United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-89/087
September 1989
&EPA
Superfund
Record of Decision
De Rewal Chemical, NJ
-------
50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-89/087
3. Recipient'* Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
De Rewal Chemical, NJ
First Remedial Action - Final
5. Report Date.
09/29/89
7. Author(s)
8. Performing Organization Rept No.
9. Performing Organization Name and Address
10. Project/Task/Wortt Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460 ;. ;•
11 Type of Report a Period Covered
800/000
14.
IS. Supplementary Notes
16. Abstract (Umit: 200 words)
The De Rewal Chemical site is in Kingswood Township, Hunterdon County, New Jersey. The
3.7-acre site lies-within the 100-year floodplain of the Delaware River and consists of a
former dumping area, a garage, a private residence, and a building formerly occupied by
the De Rewal Chemical Company. Between 1970 and 1973 the De Rewal Chemical Company
reportedly manufactured and stored a textile preservative and an agricultural fungicide
onsite. The State discovered De Rewal Chemical Company's improper chemical handling
practices in 1972 but was unsuccessful in forcing the company to comply with permit
requirements. The De Rewal Chemical Company continued to improperly dump chemicals
onsite including one incident in which a tank truck containing 3,000 to 5,000 gallons of
highly acidic chromium solution was allowed to drain onto the soil and eventually to the
Delaware River. In 1973 the State ordered the company to excavate and place contaminated
soil on an impermeable liner. The company reportedly only placed a portion of the
contaminated soil on an uncovered plastic sheet before filing for bankruptcy. The
primary contaminants of concern affecting the soil and ground water are VOCs including
PCE, TCE, and toluene; other organics including PAHs; and metals including chromium and
lead. (Continued on next page).
NJ
17. Document Analysis a. Descriptors
Record of Decision - De Rewal Chemical,
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (PCE, TCE, toluene), other organics (PAHs), metals (chromium,
lead)
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
51
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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16. Abstract {Continued)
EPA/ROP/R02-89/087 :
De Rewal Chemical, NJ .
The selected remedial action for this site includes excavation of 8,000 cubic yards of
soil with onsite thermal treatment of 2,100 cubic yards of organic-contaminated soil
followed by solidifying the soil and ash residue along with the remaining 5, 900 cubic
yards of inorganic-contaminated soil and onsite disposal; monitoring and controlling air
emissions generated during thermal treatment; pumping and offsite treatment of ground
water at an offsite industrial wastewater treatment facility; ground water monitoring;
provision of a treatment system for the onsite residential well; temporarily relocating
onsite residents; and preparing a cultural resources survey to ensure compliance with the
National Historic Preservation Act. The estimated present worth cost for the selected
remedial is $5,097,000, which includes O&M costs of $865,400. , :
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DECLARATION STATEMENT
RECORD OF DECISION
DeRewal Chemical Company
SITE NAME AND LOCATION
DeRewal Chemical Company,
Kingwood Township, Hunterdon County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial ^action for
the DeRewal Chemical Company site, chosen in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, as amended by the Superfund Amendments and
Reauthorization Act of 1986. and, to the extent applicable, the
National Oil and Hazardous Substances Pollution Contingency Plan.
This decision is based on the administrative record file for this
site. .. •.'••• •. ';••''. '..' '' .. ,' ' .• / • ••-. '•' • •
The State of New Jersey concurs with the selected remedy.
ASSESSMENT OF THE SITE . ..<'..'.;
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision, may present a current or
potential threat to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY . .
The remedy described in this document represents all planned
activities for the site. It addresses contaminated soil and
contaminated groundwater in the shallow aquifer underlying the
site. In addition, the remedy includes post-remedial action
monitoring of the deeper bedrock aquifer.
The major components.of the remedial action are as follows:
T Excavation of soil contaminated with organic and inorganic
compounds above action levels;
- On-site thermal treatment of the organic-contaminated soil;
- On-site solidification/stabilization of the thermally
treated soil and the remaining inorganic-contaminated soil;
-------
-2- .'/ •'•'••• .•./.••.
- Extraction of shallow groundwater contaminated above
drinking water standards, on-site storage, and off-site
disposal at an approved industrial wastewater treatment
facility;
- Provision of a treatment system for the on-site residential
well;
- Appropriate environmental monitoring to ensure the
effectiveness of the remedy; and
- Establishment of deed restrictions, as necessary, to ensure
the effectiveness of the remedy.
STATUTORY DETERMINATIONS . , :
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable and
satisfies the statutory preference for remedies that employ
treatment that reduce toxicity, mobility, or volume as.a
principal element.
u
Date William^. Mu's^fiski, P.E.
Acting Regional Administrator
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Decision Summary
DeRewal Chemical Company
Kingwood Township, New Jersey
SITE DESCRIPTION
The DeRewal Chemical Company site (Figure 1) is located in
Kingwood Township, Hunterdon County, New Jersey. The 3.7-acre
site lies one-half mile south of Frenchtown, between New Jersey
State Route 29 to the east and the Delaware River to the west. A
bike path, which is part of the Delaware and Raritan Canal State
Park, divides the site into eastern and western portions. The
site is located within the 100-year floodplain of the Delaware
River, and its topography is flat to gently sloping toward the
west. ' . ;•'•.:.-''•'".-'•'
Three buildings are located on the eastern half of the site: a
private residence, a building formerly occupied by the. DeRewal
Chemical Company, and a garage. Two intermittent drainage
ditches are located on the site, one east and one west of the
bike path. The area north of the site is occupied by a small
business, and the closest off-site residence is approximately 450
feet to the south. The population of Kingwood Township is
approximately 3,000.
Hunterdon County, in general, depends on both surface and
groundwater for its public water supply. Near the site,
groundwater is the only potable source of water. . At Frenchtown,
the Delaware River is used for navigation and recreational
purposes but is not used for public water supply. However, West
Amwell Township, located approximately 12 miles downstream from
the site, uses the Delaware River as the primary source of
potable water. Groundwater in the vicinity of the site generally
occurs in unconfined aquifers of recent river sediments or in the
fractured bedrock aquifer of the Brunswick Formation.
SITE HISTORY AND ENFORCEMENT ACTIVITIES ' ,',
• .
In 1970, Mr. Manfred DeRewal reached an agreement to lease the
eastern portion of the site from the Flemington Block and Supply
Company. It is believed that, from 1970 to 1973, the DeRewal
Chemical Company manufactured a textile preservative and an
agricultural fungicide and served as a warehouse for the storage
and resale of chemicals. The first of a series of reports of
improper chemical handling at the facility was received by the
New Jersey Department of Environmental Protection (NJDEP) in
1972, which led to several unsuccessful attempts to force the
company to abide by permit requirements. Numerous spills were
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DEREWAL CHEMICAL CO. SITE
FORMER
DEREWAL
CHEMICAL
CO.
MILE POST
34
LfSEHO
JSfc TREES, VEGETATION
—— PROPERTY UNE
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reported in 1973, including one incident in which a tank truck
containing a highly acidic chromium solution was allowed to drain
onto the soil and eventually to the Delaware River. Inspectors
estimated that the spill involved 3,000 to 5,000 gallons of what
were believed to be plating wastes. In November 1973, the State
of New Jersey ordered the DeRewal Chemical Company to excavate
the contaminated soil and place it on an impermeable liner. It
is believed that some soil was placed on plastic sheeting at the
site, but was left uncovered and allowed to erode. In 1974, the
DeRewal Chemical'. Company filed for bankruptcy.
The DeRewal Chemical Company site was proposed for addition to
the National Priorities List (NPL) of Superfund sites in
September 1983. After a public comment period, final listing was
made in September 1984. Also in 1984, the site was inspected by
a team of Environmental Protection Agency (EPA) and contractor
personnel to evaluate the need for immediate removal of the
contaminated soil. Immediate removal was not recommended. On
April 28, 1985, soil samples were taken by NJDEP. Chromium,
arsenic and nickel were found at concentrations above the
background level.
The EPA began a remedial investigation and feasibility study
(RI/FS) in June 1985 to determine the nature and extent of
contamination at the DeRewal Chemical Company site. This study
determined that contamination is present in the soil and the
shallow groundwater above bedrock. The site is not contributing
contamination to the surface waters that is detrimental to human
health or the environment. Site-related sediment contamination
exists at low concentrations and does not require remediation.
Similarly, few contaminants were detected, and at low
concentrations, in the water in the deeper bedrock aquifer at the
site. .••••..-." . .. . " •• •;
In June 1985, the EPA sent letters to Potentially Responsible
Parties offering them the opportunity to undertake cleanup
activities. None of these parties agreed to participate. In
November 1988, the EPA sent an information request letter,
pursuant to 42 U.S.C. §9604 and 42 U.S.C. §6927, to the owner of
the area of the site east of the bike path. The EPA received no
response to this letter. On March 15, 1989, pursuant to an
administrative subpoena issued by EPA Region III, Manfred DeRewal
was deposed by representatives of EPA Regions II and III. In
June 1989, the EPA sent 16 information request letters, pursuant
to 42 U.S.C. §9604 and 42 U.S.C. §6927, to potential waste
transporters and waste generators and to Manfred DeRewal. EPA is
currently assessing the responses that it has received to date.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI report was released to the public in October 1988. The FS
report and the Proposed Plan, which identified the ZPA's
-------
preferred remedial alternatives, were released on July 25, 1989
andJuly 27, 1989, respectively. The documents were made
available to the public at information repositories maintained at
the Kingwpod Township Municipal Building and the Hunterdon County
Library. The public comment period was; held from July 28, 1989
through August 28, 1989. A public meeting was held on August 10,
1989 to present the findings of the study and the Proposed Plan,
and to solicit public input. The issues raised at the public
meeting and during the comment period are addressed in the
Responsiveness Summary, which is part of this Record of Decision.
This decision document presents the selected remedial action for
the DeRewal Chemical Company site, chosen in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act, as amended by the Superfund Amendments and Reauthdrization
Act and, to the extent applicable, the National Contingency Plan.
The decision for this site is based on the administrative record.
SCOPE OF RESPONSE ACTION .
This Record of Decision (ROD); addresses all planned activities
for the site. It documents the selected remedies for the
remediation of the soil and shallow water-bearing zone.
Inorganic contaminants were detected in the bedrock aquifer at
slightly elevated concentrations. At present, the bedrock
aquifer does not.require remediation. However, it will be
periodically monitored prior to the start of the remedial action,
as well as during and after the remedial action. Monitoring of
the bedrock aquifer after the completion of the cleanup will
indicate the need for any further action. .
SUMMARY OF SITE CHARACTERISTICS :. .
A remedial investigation was conducted at the DeRewal Chemical
Company site to determine the type and concentrations of
contaminants in the various media at the site, and in the near
vicinity of the site. Samples were collected from sediments
deposited along natural surface water runoff pathways, surficial
soil to depths of up to two feet, and subsurface soil at varying
depths to the bedrock. Water samples were collected from surface
runoff from natural runoff pathways, the Delaware River, and
shallow and deep groundwater wells. Details of these sampling
efforts may be found in the remedial investigation and
feasibility study reports.
Origin of Contamination
Chemicals handled by the DeRewal Chemical Company included
copper aluminum sulfate, ammonia, micronutrients (containing '
copper, iron, zinc and manganese) used in fertilizers, a textile
preservative, acrylic acid, lime, ferric chloride, chromic acid,
and chromium and copper etching solutions. .
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'Soils. •'.... : ',-....
Surficial soil samples (0-2 feet) and subsurface samples (2-i4
feet) were collected. A summary of soil data is presented in
Table 1. Areas of contamination have been separated as those
east of the bike path and those west of the bike path. The
tables also show the NJDEP soil action level for the contaminants
found. ;
SUrficial soil is-contaminated with volatile organic compounds
(VOCs), semi-volatile organics [mostly polycyclic aromatic
hydrocarbons (PAHs)], and metals. VOCs were detected, above and
below action levels, throughout the site* Soil samples exceeding
the action level for total VOCs were found in the southern
portion of the site on both sides of the bike path. The
contaminants frequently detected include trichlbroethene,
tetrachloroethene and toluene. None of the samples collected
below a depth of 0^2 feet exceeded the action level for total
volatile organics/
Semi-volatile organics, including PAHs, were found mainly in the
surface soils. Contaminants frequently detected include
fluoranthene, pyrene, and Benzo (B) fluoranthehe. Although some
semi-volatiles were detected in the subsurface soil, no samples
below two feet exceed the action level for total semi-volatile
organics. ...';':/' •''•'.... '• ."' •' . '- •''.
Metals were found east and west of the bike path in both surface
and subsurfac^ soils. Metals frequently detected include
chromium, copper, lead and zinc. Unlike the total volatile and
semi-volatile, contaminants, metals were found below a two foot
dep* in concentrations exceeding NJDEP action levels.
Estimates for the volume of soil which has contamination greater
than the NJDEP action levels are summarized in Table 2.
-------
TABL
••
• .' "
• • .
'.'••. •
'• rnMfttMn
IMMOnNtCS .
CadHiUN
• •.-.••••
ChroMtUN CfotaD
Cnrr«r '
Cyanide
Lead ' ••">••• • • <
Herctary
Nickel
Sol et«* UN
Silver
Hnc
Heitevalent ChroMluM
ntanmcs
rotal Velatll* Or^^nlc*
rol«l S*«tt-volatil* Organic*
r»t.t r»^»-4 •><»»«<<- i»flii. at
-
Hjnrr
nrrinN
i run
•
! 3
ion
170
12
rw
\
100
•i
s
35O
•ton* »»t
1
» »
10
1
t
!
' StMTICIl
1
! HRNIMM
: coNctNritnrioN
tvt :'-• ' .
izro
1160
*M
783
2.S
M7
NO
fc-5
2300
3.5
31.5
l-fc.^7
.. .
74 «
cnsr or i
•
m. siMPics
rnrctMr or
smn.cs > NJntr .«
ib
M
22
1
•1 ••
K.
: • t
T
0
•2
M
M
12 i
M
urn
ii KC ram
SUBSIKFM
MWIMIM
•coNrrHiMnnoM
MO
«•<
93S
12
16
0.7
SI
_. 'k..^.,.
HO
2.5
SO7
IS
0.37
«_.
12 •
^ «
:
x sumrtrs
: pcuccNr or
ISfWPLES > NJOET •
o
•
9
2
0
o
o
o
o
2
37
a
2
«
MOTCS
• Percent of »aiyl»« Mhich contain ch»«itc»l c«nc«nlrations that oxcaad th* NJWP action
l*v»ls. owcapt h»M*v»l»nt chroniun atMl carcifM>9»nic PfHIs. ll*Mav«l*t«t chroNiix and
total carcinogenic Pfllls *r» calculated on the basis of tho total niMber or €*»t»cHons.
n Both detection* froatar than th* HJntP action level are frow the sane location.
• Haiti nun valuo for total «etil-volati le orqanlcs froti east and west of th* bile* path Is
fro** the sane location. ,
It Total carcinogenic PAMs Is a sub-category of total sewI-volatIIe organics.
NO Hone detected.
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TABLE I (continued)
SOIL SFtMF>l_IMG
CBR nvirn
Cfll I readings In
1 •-' • .'..•••..
« . • • ' ' • • ' • • . '
> • '- .
" . " '-
' • • . . -
' ' ' - " • -
'
.i -
INOKCnflCS
CadnluH
ChroMluN (Total)
Copper - • ' . '•••'-
Cyanide
Lead
Mercury
Nickel
SelenluN
Silver
21 nc
_ —
HeMavalent ChroniuH
OROflNICS
fetal Volatile Organic* UVO>
Total Sent -vol at 1 1 e Organics
Wmt»t rATY^MOMlr PMU It
;
HCHON
i LFVt L
!
1
I
3
100
iro
12
25O
1
100
1
s
350
0tOf%9 9^1
i
10
_
••*»•••* *****
• . • • •
SIKTICI
HnKIMM
OMLIHIKnrlON
10
100
201
_ _— — ^._ _ —
II
•
1*|9
• • »»
0.9
•1
7.1
12
sosn
^_
NO
S.l«
(6.11
i?. in
NEST OF UNO INCLUD1
tM. SntTttS
PCRCFNr OF
! SflNPlCS > HJHff • *
17
3
ft
—
O
O
0
0
a
33
0
29
V
7H
NO UK BIKC ran
SIBSIKFI
NRNIMM
CONCINIMirlON
NO
in
12
NO
11
0.2
NO
NO
158
12
O.T5
12 •
1 «Ut
« t
1
KC SMNrtES t
i mtccNr OF
: SMrtcs > Njocp •
0
ft
a
o
o
o
o
o
o
3
26
o
3
•fl
Hons
• Percent *f •*>q>t*« Mnlcti contain ctmilcai concentrations that encaed tne NJDCP action
levels. OMC*f»t ttettavalent chroNiun and carcinoq*nic r«l».- lleMavalent chroMim and
total carcinogenic rtHI* are calculated on the basis or the total nunber of detections.
•» Both detections «r*ater than the NJWP action level are fron the sane location.
I -HaidnuM value for total sewl -vol at 11 e organic j fro* east and uest of the bllre path is
Fran the s*ne location. «
• I Total carcino9*nic PflHs Is a sub-cate9orij of total *e*i-volat 11e organlcs.
NO None detected.
-------
Table 2. SOIL CONTAMINATION
Depth (feet) Contaminants Estimated Volume
0-2 Organics only 1,100
Organics+Inorganics 1,000
•Inorganics 800
SUBTOTAL 2,900
2-14 ..''.:•• Inorganics only 5,100
TOTAL 8,000
Groundwater
Groundwater was sampled from the monitoring wells and boreholes,
which were installed at the site (Figures 2). Groundwater samples
were also collected from residential wells. Groundwater samples
were collected in two phases, and the results of the analyses are
found in Tables 3 through 7. :
Two water-bearing zones were identified at the site: a shallow
water-bearing zone and a bedrock aquifer. The shallow water-
bearing zone located in the sand and gravel immediately above the
bedrock appears to contain little water, particularly west of the
bike path (see Figure 2) . The shallow water-bearing zone is not
a source of potable water in the surrounding area. Water level
data from the shallow groundwater wells indicate that groundwater
flows toward the west.
The shallow groundwater zone is contaminated with organics and
metals which exceed New Jersey Safe Drinking Water Act Maximum
Contaminant Limits (NJ SOWA MCLs) in most locations. Organic
contaminants of concern include trichioroethene,
tetrachloroethene, l>2-dichloroethene (total), methylene chloride
and 1,1,1-trichloroethane. Metals of concern include chromium,
copper, lead, nickel and zinc.
Contamination in the bedrock aquifer ranges from below to
slightly above the NJ SDWA MCLs as shown in Tables 3, 4 and 6.
Contaminants of concern include: trichioroethene,
tetrachloroethene and cadmium. The latest round of sampling of
the bedrock aquifer did not detect any organic contaminants at
concentrations exceeding ARARs.
8
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O •-••
LEGEND
WET SAND S WAVEL
O DRY SAND a 6RAVCL
LIMIT OF SHALLOW SITE
WATER CONTAMINATION
NOTE' MW-f, MW2 AND MW5
ARE THE ONLY DEEP
WELLS
DEREWAL CHEMICAL CO. SITE
ESTIMATED LIMITS OF SHALLOW GROUNDWATER
CONTAMINATION
DATE
JUNE 1989
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T H H L E
n R o n H n n n r E R s H M p L i H G
R I i P H H s t i - i) i! i; n N i i: s
(HI I readings in uq/l )
SHMPLE LOCnTION
COMPOUND SRHPLE NO.
I.I-DICHLOROETHENE
TRHNS-I.3.-OICHLOROETHENE
1 . 1 . 1 -TRICHLOROETHRNE
IRICHnLOROETHENE
TE TRHCHLOROETHENE
TOTflL XYtENES
1 . 2-0 ICHLOROBENZENE
2 . 4 , S-TR 1 CHLOROPHENOL
BISC2-ETHYLHEXYL) PHTHHLHTE
NJ
SOUfla
MCL
2
-
26
1
1
44
600
-
-
RESIOENTIRL HELL
• RH-I
BH 496
RM-2-1
BH 497
RW-2-2
BH 498
0.7
RM-3
BH 502
RM-4
BH 499
RM-5
BH 501 1
1.6
DEEP HELL
HW-I
BH sns
3.9
7.1
8.4
13. 1
HM-2
BH 506
MU-5
BH 5OI
.7.80
5HHLLOW WELL
MH-4
BH 507
270
ionn
13(1
i
3. 10
MH-6 ! MM- 7
BH 5O9
I7U
isnrai
BH 50B
69
180
4.60
I.4O
1.70
x Safe Drinking Hater Hct Haxiaum Contaminant Levels
•-" No standard available
-------
T H II I.
GPOIINDMHTEP SHHPI. ING
Rl I PHHSE II - OBGHNICS
(HI I reailin<]3 in iig/l)
SAMPLE LOCHTION
COMPOUND SAMPLE NO.
Hethtjlene Chloride (75-09-21
Acetone (67-64-13
1.2-Dichloroethene (Total) C 5-40-59-0)
Trichloroethene £79-01-61
Tetrachloroethene £127-18-41
Toluene [108-88-31
NJ
SIIHfl
MCL
-
2
-
-
1
1
-
REEP WELL
MH-I
BJ45I
KB
KB
3.5 J
MH-2
8.1452
KB
K
HII-5
BJ45S
SIUILLOH WELL
MH-4
0.1454
pa
KB
ISO
440
28
MM-:I
11.1453
Mll-ft
IJM!)b
92O
1600 J
700 J
34OOO
UN- 7
B.M57
K
12
75
7.5
BH-4 (HP)
BI458
K
2.7 J
3.3 J
K
1)1 HNK
TB-2
B.I 4 68
KB
KB
FB-2
BJ469
RB
KB
K
OHTH QUALIFIERS
R - Data value rejected because quality control criteria uere not met.
8 - Compound uas detected in the blank
J - Estimated value because the amount detected is helou the required
linits or because quality control criteria uere nut fill l«j out.
"-" No standard available
-------
T H n L f. 5
G P II II N II W R F E C S B H P I- I M G
PI I I - V 0 L fl f I L fi n 8 G H N I C 5
CHI I readings in uq/l )
SRHPLE NUMBER
COMPOUND SHMPLE NO.
Mtfthijlene Chloride I75-O9-2]
Rc:eLone [67-64-1 1
1 . 1 -0 i ch 1 oro. then. I 75-35-4 J
1, l-Dich lor oe thane 175-35-31
l.2-nichloroeihene (Total) CS^Q-59-Ol
i:t>lorofor« (67-66-31
( , 1 . l-Irichloroethane C7I-5S-61
Ir ichloroethene [79-01-6]
Tetrachloroethene [127-1B-41
NJ
MCL
2
-
• ' .'2
'• ' ' - - "
.
.
26
1
-
mi- 12
Bonru
IS
9
•45O
410
6100
5
HH-12-2
RIJI1H6
16
1°
46O
7
320O
5
MH-12
HI10H7
•q
4411
isn
!54QO
36
MH-13
BQIISb
5
FIEI.O HLHHK
BI1I1B3
7 B
440 BE
TIHP 111 HHt;
annu2
7 B
9 BJ
flHTR OttflLIFIERS
ii •- Compound uas tie tec ted In the blank
Estimated quant ittj because amount detected uas be low required
1 in i ts or qua I i tij control cr i ter i a uere not met.
£ - Value estiMated or not reported due to presence of interference.
No SOUR MCL available.
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T H B I. E 6
0 R 0 II N 0 H H I F. P S H H l> I. I H U
PI I P H fl S t II - INI) B "(J H II I C S
(Hll readings in uq/l )
SHMPLE LDCHTION
UjHPIHJUa SHMPLE MO.
Rluminua [7429-90-51
Barium 17440-39-3]
Cadmium (7440-43-91
1 l.:i.,« [7440-70-21
..:,,„!> C7440-47-31
. Li^per [744O-50-BJ
: Iron (7439-B9-61
:Lead ( /439-92-I 1
: Magnesium [7439-95-41
:Hanqanese t 7439-96-51
:Mercurij [7439-97-61
: Nickel [7440-O2-21
:Potassiun (7440-09-71
: Silver 17440-22-41
-.Sodium 17440-23-51
tUanadiua (7440-62-21
:Zinc (7440-66-61
NJ
ICL
10OQ
10"
-
50
-
-
50
-
-
2
13.4
-
50
'• -'
-
-
HH-KU)
MBK907
BBS
21)6
40
34200
27
43
1250
P
1 1 hill 1
97
(5H21
8B30
IB7
MW-KF)
HHK90B
(1261
(I9B1
36500
15
12100
(9.61
7650
(11.61
32
llhtP III
MH-2(II>
MHK909
244
346
391100
15. 11
31
226
1 .?H(in
3.4
isinn
LI.
I1U-2(F)
MHK9H1
310
3'JOOO
15
(231
1 I6OO
I740Q
26
MH-l.dl)
llflKgifi
4bl
283
33/011
19-
39
6/7
P
126011
hfi
(161
8430
33
MH-SCK)
HilK916
23B
3OSI10
19
49
137
1 1 700
B260
33 :
dura OUHLIFIERS
H - Data value rejected because quality control criteria uere not met.
( 1 - If the result is a value greater than or equal to tlie instrument
detection limit but less than the contract required detection limit,
the value is reported in brackets (i.e., (11)11).
-------
THHLE 6 < C O N T 0 . )
n R n n M n w n T E R *> n H r> i. ING
R I I (' H II S E II - I N a R G H N I C S
(1)11 reailiiujs in ni)/l>
:
: SHHPLE LOCHTION
: COMPOUND SHMPLE NO.
:Hlu«inua [7429-9O-51
:B*riua C 7440-39-3)
-.Cadmium [744(1-43-91
;C*lciu« C744Q-7O-2)
: Chromium [7440-47-31
: Cobalt [7440-48-4]
: Copper [7440-5O-81
Ilroo (7439-B9-61
:Lead [7439-92-11
:Haqnesiu« [7439-95-41
:Hanqanese [7439-96-5]
: Mercury (7439-97-61
:Nickel (74411-02-21
:PoLassiuni (7440-09-71
:Silver (744O-22-4)
: Sodium (7440-23-51
:Uanadiu«i (7440-62-2)
:Zinc (7440-66-61
N.I
sown
MCL
-
IOOO
in
-
so
-
-
-
50
-
-
2
13.4
-
50
-
-
-
SHHIIIIH HELL
MM-3(U)
MBK9II
11300
213
19600
5030
(23)
161
33700
K
1 1300
496
758
(26901
13900
(371
107
MH-3(F>
MOK9I2
(75)
14400
17
5980
70
138
(7341
12000
46
HH-4(II)
MOK9I3
3490
(1271
6230O
26
40
5210
R
19900
1220
(21 1
(41601
21200
(15)
44
MH-4(F>
MHK9 1 4
(791
61 ICO
10
(24)
IS30O
944
(33401
2060O
43
MU-6CIIJ
MIIK9I7
il/SO
1 1441
323OO
155
(221
112
24SITO
n
S340
8150
IB9
(2881)1
isuno
cr.i
/')
HH-6
HI1K9I8
468
(67)
327OO
24
( IO)
53
687
7330
IJ660
136
(10701
(9.1)
Mono
41
MN-7(II>
MUK9I9
1970
23HO
20
70500
27
(II I
61
1 38OOO
1.'
Ill/lilt
B'lHIl
S6
5030
I7RIIO
(421
to
MH-7
MHK9?0
(1301
(4.6)
5531)0
25
30
16600
3740
[458n]
1 5 1 1111
22
UH-4UPUD
MBK93 1
4720
(181 ]
36900
107
113
6810
61
9430
100
(36)
(21110)
1 Hill HI
TIKI
•12 :
UH--!NI':
MBK922 :
(103) :
(70) :
"
3280O :
30 :
:
31 :
:
:
7550 :
:
"
(14.6) :
(II1SO1 :
:
1 45110 :
:
32 :
: RLRNK
: FB-2
: HBK926
:
:
:
:
:
i
: (24)
:
:
:
:
;
:
:
:
:
:
.
TB-2
MBK925
( 19)
MHTR QURLIFIERS
R - Data value rejected because quality control criteria were not met.
C ] — I f the rest 111 i s a value greater than or equal to I he i nstrtiment
f Jetect i on limit, hut less I .h.-«ri the contract i t'quir e«l »lel ect inn limit,
t .he value is reporteil in li» .M.kt-ts (i.e., I 111 I 1 >.
-------
T R B I. E
GROUNOURTER SRHPLINH
R 1 1
-------
As previously stated, there are two distinct bodies of
groundwater at the site; a shallow water-bearing zone and a
bedrock aquifer. The shallow water-bearing zone consists of
recent fluvial deposits. Groundwater present in this zone is
discontinuous across the site and is generally contained in
depressions formed by the hummocky bedrock topography. The upper
water-bearing zone is separated from the bedrock topography by a
low permeability saprolite layer formed of weathered bedrock
material. The bedrock aquifer is comprised of the Triassic age
Brunswick shale. Groundwater flow in the bedrock is primarily
controlled by fracture systems. To date, no data has been
collected that identifies a strong connection between the shallow
water-bearing zone and the deeper bedrock aquifer at the site.
Surface Water
Surface water samples were collected from the Delaware River at
eight locations, including areas upstream, downstream, and
adjacent to the site. Adjacent sampling locations are shown on
Figure 3.
Surface water runoff from the site does not appear to affect the
water quality of the Delaware River. Surface water samples taken
near northern and southern site boundaries, including a ditch
which drains the site, contain approximately the same
concentrations as background samples taken upstream.
Sediment
Sediment samples were collected along the eastern bank of the
Delaware River (Figure 3). Analyses reveal that contaminants are
present only in the sediment immediately adjacent to the site.
Table 8 summarizes the results of the sampling.
There are no promulgated standards, or cleanup criteria, for
sediments. However, based on the risk assessment performed for
the site, the sediments do not pose a threat to human health.
Further, the feasibility-study determined that the adverse impact
on the local environment associated with a remedial measure
addressing these sediments would be significant enough to
outweigh the benefits of such an action. Therefore, sediment
cleanup is not included in the scope of the response action.
» • - ';. '"?• ' * • S "5
Potential Routes of Human and Environmental Exposure
As shown on Figure 1, there is a private residence at the site.
The occupants currently include the owner of the portion of the
site east of the bike path, and tenants. Under current land-use
conditions at the site and neighboring areas, the principal
exposure pathways through which humans might potentially be
exposed to site contaminants are through groundwater, and direct
contact with contaminated soil.
16
-------
Iftine
••Tf OOtr«4.L
ttmract VATCM
SAUPLIIM
•OUUCCi VIP ASSOCIATE!
CUAVEV, IB8C
DEREWAL CHEMICAL CO. SITE
FIGURE 3
Rl I SEDIMENT AND
SURFACE WATER
SAMPLING LOCATIONS
-------
A potential route of environmental exposure is a pathway by which
an individual, population, community or ecosystem might encounter
the chemicals of potential concern. Exposure pathways may be
direct or indirect in nature. Direct pathways would be dermal
contact, inhalation, or ingestion of contaminated media such as
soil, sediment, water, or air. Indirect pathways, for the
purposes of the assessment conducted for the site, are those in
which an animal is exposed through the food chain (i.e., consumes
other previously contaminated organisms) . Some of the metals arid
organic compounds may bioaccumulate to some extent and,
therefore, exposure via the food chain is possible.
SUMMARY OF SITE RISKS
CERCLA directs that the EPA must protect human health and the
environment from current and potential exposure to hazardous . ;
substances at the site. In order to assess the current and
potential risks from this site, a risk assessment was conducted
as part of the remedial investigation. This section summarizes
the Agency's findings concerning the risks from potential
exposure to groundwater, direct contact with contaminated soil, ;
and direct and indirect routes of environmental exposure.
Human Health Risks .,'•.'
Exposure Assessment
The water in the bedrock aquifer is a current source of drinking
water; it is classified as Class IIA based on the Agency's
Groundwater Classification Strategy. The on-site residents use
an on-site well for their domestic water needs. In developing
the hypothetical exposure scenarios for groundwater at the site,
it was assumed that each well in the lower aquifer could be
hydraulically connected to the contaminated shallow groundwater.
It was further assumed that future concentrations of chemicals of
concern in residential or municipal wells.would be similar to
concentrations currently detected in the shallow monitoring
wells. In the scenario consisting of direct contact with
contaminated soil, exposure was evaluated for soil east of the
bike path, and west "of and including the bike path.
-------
TRBUE 8
SUMMRP5V OR SEDIMENT SRMF>I_ IMG ORTR
VOLATILE ORGflNICS
COMPOUND t SAMPLE NO.
H*fchylOT» Chlorid*
Be* ton*
1 , 1-Oichlorovfcharw
Tranc-1.2-Clichlara»th«rw
2-BuLmnan*
I,ltl-Trichloroethan»
Tr i ch 1 oro*thcn»
Y^
Bcnzvtiv
T«rtf-ach 1 ono*th»o»
Tolucnv
SO-1
22
3.4 J
S3
SD-2
160 B
2.1 J
IS
3.4 J
110
39O
190 B
SO-3-1 MM
ISO B
2.4 J
11
SD-3-2 UN
23 B
2.1 J
10
50-4
A
4.4 J
-
32
SO-S
12 J
3.7 J
50 B
(continued)
-------
TFIBLE 8 Cc=
SLJMMRRV OF=^ SEOIMEMT SF«MF»l_ IMG DFITR
SEMI-VOLRTILE ORGflNICS
COMPOUND SRMPLE NO.
1 , 2-0 i ch 1 or-obenzene
2-«ethyl phenol _ ;
Naphthalene
N-W i trasod i pheno 1 an i ne
Phenanthrene
Hnthracene
Oi-N-Butyl Ph thai ate
F 1 uoranthene
Pyrene
Benzo(fl) fVtthracene
Bis(2-Ethijlhexyl> Phthalate
Chryserte
Oi-N-Octyl Phthalate
BenzoCB) Fluoranthene
Ben2Hi(l%) Flucwanthene
Benzo(R) Pyrene
IndenoCl,2,3-CD) Pyrene
EJenzo(GHI) Peryleoe
fVoch lor- 1254 :
5D-1
530 J
13OO J
B70 J
410 J
680 J
550 J
BOO J
620 J
sn-2
92O J
300 J
17DQ
12OO J
850 J
52O JB
770 J
630 J
660 J
75O J
•
SO-3-1 MM
92 J
110 J
58 J
53 J
340
96 J
65 J
BIO
410
35O
57 J
41O
33O
130 J
23O J
SD-3-2 »•*•
81 J
310 J
92 J
51 J
840
460 J
490 J
460 JB
440 J
74 J
44O J
31O J
41O J
22O J
170 J
50-4
50O J
K 1000 J
59O J
540 J
42O JB
6OO J
500 J
SD-5
41O J
930 J
970 J
63O J
500 JB
61O J
55O J
53O J
55Q J
46OO M
(continued)
-------
TRBL.E 8 Ce=
•
SUMMRRV OF SEOIMEMT SRMF»I_ I NG DHTR
TNGRGBNICS Cag/kg)
{COMPOUND SAMPLE NO.
1 _ ,,11!
!Rlu«intM
IBariu-i
I •' ,
: i...rijl 1 iu«
'.CadMiua
• _
',Chro»ium
•
t Topper*
. .'i »
i Lead
• —
! Manganese
• i, . . i j
! Nickel
* - - i
JZtnc
t .
'.Cyanide
SD-1
B97O
(851
11.21
t^ll
22
29
25/uiJ
49
352
(341
354
1.31
SD-2
9470
1911
ci.n
146
159
217OO*
74
3O1M
52
326
1.31
SD-3-1 MM
57OO
[611
tO.93J
22
27
162OQ*t
40
2O3»»
[291
271
O.B6
SD-3*-2 MM
5O9O
[601
•
17
24
1530OM
38
194M
t271
240
1.28
SO-4
747O
t971
Cl.ll
(41
19
3O
tr
167OOM
46
356M
1281
357
1.46
SD-5 t
12900 I
(1581
7.6
44
78
27700W
124
208*
(301
529
2.34
NOTHS
8: CiMpound was detected in the blank.
C 1: IF the result is a value greater than or equal to the instrument
detection limit but less than the contract required detection liait.
**: Duplicate analusis uas not uithin control.
NM; Duplicate samples fro* the sa«e location.
•1- Estimated amount due to interFerences during analysis.
-------
Toxicity Assessment
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed as the reciprocal of
milligrams per kilogram-day [(mg/kg-day) ~1], are multiplied by
the estimated intake of a potential carcinogen, in mg/kg-day, to
provide an upper-bound estimate of the excess lifetime cancer
risk associated with exposure at that intake level. The term
"upper bound" reflects a conservative estimate of the risks
calculated from the CPF. Use of ;this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiolbgical studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied (i.e., to account for the use of animal data to predict
effects on humans).
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects caused by exposure to
chemicals exhibiting noncarcinogeriic effects. RfDs, which are
expressed in units of mg/kg-day,, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested" from contaminated drinking
water) can be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied. These uncertainty factors help ensure
that the RfDs will not underestimate the potential for adverse
noncarcinogenic effects to occur.
CPFs and estimated intake levels for carcinogenic chemicals found
in the groundwater at the DeRewal site are provided in Table 9.
Table 9 also provides RfDs and estimated intake levels for
chemicals in the groundwater which exhibit noncarcinogenic
effects. . '. •••'.' ••'.'.'
CPFs and estimated intake levels for carcinogens in the soil at
the DeRewal site, east of the-bike path and west of and including
the bike path, arerfound, in Tables 10 and 11, respectively.
Tables 10 and 11 also provide RfDs and estimated intake levels
for chemicals in the soil which exhibit noncarcinogenic effects.
Risk Characterization
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., IxlO"6 or 1E-6) . An excess lifetime cancer risk of IxlO"6
indicates that, as a plausible upper bound, an individual has a
22
-------
one in one million chance of developing cancer as a result of
site-related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at a site.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ) (i.e., the ratio of the estimated intake derived
from the contaminant concentration in a given medium to the
contaminant's reference dose). By adding the HQs for all
contaminants within a medium or across all media to which a given
population may reasonably be exposed, the Hazard Index (HI) can
be generated. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single/medium or across media.
''' i '
Excess lifetime cancer risks associated with the carcinogens in
the groundwater are provided in Table 9. Table 9 also provides
the HQs for the noncarcinogens in the groundwater, as well as the
Hazard Index. In general, the upperbound risk estimated for the
groundwater is 3X10"5. . While this risk is within the acceptable
range, contaminants were found in concentrations exceeding the
SDWA MCLs, and therefore, cleanup is warranted.
Excess lifetime cancer risks associated with direct contact to
soils east of the bike path and west of and including the bike
path are provided in Tables 10 and 11, respectively. Tables 10
and 11 also provide the HQs associated with the noncarcinogens in
the soil, as well as, the Hazard Index. In summary, the
upperbound risk associated with the soil, under the conditions
and assumptions of the maximum exposure scenario, is 2X10"3.
Environmental Risks
Environmental Assessment
Potential environmental impacts of the chemicals of concern at
the site also were evaluated. Plant and animal species
potentially exposed to the chemicals of concern at the site were
identified. Absolute conclusions regarding the potential
environmental impacts of the site cannot be made because there
are many uncertainties surrounding the estimates of toxicity and
exposure.- However, given the available data and the associated
limitations, several general conclusions regarding the potential
for environmental impacts are presented below.
The maximum concentrations of cadmium, chromium, cobalt, selenium
and zinc in the site soil exceed levels known to be phytotoxic
based on acute toxicity studies of soybeans, bean leaves, rice,
wheat and barley, respectively. These species were used in the
evaluation of the phytotoxicity because data was available for
these species. No studies were performed to assess the specific
terrestrial plant life at the DeRewal Chemical Company site in
23
-------
TABLE 9
DAILY INTAKES AND RISKS ASSOCIATED WITH EXPOSURE TO GROUHOUATER.
DEREWAL SITE, FRENCHTOUN, NEU JERSEY
Carcinogens
Tetrachloroethene
TricMoroethene
Total
Noncarcinogens
CtiroBiuB (heaavelem)
T«X rach I oroethene
1,1,1-Trichloroethane
lazard Index
t
Water
Concentrations
(mg/liter)
1.3E-02
8.4E-2
Water
Concentrations
(mg/liter)
2.SE-02
1.3E-02
7.1E-03
Daily Intake
from
Ingest ion
(ing/kg/day)
3.76-04
2.4E-04
Daily Intake
from
Inflection
(•g/kg/day)
7.16-04
3.76-04
2.0E-04
Daily Intake
from Showering
(«g/kg/day)
1.6E-04
1.16-0*
Daily Intake
from Showering
(»g/kg/day>
NEC
1.6E-04
9.7E-05
Total Chronic
Daily Intake
(COD
(mg/kg/d*y)
5.3E-04
3.SE-04
Total Chronic
Daily Intake
(COD
(ng/kg/day)
7. 16-04
5.36-04
3.0E-04
Potency Factor
. <«9/k8/.diy)-.'1
5 J6-02 (82). .
1.16-02 (82) ';
' 1
t«f«rence •
Oo«e (RfO)
(•g/kg/day).
5.06-03,' .
2.06-02: .•;•'•'
8.66-02 '•
Risk
(Uopereo^d)
3E-05
3E-06
3E-05
• CDIclfO
Ratio
(COI/RfO)
1E-01
•
3E-02
3E-03
<1(1E-01)
EG
to be negligible.
-------
TABLE 10
Milt IMIAttS AW MM* ASSOCIAin Hill •llfd
RMH AC I 10 SOUS MSI Of INt lilt Mill
MRtlMl SHI, IIENCIIIOM. MW JliMI
A. CMCIKHtM
toll
Cenc*n«r*tl*m
!••/••)
Quantity of
Cli**lc*l lnf*tt*il
{•l/kfl/dny)
OlMntlty *• Cn*alc*l
AbiOfberf torvwlly
|«f/k«/d»y>
Chronic 0*lly Intak*
•r«r*t*d Ov*r
m for 111*1 )•*
• Ilk
CMt
•laiMlbl*
CM*
AMI MI
CM*
Nailau*
CM*
Av*r*t*
CM*
M«nlbl*
CM*
Av*r*t*
Cat*
Mwnlbl*
CM*
t«clor
Av*r*f*
CM*
CM*
•U(l-*ll*lli««yl>l*HMlM«
Ckl*r*l*«ti
MM (c*rcln^»nlc)
Ulr*ckl«rM|»Mn*
lrlrtil*r*«llMn*
Utal
1.9
•.Otf*
•••!*
•.•»
?4
l.f
f.f
I.M-W
I.4C-M
S.M-M
f.ll 09
9.M-M M
t.M-M
2.K-OI
».« W
I.M-M
l.« »f
4.9E-IO
I.IC-09
I.II-M
.2t-M
I.lt-M
.OC-M
I.K-Ol
M
).«••!•
).!€••/
1.81 W
{.K-IO
I.H-M
$.» 0»
t.M Oi
B.M 04
1.810)
•.00068
•.OBI
11.1
•.0)1
0.011
tl-lt
«t M
«t II
H-ll
ll-tf
41 09
» 01
*l or
nor
4C-06
01
I. MCMCIMMM
toll
lly •(
•Mntlly •• OwMcal Ox-onlc tolly lM*k«
cat
CM*
CM*
CM*
A**r*f*
CM*
•l*u*IM«
CM*
CM*
CM*
•Ilk •*f*r*nc*
•M*
CM*
H*uilbl*
CM*
CyMtld*
Iran*- I.I -«lcM*rwtlMNI
•l-n-birfyl
9.1
M
•.49
SI
•.ft
9.4
n
?4
m
•.•a
s.«
4IN
1M
•.a
».rr
IM
4.M-M
I.4C-M
F.4C-M
9.4C-M
I.V 91
t.n-»r
4.K-M
s.ti-w
».»-•»
i.n »4
9.81-M
9.91 ••)
Ht«
«•
MO
I.II-M
MO
4.IC-M
MS
MO
M«.
4.2l-t7
7.«-04
'MO ' -
4.HrM 9.M-M
J.M-«f
1.41-91
9.9C-»r
t.u-oi
I.M or
4.K-01
l.ll M
l.U 91
I.»;04
i.Of-04
5.9f-01
0*9
01
001
•if
029
.01
.1
0014
U-OI
01 01
4C-04
M
M-M
H»90
41 81
M:6I
It 01
1C -01
Of -01
M-M
no*
tt m
4100
-------
TABLE 10
Milt IMMtt M» •!«» MMCMin Will OlMCt
OKI AC I IO SOU* Mil Of IW OUt Ml*
KMtMl till, IRtlKNICMI, MU JflUT
toll
Concentrotton*
Ouontltr ol
Ouontll* •» Owaleol
ofbod Dorvollr
(•4/ko/doy)
Chronic ••lly
*v*r»«rd
lipmurt Period
(Upperboml)
0~.c.l
Mercury
fMnol
1 • 1 r oe* 1 •rwttom
Ulutn*
tine
CM*
•r
M
•.0074
o.oia
M
CM*
1200
s!«
2.f
IHO*
Cot*
».rt 01
i.M-oa
M
1.«f 0»
t.4f-M
4.61-01
Noilouo)
•louilblt
CM*
f.tl-01
1.2f 01
t.n m
t.H 01
i.rc-oi
t.ac-02
CM*
MO
MO
M
6.*f-IO
i.n-o«
MO
Moilou*
• lomlbl*
CM*
MO
MO
1.0* 01
O.Of-0*
1.41 01
M«
Hoiilouo
. -A«*ro«* riouilbl* Ultk 0*l*r*nc*
CM* C»i* Oo«t
».H 01
I.W 08
ft.M-0*
I.1C-08
4.6f -OT
.11-01
.21-01
.n-oi
.Of-01
.11-01
.K 01
.1
.0014
.04
.02
.1
.2
A**r*fl*
CM*
* 04
II 01
M
K-or
If 08
«-04
Cot*
11 02
21 02
W 04
2f -01
2f -04
«f 02
02)
«00
Mf
Clf *)H*cll*n IMl
•! Inorfonlc dMoilcaU tr«M Mill U
t* to iwtltflM*
-------
TABLE 11
DAIIV INIAKES AND RIMS ASSOCIMID UIIN OIRECI
COM I AC I 10 SOUS MfSI Of AND INCUBING IKE RIKE PAIN
OERtUAl SI If. fRENCNIQIM, NEU JERSEI
A. CARCINOGENS
toll
Concentrations
<-t/kg)
Chemical
• 1 1< 2- elhylheiyl )phthal ate
Chlorofona
DM » 001
Helhylene chloride
PAR* (carcinogenic)
letrachloroethen*
IrlcMoroethene
total
Average
Case
0.14
M
0.40
0.015 '
1.7
0.09}
0.04B
Haiilaua
Plauslbl*
Case
It
o.oia
0.15
i.)
32
1
0.54
Boll
Concentration*
(•g/kg)
Chaarical
Antlaony
Rarlua
Oerylllua
Cedelua
Chi or of om
Copper
Cyanld*
Averag*
CM*
11
tto
9.99
O.S4
0.62
• M
16
55
I.J
Hailaua
Cat*
74
1500
l.f
II
10
o.oia
100
100
11
Quantity ol
Chmlcal Ingested
(•g/kg/day)
Hex leu*
Average Plausible
Case Case
1. IE-OB 7.7E-06
NO I.1E-08
1. 91-08 I.Of-07
1.5E-09 9.1E-07
I.Tf-07 2.2E-05
9.1E-09 7.0E-07
4.7C-09 l.BC-07
R.
Quantity af
Chevlcal Ingested
(••/kg/day)
Naiilaua
Average Plausible
Cat* Case
1.11-06 5.21-05
2.01-05 I.OE-0)
B.7E-08 I.K-06
S.Si-OB 7.7E-06
a.OC-OB 7.0E-06
NQ t.K-08
I.6C-06 7.0E-05
5.41-06 1.K-04
1.5E-07 7.7C-06
Quantity ol Cheajlcal
Absorbed Deraelly
Average Plausible
Case Case
8.1E-09 .91 06
NO .6i 09
9. 91-09 .BE-OB
1.7E-10 .9E-07
4.2E-OB .7E-05
2. IE 09 .IE 07
1.2E-09 .91 0?
NONCARCINOGENS
Quantity ol Chemical
Absorbed Oenailly
(eq/kg/day)
Hailaua
Average Plauslbl*
Case Case
NEC NIC
NEC NEC
NEC NEC
fl.JE-09 5.9E-06
REO NEC
M 9.6E-09
NEB NEC
NEB NEC
NEO NEC
Chronic Dally Intake
Prorated Over
70 tear lifeline
Hanlaua
Average Plausible
Case Case
5.9E-09 I.9E 06
JK> 1.2C 09
7.0E-09 2.&C-08
2.6E 10 2.1E-07
3.0E-OB 5.6E-06
1.6E-09 I.6E-07
B.4E-IO 9.5E-OB
Chronic Dally Intake
Averaged Over
Enposure Period
NaiilauB
Average Plauslbl*
Cat* Case
1. 11-06 1.21-05
2.K-05 t.Oi-01
a.TE-oa t.ii-06
4.11-08 1.41-05
a.OE-Oa 7.0E-06
NO 2.21-08
1.61-06 7.0E-05
5.41-06 1.JE-04
1.51-07 7.71 06
Risk
(Uppci bound 1
Potency Factor
(e>g/kg/day>-t
0.00068
O.OBI
O.H
0.0075
11.5
0.051
0.011
Average
Case
*E 12
NQ
2t 09
2E 12
IE 07
BE 11
9E-I2
5E 07
H.llllMI
Plausible
C»sc
IE 09
Jl 10
9E 09
H 09
6E OS
9E 09
IE 09
6E 05
Risk
(Upperboundl
Risk Reference
Oo*e
0.0004
0.05
0.005
0.02
0.0029
0.01
0.005
0.04
0.029
Average
Case
K-01
4E-04
2E-05
2E-06
JE 05
NQ
IE -04
IE 04
5E-06
HailatM
Plausible
Case
IE-01
2E-02
IE IK
7E Ol>
2E-OI
« 06
IE 0?
K-OI
IE M
-------
TABLE 11
OAIIV (MIMES AND RISM ASSOCIAIED UIIM OIRECI
CONIACI 10 SOUS UCSI Of AND INUIDIMG INE lltE PAIN
DEREUAl SHE. IRENCMIOtM. NEU JERSEI
Soil
Concentration*
(•9/kR)
u—ic.1
Ol-n butyl pMhalate
lead
Planganese
Htrcury
Hethylene chloride
Mlckel
Itlrnlua
illver
UlracMoroetfcene
toluene
l.t.l-lrlcfcloroethene
•aiard IndeN
Average
Case
0.21
20
260
M
0.015
2)
0.41
1.2
0.091
0.16
0.0051
190
Nailaua
Plausible
Case
1.1
200
1500
0.5
1.1'
84
f I
12
1
4.9
0.026
5100
-
. . Quantity ol
Cheailcal Ingested
Nanlaua
Average Plausible
Case Case
2.11-08 9.IE-0/
I.9E-06 1.4E-04
2.5E-05
M
1.51-09
2.11-06
4.2C-08
1.2t-07
9.11-09
I.5E-08
.4E-01
.5E-07
.IE 07
.91-05
.OC-06
.4E-06
.OE-0/
.41-06
5.21-10 l.et-08
1.9E-05 1.5E-01
Quantity ol Cheailcal
Absorbed Oeroally
|aq/kg/day>
Average
Case
5.8E 09
MEG
MEG
MEG
i.n-io
MEG
MEG . • ..
./Mid. •• . .•
2.1C-09
1.9E-09
I.SC-IO
MEG
Maiilau*
Plausible
Case
6.9E-07
MEG
MEG
MEG
6.9C-Or*
' MEG •'• •'..-
NEC ' .
ME«. '' ..' • '.
5.K-Of
2.6E-06
1.41-08
•EG
Chronic Dally Intake
Averaged Over
Exposure Period
Average
Case
2.9E-M
1.9E-06
2.SE-05
NO
I.8E-09
2.1E-06
(.2E-08
\.Jl-Qf
LIE -06 .
1.9E-08
6.5E-IO
I.9J-C5
MaiilauB
. Plausible
Case
I.6E-06
i.4E-M
2.4E-0)
l.iE-Of
1.6E-06
J.9E-05
5.0t 06
8.4E-06
1.2E-06
4.0E-06
i. 21-07
5.5E-01
Risk Relerence
Dose
0.1
0.0014
0.2. ;.'...••
0.0014
0.06
0.01 .
0.001
o.obi
0.02
0.1
' 0.086
0.21
Risk
(Upper bound I
Average
Case
iE-or
1E-01
II M
MO
11-06
2E-04
IE -05
4E-05
6E-0/
M 06
8E-09
9E-05
.IISC-011
Nailaxa
Plausible
Case
2E-05
IE 01
IE -02' •
2E 04 ..
]E-05
6E-0]
2E-01
JE-OJ
6E-OS
21 1 05
4E:06
2E -02
<1(SE Oil
MM • Mot refMrlad;
M • Rot opanllllad
MEG • k>gll|lble; denail
MM below ttP detection Hail I
afaaorptlon •! Inorfanlc chemlcaU Iroa aolU It aisuaed to be negligible
-------
terms of the tpxicity of contaminants at various concentrations.
Only a qualitative assessment was performed, noting stressed
vegetation in areas on the site. The geometric mean
concentrations: of cobalt and zinc in the soil in the wooded areas
exceed levels toxic to rice and barley in acute toxicity studies
and are at concentrations that may be toxic to plant species
which occur in the area of the site. Since the area west of the
bike path is.vegetated and even heavily wooded, it is likely that
the presence of contaminants in that area does not pose
significant risks to these plants and trees.
The site is not within the coastal zone as defined by the State
of New Jersey. Additionally, there are no federally designated
wild and scenic, rivers and there are no significant agricultural
lands in the vicinity of the site. The project area is sensitive
for the discovery of cultural resources. In particular, the area
adjacent to .the Delaware River is extremely sensitive with
respect to prehistoric occupation.
EPA consulted with the U.S. Fish and Wildlife Service (FWS) with
regard to the presence of federally listed or proposed endangered
and threatened: species within the study area of the site. The
FWS responded that wintering bald eagles (Haliaeetus
leucocephalusV are known to utilize the Delaware River; however,
occurrence in the project vicinity is not well documented.
According to the FWS, aside from this species and occasional
transient species, no other federally listed or proposed species
are known to exist at this site. Similarly, EPA consulted with
the National Marine Fisheries Service (NMFS) with regard to the
presence of shortnose sturgeon (Acipenser brevirostrum) in the
vicinity of the site. EPA also requested advice from the NMFS on
whether remedial action at the site may result in impacts to this
species. The NMFS responded that currently available information
shows the upper range limits of shortnose sturgeon to be just
above Lambertville, New Jersey, approximately 24 miles downstream
from the DeRewal site, and indicated that it is unlikely that the
site affects these fish over such a distance.
Conclusion
Actual or threatened- releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF ALTERNATIVES
The Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) requires that each selected site remedy be
protective of human health and the environment, comply with
applicable or relevant and appropriate requirements (ARARs),
utilize permanent solutions and alternative treatment
29
-------
technologies or resource recovery technologies to the maximum
extent practicable, and be cost effective.
The FS evaluated, in detail, five alternatives for remediating
the soil and three alternatives for remediating the shallow
water-bearing zone. Alternative S-l has been further separated
into two components.
Soil Remediation Alternatives
8-1(a) No Action
Estimated Construction Cost: 0
Estimated Operation & Maintenance Cost: 0
Estimated Total Present Worth: 0
Estimated Time to Completion: Not Applicable
The Superfund program requires that the "no action" alternative
be evaluated at every site to establish a baseline for
comparison. Under this alternative, EPA would take no further
action to address the contamination at the site.
S-l(b) Limited Action
Estimated Construction Cost: $31,000
Estimated Operation & Maintenance; Cost: $476,000
Estimated Total Present Worth: $507,000
Estimated Time to Completion: 6 Months
Under this alternative, no remedial action would be taken. On-
site residents would be permanently relocated to a residence
mutually acceptable to both the property owner and EPA, deed
restrictions on future use of the property would be sought, a
fence enclosing the entire area formerly leased by Mr. DeRewal
would be installed, and periodic monitoring of site groundwater,
surface soil, surface water and sediments would be performed.
8-2 Excavation/ On-site Thermal Treatment and On-site
Solidification/Stabilization
Estimated Construction Cost: $4,224,000
Estimated Operation & Maintenance Cost: $180,000
Estimated Total Present Worth: $4,404,000
Estimated Time to Completion: 12 Months
Under this alternative, an estimated total of 8,000 cubic yards
of contaminated soil would be excavated. A mobile thermal
treatment unit would be brought to the site to destroy the 2,100
cubic yards of organic-contaminated soil. Following thermal
treatment, the heated soil/ash residue would be combined with the
remaining 5,900 cubic yards of inorganic-contaminated soil and
solidified on-site. The soil and binder material could be added
30
-------
and mixed in conventional cement mixing or rotary drum equipment.
The resulting material would be a thick elastic slurry, which
sets as dense and concrete-like material. The solidified mass
would be returned to the excavated area, and a vegetative cover
would be placed over it to promote surface water runoff and
reduce leaching due to infiltration.
8-3 Excavation/ Off-sita Thermal Treatment and on-site
Solidification/Stabilization
Estimated Construction Cost: $9,956,000
Estimated Operation & Maintenance Cost: $160,000
Estimated Total Present Worth: $10,116,000
Estimated Time to Completion: 7 Months
This alternative is similar to the one described above, except
that the 2,100 cubic yards of organic-contaminated soil would be
thermally treated and disposed of at an off-site facility. It is
anticipated that a total of 126 trucks with a 20 cubic yard
capacity would be required for hauling.
8-4 Excavation and On-aite Solidification/Stabilization
Estimated Construction Cost: $2,252,000
Estimated Operation & Maintenance Cost: $190,000
Estimated Total Present Worth: $2,442,000.
Estimated Time to Completion: 8 Months
This alternative is similar to the previous two alternatives,
except that the organic-contaminated soil would not be thermally
treated. Instead, all 8,000 cubic yards of contaminated soil
would be solidified on-site.
8-5 Off-site Disposal
Estimated Construction Cost: $6,115,000
Estimated Operation & Maintenance Cost: $110,000
Estimated Total Present Worth: $6,225,000
Estimated Time to Completion: 5 Months
This alternative provides for remediation of all of the 8,000
cubic yards -of contaminated soil at the site, through off-site
disposal at_a RCRA-permitted, Subtitle C landfill. It is
anticipated that a total of 480 trucks with a 20 cubic yard
capacity would be required to haul this material. Before
hauling, the 2,100 cubic yards of organic-contaminated soil would
be mixed in an on-site chamber to induce volatilization. The
vapor/dust emissions would be controlled.
31
-------
Shallow Groundvater Remediation Alternatives
GW-l No Action
Under this alternative, no remedial action would be taken. The
shallow groundwater above bedrock, as well as the deep bedrock
groundwater, would be monitored annually. Public health
assessments would be performed periodically. The costs for this
alternative are included in the Limited Action (S-l[bj)
alternative for soil remediation.
GW-2 Extraction, On-site Storage, On-site Treatment and
Discharge to the Delaware River
Estimated Construction Cost: $21,600
Estimated Operation & Maintenance Cost: $730,300
Estimated Time to Completion: 2 Years
This alternative provides for the complete treatment of the
shallow groundwater above bedrock. The shallow groundwater would
be extracted using a wellpoint dewatering system with vacuum v
pumps or other suitable pumps at the surface. The treatment
system would include a 10,000 gallon storage tank, an air
stripping column and a carbon adsorption unit. Treated
groundwater would be discharged to the Delaware River through an
underground discharge pipe. For the purpose of estimating the
cost of this alternative, and the alternative which follows, it
is assumed that removal of 10 pore volumes (approximately
1,000,000 gallons) would be .required for remediation. An
extraction rate of 1 gallon per minute is also estimated.
GW-3 Extraction/ On-site Storage and Off-site Disposal
Estimated Construction Cost: $8,500
Estimated Operation & Maintenance Cost: $684,400
Estimated Time to Completion: 2 Years
Under this alternative, the shallow groundwater would be
extracted by a wellpoint dewatering system as described above.
Extracted .water would be collected in an on-site storage tank
with a capacity of 5,000 gallons. Water would be pumped from the
storage tank:.into a tanker truck for hauling to an industrial
wastewater treatment facility (IWTF). It is anticipated that
only one tanker truck with a capacity of 5,000 gallons would be
rented.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Pursuant to CERCLA, as amended, EPA must evaluate each
alternative with respect to nine criteria. These criteria were
developed to address the requirements of Section 121 of SARA.
32
-------
The nine criteria are: overall protection; compliance with
ARARs; long-term effectiveness and permanence; reduction of
toxicity, mobility, or volume; short-term effectiveness;
implementability; cost; State acceptance and community
acceptance. The discussion which follows provides an analysis,
relative to these criteria, of all of the alternatives under
consideration for cleanup of soil and shallow groundwater at the
DeRewal Chemical Company site.
Overall Protection
Soil Remediation Alternatives
All of the alternatives, with the exception of S-l(a) and S-l(b),
would provide adequate protection of human health and the
environment by eliminating, reducing, or controlling risk through
treatment, engineering controls, or institutional controls.
Alternative S-5 would provide the greatest overall protection at
the site; however, the health risks would be transferred to the
designated disposal facility. Alternatives S-2 and S-3 would
remove the organic contaminants in the soil, which will eliminate
long-term risks due to dermal contact, ingestion and inhalation,
and stabilize the remaining wastes to minimize the potential
release into the environment. S-4 is less protective than the
selected alternative because the organic contaminants would not
be destroyed.
Because S-l(a) and S-l(b) are not protective of human health and
the environment, they are not considered further in this analysis
as options for the site.
Shallow Groundwater Remediation Alternatives
Both alternatives which actively remediate the shallow
groundwater are protective of human health and the environment.
GW-1 is not protective and, therefore, is not considered further
in this analysis as an option for the site.
Compliance with ARARs
Soil Remediation Alternatives
All active alternatives would meet applicable or relevant and
appropriate requirements of Federal and State environmental laws.
Off-site disposal is the least preferred alternative based on
SARA. Emissions from the on-site thermal treatment unit would be
monitored and controlled. It is anticipated that the solidified
mass resulting from Alternatives S-2, S-3 and S-4 would be
returned to the excavated area and that a vegetative cover would
be placed over it.
33
-------
During the Remedial Design, studies will be undertaken to
determine whether returning the solidified material to the
excavation will comply with then existing New Jersey Solid Waste
Regulations. If it is determined these regulations would
prohibit the return of the solidified material, the contaminated
soil will be disposed of off-site in accordance with applicable
regulations. In addition, each of the alternatives would require
the preparation of a cultural resources survey to ensure
compliance with the National Historic Preservation Act. No
waiver from ARARs is anticipated to implement any of the active
cleanup options.
Shallow Groundwater Remediation Alternatives
Alternatives GW-2 and GW-3 would meet applicable or relevant and
appropriate requirements of Federal and State environmental laws.
Although inorganic contaminants were present in the bedrock
aquifer above ARARs, it is anticipated that remediation of the
soil and shallow groundwater above bedrock will result in these
contaminants being reduced to ARARs or naturally occurring
background levels. The bedrock aquifer will be periodically
monitored prior to the start of, as well as during and after, the
remedial action. Monitoring of the bedrock aquifer after the
completion of the cleanup will indicate the need for any further
action. No waiver from ARARs is necessary to implement any of
the active cleanup options.
Long-term Effectiveness and Permanence
Soil Remediation Alternatives
Implementation of Alternative S-2 would result in minimal risks
remaining at the site. Most of the organic contaminants would be
destroyed by the thermal treatment process, and the risk of
future groundwater contamination would be minimized by the
solidification of the soil/ash residue and inorganically
contaminated soil. Implementation of S-3 would result in a
similar magnitude of residual risk; it differs from S-2 in that
the organic contaminants would be removed from the site before
being destroyed and the resulting soil/ash residue would be
disposed of off-site". Alternative S-4 would not reduce the
inherent hazards posed by-the organic contaminants to the extent
that S-2 would, since the organic contaminants would be •-
solidified rather than destroyed. Implementation of Alternative
S-5 would result in the contaminants being removed; therefore,
the risk of future migration of contaminants to the shallow
water-bearing zone would be eliminated.
34
-------
Shallow Groundwater Remediation Alternatives
Both Alternatives GW-2 and GW-3 would result in minimal
residual risk. GW-3 poses no technological concerns. Under GW-
2, however, required process efficiencies would need to be
maintained prior to discharge to the Delaware River.
Reduction of Toxicity. Mobility. or Volume
Soil Remediation Alternatives
Alternative S-2 utilizes thermal treatment and on-site
solidification/stabilization to clean up the contaminated soil at
the site. The toxicity, mobility and volume of soil contaminants
would be reduced. The process would be irreversible for
organics, and nearly irreversible for inorganics. Immobilized
inorganics at concentrations above NJDEP action levels would
remain in the soil.
S-3 would achieve similar reduction in toxicity, mobility and
volume. Under S-3, the soil contaminated with organics would be
removed from the site for off-site thermal treatment. S-^4 would
reduce only the mobility of the soil contaminants.: Alternative '
S-5 would reduce toxicity, mobility and volume of soil
contaminants at the site. However, contaminated soil would be
disposed of at the off-site landfill.
Shallow Groundwater Remediation Alternatives
Under Alternative GW-3, the extracted shallow groundwater would
be transported to, treated, and disposed of, at an industrial
wastewater treatment facility, resulting in reductions in
toxicity and volume of contaminants. GW-2 would reduce toxicity
and volume of contaminants through on-site treatment. Under GW-
2, treated water would be discharged to the Delaware River.
Short-term Effectiveness
Soil Remediation Alternatives
It is estimated that implementation of Alternative S-2 would take
12 months to complete. Similarly, S-3 would require 7 months,
S-4, 8 months and S-5, 5 months to complete,.
For all'of the active alternatives, the potential for erosion and
transport of contaminated soil into surface water or areas off-
site would be minimized by standard erosion control methods.
Dust suppression technologies would be used to minimize or
eliminate fugitive emissions. Appropriate personnel protection
equipment would be used.
35
-------
Alternative S-2 presents a slight increase in risk resulting from
emissions; these, however, can be minimized through careful
management of the trial run of the thermal treatment unit, and
through monitoring of the thermal treatment unit. The duration
of the trial run would be approximately a few hours, and would
not be allowed to continue if unsafe emissions persist. The
actual thermal treatment should take about four weeks. For all
of the active alternatives, there is a risk to workers associated
with excavation. This risk, as mentioned, would be minimized
through the use of personnel protection equipment. Under S-3,
there is also a risk associated with the transport of
contaminated soil to--the off-site thermal treatment unit.
Shallow Groundvater Remediation Alternatives
For both alternatives, the remedial response objectives would be
met on removal of contaminated water from shallow soil. Both
alternatives are estimated to take two years to complete.
Under Alternative GW-3, there is a low risk involved during the
transport of contaminated water. Under GW-2, personnel
protection equipment may be necessary for worker protection.
Also, proper air pollution controls would be necessary during air
stripping.
Soil Remediation Alternatives
The alternatives have few associated administrative difficulties
which could delay implementation. The remedies have been used
successfully to address similar contaminants at other Superfund
sites, and the skilled workers needed to implement the remedies
are readily available in the area. The on-site thermal treatment
unit will meet permit requirements. There is currently only one
company with a mobile thermal treatment unit of appropriate size
known to be available for the job. However, it is anticipated
that other companies may be available when the remedial action is
implemented. Also, for all alternatives, deed restrictions on
the future use of the property would be sought. For Alternative
S-l(b), deed restrictions are necessary to protect the public
from the,contaminated material. For Alternatives S-2, S-3 and
S-4, however,.deed restrictions will be used'as a precautionary
measure to ensure the integrity of the concrete-like material
remaining on-site. During remedial action, on-site residents may
be temporarily relocated to a location mutually acceptable to
them and EPA.
Shallow Groundvater Remediation Alternatives
There are no technical design concerns for Alternative GW-3.
Tanker trucks are readily available to rent. Permits are
36
-------
required for transportation of contaminated water, and for off-
site disposal. Off-site disposal facilities are available within
100 miles of the site.
For GW-2, stripping and carbon adsorption units are readily
available for rent, and can be easily operated and maintained.
Effluent concentrations would need to be monitored prior to
discharge to the Delaware River. The underground discharge pipe
would have to be constructed. The substantive requirements of a
permit for surface water discharge would need to be met.
Coat
Soil Remediation Alternatives
The present worth cost of Alternative S-2 is $4,404,000. The
lowest-cost active alternative is S-4 at $2,442,000. Alternative
S-3 has a present worth cost of $10,116,000, and Alternative S-5
has a present worth cost of $6,225,000. Should part or all of
the treated material resulting in Alternatives S-2, S-3, and S-4
need to be disposed of off-site, the estimated cost of these
remedies could be increased by up to $3.4 million.
Shallow Groundwater Remediation Alternatives
The estimated total cost of Alternative GW-3 is $693,000.
Alternative GW-2 has an estimated total cost of $752,000. The
Operation and Maintenance costs associated with the active
ground-water cleanup alternatives are consistent with Section
104.(a)(C)(6) of CERCLA.
State Acceptance
The State of New Jersey supports the remedial actions indicated
in the selected remedy.
Community Acceptance
Issues raised at the public meeting and during the public comment
period are addressed in the Responsiveness Summary section of
this ROD.
SELECTED REMEDY
The Environmental Protection Agency has been directed by Congress
in Section 121(b) of CERCLA, as amended, to select remedial
actions which utilize permanent solutions and alternative
treatment technologies or resource recovery options to the
maximum extent practicable. In addition, the Agency prefers
remedial actions that permanently and significantly reduce the
mobility, toxicity or volume of site wastes.
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After careful review and evaluation of the alternatives evaluated
in detail in the feasibility study, EPA presented Alternative
S-2, excavation, on-site thermal treatment of organic-
contaminated soil with on-site solidification/stabilization of
the treated soil/ash residue and all other contaminated soil, and
Alternative GW-3, extraction of shallow groundwater, on-site
storage and off-site disposal at an industrial wastewater
treatment facility, to the public as the preferred remedy for the
soil and shallow groundwater, respectively, at the DeRewal
Chemical Company site. The input received during the public
comment period, consisting primarily of questions and statements
submitted at the public meeting held on August 10, 1989, is
presented in the attached Responsiveness Summary. Public
comments received encompassed a range of issues but did not
necessitate any changes in the preferred alternatives for the
site. Accordingly, the preferred alternatives were selected by
EPA as the remedial solution for the site. Some additional
activities will be performed during the remedial design process
and remedial action. These activities are described and
justified as follows:
': The bedrock aquifer will be periodically monitored prior to v
the start of the remedial action, as well as during and after
the remedial action. Monitoring of the bedrock aquifer after
the completion of the clean-up will indicate the need for any
further action:.
Soil samples will be taken at varying depths from under the
building formerly occupied by DeRewal Chemical Company. The
walls of this building Will also be sampled. The soil
investigation results show that there is contamination
surrounding the garage, a small fish pond on the site, and the
building formerly occupied by DeRewal Chemical Company.
Since contamination is surrounding these structures, it is
. possible that contamination exists beneath them. Therefore,
the selected remedies may need to include the areas occupied
:by these structures. Investigation of the structures during
the design phase is also necessary to determine the necessity
of demolition.
On-site residents will have to be temporarily relocated. The
portions of the remedial action which will necessitate re-
location; will be determined during the remedial design phase
of the project. EPA will consult with other agencies on this
task, such as the Agency for Toxic Substances and Disease
Registry (ATSDR) or the Federal Emergency Management Agency
(FEMA), as appropriate.
It is anticipated that the solidified mass resulting from the
remedy would be returned to the excavated area and that a
vegetative cover would be placed over it. The solidified mass
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placed at the site is expected to be protective of human
health and the environment.
During the Remedial Design, studies will be undertaken to
determine whether returning the solidified material to the
excavation will comply with then existing New Jersey Solid
Waste Regulations. If it is determined that these regulations
would prohibit the return of the solidified material, the
contaminated soil will be disposed of off-site in accordance
with applicable regulations. Appropriate deed restrictions on
future use of the property will be sought, as a precautionary
measure, to ensure the integrity of the solidified mass. The
solidified mass would be disposed of off-site at an
appropriate landfill if the tests indicate the need for this.
A cultural resources survey will be prepared to ensure
compliance with the National Historic Preservation Act.
There will be additional sampling of the soil on-site to
verify the extent of excavation.
Air emissions generated during execution of the remedial
action will be monitored and controlled.
A treatment system will be placed at the on-site
residential well as a protective measure on an interim
'•• 'basis.'- • -' • "''' •-.-'; •''.'•. .:'.-.
Any buried drums discovered during remediation will be
disposed of properly.
Any significant surficial debris west of the bike path at
the site at the date of this ROD will be removed.
After remediation of the site, the bike path will be restored
to the present or equivalent condition.
STATUTORY DETERMINATIONS
Superfund remedy selection is based on the Superfund Amendments
and Reauthorization Act of 1986 and the regulations contained in
the National Contingency Plan. EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment.
Additionally, several other statutory requirements and
preferences have been established. These specify that, when
complete, the selected remedy must comply with ARARs, unless a
statutory waiver is justified. The remedy must also be cost-
effective and utilize permanent solutions and alternative
treatment or resource recovery technologies to the maximum extent
practicable. Finally, there is a preference for remedies which
employ treatment that permanently and significantly reduce the
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toxicity, mobility, or volume of hazardous wastes as their
principal element. The following sections discuss how the remedy
selected for the DeRewal Chemical Company site meets these
requirements and preferences.
Protection of Human Health and the Environment
The selected remedy protects human health and the environment
through the excavation, on-site thermal treatment of organic-
contaminated soil, and on-site solidification/stabilization of
the treated soil/ash residue and all other contaminated soil, and
through the extraction of shallow groundwater, on-site storage
and off-site disposal of the extracted groundwater at an
industrial wastewater treatment facility.
On-site thermal treatment will eliminate the threat of exposure
from direct contact to carcinogens. The current risks.associated
with these carcinogens, under the conditions and assumptions of
the plausible maximum exposure scenario, is 2xlO"3 (upperbound).
By thermally treating the organic-contaminated soil on-site, the
cancer risk will be reduced to the range of acceptable exposure
levels of between 10"4 and 10"7. On-site solidification/
stabilization of the soil/ash residue and inorganic-contaminated
soil effectively eliminates the potential for migration of any
remaining contaminants to the shallow water-bearing zone. :
Extraction of shallow groundwater, on-site storage and off-site
disposal at an industrial wastewater treatment facility will
significantly reduce the threat of exposure to groundwater
contamination. The current risk (upperbound) associated with
this pathway is 3xlO"5, which is in the range of acceptable
exposure levels. However, cleanup is warranted because
contaminants are present at concentrations exceeding SDWA MCLs.
In addition, it effectively eliminates the potential for
migration of contaminants from the shallow water-bearing zone to
the deeper bedrock aquifer at the site.
There are no short-term threats associated with the selected
remedy which cannot be readily controlled. In addition, no
adverse cross-media impacts are expected from the remedy.
Utilization of Permanent Solutions and Alternative Treatment or
Resource Recovery Technologies to the Maximum Extent Practicable
EPA arid the State of New Jersey have determined that the selected
remedy represents the maximum extent to which permanent solutions
and treatment technologies can be utilized in a cost-effective
manner for the DeRewal Chemical Company site. Of those
alternatives that are protective of human health and comply with
ARARs, EPA and the State have determined that the selected remedy
provides the best balance of tradeoffs in terms of long-term
40
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effectiveness and permanence, reduction in toxicity, mobility, or
volume achieved through treatment, short-term effectiveness,
implementability, cost, and State and community acceptance.
The selected remedy for soil cleanup does present a slight short-
term risk increase resulting from emissions during remedial
action; these, however, will be minimized through careful
management of the trial run of the thermal treatment unit and air
monitoring throughout remediation. Under the selected
groundwater remediation alternative, there is a low risk involved
during transport of contaminated water. There are, however, no
technical design concerns for the selected alternative.
Cost Effectiveness
Of the alternatives which most effectively address the threats
posed by the contamination at the site, the selected alternatives
for soil and shallow groundwater remediation afford the highest
level of overall effectiveness proportional to their cost. The
selected alternatives are determined to be cost-effective because
they provide the highest degree of protectiveness among the
alternatives evaluated, while representing cost value. A
detailed breakdown of the costs associated with the selected
remedies are shown in Table 12.
Compliance with Applicable or Relevant and Appropriate
Requirements .
The selected remedy will comply with all applicable or relevant
and appropriate action-, contaminant-, and location-specific
requirements (ARARs). The ARARs are presented below.
Action-Specific
The selected soil remediation alternative will comply with
action-specific ARARs. Soil containing contaminant
concentrations above the NJDEP Action Levels will be excavated.
Organic contaminants will be destroyed by thermal treatment. The
soil/ash residue and the metal-contaminated soil will be
solidified and stabilized on-site. Although the solidified mass
may contain inorganics at concentrations above the NJDEP Action
Levels, it will be tested for leachability prior to disposal.
No RCRA action-specific ARARs are triggered by the remedy, since
the waste is not a RCRA waste. Therefore, the RCRA Land Disposal
Restrictions do not apply.
Stack emissions would conform to the provisions of the Clean Air
Act. This will be accomplished through the installation of
appropriate air pollution control equipment. Occupational Safety
and Health Administration requirements would be complied with
during implementation.
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TABLE 12
COST SUMMARY FOR THE SELECTED REMEDIES
SOIL REMEDIAL ACTION
Excavation, Treatment and
On-site Disposal
CAPITAL COSTS: $ 4,224,000
OPERATION AND MAINTENANCE 180,000
SUBTOTAL $ 4.404.000*
GROUNDWATER REMEDIAL ACTION
Extraction, On-site Storage and
Off-site Disposal
SUBTOTAL $ 693.000
TOTAL REMEDIAL ACTION COST $ 5,097,000
Should part or all of the treated material resulting in this
alternatives need to be disposed of off-site, the estimated
cost of this remedy could be increased by up to $3.4 million.
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With respect to State action-specific ARARs, the thermal
treatment unit and the solidification units will be designed,
constructed and operated to meet with the Air Pollution Control
and the Noise Pollution Control Act requirements.
The selected remedy for shallow groundwater will also be in
compliance with all the Federal and State ARARs. The residual
water remaining in the shallow water-bearing zone will meet the
NJ SDWA MCLs. Action-specific ARARs with respect to the
transport of contaminated groundwater to the IWTF located off-
site will be followed.
Contaminant-Specific
NJDEP Action Levels (June 1, 1988) will be used as soil cleanup
criteria for metals, total volatile organics and total semi-
Volatile organics (includes PAHs). MCLs under the January 1989
amendments to the New Jersey Safe Drinking Water Act will be used
as cleanup criteria for the shallow groundwater.
Location-Specific
The site is not within the coastal zone as defined by the state
of New Jersey. Additionally, there are no federally designated
wild and scenic rivers and there are no significant agricultural
lands in the vicinity of the site. The project area is sensitive
for the discovery of cultural resources. In particular, the area
adjacent to the Delaware River is extremely sensitive with
respect to prehistoric occupation. Therefore, as discussed in
the previous section, a cultural resources survey will be
prepared. The 100-year floodplain will be considered for on-site
solidification/stabilization, though it is expected that the
floodplain restrictions would not apply.
Preference for Treatment as a Principal Element
By thermally treating organic-contaminated soil on-site, and
solidifying the soil/ash residue and inorganic-contaminated soil,
and by extracting the shallow groundwater for off-site disposal
at an industrial wastewater treatment facility, the selected
remedy addresses the threats posed by the site through ,the use of
treatment technologies. Therefore, the statutory preference for
remedies that employ treatment as a principal element is
satisfied.
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U » • Ji
STATE OF NEW JERSEY
DEPARTMENT OF ENVIRONMENTAL PROTECTS
CimiSTOI'llCK J. DACKSirrr, COMMtSSIONHK
CN 402
TRENTON. N.J. 08625
609-292 288.1
William J. Muszynski, P.E.
Acting Regional Administrator
U.S. Environmental Protection Agency
Region II
26 Federal Plaza
Hew York, N. Y. 10278
Dear Mr. Muazynski:
A draft Record of Decision (ROD) has been prepared by the United
States Environmental Protection Agency (USEPA). in accordance
with the requirements of the Comprehensive Environmental v
Response, Compensation and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA), for the DeRewal Chemical Company site in Kingwood
Township, Hunterdon County, New Jersey. The State of New Jersey
concurs with the remedy outlined below.
Deaeription of the Selected Remedy
The selected remedy addresses contaminated soil and contaminated
groundwater in the shallow aquifer underlying the site. In
addition, the remedy includes post-remedial action monitoring of
the deeper bedrock aquifer.
The major components of the selected remedy include:
- Excavation of soil contaminated with organic and inorganic
compounds above action levels;
- On-site thermal treatment of the organic-contaminated soil;
- - On-eite solidification/stabilization of the thermally
•.. treated soil and the remaining inorganic-contaminated soil;
- Extraction of shallow groundwater contaminated above
drinking water standards, on-site storage, and off-site
disposal at an approved industrial wastewater treatment
facility;
- Provision of a treatment system for the on-site residential
well;
- Appropriate environmental monitoring to ensure the
effectiveness of the remedy; and
.V*» Jtrtey It «* &4*al Cp.--
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09. 28. 89 li:OS >.** ' -DIPT. OF SNV. PROT. PQ3
• Establishment of deed restrictions, as necessary, to ensure
the effectiveness of the remedy.
After a review of the final decision document, the State may have
additional comments to be addressed by USEPA during remedial
design. These comments would not affect our concurrence with the
above remedy.
The State of New Jersey appreciates the opportunity to
participate in this decision making process and looks forward to
future cooperation with USEPA.
Very truly yours,
. Christopher J. Daggett, Commissioner
AT- Department of Environmental Protection
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DEREWAL CHEMICAL COMPANY SITE
KINGWOOD TOWNSHIP, NEW JERSEY
RESPONSIVENESS SUMMARY
I. OVERVIEW
The Proposed Plan for the DeRewal Chemical Company site was well-
received by the public. No objections to the Proposed Plan were
raised at a briefing for interested local officials and at the
public meeting. The selected remedy outlined in the Record of
Decision is the same as the preferred remedy described in the
Proposed Plan.
II. BACKGROUND ON COMMUNITY INVOLVEMENT
Community concern regarding the DeRewal site has generally been
limited. However, the site has received coverage from the local
newspapers on several occasions, including during the years when
DeRewal Chemical was in business, when the site was proposed for
inclusion on the National Priorities List (NPL), and when EPA
held a public meeting to announce that a remedial investigation/
feasibility study (RI/FS) would be conducted at the site. There
have also been several newspaper articles since the Proposed Plan
was released to the public.
As part of the RI/FS, a community relations plan (CRP) was
prepared. Issues of community concern which were identified in
the CRP included the timely release of site-related information,
and the need for investigation of a nearby property which
received contaminated soil from the DeRewal site. EPA's efforts
to keep the public informed are summarized in Attachment 1.
In 1983, the owner of the area of the site located east of the
bike path had approximately 30 tons of soil excavated from that
property. The soil was deposited at an open dump located near
the Frenchtown Roller Rink, approximately 1/4 mile southeast of
the DeRewal Chemical Company site. This area is known as the
Pinkerton Dump. The deposited soil from the DeRewal site has
since been buried by more recently dumped construction debris and
household waste. EPA completed a Preliminary Assessment (PA) of
the dump in December 1986 which showed that soil contamination is
present. -EPA-is currently assessing the need for further
evaluation of the dump.
The conditions at the DeRewal site have had no known impact on
local residential property values. Similarly, the site has had
no known impact on the business which borders the site on the
north. The contamination has affected the manner in which the
owner of the area of the site located east of the bike path can
use his property for commercial purposes. During the cleanup of
the site, access to the bike path which bisects the site will be
restricted.
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-2-
The impact that the cleanup will have on traffic on New Jersey
State Route 29 will be assessed during the design phase of the
proj ect.
III. SUMMARY OF PUBLIC COMMENTS AND EPA RESPONSES
COMMENT: What is the status of the investigation of the
Pinkerton Dump?
RESPONSE: Preliminary sampling was performed at the Pinkerton
Dump. EPA is currently assessing the need for further evaluation
of the dump.
COMMENT: Deed restrictions should be established no matter which
alternative is chosen.
RESPONSE: EPA agrees that some form of institutional controls
should be established.
\
COMMENT: A desire was expressed for the contaminants to be
"detoxified" on-site, as opposed to having contaminants being
handled elsewhere.
RESPONSE: EPA's proposed remedy includes on-site treatment of
contaminated soil.
COMMENT: Questions were asked about the relocation of the on-
site residents.
RESPONSE: The on-site residents will be temporarily relocated to
a mutually acceptable location during the appropriate periods of
the remedial action.
COMMENT: Is there contamination west of the bike path?
RESPONSE: Contamination is present west of the bike path at
levels requiring remediation. Those areas will be included in
the remedial action.
COMMENT: Why haven't signs been posted at the site alerting the
public that the site is contaminated?
RESPONSE: Sims would have been posted if an immediate health
hazard existed, or if people were required to avoid the site.
Since these conditions did not apply, signs were not posted.
COMMENT: There was concern about an active non-NPL facility in
Kingwood Township.
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RESPONSE: Representatives of the NJDEP present at the public
meeting indicated that Don Cramer (with the NJDEP Bureau of
Discharge Control) can be contacted with regard to the facility.
COMMENT: Mr. DeRewal should pay for the cleanup. There was also
concern about sites in Pennsylvania that Mr. DeRewal has been
associated with.
RESPONSE: EPA has been conducting enforcement activities for the
site, and will continue to do so. The two nearby Superfund sites
that Manfred DeRewal has been associated with in Pennsylvania are
being investigated by the EPA Regional Office in Philadelphia.
COMMENT: One citizen expressed a preference for Alternative S-4
over S-2.
RESPONSE: Alternative S-4 is not as protective of human health
and the environment as S-2 because the organic contaminants would
not be thermally treated. Also, Alternative S-2 satisfies the
statutory preference for permanent solutions to a greater degree
than S-4. Finally, Alternative S-2 provides the best balance
among all of the soil remediation alternatives with respect to
the nine criteria used to evaluate remedial alternatives.
COMMENT: The owner of the area east of the bike path commented
that because his property is part of a Superfund site, he cannot
fully utilize it for commercial activities. He offered to sell
the property to EPA.
RESPONSE: Issues pertaining to access, relocation, and use will
be resolved during remedial design activities. EPA will not
purchase the property.
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ATTACHMENT 1
COMMUNITY RELATIONS ACTIVITIES FOR THE
DEREWAL CHEMICAL COMPANY SITE
The Community Relations activities conducted to date by the
Environmental Protection Agency (EPA) for the DeRewal Chemical
Company site have included the following:
I. PUBLIC MEETING OH March 17, 1986
At this meeting, EPA's presentation consisted of an overview of
the Superfund Program, and a discussion of the Work Plan for the
remedial investigation/feasibility study (RI/FS). Prior to this
meeting, the two information repositories established for the
site were provided with copies of the Work Plan and Community
Relations Plan.
II. PUBLIC COMMENT PERIOD: JULY 28, 1989 - AUGUST 28, 1989
Comments on any of the remedial alternatives addressed in the
Proposed Plan and the RI/FS reports were considered during the
public comment period.
III. BRIEFING FOR INTERESTED LOCAL OFFICIALS ON AUGUST 7, 1989
The Kingwood Township Committee was briefed at this meeting on
the findings of the RI/FS reports and the Proposed Plan. EPA
also solicited input on all of the remedial alternatives
evaluated for the site. Copies of the RI/FS reports and the
Proposed Plan were provided to the information repositories prior
to the meeting.
IV. PUBLIC MEETING ON AUGUST 10, 1989
At this meeting, EPA again presented the findings of the RI/FS
reports and the Proposed Plan, as well as solicited public input.
V. TELEPHONE CALLS
*
Telephone calls were made on a regular basis to key official
contacts and interested citizens, including the director of the
Hunterdon County Health Department, the Kingwood Township Clerk,
and the owner of the area of the site located east of the bike
path.
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