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

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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;

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                               -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.       .

-------
'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.

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                                            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.

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                   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

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                                                                       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.

-------
                                              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

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                                                                           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

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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

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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.
                                37

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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


                                38

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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

                                39

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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.

                                41

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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.
                               43

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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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