have been more effective if the sound system and
general logistics had been checked beforehand.
EPA and NJDEP agree that the sound system and the meeting
room acoustics were less than desirable. Before reserving
the meeting room, the Ironbound Community Citizen's Group
was asked its preference for the meeting location. Its
preference was the St. Aloysius Theater. Since no
complaints had been received at the previous public meeting
on this site held in the St. Aloysius Theater, it was
assumed that the facilities were acceptable. The Agencies
apologize for the noise of the air conditioners.
4. Mr. Gordon said he believed that EPA/NJDEP had failed
to measure the "emotional factor" of the preferred
alternative.
.•
The proposed remedy is the alternative which is most
protective of public health and the environment and
represents a major improvement over the current situation.
If Alternative VI were selected, the emotional response
• from the public might be more favorable at first. However,
the implementation problems associated with Alternative VI
would result in later disappointments. The Agencies will
continue to stress the advantages of the proposed remedy.
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It is hoped that the community will appreciate the positive
aspects of the Proposed Plan.
5. One person expressed the opinion that HJDEP has done
nothing to remedy the situation at the site.
Over the course of the last four years much work-was done
to remove contamination from the community and place it on
the site, where people will not be in contact with it. The
proposed remedy will further contain the release of toxic
substances into the environment. Since 1983, NJDEP and EPA
have made major strides in controlling risks from the site
and will continue to do so.
6. Mr. Montague spoke of his concern that EPA and NJDEP
had reasons for the proposed selection of a remedial
alternative which are being hidden from the public.
There are no hidden reasons for selection of the proposed
remedy. For example, both the fact sheet distributed at
the meeting and the Proposed Plan clearly state that a
major disadvantage of Alternative VI is the problem of
siting a thermal treatment unit. All reasons for the
selection of a remedy at the Diamond Shamrock site are
found in the Proposed Plan and will be presented again, in
more detail, in the Record of Decision.
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III. Summary of Written Comments
The following is a summary of written comments and questions
received during the public comment period, July 31, 1987
through August 31* 1987, and the responses to them. Comments
given at the public meeting and reiterated in writing have not
been repeated here but are addressed in the previous sections.
A. In a letter dated August 31, 1987, Kaxus Energy Corporation:
expressed its concern "about the delay in the approval
of a remedial action plan which would enable the
closure of the site and elimination of the interim
measures."
EPA plans to sign a Record of Decisions for this site,
which would constitute formal selection of a remedy, in the
very near future. Once a remedy is selected, EPA plans to
expedite its implementation.
urged EPA and HJDEP to revise the proposed timing of
the biennial re-evaluation of the remedy from every
two years to an "as-needed" basis. The remedy would
then be re-evaluated "only if it proves to be
ineffective in removing and controlling the movement
of contaminants which pose an unacceptable risk to the
public..."
CERCLA requires that not only releases, but also the threat
of releases, be remediated. Even if the Proposed Plan
works soundly, there is still a threat of release which
should be examined regularly. Therefore, EPA and NJDEP
have no plans to change the requirements of the
re-evaluation of the selected remedy every two years.
stated its belief that the acceptable levels of
dioxin at the site should be reviewed. Currently, "an
action level of less than one part per billion (ppb)
in the soil has been shown to be an acceptable
standard for public or residential areas, with a level
of 5-7 ppb being the NJDEP and EPA standard for
industrial sites." Kaxus recommended that the
acceptable level of dioxin be set at 5-7 ppb rather
than 1 ppb at the Diamond Shamrock site, since the
site is industrial.
At the present time, it is impossible to predict with
certainty the future land use at the site. Therefore, EPA
and NJDEP will require a 1 ppb standard to protect the
possibility for all potential land uses.
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B. Zn his letter of August 17, 1987. Michael Gordon stated
that, "The DEP decision not to require site stabilization
(alternative 3) in conjunction with a requirement that an
off-site incinerator be sited, designed and constructed
pursuant to a detailed tine schedule, is arbitrary and
unreasonable."
EPA and NJDEP have not established that excavation can be
conducted with acceptable impact on health and the
environment. Furthermore, EPA and NJDEP do not know at
this time whether off-site incineration will be preferable
to on-site incineration or to some other remedy at some
point in the future. This will depend on factors such as
the future availability of off-site facilities permitted
for dioxin, the ability to resolve siting difficulties in
the future, the cost differences between on-site and
off-site incineration, the performance of the interim
remedy (which would dictate the urgency of undertaking
additional remedial action), etc. These factors can be
better evaluated in the future. Therefore, it is premature
to select off-site incineration or any other option as the
second phase of a remedy which begins by stabilizing the
site by implementing the proposed containment plan.
C. The mayor of Newark, Mr. Sharpe James, in his letter of
August 18, 1987:
stated his belief that NJDEP will soon "fail to meet
its own recommended biennial timetable. 'The
Feasibility Study on which the public meeting was
based, was dated December, 1985. Almost two years
have already lapsed without any of the alternatives
being implemented. Therefore, per DEP's commitment,
the biennial review process of feasible disposal
alternatives should be initiated before December,
1987."
The biennial timetable as described in the Proposed Plan
has not yet begun. It is scheduled to begin two years
after the selected remedy has been installed However, as
noted in answer to question 7, this Record of Decision is
not based solely upon the feasibility study, but also upon
additional information, not available at the time the FS
was prepared, contained in the Administrative Record.
•
stated that the proposed containment plan cannot be
implemented until it meets the siting criteria of the
Major Hazardous Naste Facility Siting Act. The plan
must be approved by the Siting Commission.
The Major Hazardous Waste Facility Siting Act applies only
to commercial hazardous waste management facilities, and
does not apply to the Proposed Plan.
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D. In her letter dated July 27, 1987, Ms. Kathleen Craig
eomnented that the proposed containment plan "is only a vay
of putting off the inevitable." She enclosed some
literature concerning a recently developed thermal
treatment system (Ogden Environmental Services' circulating
bed combustor). • ' _
EPA and NJDEP are aware of the Ogden combustor, which has
not yet been demonstrated for dioxin wastes. However, its
success in treating PCB wastes makes it promising for
future use with wastes from the Diamond Shamrock site.
Responses to other comments on thermal treatment are also
relevant to Ms. Craig's comment.
Although Ms. Craig did not elaborate on what she means by.
"putting off the inevitable," EPA and NJDEP recognize that
the proposed containment remedy requires continued
operation and maintenance, and may require additional
remedial action should it become less effective with the
passage of time. The proposed remedy includes provisions
for operation, maintenance, periodic re-evaluation, and
additional remedial action, if appropriate. EPA and NJDEP
have determined that the proposed containment remedy is
currently the most protective of the available remedial
alternatives.
E. In bis letter dated September 6, 1987, Peter Montague
submitted written comments elaborating on the comments
which be made at the August 11, 1987, public meeting.
Because his written comments were submitted after the close
of the public comment"perTda, a response to' Hr. Montague's
written comments is not provided in this responsiveness
-summary. However,-Mr r Montague's oral comments-have been —
addressed in a previous section of this document. To
address Mr. Montague's written comments in this document
would delay the Record of Decision and the initiation of
remedial action. EPA and NJDEP have decided that
Mr. Montague's written comments do not merit any change in
the selected alternative. However, NJDEP intends to send a
written response directly to Mr. Montague.
-19-
-------
APPENDIX B
Sit* Evaluation A&Aljtictl Result*
-------
site twresricATtw
AMICWT All tESULTS fm DIOHN
*
MTff AM> SMffU l» Hf-tA 9-ll-M f-lt-§4 9-tt-M 9-19-U 9-tl-Sft 9-14-M f-«-t4 lf-3-§4 lt-4-t«
•tIM-A-C -till- -«IM- -»4I4- •t)9f- -Oil- HMI4- -W4J- -1084- -I24I-
«K<§) «bf<«) IM
-------
titt
Mtitnrr AIM MSULTS rot MA
Mtt AND tMtnt tt
RMI
•*M»ft,fct I Ifcrf !•••
IfMCfWf I f If J— C
0.94
t.10
t.O
0.M
I.M
0.M
I.M
1.19
0.10
t.M
0.19
f.lt
•11-04 9-11-04 9-l?-04
till- -0101- -0414-
i
1
1
0.49
0.41
I.M
0.99
0.90
0.M
0.M
0.M
1.10
1.14
0.49
t.M
.0.49
9.?9
1.01
0.00
9.01 1 0.99
1.10
0.11
0.09
1.90
l.»l
1.94
1.00
t.lt
0.90
0.9?
0.11* 0.09
i
4.44, 1.01
I.f4 I.IJ
t.MJ t.f4
1.90 t.19
9.94 0.90
• 1 0.09
1.41
r.90
r.M
1.9?
1.0?
I.M
1.9?
I.I?
1.49
1.4!
1.49
•
I.M
ll.tl
t-»t-04
-tm-
t.fl
1.44
I.It
1.0?
0.44
0.91
0.91
0.M
1.0?
1.4?
0.99
l.t?
9.99
9.ft
f-t4-M
-0f|4*
1.14
1.19
1.09
0.94
0.09
0.40
I.M
0.11
1.14
1.04
l.ll
l.fl
l.ll
11.99
9-19-04
-M4)-
3.M
1.19
1.99
I.M
0.71
0.M
1.99
0.09
1.01
1.01
1.10
t.M 9
1.91
10.40
10-9-0*
-It84-
t.fJ
0.?4
1.49
0.44
0.19
1.19
>.9!
1.91
L94
1.99
1.9?
1.04
1.99
1.14
10-4-04
-1141-
1.99
I.f9
I.M
9.M
9.0*
9.99
1.09
0.11
1.11
I.M
I.M
l.ll
l.lf
19.41
I*.
-------
•ITC INVCSrtCATIM
AH RESULTS ron resnciKS
MTC AM f AMPLE 10
PAMMBTCM
fettle MM I !*/•')
Mltmyl
chl«ri««
tmf^tmnmmf
•vlfwiyl cMorl««
9-10-04 9-ll-M 9-11-04 9-ll-M 9-19-04 9-ll-M 9-14-M 9-»-04 10-3-M 10-4-04
-9I44-A-* -0101- -0101- -0414- -0)91- -0111- -0114- -0041- -1084- -1141-
f.tf
O.SI
41.91
0.91
3.30
4.93
0.31
f.31
4.00
«f.2f
30.99
0.99
1.90
0.19
-------
COW «•»«»• *.M ^.j *** fr>M fr4^ t-MI •»!•• •-»-• »•** «-VI trV* •-*-* «•»•« *** «.|m ».f^ «.|HI ».V» +t-9 ».fHI J»t
. «• . - ' . i
•* 1M «.W Ml HI ».• t.« Itt M.« •!• IJiM IM tW Ml Ml «.» ««.« f.M* ».« «^M ft.t >.%
t-lt tW l.t Ml H.I •».« t.l ».l M.« W» M.I IM 9.M* lit M» «.« «t.« I.IM M.I l.f» II. » l.«
u-i* tw i.i t.i •« it. • i.i •.• t»M it.w* ».• ii.« t.m «».» in it.i i»t «ra »» N* if» «.«t
M-M •••••••••••«•«*««•«•«
• ft ft • ft • ft ft ft ft • ft ft ft ft ft ft ft • • • •
ft ft ft* • • • ft ft ft ft ft ft ft . ft ft • ft ft ft ft
ft • %%• ••»!• «
t • »«fM«l. tlM* •
-------
•EAR-SURFACE SOIL SAMPLE 2.3,7,8-TCDD REANALYSXS SUMMARY
STATION
'VUMBER4
A-2-C
A-2-C
A-5-C
A-3-C
r-s-E
F-S-E
F-3-E
C-3-I
C-3-L
C-4-A
C-4-A
C-4-A
C-3-F
C-3-F
B-2-H
H-2-H
H-2-H
H-3-F
H-7-F
H-7-r
H-7-F
DEPTH
( inches)
0-6
6-12
0-6
6-12
0-6
6-12
12-24
0-6
0-6
0-6
6-12
12-24
0-6
6-12
0-6
6-12
12-24
12-24
0-6
6-12
12-26
ELEVATION
CODE
100
101
100
101
100
101
102
100
100
100
- 101
102
100
101
100
101
102
102
100
'101
102
INITIAL
RESULTS
296
289
900
460
268
24?
M9.000
1,110
261
393
323
339
»1,586
1,160
286
336
>S,H8
»1,9SO
231
CORRECTIVE
ACTION
gram
gram
gram
gram
gram
gram
1 gram, dilution 10 tl
1 gram
1 gram
1 gram
1 gram, dilution 9s 1
1 gram
gram
gram
gram
gram
gram
1 gram
1 gram, dilution Ssl
1 gram
1 gram
tEANALYSYS
tESULTS
(ppb)
326
330
693
470
394
19.300
1,010
310
276
3,690
1,770
361
494
2,390
1,230
S10
383
9,050
. 2,730
200
-------
SUMMARY or DETECTED VOLATILE ORCANICS
NCAR-SURFACe SOILS
(Ei»ret»ed •• Hft/fcf or »pb)
0-4 INCHES
Benzene
Chlorobenaene
Chloroform
Kthjrlbencene
Kcltiylene chloride
TelrMhtoroethanc
Toluene
Trlchloroothcne
Acetone
21
84,000-99
38
1,400-130
Carbon 4it»lflo>
ION RANGE POSITIVE
RESULTS
Total ay tenet
I
2
I
0
21
1
0
0
'13
2
•
0
0
12-24 INCHES
NUMHER
SAMPLES CONCENTRATION RANG*.
ANALYZED
* •
21 23,000-11
21 170,000-22
21 38,000-13
21 40,000
21 130,000-21
21 34,000-1,300
21 2,000,000-7
21 9
21 2,000-48
21 9,200-91
21 7
21 34,000
21 310,000
NUMBER
POSITIVE
RESULTS
1
J
ft
2
1
21
2
ft
1
1)
•
1
I'
1
NUMBER
SAMPLES
ANALYZED
21
21
21
21
21
21
21
21
21
21
21
21
21
-------
Hentof • ) py rene
l)rnKo(b)fluoranthene
Chrjrfcnc
Acenapttthylene
Anthracene
Nnorene
PticfiMithrcne
In4eno( I ,2 f 3 •-CD)-fyrene
rjff CM
Di bcmtof uran
2-Netliyl i
cotfcornumo* MNCB
/
4,800-1,000
1,100-2,100
12,000-2,600
690-210
3,000-310
11,000-3,300
320
4,100-2)0
2,900-2,200
2,200-230
220
0-6 INCHES
NUMBER NUMMKR
POSITIVE SAMPLES
BESULTS ANALYZED
• •
t
«i
21
21
21
21
21
21
21
21 •
21
I 21
coNCEimumuN RMNX
MKSW.TS
44,000-^60
11,000-940
120,000-1,400
B60-240
1,200-630
32,000
300-2)0
•1,000-440
21,000-480
18,000-280
4)0
21,000
12-24 INCHE
HIM
INCE POSI
ANAl
1
S
*
BK*
TIVE
YZEO
SAMPLRS
21
21
21
21
21
21
21
21
21
21
21
21
-------
SOMMART OP MIECIED RERBIC1DES, KSTICIDCS, AND
NEAR-SURPACE SOILS
4,4'-DDT
4V4*-DDE
4,%'HfDO
Al pti*-En4o«ul fan
2,4-0
or
CONCENTRATION RANGE
3,508,000-420
93,000-20
13,000-1,100
8,900
10,000-190
1,400-148
1,300-190
0-4 INCHES
i 1
• NUMBER
1 POSITIVE
j RESULTS
•
.
1 !,
i
t
» .
NUMBER
SAMPIJ-S
ANALYZED
21
21
21
21
21
21
21
INCHES
CONCENTRATION RANGE
5.090,000-1,400
11,000-1,200
144,000-1,200
1,400
2f,000-420
85,000-190
84,000-490
NUMBER
POSITIVE
RESULTS
15
8
5
1
9
13
10
NUMBER
SAMPLES
ANALYZED
21
21
21
21
'I
21
21
-------
000IM: SMI MMTUS
t,».r,0-ici0
BMf 100 0VNMM
CVATIO0
COM
100
101
101
109
901
VCrVW
„
0-11
19-14
•tow •III
•lit
.»
**H»
H.I
M.0
99.5
t W* W
ft H»J*J
•0 C0.09I
»-f^ , e-f-e
19.9 1*0
10.0 fM
9.4 941
m 10.09) 91.0
<4.»-0.0*) (4.V4.0*)
00 10.1) t.l
0-I-,
•1.0
9.)
4.9
0.90
(4.1-4. f>
00 10.04)
f-9-0
9.S40
109
409
<0.Vi*)
0.49
l-9-l
9,190
910
91.4
19.1
9.9
1-5-4 >
59)
00S
•w
90.9
(11.5-15.9*)
•• -
l-9-l
)50
).9I0
59. S
5.0
19-1.5*)
9.0
III.0-IS.0*) CI0.0-I9.0*) CI0.9-I9.9*) CI0.0-I9.0*) 119.0-19.0')
-------
••• II
•••MI or Kitctn wuffiu MCMICS
!• MIL «MI«C*
It-H
MNriKt coMMittTton •<
•esvtts
MMITIVC
KSM.TS
•tit
vosmvc
•CSVI.T9 AMALVZMI
M
H
nt
•
•If-M
It-t
IM-tf
A ^
I
•
• (
tt.
l4.Mt-IM
M
j
II
t.ltt
-------
MM^M^^^^^fe ^^M^^kA^M)^^Mft ^MMMM)4»flMMA A^Mk ^MM>9^
•CTCCTO OTMncm. fonciMi( MB vn •.
I* MIL Mil
If-M IMMS
fit?
UNTU4
MM.no
nrnwrtoi
romivc
•esvits
SMVUS
MALTtt*
flwm.»:f
wsatts
M
f
•A .
fW 9 ™« 9
f.«-M
••MJ ^M^K^^^A
•WtOTV^VW
• A flBA»ttft
WV-flt
W
9
IU.M9O.9M
IM.Mt
$
I
f
f
•
f
I
t
|M.Mf.|M
II0.M9-4}
I ^|a
^v.^^w
•
IM
•W.M9-4I*
lit
-------
SUMMARY or DETECTED MSE/NEUTRAt/Acio ORGANIC COMPOUNDS
NEAR-SURFACE SOILS
(E*preMe4 •» »g/fcft or ppb)
UUNLU IMTtON RANCE
2,4,4-Trichlorophenot
7,4-01chlorophenol
7,4-DlMthjrlthenol
Bencolc Ac14
7,4,5-Trichlorophenot
Aeencphthene
I,2,4-Trlehlerobenten*
NcMchtorobentcnc
Iv J-Dlchlorobenscnc
I, J-Di ctilorobeiwcnc
i ,4-Dichlorobtiiitnt
Fluoranthenc
Naphthalene
Bisd-ethylheiyt Iphthalate
1,100
15,000,000-870
11,000-1,500
iio,ooo-5fti
5tO-t)0
•
1,400-470
•,100-5 JO
too
1,500-510
47,000-910
0-4 INCNCS
NUMBER
rosiTive
RESULTS
5
7
0
1
5
1
* ,
15
2
0
5
5
1
5
0
5
NUMBER
SAMPLES
ANALYZED
11
21
21
21
21
21
21
21
21
21
21
21
21
71
71
71 '
12-M maies
TION RANCK
1,700,000-8,700
2,500,000-870
1,700,000
7,500,000-2,500
19,000
720,000-5,200
9,000
410
1,300
44,000-470
8,700
510,000-5,100
570,000-7,000
47,000-510
NUMBER
POSITIVE
RESULTS
4
8
1
0
5
0
1
9
1
1
1
t 1
1
J
7
^
NUMBER
SAMPLES
ANALYZED
71
71
71
71
71
71
71
71
71
71
21
21
71
71
71
71
-------
Mcftvl
•ll
tl
!• Wit *>«I«C«
!«•»?••••« •• *•/»• ••
rositivt
•man
If-M II
fomtvt
MSVttt MMlTtU
flltt
CMCEMVNYIM UMCC MMITIVK
< MSOttS AMI.fZK»
ll-».t
ft-l.t
M.1
Yff-f.t
«^A_AA
•^^^i*
I.M0-IS
II-9.I
t»-l»
.•.w-«.f
I.9W-IN
|.t-«.M
•«^ •
l.f-«.l
M-f.l
».!-§.»
I.V4.I
AA.lt
W^IV
9W-M
f.IM-IM
!.*-«.»
• ff^ll
lfw*if
t.f^.l
|«^_iaa
»J*»-I*»
>!•• 1%
• »*W«i»
»-•.»
l.l^.l
Itt-t.f
l.«««.l
f-t.l
»-».»
•.•M-M
II.IM-19
9>-«.t
fl-».i
!.•••.«
I.W»-4»
!.!••. 1
|.«W-t.)
-------
t-« IWM
| !• »
fC»»ra«M*
Mil
••
MIIK*
•MtTUM
•UMTS
».
»•
It.
I.9W
».
• ^
§
•.
•1 •< t-Mkf lltMfl IpMlMlal*
mCMHCf
|I->4 |MNO
IDSItlVC SMirtCS
MALVXC*
•M
»».
I9.<
•.9M-M0
^••••^
•>•
II.<
U.I
-Mt
^
SILT
, tesui.TS M»IW:I»
I
f
5
f
ft ,
0
I
I
0
I
I
t
f
-------
••4 IKMt
limn «Mint»
•CM! I
n
t.iw
•.IW-fft
Atcrfwt
I
I
1
9
f
9
I
I
If-f* I
SILT
IMM-I.I
I9.9M
f.199
•ositivc wtrus
MSWLTS '
I
$
I
»
I
I
I
l,fM
I.
I4.M9-I.
KESVtTS MAl.mil
I
9
9
9
I
9
>
I
9
-------
SUMMARY OP 2,3,7,8-TDDD
POR GROUND WATER
WELL
.VUM8ER
•
1
2
3
4
3
•
7
t
WCATIO"
• . •
1-2-L
I-5-A
I-7-K
C-7-C
A-2-K
A-3*C
D-i-r
r-7-8
SAMPLING
10-09-84
10-09-84
10-10-84
10-09-84
10-09-84
10-09-84
10-09-84
10-09-84
tESULTS
-------
SUMMARY OP ftKTKTCD I MM CAN 1C PARAMETERS
HELL WATER SAMPLES
(Ea»r««»etf •• UK/I or ppb) .
10-09-84
Antlwmy
Ar rente
Beryl I !«•
Nercvry
Nickel
Silver
Zinc
Total Cyanide
Total Mienol
MMBKR
ooncomiATioN MNce rosirive SAMPLES
RESULTS ANALYZED
t.oos-o.m
O.OIS-O.MI
0.009-0.008
0.002-O.Olf
0.01-0.13
0.091-1.9
0.18-41
'O.OOI-O.U
•
0.0«-0.90
MD
0.003-0.001
0.249-19
0.01-0.3)
0.03-102
RANCK
0.001-0.024
0.028-0.t29
0.002-0.010
0.002-0.023
0.08-1.1
0.2M-2.9
0.44-14
0.002-O.OH
0.06-0.42
0.009
0.002-0.01)
0.864*19
0.01-0.63
0.03-98
.10-38-84
NUMBER NUMBER
POSITIVE SAMPLES
RESULTS ANALYZED
1
8 .
8
8
8
8
8
8
8
8
8
8
8
8
8
-------
SUMMARY OF
NEMIClim, H3TICIKS, AND
WELL HATCR SAUNAS
•• M/t or ppb)
10-09-84
10-30-84
M'-ODT
4,4*-DI«
4.4'-DM>
Al ptia-entfowlf an
7,4-0
7.4-08
Di notch
OONCBnVATIOIf RANCB
.
17-22,000
11-54
15-13,000
NO
. t.9-t7,OM
4 70-5, tOO
500
4.2
NUMtni
rosiTive
RESULTS
4
2
5
0
4
i
4
1
1
WJNRKII
SANfLE*) I
ANALY7.MI
8
8
8
8
8
8
8
. 8
'.OttCKNl RATION RANCK
!4-2,yfO
7-14
1-1,390
1,240
14-20,000
•8-3,300
NO
NO
NUNVKR
fOSITIVK
RP.SUI.TS
4
2
4 '
1
4
4
0
.0
NUMBm
SAMIM.KS
AWALYZKD
8
8
a
a
a
a
a
a
-------
SUMMIT Of DETECTED VOLATILE ORCANICS
HELL WATT.* SAMPLES
(Expressed •• »ft'l or
10-09-84
Chtorobencene
1 , 2-Dl chtorocttMiw
1,1, l-TrichloroethMte
1 , 1-DtcMoroethane
Chi or* ton*
1 , 1-Di ettloroctlMM
I rang- 1 , 2-01 cht oroothene
Methylcnc chloride
Tetrncht oroethcnc
Toloenc
Trictit«roctlM«i«
Vinyl etilorlfe
Acetone
?-8i«i«nonc
Carbon JUulMfe
A-Melhyl -?-p«nt«nune
Total «ylcn««
CXMCEHTRAttON RAMCC
1.80,900
14-8,900
1,108
410
$
10-230
NO
JJ-MO
44-740
t-12,000
2-5
7-1,100
19-290
28-88
29-940
870
2-49
3,300
42-960
POSITIVE
RESULTS
NUMBER
SAMPLES
ANALYZED
I
4
CONCENTRATION RANGE
10-7,900
4-21,000
2,000
1,900
190 .
19-240
91
10-1,100
41
1-7,400
2-41
99-1,100
9-780
24-220
21-920
180-410
M1>
1.800
II-WO
10- 90-84
NUMHER
POSITIVE
RESULTS
7
7
1
1
I
1
1
2
2
8
1
*
t
ft
I
2
• -o
1
4
NUMBER
SAMPLES
ANALYZED
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
-------
stwmiiY or DETECTED MSE/NEVTIIAL/ACID OMANICS
HELL HATCH SAMPLES
(Exprettee' •• »•/! «r ppb)
IO-09-84
10-10-84
2 , 4 ,4-Tr lehl orophenot
7-Chlorophenol
7,4-Diehlorophenol
Phenol
Bensoic Ac 1 4
2-Nethf I phenol
4-Nethyl phenol
1 • 4 v 3-Tr i chl orophenol
Acenaphthene
CXHfCOnHATIOII
lvfOt-ll,9M
290-49oOO
rosiTive
•JESUITS
MUNHKR
SAMPLES
ANALYZED
H-3,?00
2)0
MD
39-M
lfe««chlorobensene
?>Chloron«phthalene
I * 1-Dl eh I orobencene
l,)-Diehlorobentene
I , 4-01 eh I orobeniene
Pl««ranthene
Nuphtliiilenc
Bi •
8
8
4
12
3-110
)-44
4.100
1-900
NUNBEft
SAMPLES
ANALYZED
-------
KMUIT Of UCBT WOXII OMCBRIAnon
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SEWERS AND SUMPS
2,3,7.8-TCDD RESULTS SUMMARY
ANALYSIS
LOCATION
•
Stvtrt
Suapt
Manufacturing
•wilding
Froctti Building
TOTAL
NUMBER OP
SAMPLES
3
12
NUMBER OP
POSITIVE
BESULTS
3
12
RANGE OP
CONCENTRATION
(ppb)
10S-2.9SO
350-9,If0
19.S-9.UO
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