United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R02-90/128
September 1990
EPA Superfund
Record of Decision:
Imperial Oil/Champion
Chemicals, NJ
-------
50278-101
REPORT DOCUMENTATION
PAGE
1. REPORT NQ
EPA/ROD/R02-90/128
X B»ript«nr» AcMMlon No.
4. TM» and SuMM
SUPERFUND RECORD OF DECISION
Imperial Oil/Champion Chemicals, NJ
First Remedial Action
S. RtportOM*
09/26/90
7. AUhoK.)
«. Pwfoimlng Orgmlaton Ropt No.
«. P«feaningOraiHa*>fiN*n»indAddmM
10. Pro|tctfTMk/Worii UnU No.
11. ContracKO or GrvtUQ) No.
(Q
(Q)
12. Sponsoring OfgsnUatioo Nun* and AddraM
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
IX Typo of Report * Pwtod Covored
800/000
14.
IS. Supplementary Notts
1«. Absrscl (UmH:
The 15-acre Imperial Oil/Champion Chemicals site is an active oil blending facility in
Marlboro Township, Monmouth County, New Jersey. Surrounding land use is primarily
residential, and several contaminated wetland areas are located to the north of the
site. Since 1912, a variety of operations have taken place onsite, including food
processing, chemical manufacturing, and flavor and essence production. In 1950, the
plant was modified for oil reclamation during which time used oil was washed and
distilled onsite. Residual sludge and oily filter clay were disposed of onsite and wash
water was discharged to an onsite settling lagoon. Wash water and used oil were also
reportedly spread on area roads to control dust. In 1969 Imperial Oil began onsite oil
blending operations that included mixing and repacking unused oil. Currently, chemicals
are delivered by truck and transferred to 56 onsite above-ground tanks. The resulting
oil/water separator sludge reportedly has been disposed of onsite near the oily filter
clay pile. Several private and State investigations from 1981 to 1990 revealed
contamination in onsite soil and ground water, as well as contamination by oily sludge
in two of the offsite wetland areas. Probable sources of the contamination include
leaching and erosion of material from an onsite waste pile, overflowing of oil/water
(See Attached Page) ^^^^^^^^^^^
17. Documnt Analysis a Descriptors
Record of Decision - Imperial Oil/Champion Chemicals, NJ
First Remedial Action
Contaminated Medium: soil
Key Contaminants: VOCs (benzene, toluene, xylenes), other organics
PCBs), metals (arsenic, chromium, lead)
b. Mentfflers/Opon-Endsd Term
(PAHS,
c. COSATI FMd/Group
18. Avril«b«Hy SUtement
19. Security Ctau (This Roport)
None
JO. Security CUu (This Ptgo)
None
21. No.otPigM
59
22. Prico
(So* ANSI-Z19.18)
S»f Instruction* on flt
(Formrty NT13-JS)
Dtpvtmtnt of Commtrc*
-------
EPA/ROD/R02-90/128
Imperial Oil/Champion Chemicals, NJ
First Remedial Action
Abstract (Continued)
separators, and improper treatment of separator effluent for arsenic. This Record of
Decision (ROD) addresses remediation of the contaminated offsite wetland areas.
Remediation of onsite sources and contaminated ground water will be addressed in a
subsequent ROD. The primary contaminants of concern affecting the soil are VOCs
including benzene, toluene, and xylenes; other organics including PAHs and PCBs; and
metals including arsenic, chromium, and lead.
The selected remedial action for this site includes excavating approximately 3,700 cubic
yards of soil from the offsite wetlands area contaminated with greater than 1 mg/Jcg PCBs;
temporarily storing the excavated material onsite in a dewatering and staging area before
disposing of the material offsite in a hazardous waste landfill; air monitoring and soil
sampling; restoring the wetlands after completion of excavation; and controlling site
access with fencing until remediation has been completed. A contingency for soil
treatment has been included if leachability studies determine treatment is necessary to
meet land disposal restrictions. The estimated present worth cost for this remedial
action is $6,889,985, which includes an annual O&M cost of $1,700 for 10 years.
PERFORMANCE STANDARDS OR GOALS: Cleanup levels for soil have been based on State Soil
Cleanup Objectives and include lead 250-1,000 mg/kg, PAHs 10 mg/kg and PCBs 5 mg/kg. The
actual excavation volume of 3,700 cubic yards of soil has been based on a -PCB level of 1
mg/kg, which is designed to account for all soil contaminated above Soil Cleanup
Objectives for any contaminant of concern.
-------
ROD FACT SHEET
SITE
Name:
Location:
EPA Jurisdiction:
HRS Score:
NPL Rank (date):
Imperial Oil Company Inc./Champion Chemicals
Marlboro Township, Monmouth County, New
Jersey
Region II
42.69
583 (9/1/83)
ROD
EPA Signature:
Remedy:
Capital Cost:
0 & M Cost:
Present Worth:
September 26, 1990
Excavation and appropriate off-site disposal
of contamination soil from within a wetlands
and restoration of the wetlands
$ 5,670,200
$ 1,700
$ 6,889,000
Lead
Agency:
Primary Contact:
EPA Contact:
NJDEP
Michael Lukas, (609) 633-0769
Trevor Anderson, (212) 264-5391
Waste
Type:
Medium:
Origin:
Est. Quantity:
Total petroleum hydrocarbons, inorganics, and
PCBs
Soil
Potentially a former dump site for waste oil
3,700 cubic yards
-------
DECLARATION STATEMENT
RECORD OF DECISION
IMPERIAL OIL/CHAMPION CHEMICALS
SITE NAME AND LOCATION
Imperial Oil Company Inc./Champion Chemicals
Marlboro Township, Monmouth County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Imperial Oil Company Inc./Champion Chemicals site in Marlboro
Township, which was chosen in accordance with the requirements of
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 practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan.
This decision is based on the administrative record for this
site.
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 an imminent and
substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE SELECTED REMEDY
The remedial action described in this document is the first
planned operable unit for the site. It will address the
contaminated soil in the wetlands adjacent to the site which
poses a sufficiently imminent hazard to require expedited
remediation. The principal threats posed by the conditions on
the site itself are not addressed by this operable unit, but will
be the subject of a future Record of Decision.
-------
-2-
Subsequent operable units for long-term remediation of the site
will be determined as appropriate. A comprehensive remedial
investigation to determine the nature and extent of contamination
is underway. Areas of concern include soils, surface water,
groundwater, sediments, air quality, and other remaining
contaminant sources.
The major components of the selected remedy for this first
operable unit include:
- Installation of fencing to control access to the
contaminated soil areas;
- Excavation and appropriate off-site disposal of
contaminated soil from within the wetlands; and
Restoration of the affected wetlands.
Prior to landfilling, the contaminated soil will be analyzed to
determine its leachability characteristics. If required by the
RCRA Land Disposal Restrictions, the soil will be properly
treated prior to disposal.
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, given
the limited scope of the action. It provides a permanent
solution for the contaminated soil areas.
Sidamon-Eristof^ / n)ate
Regional Administrator
-------
DECISION SUMMARY FOR THE RECORD OF DECISION
IMPERIAL OIL COMPANY, INC./CHAMPION CHEMICALS SITE
MARLBORO TOWNSHIP, MONMODTH COUNTY
NEW JERSEY
Op«rabl« Unit I
-------
TABLE OF CONTENTS
Sections Pag*
Site Location and Description 1
Site History and Enforcement Activities 4
Highlights of Community Participation 9
Scope and Role of Remedial Action 10
Summary of Site Characteristics 10
Summary of Site Risks 16
Description of Alternatives 24
Summary of Comparative Analysis of Alternatives 27
Selected Remedy 32
Statutory Determinations 34
Documentation of Significant Changes 37
Appendices
Appendix A. NJDEP Letter of Concurrence
Appendix B. Administrative Record Index
Appendix C. Responsiveness Summary
-------
DECISION SUMMARY FOR THE RECORD OF DECISION
IMPERIAL OIL COMPANY, INC./CHAMPION CHEMICALS
SITE LOCATION AND DESCRIPTION
The Imperial Oil Company, Inc./Champion chemicals (IOC/CC) site
is a 15-acre facility located in the Morganville section of
Marlboro Township, Monmouth County, New Jersey (Figure 1).
Champion Chemical Company is the owner of the real property
located on Lot 30, Block 10, Orchard Place in Morganville. The
premises are leased to the Imperial Oil Company, Inc., which
operates an oil blending facility. The site is currently active
with an oil blending operation that occupies approximately 4.2
acres.
The site consists of seven production, storage and maintenance
buildings. There are also 56 above-ground storage tanks which in
1975 had a total storage capacity of 963,000 gallons. Sandy soil
extends over those areas not covered by buildings, asphalt or
pavement. The process area is enclosed within a six-foot chain-
link fence and is protected by security. The western property
line abuts the abandoned Central Railroad of New Jersey's
Freehold and Atlantic Highlands Branch Main Line
(Figure 2).
The site is situated in a predominantly residential area of
Monmouth County. The population size of Marlboro Township is
approximately 27,000. There are approximately 30 residential
properties sparsely located along the surrounding roads within a
one mile radius of the site. The nearest residence is within 100
feet of the employee parking lot. A small commercial center
(Morganville) is located approximately 1/2 mile southeast
of the site at the junction of Route 3 and Route 79. Two
automobile scrap yards are located just to the northeast of the
site. Lake Lefferts, a swimming and recreational area, is
located approximately one mile north of the site. Lake Lefferts
has been identified as a potential potable water source for the
area.
The site is located within the Matawan watershed of the Atlantic
Coastal Drainage Basin. The topography of the site ranges from
120 feet above mean sea level (MSL) in the southwest corner of
the site to 97 feet above MSL at the northern boundary. Surface
water runoff at the site is to the north. During periods of
heavy rainfall, water accumulates in a catchment area in the
northern section of the site. Surface water is contained by an
earthen berm which extends along the northeastern fence line of
the site. To the east of the berm is a fire pond which
discharges to Birch Swamp Brook. Birch Swamp Brook, an
intermittent stream at the site, flows through a bog northwest of
the site, and subsequently drains into Lake Lefferts which, in
turn, empties into Raritan Bay.
-------
MMCMfMT
W •MOCMnt. PM.MUJMA. M
•O. II-«M. t/M/M
FIGURE 1
MPER1AL «L/CHAyPWM CNB0CAL8 WTE
MOROANVLLE, NEW JERSEY
-------
LEGEND
EOCTEWT Of PAVED AJ«A
SCALE
SO
liOO
7ZOURX 2
SCHEMATIC LAYOUT OF
IMPERIAL OIL CO. FACILITY
IMPERIAL OIL/CHAMPION CHEMICALS SITEl
2oo FEET MORGANVILLE, NEW JERSEY
• ECJCREANCO -
-------
A significant natural resource in the area of the site is the
groundwater contained in the Englishtown Aquifer. The geologic
formation hosting the Englishtown Aquifer, the Englishtown
Formation, outcrops in the vicinity of the site. The Englishtown
Aquifer is classified as potable (GW-2) and is an important
source of water supply for Monmouth and northern Ocean Counties.
The groundwater in the shallow and deep zones of the aquifer
beneath the site flows to the north and northeast, respectively.
Wetlands are present north of the site. Based on a preliminary
survey, some of the land surrounding the Fire Pond, as well as
most of the area encompassing the off-site areas, appear to
qualify as wetlands. Soils in these areas are somewhat poorly to
very poorly drained. Vegetation observed in these areas is
consistent with those normally found in wetland areas. The two
types of wetlands identified are forested wetlands and a more
traditional freshwater marsh. These areas appear to be
hydraulically connected.
Off-site Areas 1 & 2 are located approximately 220 feet and 700
feet northwest of the facility, respectively. These areas
contain surface soils which are stained with an oily sludge
residue. They appear to have been former dump sites for waste
oil. The vegetation in these areas is visibly stressed and the
soils are highly stained, as are the soils in the adjacent banks
of Birch Brook. These two areas are the subject of this operable
unit.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Historical site Use
The Imperial Oil Company, Inc. facility and associated land has
been the site for a variety of business operations since the
original buildings were constructed in 1912.
The first company to occupy the site produced tomato ketchup and
tomato paste. The plant changed operation and possibly owners
around 1917. Also, around that time, the Stratford Chemical
Company took over the site and began producing arsenate and
arsenic acid. In the 1930s, the Stratford Chemical Company
changed its name to the Brocker Chemical Company and continued to
manufacture chemicals until bankruptcy forced them to sell out
around 1945 to S. B. Penick and Company. S. B. Penick and
Company produced flavors and essences until 1949.
The Champion Chemicals Company acquired the property in 1950.
The existing facilities were modified to support Champion
Chemicals' oil reclamation operations. During this period of
time, Eagle Asphalt Company was also utilizing the property. The
process of oil reclamation involved washing the used oil with
caustic material in vertical process tanks to remove the sludge
and impurities. The washed oil was distilled to remove the heavy
-------
oil and then passed through a clarification process. This
process involved mixing the oil with filter clay (diatomaceous
earth) in large holding tanks, where the filter clay was allowed
to settle to the bottom and the oil was skimmed off the top. The
filter clay was used to.remove the heavy metals (tetraethyl lead,
zinc, iron, etc.) present in the waste oil. The purified oil was
then passed through a filter press to remove any remaining earth.
The waste products of the reclamation process included wash
water, waste oils and sludges, and oily filter clay. Reportedly,
the waste filter clay was piled outside near the settling tank
for temporary storage. Wash water was discharged into a lagoon
located just north of the shop building for settling. The
purpose was to recover excess oil which would float to the
surface. Waste wash water and used oil was used to oil dirt
roads in the area, a practice which was performed to reduce
fugitive dust. In addition, it has been reported that waste wash
water and used oil was dumped into leaching ponds located off
North Texas Road. It has also been reported that oil-
contaminated soil was dumped on the site in the area east of the
front gate and the on-site house trailer.
Since 1969, Imperial Oil Company, Inc. has leased the facility
from Champion Chemicals. The Imperial Oil Company, Inc. runs an
oil blending operation at the site which involves the mixing and
repackaging of unused oil for delivery. Currently, raw product
(refined clean oils) is delivered by truck and transferred to
above-ground tanks on the site. The Imperial Oil Company, Inc.
has reportedly removed sludge material from the oil/water
separators and deposited it in the area between the old process
building and the filter clay pile. Laboratory wastes and
sanitary wastes were disposed in a septic system located north of
the office building.
Remedial Actions to Date
The New Jersey Department of Environmental Protection (NJDEP),
U.S. Environmental Protection Agency (EPA), Princeton Aqua
Science (PAS), Fred C. Hart and Associates, and the Monmouth
County Health Department have conducted investigations at the
loc/cc site to date.
In April 1981, a NJDEP site inspection found oil-contaminated
soils and numerous large puddles at the base of tank farms 1 and
2. The outfall area for the three oil/water separators was also
inspected. This area showed oily surface water and oil-stained
surface soils. The catchment area for the site surface water
runoff, north of the separators, was also stained with oil.
Results of analyses of soil and waste pile samples revealed
petroleum hydrocarbons, lead, barium, arsenic, and
polychlorinated biphenyls (PCBs). Sediment samples from Birch
Swamp Brook also showed significant concentrations of lead,
arsenic, PCBs, and petroleum hydrocarbons.
-------
In Nay 1981, the EPA conducted a limited sampling program at the
off-site areas and the waste filter clay pile.' Results of
analyses of the sediment samples from the stream bed of Birch
Swamp Brook confirmed the presence of PCBs, petroleum
hydrocarbons, lead, and arsenic. The analytical results of the
samples from the clay pile indicated that this material contained
significant concentrations of PCBs.
In June 1981, a letter from the Imperial Oil Company, Inc.
consultant (Harold Seldin) to the EPA indicated that, in 1976,
the Imperial Oil Company, Inc. excavated contaminated soil and
replaced it with clean sand in the area of the oil/water
separators. An earthen berm was constructed and one oil/water
separator was cleaned and repaired.
In June and August 1981, the NJDEP conducted two site inspections
and identified the following potential sources of contamination:
• Oil/water separators; Overflow from flooding has
contaminated surrounding soils; sludge was being removed
from the skimmers and dumped on site.
• Waste filter clay pile; Initial estimated volume was
approximately 50 to 75 cubic yards.
• Tank farm areas; Tanks appeared to be discharging oils
and additives to the surrounding grounds; fill hoses,
pipes, and boiler blowdown fluids drained onto the
grounds.
• Floor drains; Boiler room and machine shop, unknown
composition of liquids being drained, destination of
liquids unknown.
• Septic tank and leach field; Receives laboratory wastes
generated on site.
• Drum washing area; Oil spillages observed.
• Waste dump; Contaminated soils dumped east of house
trailer.
• Two off-site waste dumps; Visible oil sludge and residue
on the ground and stress vegetation.
• Banks of Birch Swamp Brook; Stained with oily residue.
In August 1981, the NJDEP conducted an inspection of the off-
site waste oil contamination areas. During the inspection, two
distinct areas of contamination were identified. The areas are
located north of the Imperial Oil Company, Inc. along the flanks
-------
of Birch Swamp Brook. At both areas, the surface soils were
visibly stained with oil material. The banks of the stream were
also observed by the NJDEP to be stained with oily residue.
Vegetation in these areas was noticeably stressed.
In December 1981, the Imperial Oil Company, Inc. entered into an
Administrative Consent Order (AGO) with the NJDEP in which the
Imperial Oil Company, Inc. agreed to cease discharging of
hazardous waste and other pollutants into the waters of the
State, except if the effluent met certain specified discharge
limits set forth by New Jersey Pollutant Discharge Elimination
System (NJPDES). In addition, the AGO required the Imperial Oil
Company, Inc. to repair the oil/water separators and dispose of
oil/water-separator sludge in a manner acceptable to NJDEP.
Further, the ACO required the company to conduct an environmental
assessment of their site to determine the nature and extent of
contamination and implement a remedial plan for cleaning up the
site.
In May 1982, Princeton Aqua Science (PAS), contracted by the
Imperial Oil Company, Inc., conducted an evaluation of the site.
During this investigation, seven test pits were excavated and
sampled. In addition, four monitor wells were installed. The
purpose of the investigation was to assess the nature and extent
of contamination in the soil and groundwater at the site. The
results of this investigation were presented in a report issued
by PAS in January 1983. The analyses performed on the selected
samples confirmed the presence of petroleum hydrocarbons, PCBs,
arsenic, and volatile organic compounds in the groundwater and
soil. A floating product layer was detected in monitoring wells
MW-3 and MW-5 during sampling.
In August 1982, the site was ranked using the MITRE Hazardous
Ranking System (HRS) and received a computed score of 42.69. The
IOC/CC site was proposed for inclusion on EPA's National Priority
List (NPL) of hazardous waste sites on December 1, 1982; the site
was finalized on the NPL on September 1, 1983.
In May 1983, a NJDEP inspection of the Imperial Oil Company, Inc.
site, including the off-site waste oil contamination areas,
confirmed the continued presence of oily stained soils in the
areas that had historically exhibited visible contamination.
In September 1983, a Remedial Action Master Plan was prepared by
Fred C. Hart Associates for EPA for the IOC/CC site. The report
summarized the data collected up to that point in time and
concluded that soil and groundwater on site, and sediment off
site, were contaminated with heavy metals and priority organic
pollutants, including PCBs.
From 1984 through 1985, three site inspections by the NJDEP
detected several occasions of overflowing of impounded surface
-------
water from the catchment area, erosion of material from the waste
filter clay pile by surface runoff, and flooding into the Fire
Pond and Birch Swamp Brook. There was a noticeable oil sheen on
the surface of Fire Pond. The inspections also revealed
laboratory waste contained in 55-gallon drums stored in a
warehouse, overflowing of the oil/water separators, and the
oil/water separator effluent not being passed through the arsenic
treatment system.
In July 1986, the Monmouth County Prosecutor's Office conducted
an investigation of the IOC/CC site. Samples were obtained and
analysis showed that heavy metals, PCBs, and petroleum
hydrocarbons were present in soil and groundwater.
In October 1986, a site reconnaissance by the NJDEP's consultant,
E.C. Jordan Company, was undertaken. During the reconnaissance,
on-site and off-site areas were inspected. Oil-stained surface
soils were evident throughout the site. The inspection also
revealed mats of oily sludge along the banks of Birch Swamp
Brook, in the immediate 'flood plain, and at the two off-site oil
contamination areas.
A remedial investigation (RI) was conducted at the IOC/CC site in
two phases. Phase I and Phase II were performed in 1987, and
1989 through 1990, respectively. At the completion of the first
phase, a draft Phase I Sampling Report (July 1987) was prepared
detailing the findings of the field investigations. Also
included in the Phase I Sampling Report were recommendations for
a second phase of investigation. The objective of the Phase II
investigation was to further delineate the distribution of
contaminants identified during Phase I and previous
investigations in preparation for a site risk assessment and a
feasibility study (FS). In June 1990, a draft RI report was
prepared.
In June 1987, the IOC/CC entered into a Plea Agreement with
Monmouth County. The companies agreed to remove the clay pile to
grade at a cost not to exceed $400,000. In addition, the
companies agreed to contribute $400,000 to Phase I of the
remedial investigation and feasibility study (RI/FS) and a sum
not to exceed $7,000 to defray State costs for laboratory fees.
The companies also agreed to abide by the 1981 ACO with the
NJDEP.
In September 1987, the EPA initiated a Superfund Innovative
Technology Evaluation (SITE) demonstration Program at the IOC/CC
site. The technology demonstrated was the solidification/
stabilization process developed by Solitech, Inc. of Houston,
Texas. A Technology Evaluation Report for the project was
released in February 1990.
8
-------
In September 1989, the EPA issued an Administrative Order (AO) to
the Imperial Oil Company, Inc. and Champion Chemicals Company for
the delineation, characterization, removal and/or treatment and
disposal of the waste filter clay pile.
In July 1990, a focused feasibility study (FFS) was prepared by
NJDEP to addressed the soil contamination at two off-site areas.
This study was based on surface and subsurface soil samples
collected during the Phase I and II field investigations of the
RI. Samples were either field screened using an on-site portable
gas chromatograph or submitted to a Contract Laboratory Program
(CLP) approved laboratory. The soils in these areas were found
to contain petroleum hydrocarbons, heavy metals and PCBs.
Meanwhile, the full RI/FS evaluation for the entire site is
ongoing.
In August 1990, the EPA noticed four potentially responsible
parties (PRPs) pursuant to Sections 106(a) and 107 (a) of CERCLA,,
that they may be ordered to perform response actions deemed
necessary by EPA to protect public health, welfare or the
environment.
current Conditions
The site is presently an active oil blending facility under the
control of the Imperial Oil Company, Inc. The on-site facility/
operations is fenced on all sides. The off-site areas are not
restricted from access and are currently being used for
recreational purposes by children.
The E.C. Jordan Company, contracted by the NJDEP, is currently
finalizing the RI report and commencing the FS which will
identify and evaluate remedial alternatives for the on-site
contamination and the Birch Swamp Brook contamination. This
study is being conducted concurrently with the off-site areas
operable unit action and will address the remaining site
contamination. Virtually all of the sampling activities for the
RI/FS have been completed.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The focused feasibility study and the Proposed Plan for
remediation of the off-site areas of the IOC/CC site were
released to the public for comment on July 26, 1990. These two
documents are available to the public in both the administrative
records at the NJDEP, and at the Marlboro Township Municipal
Building. The notice of availability for these two documents was
published in the Asbury Park Press on August 1, 1990. A public
comment period was held from July 26, 1990 to August 25, 1990.
In addition, a public meeting was held on August 14, 1990. At
this meeting, representatives from the NJDEP presented the
-------
findings of the FFS and the Proposed Plan and also answered
questions about problems concerning the site and the remedial
alternatives under consideration. A response to the comments
received during the public comment period is included in the
Responsiveness Summary, which is part of this Record of Decision
(ROD).
This decision document presents the selected remedial action for
the off-site areas of the IOC/CC site, in Marlboro, New Jersey,
chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act (SARA) and, to
the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). The decision for this site is
based on the administrative record.
SCOPE AND ROLE OF REMEDIAL ACTION
As with many Superfund sites, the problems at the Imperial Oil
Company, Inc./Champion Chemical site are complex. As a result,
NJDEP has organized the remedial work into phases or operable
units. This ROD addresses the first planned remedial action at
the site which will address those hazards in the off-site areas
that require immediate attention. Remedial alternatives for a
permanent cleanup of the entire site are being evaluated in the
ongoing RI/FS.
• Operable Unit 01: is the subject of this decision document.
It will address the principle threats posed
by the off-site areas that require expedited
remediation. These areas include
contaminated soil within the wetlands
adjacent to the IOC/CC site.
• Additional Units: will determine the nature and extent of
contamination over the entire site. An
RI/FS is currently being performed that will
address the remaining areas of contamination
at the site. The RI/FS will examine soils,
surface water, groundwater, sediments, air,
and other remaining contamination sources.
The remaining areas will be examined for
further operable unit segregation so as to
address the worst areas of the site first.
SUMMARY OF SITE CHARACTERISTICS
A variety of manufacturing operations have utilized the site over
the years. Most recently, the IOC/CC site has been used for the
reclamation and blending of oil products. As a result, there are
10
-------
a variety of potential sources of chemical contamination,
numerous potential mechanisms for chemical migration, and many
potential exposure pathways for both human and ecological
receptors.
Numerous potential contamination sources of hazardous wastes are
identified at the site. Below is a list of potential sources
segmented into areas to be addressed under this ROD and those to
be addressed in the ongoing RI/FS.
Operable Unit 1
• Approximately 3,700 cubic yards of contaminated soil
contained in Off-site Areas 1 & 2.
Polychlorinated biphenyls and total petroleum hydrocarbons (TPHs)
appear to be of the greatest concern in Off-site Areas 1 & 2.
Arsenic, antimony, beryllium and lead, were also detected in the
off-site areas at elevated concentrations. Other contaminants
identified in the study areas include volatile organic compounds:
benzene, ethylbenzene, toluene and xylene; semi-volatile organic
compounds: bis(2-ethlhexyl) phthalate, butyl benzyl phthalate,
chrysene, di-n-butyl phthalate, fluoranthene, phenananthrene, 2-
methylnaphthalene and pyrene; and inorganic compounds: chromium,
copper, silver and zinc. Maximum and mean concentration levels
of validated data are presented in Table 1.
The most widespread soil contaminant at Off-site Areas 1 & 2 is
PCBs. The horizontal distribution of PCBs within the off-site
areas are displayed on Figures 3 and 4. At Off-site Area 1, PCBs
was detected above 50 parts per million (ppm) in an area of
approximately 2,400 cubic feet. At Off-site Area 2, PCBs were
not detected above 50 ppm. PCB concentrations greater than 10
ppm were detected below two feet.
The soils of the off-site areas appear to be a source of
contamination and potentially impact the sediments and surface
water of Birch Swamp Brook. While some contaminants have
relatively low solubility and tend to sorb to soil and sediments,
some potential routes of migration occur during sediment erosion
and flooding events.
The RI soil sampling analyses demonstrate that the distribution
of PCBs and other organic and inorganic contaminants in the soils
is similar. Therefore, remediation of the PCB contaminated soil
will also effectively remediate all other contaminants of
concern.
Based on the distribution of PCBs, the volume of soil to be
remediated to the NJDEP cleanup level of 5 ppm, is approximately
1,900 cubic yards. However, the existing RI data has not ruled
out the possibility that concentrations of carcinogenic
11
-------
TABLE 1
CHEMICALS DETECTED IN SOILS (0-3 FEET)
OFF-SITE AREAS 1 AND 2
CHEMICAL COMPOUNDS
CONCENTRATION LEVEL
VOLATILES (PPB)
Benzene
Ethylbenzene
Toluene
Xylenes
MAXIMUM
16.0
170.0
740.0
660.0
MEAN
2.37
27.30
89.20
69.40
8EMI-VOLATILES (PPB)
Bis(2-ehtylhexyl) phthalate
Butyl benzyl phthalate
Chrysene
Di-n-butyl phthalate
Fluoranthene
Phenanthrene
2-Methylnaphthalene
Pyrene
140000.0
19000.0
41.0
5700.0
49.0
270.0
700.0
590.0
33158.00
3979.00
3.15
. 651.00
3.77
20.76
117.00
100.15
PCBS (PPB)
Aroclors
22040.0
1465.00
INORGANICS (PPM)
Antimony
Arsenic
Beryllium
Chromium
Copper
Lead
96.2
203.0
3.6
71.5
107.0
2330.0
14.2
31.9
0.897
18.4
22.5
178.0
NOTES: • Concentration levels presented in this table represent
Contract Laboratory Program (CLP) analyzed data, and
^ does not include results from field screening
activities.
• Parts per million is denoted by ppm.
Parts per billion is denoted by ppb.
-------
4-
4
FIODRB
OF PCS*
M tURFMCC 8«L SAMPLES
o»»-«rn! AREA 1
MPEMAL CML/CMAMPJOM CHEMCAL8 SITE
MONQANVBXE. NEW JERSEY
ECJORDANOQ-
-------
4-
KEY
!«*•
U Otfl
t«»-M
8CNL SAMPLES FROM OO • 141 FOOT
OFF-SITE AREA 2
MPERtAL OL/CHAMPION CNBMCAL8 SITE
MORQANVLLE. NEW JERSEY
ECJORCKNOQ-
-------
polycyclic aromatic hydrocarbons (cPAHs), arsenic (As) or lead
(Pb) above the NJDEP Soil Cleanup Objectives may remain
unremediated in the horizontal and/or vertical fringes of the
off-site areas where total PCB concentrations are below the 5 ppm
cleanup level.
In order to fill this data gap, surface sampling (0-12") of the
fringe areas (between the 1 ppm and 5 ppm PCB contour) and
subsurface sampling (12-24") underneath the central, heavily
contaminated portions of each off-site area for targeted analytes
(i.e., cPAHs, As or Pb) will be included as part of the remedial
design (RD) for this operable unit. To allow for the potential
existence of these contaminants, the volume of contaminated soil
to be addressed by this ROD (3,700 cubic yards) is based on the
soil contaminated with PCBs greater than 1 ppm. This volume will
be adjusted based on the findings of the remedial design phase
for this operable unit.
Additional Contamination
The on-going RI/FS is addressing the contamination at the site
itself. The potential sources of contamination include:
• Approximately 56 above-ground tanks and surrounding soils
located within the four on-site fuel tank farms.
• A waste filter clay pile with an estimated volume of
contaminated soil ranging from 1,000 to over 3,600 cubic
feet.
• A layer of oil floating on the surface of the groundwater
immediately beneath the waste filter clay pile and adjacent
catchment area.
• Three oil/water separators which are used to treat
accumulated storm water runoff and discharge under a permit
to the fire pond.
• Seven on-site buildings which contain environmental hazards
including contaminated sediments on the floor.
• A fill area which is the site of a former settling lagoon
for the oil reclamation process.
• Contaminated soils in the catchment area.
• A septic tank and leaching field which potentially received
laboratory wastes.
• Sediments contained in a storm water drainage system flow
into the oil/water separators.
15
-------
• Contaminated fill areas located west of the outparking area,
south of the fire pond, and adjacent to the drum wash
building.
• Sediments along Birch Swamp Brook.
In addition to the numerous contamination sources described
above, contaminants have migrated into the soil, water, sediment
and air. Sampling of contaminated environmental media was
conducted and is still under investigation.
SUMMARY OF SITE RISKS
Hunan Health Risks
The EPA conducted an Endangerment Assessment (EA) of the "no
action" alternative to evaluate the potential risks to human
health and the environment associated with the two off-site areas
of Imperial Oil Company, Inc./Champion Chemical site in its
current state. The EA focused on the surface soil contaminants
at Off-site Areas 1 & 2 which are likely to pose the most
significant risks to human health and the environment. Selected
contaminants of concern (COC) at Off-site Areas 1 & 2 include:
Volatile Organic Contaminants Inorganic
Contaminants
• Benzene
• Ethylbenzene
• Toluene
• Xylenes
Semi—Volatile Organic Contaminants
Antimony
Arsenic
Beryllium
Chromium
Copper
Lead
Bis(2-ethylhexyl) phthalate
Butyl benzyl phthalate
Chrysene
Di-n-butyl phthalate
Fluoranthene
Phenanthrene
2-Methylnaphthalene
Pyrene
Polychlorinated Biphenyls (PCBsl
• Aroclors
16
-------
EPA1s EA identified several potential exposure pathways by which
the public may be exposed to contaminant releases. The potential
exposure routes identified in the EA include:
• Inhalation of Soil
• Dermal Contact and Ingestion of Soil
At Off-site Areas 1 & 2, the current receptor population is
primarily limited to children known to use the off-site areas for
dirt-biking in contaminated soils. Future receptor population is
anticipated to be the children using the area under a residential
scenario. Potential exposure pathways include the direct dermal
contact, incidental ingestion and inhalation of airborne soil
particulates by children. For most exposure pathways, exposure
assumptions were made for a most probable and realistic worst
case exposure scenario.
Under current EPA guidelines, the likelihood of carcinogenic
(cancer causing) and noncarcinogenic effects due to exposure to
site chemicals are considered separately. It was assumed that
the toxic effects of the site related chemicals would be
additive. Thus, carcinogenic and noncarcinogenic risks
associated with exposures to individual COCs were summed to
indicate the potential risks associated with mixtures of
potential carcinogens and noncarcinogens, respectively.
Summary of Noncarcinogenic Risks
Noncarcinogenic risks were assessed using a hazard index (HI)
approach, based on a comparison of expected contaminant intakes
and safe levels of intake (reference doses). Reference doses
(RfDs) have been developed by the EPA for indicating the
potential for adverse health effects. RfDs, which are expressed
in units of milligrams per kilogram per day (mg/kg-day), are
estimates of daily exposure levels for humans which are thought
to be safe over a lifetime (including sensitive individuals).
Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking
water) are compared with the RfD to derive the hazard quotient
for the contaminant in the particular media. The hazard index is
obtained by adding the hazard quotients for all compounds across
all media. A hazard index greater than 1 indicates that
potential exists for noncarcinogenic health effects to occur as a
result of site-related exposures. The HI provides a useful
reference point for gauging the potential significance of
multiple contaminant exposures within a single medium or across
media.
The RfDs and His for the COCs at the Imperial Oil Company, Inc./
Champion Chemical site are presented in Tables 2 and 3,
respectively. The hazard index for non-carcinogenic effects from
soil exposure under a future residential scenario is greater than
1, suggesting that noncarcinogenic effects may occur.
17
-------
TABLE 2
REFERENCE DOSES (RfDs)
CHEMICALS OF CONCERN
IMPERIAL OIL/CHAMPION CHEMICAL COMPANY SITE
OFF-SITE AREAS 1*2
RfD (Oral)
Compound (mg/kg/day)
Antimony
Butyl benzyl Phthalate
Chromium III
Copper
Di-n-butyl phthalate
Ethylbenzene
2-Methylphenol (o-cresol)
Toluene
Xylenes (total)
4.00E-04
2.00E-01
l.OOE+00
3.70E-02
l.OOE-01
l.OOE-01
5.00E-02
3.00E-01
2.00E+00
-------
TABLE 3
SUMMARY OP KONCAKCER RISK
IMPERIAL OIL/CHAMPION CHEMICAL COMPANY BITE
OFF-SITE AREAS 1 & 2
INHALATION OF SOIL:
Most Probable
Case
Realistic Worst
Case
Children Dirt-Biking
0.01
0.06
DERMAL CONTACT AND INGESTION OF SOIL:
Most Probable
Case
Realistic Worst
Case
Children Dirt-Biking
0.03
0.20
Residential Children
0.40
3.00
COMBINED INHALATION/DERMAL/IN6E8TION OF SOIL:
Most Probable
Case
Realistic Worst
Case
Children Dirt-Biking
0.04
0.26
-------
Potential carcinogenic risks were evaluated using the cancer
potency factors developed by the EPA for the COCs. Cancer
potency factors (CPFs) have been developed by EPA's Carcinogenic
Risk Assessment Verification Endeavor for estimating excess
lifetime cancer risks associated with exposure to potentially
carcinogenic chemicals. CPFs, which are expressed in units of
(mg/kg-day)', are multiplied by the estimated intake of a
potential carcinogen, in mg/kg-day, to generate an upper-bound
estimate of the excess lifetime cancer risk associated with
exposure to the compound at that intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated
from the CPF. Use of this approach makes the underestimation of
the risk highly unlikely. The CPFs for the COCs and their
corresponding cancer risk levels are presented in Tables 4 and 5
respectively.
For known or suspected carcinogens, the EPA considers excess
upper bound individual lifetime cancer risks of between 1 X 10~*
to 1 X 10* to be acceptable. This level indicates that an
individual has no greater than a one in ten thousand to one in a
million chance of developing cancer as a result of site-related
exposure to a carcinogen over a 70-year period under specific
exposure conditions at the site. The EPA has determined that the
target risk for the site should be on the order of 1 X 10*, based
on the sensitivity of the neighboring population (school children
and residents in very close proximity to the site).
Uncertainties
The procedures and inputs used to assess risks in this
evaluation, as in all such assessments, are subjected to a wide
variety of uncertainties. In general, the main sources of
uncertainty include:
• Environmental Chemistry Sampling and Analysis
Environmental Parameter Measurement
Fate and Transport Modeling
Exposure Parameter Estimation
Toxicological Data
Uncertainty in environmental sampling arises in part from the
potentially uneven distribution of chemicals in the media
sampled. Consequently, there is significant uncertainty as to the
actual levels present. Furthermore, uncertainty occurs because a
large percentage of screened data was unusable in the calculation
of site risk. Environmental chemistry analysis error can stem
from several sources including the errors inherent in the
analytical methods and characteristics of the matrix being
sampled.
20
-------
TABLE 4
CANCER POTENCY FACTORS (CPFs)
CHEMICALS 07 CONCERN
IMPERIAL OIL/CHAMPION CHEMICAL COMPANY SITE
OFF-SITE AREAS 1 t 2
Compound
Arsenic
Bis(2-ethylhexyl) phthalate
Benzene
Beryllium
Carcinogenic PAHs
PCBs
Weight of
Evidence
A
B,
A
B,
B,
B,
CPF
(mg/kg/day)1
5.00E+01
1.40E-02
2.90E-02
4.30E+00
8.40E+00
1.15E+01
6.10E+00
7.70E+00
(I)
(0)
(Oil)
(0)
(I)
(0)
(I)
(0)
(I) - Inhalation
(0) - Oral
Group A - Human Carcinogen
Group Bj - Sufficient Evidence of Carcinogenicity in Animals
-------
TABLE 5
SUMMARY 07 CANCER RISKS
IMPERIAL OIL/CHAMPION CHEMICAL COMPANY SITE
OFF-SITE AREAS 1 & 2
INHALATION OF SOIL:
Most Probable
Case
Realistic Worst
Case
Children Dirt-Biking
3x10'
2x10
•s
DERMAL CONTACT AND INGESTION OF SOILS
Most Probable
Case
Realistic Worst
Case
Children Dirt-Biking
Residental Children
7x10*
2X105
7X105
8xlOJ
COMBINED INHALATION/DERMAL/INGESTION OF SOIL:
Most Probable
Case
Realistic Worst
Case
Children Dirt-Biking
4x10*
9x10*
-------
Uncertainty in the exposure assessment is related to the presence
of potentially sensitive populations (school children and
residents) in very close proximity to the site. Additional
uncertainties arise from estimates of how often an individual
that would actually come in contact with the chemicals of
concern, the period of time over which such exposure would occur,
and in the models used to estimate the concentrations of the
chemicals of concern at the point of exposure.
Uncertainties in toxicological data occur in extrapolating both
from animal to human and from high to low doses of exposure, as
well as from the difficulties in assessing the toxicity of a
mixture of chemicals. These uncertainties are addressed by
making conservative assumptions concerning risk and exposure
parameters throughout the assessment. In addition, there is
currently no lead RfD, hence the noncancer risk attributable to
lead exposure at IOC/CC was not assessed.
Site-specific information concerning public health risks,
including quantitative evaluation of the degree of risk
associated with various exposure pathways, is presented in
Section 1.3.2 of the FFS report, which is available at the
Marlboro Township Municipal Building.
Additional Health Risks
In addition to the risk assessment, concentrations of lead in the
soils of the off-site areas were compared to EPA's health-based
cleanup level of 500-1000 ppm. In general, exposure to lead in
soil is thought to be responsible for blood lead levels
increasing above background in children when the concentration of
lead in the soil exceeds 500-1000 ppm. The concentrations of
lead in the soils of the off-site areas at the IOC/CC site exceed
this level.
Environmental Risks
Environmental Assessment
A baseline ecological risk assessment of the off-site areas was
conducted. A detailed analysis of the assessment is contained in
section 1.3.3 of the FFS report.
Chemicals of Concern (COCs) for the ecological risk assessment
were identified for surface soil, sediment and surface water.
The critical habitats considered under this investigation
include: Fire Pond, Birch Swamp Brook, Lake Lefferts and the
surrounding wetland areas. Following the identification of COCs,
an exposure assessment was conducted to identify the actual or
23
-------
potential exposure routes to ecological receptors at the site,
and to estimate contamination concentrations at the point of
exposure. The potential exposure pathways identified are in
direct contact with (including ingestion of) surface water,
sediments, surface soils, and ingestion of biota which have
bioconcentrated chemicals in their tissues.
The potential for adverse impacts from site associated
chemicals was evaluated by comparing the concentrations of
chemicals detected to relevant standards and criteria.
The most relevant standards for evaluating risks to
aquatic organisms are Ambient Water Quality Criteria
(AWQC) and Sediment Quality Criteria (SQC).
The ecological risk assessment of the area indicates that PCBs,
arsenic, and lead in Birch Swamp Brook sediments pose risks to
aquatic organisms in the vicinity of the IOC/CC site. Although
PCBs in surface soils are posing limited risks to wildlife, they
are a source of further sediment contamination.
Excavation of contaminated soil will focus on reducing exposure
to contaminants on aquatic organisms and wildlife. In addition,
this remedy will limit off-site migration of contaminants to
areas downgradient from the site. The benefits of removing the
contaminated soil and restoring the affected wetlands out weighs
the risks associated with adverse impacts from construction on
the environment.
Conclusion
Actual or threatened release 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 alternatives analyzed for this action are presented below.
These alternatives are numbered to correspond with those in the
Focused Feasibility Study report and the Proposed Plan. These
alternatives were developed by screening a range of alternatives
for their applicability to site-specific conditions. They were
also evaluated for effectiveness, implementability, and cost.
The alternatives that were not eliminated from consideration
during screening were subjected to a more detailed evaluation.
24
-------
Based on the site conditions, nature of contaminants and
conclusions of the risk assessment, the primary remedial
objectives for Off-site Areas 1 & 2 are the following:
• Reduce exposure risks through incidental ingestion,
inhalation and dermal contact with contaminated soil.
• Eliminate the potential migration of contaminants into the
groundwater and surface water.
• Restoration of the affected wetlands.
• Complete remediation of Off-site Areas 1 & 2 in a short-
term timeframe.
Alternative l: No Action and Monitoring
Estimated Capital Cost: $ 0
Estimated Annual O&M Cost: $ 13,800
Estimated Present Worth: $ 280,800
Implementation Period: None
The NCP and CERCLA require the evaluation of a No Action
alternative as a basis for comparison with other remedial
alternatives. The No Action alternative consists of those
actions required for monitoring the future migration of
contaminants to groundwater, surface water and sediment. Because
this alternative would result in contaminants remaining on site,
CERCLA requires that a review of site conditions be cdnducted
every five years. If justified by the review, remedial actions
would be implemented at that time to remove or treat the wastes.
Alternative 2: Excavation with On-site storage of
Contaminated Soil
Estimated Capital Cost: $ 2,159,800
Estimated Annual O&M Cost: $ 3,500
Estimated Present Worth: $ 2,613,500
Implementation Period: 1 Year
This alternative involves the excavation of contaminated soil
followed by the restoration of the wetlands. An above-ground
storage facility would be constructed within the IOC/CC property
for storage of the contaminated soil. Excavated soils will be
loaded in rolloff containers and transported to the storage
building. Following the completion of excavation activities, the
building will be locked, and warning signs will be placed on the
exterior of the building. The storage facility will require
monthly inspections during the storage period to comply with the
Resource Conservation and Recovery Act (RCRA) regulations.
25
-------
The soil would be stored while an assessment is conducted during
the on-going RI/FS for remedial alternatives for contaminated
soils from other areas associated with the IOC/CC site. This
alternative is considered an interim remedy, but is an acceptable
means of minimizing adverse environmental impacts while awaiting
final disposition of the soil.
Prior to implementation, a fence will be installed around the
perimeter of the two off-site areas. The fence will restrict
access of children and other uninformed persons from entering
these areas until restoration of the areas are completed.
Following the completion of excavation activities, the wetlands
must be restored to its original condition. The clean fill
material will be graded to the elevation as it existed prior to
the excavation. The areas will be revegetated to stabilize the
fill material and restore the affected wetland areas. Fence
installation and restoration of wetlands are two components which
are common to Alternatives 2 through 5.
Alternative 3: Excavation with Off-site Landfill
Disposal of contaminated Soil
Estimated Capital Cost: $ 5,670,200
Estimated Annual O&M Cost: $ 1,700
Estimated Present Worth: $ 6,889,000
Implementation Period: 6 Months
This alternative involves the excavation of contaminated soil
followed by the restoration of the wetlands. Excavated soils
would be stockpiled temporarily in an intermediate staging area
prior to transport off site. The purpose of the staging area is
to permit uninterrupted progress of excavation activities while
transport trucks are loaded and manifested.
The contaminated soil would be hauled to an appropriate off-site
permitted hazardous waste landfill for proper disposal. If
additional analysis during remedial design indicates that Land
Ban Restrictions apply, the appropriate treatment will be
performed prior to landfilling. This alternative includes the
contingency for off-site soil treatment prior to landfilling to
meet these regulations.
Alternative 4: Excavation with On-site Thermal Treatment of
Contaminated Soil
Estimated Capital Cost: $ 9,549,700
Estimated Annual O&M Cost: $ 1,700
Estimated Present Worth: $11,475,800
Implementation Period: 9 Months
26
-------
This alternative involves the excavation of contaminated soil
followed by the restoration of the wetlands. A temporary thermal
treatment facility would be constructed on site to incinerate the
excavated soil. Mobilization and demobilization of the
incinerator would be a major component of this remedial
alternative. The incinerator and auxiliary equipment require
preparation of an area with dimensions of approximately 40,000
square feet.
Following a successful trial burn testing, analysis of residual
ash, stack gases and scrubber water, and the approval of
appropriate permit applications, processing of contaminated soils
will begin. Excavated soils will be delivered to the waste feed
area, where it will be conveyed to the incinerator. Residual ash
will be stored in ash bins and analyzed for contaminant levels.
A residue delisting petition documenting the quality of ash will
be approved prior to backfilling in the excavated area. If the
delisting petition is not approved, off-site disposal of the
residual ash would result.
Alternative 5: Excavation with Off-site Thermal Treatment of
Contaminated Soil
Estimated Capital Cost: $14,693,900
Estimated Annual O&M Cost: $ 1,700
Estimated Present Worth: $17,648,800
Implementation Period: 6 Months
This alternative involves the excavation of contaminated soils
followed by the restoration of the wetlands. Excavated soils
would be stockpiled temporarily in an intermediate staging area.
The staging area would also be used to drum the soils prior to
loading and transport. The soil would be placed in 55-gallon
drums to be transported to a RCRA approved off-site thermal
treatment facility for incineration.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance vith the NCP, a detailed analysis of each remedial
alternative was conducted with respect to each of the nine
criteria for selecting a site remedy. This section discusses and
compares the performance of the remedial alternatives under
consideration against these criteria. The nine criteria are
described below. All selected alternatives must at least attain
the Threshold Criteria. Alternatives that do not provide
protection of human health and the environment will be eliminated
from further consideration. The selected alternative should
provide the best trade-offs among the Primary Balancing Criteria.
The Modifying Criteria were evaluated following the public
comment period.
27
-------
THRESHOLD CRITERIA
• overall Protection of Human Health and the Environment
addresses whether or not a remedy provides adequate protection
and describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls.
• Compliance with ARARs addresses whether or not a remedy will
meet all of the applicable or relevant and appropriate
requirements of Federal and State environmental statutes,
and/or provide grounds for invoking a waiver.
PRIMARY BALANCING CRITERIA
Long-term Effectiveness and Permanence refers to the magnitude
of residual risk and the ability of a remedy to maintain
reliable protection of human health and the environment over
time once remedial objectives have been met.
Reduction of Toxicity, Mobility, or Volume Through Treatment
is the anticipated performance of the disposal or treatment
technologies that may be employed in a remedy.
Short-term Effectiveness refers to the speed with which the
remedy achieves protection, as well as the remedy's potential
to create adverse impacts on human health and the environment
that may result during the construction and implementation
period.
Implementability is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement the chosen
solution.
Cost refers to estimates used to compare costs among various
alternatives.
MODIFYING CRITERIA
State Acceptance indicates whether, based on its review of the
FFS and the Proposed Plan, the NJDEP concurs with, opposes, or
has no comment on the preferred alternative.
Community Acceptance will be assessed in the Record of
Decision following a review of the public comments received on
the FFS report and the Proposed Plan.
28
-------
ANALYSIS
The first seven evaluation criteria are considered in the order
they are listed above and the merits of each alternative relative
to that criterion are evaluated. To avoid redundancy, the
remaining two criteria, state acceptance and community
acceptance, are summarized for the preferred alternative.
Overall Protection of HMi>|an Health and the Environment
Alternatives 3, 4 and 5 appear to offer the greatest degree of
protection. Under Alternative 3, the contaminated soil is
excavated and disposed off site, thereby removing the on-site
risk. Alternatives 4 and 5 thermally destroy volatile and semi-
volatile contaminants, thereby removing the contaminants from the
soil medium. The inorganic contaminants remaining in the
residual ash would be properly treated and/or disposed. These
alternatives are expected to offer equivalent overall protection.
Alternative 2 offers on-site containment of the contaminated
soil. This alternative is an interim remedy which offers
protectiveness through potential future treatment of the
contaminated soil and addresses the immediate current
environmental concerns. The no action alternative is not
protective of human health and the environment and is not
consistent with the remedial objectives. Therefore, no action is
eliminated from further consideration in the comparative
analysis.
Compliance with Potential ARARs
There are no chemical related applicable or relevant and
appropriate requirements (ARARs) that need to be met before
implementation. NJDEP Soil Cleanup Objectives have been regarded
as To-Be-Considered (TBC) guidelines for the remediation of soils
contaminated with both inorganics and organics. The NJDEP Soil
Cleanup Objective for concentrations of PCBs in soils is 5 ppm.
Activities related to the handling of waste would be accomplished
in accordance with RCRA and Toxic Substance Control Act (TSCA)
hazardous waste management requirements. Alternatives 3, 4 and 5
meet location related ARARs involved with conducting activities
in wetland areas. Alternative 2 is expected to meet ARARs within
the limited scope of this alternative and is consistent with
Section 121 of SARA which allows the selection of an alternative
as an interim remedy. Maintenance and inspection of the storage
facility for Alternative 2 will comply with RCRA regulations.
The no action alternative, Alternative 1, does not attain either
chemical related TBCs or location and management related ARARs.
29
-------
Long-Term Effectiveness and Permanence
Alternatives 4 and 5 are considered to provide the greatest long-
term effectiveness and permanence since the contaminated soil
would be excavated and the organic contaminants would be
thermally destroyed. Under Alternative 4, the ash would be
backfilled on site depending upon meeting the land disposal
requirements. Should this alternative not meet these
requirements, the ash would then be disposed off site. The off-
site thermal treatment facility will handle the proper disposal
of residual ash generated under Alternative 5. Alternative 3
provides off-site disposal of contaminated soil in an approved
hazardous waste landfill, thereby eliminating the potential risks
associated with on-site handling and storage of treatment
residuals. However, landfilling requires long-term
monitoring/management. Alternative 2, on-site storage of
excavated soils, requires long-term monitoring until such time as
the final remedy for on-site contaminated soils is determined.
This alternative is considered an interim remedy and would not
have long-term effectiveness or permanence in and of itself.
Reduction of Toxicity. Mobility or Volume Through Treatment
Alternatives 4 and 5 provide the greatest reduction of toxicity,
mobility and volume of soil contamination. Thermal treatment of
contaminated soil offers a high degree of toxicity reduction.
Through containment and potential treatment, Alternative 3 would
reduce the mobility of the contaminants, however, no reduction in
toxicity or volume would occur. Alternative 2 offers no current
treatment of contaminated soil. The potential for future
reductions in mobility, toxicity or volume through treatment, in
conjunction with on-site soils, is beyond the limited scope of
this action.
Short—Term Effectiveness
Alternatives 3 and 5 provide the greatest overall short-term
effectiveness. They are also expected to provide the most rapid
and most effective achievement of remedial objectives because
waste disposal will occur at an off-site facility. Short-term
hazards involved in handling and transporting the waste include
risk to workers as well as a potential threat to nearby
populations. Adequate worker protection during implementation
can be ensured by wearing the proper level of protection,
following the proper handling protocols, and good safety
practices. Alternative 4 provides on-site thermal treatment of
soil contamination, thereby increasing the short-term risks
associated with a longer time to achieve the remedial objective
(though not unacceptable). Any short-term impacts during
implementation can be mitigated by following proper protocols and
30
-------
requirements. Alternative 2 offers a temporary.achievement of
remedial objectives within a relatively short time frame, but a
final remedy is not achieved until the final disposition of the
on-site contaminated soil.
Implementabilitv
Those alternatives which offer the greatest technical and
administrative feasibility, and which consider the availability
of service and material are considered to be most implementable.
Those alternatives involving off-site treatment of contaminated
soil offer the least amount of on-site construction, thereby
increasing their technical feasibility. The availability of off-
site services must also be considered. Typically, those
alternatives which involve the least innovative
treatment/disposal methods are more easily implemented.
Alternatives 3 and 5 are fairly easily implemented because
contaminated soil is handled off site, and off-site landfills and
thermal treatment facilities are currently available.
Alternative 2 is considered the next most implementable
alternative because it simply involves storage of the
contaminated soil in a building located on the site, although
adequate storage area may not exist. The implementation of
Alternative 4 is complicated by the use of an on-site thermal
treatment unit, which will need to be temporarily located in a
cleared area on private property which presents many logistical
problems. Excavation, grading, and revegetation are common
elements to Alternatives 2 through 5 and are acceptable and
constructive means for soil removal.
Cost
The cost for Alternative 2, excavation with on-site storage, has
an estimated total present worth of $2,609,700. The cost for
Alternative 3, excavation with off-site RCRA landfill disposal,
has an estimated total present worth of $6,889,000. This cost
includes the contingency for treatment of soils prior to
landfilling.
The cost for Alternative 4, excavation with on-site thermal
treatment, is $11,472,500. Off-site disposal of residual ash
would result in an increase in cost of $1,644,300. Alternative
5, excavation with off-site thermal treatment, has the highest
cost in comparison with the other alternatives, at a total
estimated present worth cost of $17,645,500.
31
-------
State Acceptance
As the lead agency for the investigation, the State of New
Jersey participated in the selection of the remedy for this site.
The State, therefore, concurs with the selected remedy of
Alternative 3.
Accetance
The objective of the community relations activities was to inform
the public about the work being performed at the site and to
receive input from the public on the remedy. The community
expressed support for the preferred alternative. Questions and
answers raised during the public meeting are presented in the
responsiveness summary.
SELECTED REMEDY
After a thorough review and evaluation of the alternatives
presented in the Focused Feasibility Study, to achieve the best
balance among all evaluation criteria, NJDEP presented excavation
with off-site landfill disposal of contaminated soil (Alternative
3) to the public as the preferred remedy for the IOC/CC site.
The input received during the public comment period, which
consisted primarily of questions and statements transmitted at
the public meeting held on August 14, 1990, is presented in the
attached Responsiveness Summary. Public comments received
encompassed a wide range of issues but did not necessitate any
changes in the remedial approach proposed to be taken at the
site. Accordingly, the preferred alternative was selected by EPA
as the remedial solution for the site. However, at the public
meeting, the Mayor requested that a fence be installed to protect
the public until the contaminated soil is remediated. EPA and
NJDEP agree with this request and has incorporated it into the
selected alternative.
The estimated total cost for all tasks associated with this
remedy is $6,889,000. This alternative includes the cost for
potential soil treatment. O&M costs provide for ground
maintenance of the two off-site areas for ten years after
implementation activities (Table 6) .
Some additional activities may be performed during the initial
phases of the remedial design process and prior to implementation
of the selected remedial alternatives. Prior to implementation,
a fence will be installed around the perimeter of the two off-
site areas to restrict access of children and other persons from
entering these areas until restoration of the areas are
completed.
32
-------
TABLE 6
ESTIMATED COST SUMMARY
EXCAVATION AND OFF-SITE DISPOSAL OF
CONTAMINATED SOILS
CAPITAL COST
DIRECT:
Runon/Runoff Controls $ 16,966
Air Monitoring $ 231,700
Removal of Contaminated Soils $3,335,050
Soil Sampling During Excavation $ 201,000
Equipment Decontamination $ 36,330
Engineering Management Mob/Demob $ 13,098
Dust Control $ 35,700
Site Restoration $ 361,721
Devatering Pad $ 198,400
Temporary Road Construction $ 12,000
TOTAL DIRECT CAPITAL COST SUBTOTAL $4,441,965
INDIRECT;
• Prime Contractor Markup $ 666,295
• Engineering and Design $ 488,616
• Legal and Administrative $ 133,259
TOTAL INDIRECT CAPITAL COST SUBTOTAL $1,288,170
TOTAL CAPITAL COSTS $5,730,135
ANNUAL OiM COSTS $ 1,700
SUBTOTAL COST $5,740,821
CONTINGENCY (20%) $1,148,164
TOTAL PRESENT VALUE COST $6,888,985
-------
During the remedial design, soil samples will be taken within the
fringes of the off-site areas and analyzed for carcinogenic
polycyclic aromatic hydrocarbons (cPAHs), arsenic and lead. The
results of this analysis will be used to determine the horizontal
and vertical extent of excavation. Also, confirmatory sampling
is needed to determine the extent of contamination with PCB
concentrations of 50 ppm and greater. TSCA regulates the
disposal of soils contaminated with PCB concentrations of 50 ppm
and greater. In addition, samples of the contaminated soil will
be analyzed prior to landfilling to determine the requirement for
pretreatment as defined by the RCRA Land Disposal Restrictions.
Also during the remedial design, a wetlands and floodplains
assessment and a wetlands restoration plan will be performed for
the vicinity of the two off-site areas. Not only is this
information necessary for the wetlands restoration effort for
this action, but may be needed for subsequent remedial actions
addressing the site and other off-site areas.
STATUTORY DETERMINATIONS
The EPA's selection of the alternative for the areas of concern
comply with the requirements of Section 121 of CERCLA as amended
by SARA. The action is protective of human health and the
environment, complies with Federal and State requirements that
are applicable or relevant and appropriate to this action, and is
cost-effective. This action utilizes permanent solutions and
alternative treatment technologies to the maximum extent
practicable, given the limited scope of the action. The
statutory preference for treatment that reduces toxicity,
mobility or volume will be addressed in this action, as
appropriate. The action does not constitute the final remedy for
the site. Subsequent actions are planned to fully address the
remaining principle threats posed by this site. A brief, site-
specific description of how the selected remedy complies with the
statutory requirements is presented below.
1. Protection of Human Health and the Environment
The selected alternative is protective of human health and the
environment, dealing effectively with the threats posed by the
contaminants which were identified. The principle threats
involve:
• Direct contact, incidental ingestion and inhalation of
airborne soil particulates by children using the areas for
dirt-biking.
• Direct contact and incidental ingestion of contaminated soil
by children using the areas for future residential
activities.
34
-------
The selected remedy addresses these contaminant pathways by
removing the contaminant sources before any additional migration
continues and will minimize any cross-media impacts. In
implementing the action, the risks associated with construction
and the length of time for implementation will be minimized. The
selected remedy will reduce risks posed through each pathway to
the population by excavating and disposing the contaminated soil
at an approved off-site facility.
2. Compliance with Applicable or Relevant and Appropriate
Requirements
The selected remedy will comply with the following ARARs and
State To-Be-Considered (TBC) requirements. TBCs are guidelines,
agreed upon by EPA and NJDEP, that are not legally binding.
Action-Specific
All remedial activities will comply with RCRA/CERCLA regulations.
• RCRA Subpart 268 - Land Disposal Restrictions
• RCRA Part 264 standards are applicable to the bulking and
storage of hazardous waste for off site disposal. If the
material, once displaced, remains on site for more than 90
days, RCRA standards are applicable to the storage of
hazardous waste on the facility property. Even if not
stored for more than 90 days, RCRA standards are relevant
and may be appropriate.
• Toxic Substances Control Act regulates the storage and
disposal of soil contaminated with PCB concentrations of 50
ppm and greater. TSCA regulations are applicable to
decontamination of heavy equipment used during construction
activities.
Chemical-Specific
• EPA plans to analyze the contaminated soil prior to
disposal. If required, the contaminated soil would be
treated in conjunction with off site disposal. The pre-
disposal treatment measures would reduce toxicity to levels
(treatment standards) specified by the RCRA Land Disposal
Restrictions (LDR). Treatment methods will have to reduce
the waste's leachability to TCLP concentrations established
by LDR.
35
-------
Location-Specifig
• The National Environmental Protection Act (NEPA) regulations
(40 CFR Part 6) are applicable for actions involving
construction of facilities in wetlands or alterations of
wetland property.
To—Be—Considered fTBCs)
• The shipment of hazardous waste off site to a treatment
facility should be consistent with the Off-Site Policy
Directive Number 9834.11 issued by the Office of Solid Waste
and Emergency Response (OSWER), which became effective
November 13, 1987. This directive is intended to ensure
that facilities authorized to accept CERCLA generated waste
are in compliance with RCRA operating standards.
• NJDEP Soil Cleanup Objective for concentrations of lead in
soil, ranging between 250-1000 ppm.
• U.S. Department of Health and Human Services (Centers for
Disease Control) health-based concentrations of lead in
soil, which range between 500-1000 ppm
• NJDEP Soil Cleanup Objective for concentrations of PCBs in
soil, which is 5 ppm.
• NJDEP Soil Cleanup Objective for concentrations of
carcinogenic PAHs in soil, which is 10 ppm.
• NJDEP Soil Cleanup Objective for concentrations of inorganic
compounds in soil.
• Potential emissions are expected in the form of
volatilization of hazardous constituents and fugitive dust
during excavation, transport and disposal of contaminated
soil. Dust control measures will be included in the design
specifications, and health and safety plans to ensure
compliance with RCRA, Clean Air Act and State regulations
during implementation.
3. Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
The selected remedy utilizes permanent solutions and alternative
treatment (or resource recovery) technologies to the maximum
extent practicable by providing the best balance among the nine
evaluation criteria for all the alternatives examined. While the
selected remedy does not offer as high a degree of long-term
effectiveness and permanence as the incineration alternatives, it
36
-------
will significantly reduce the inherent hazards posed by the
contaminated soils by removing them permanently Off site to an
appropriate RCRA approved treatment and disposal facility.
4. Preference for Treatment as a Principal Element
This selected remedy addresses contamination in the off-site
areas of IOC/CC, only. While the risks posed by this
contamination are unacceptable if left in place, the levels of
contamination found in these areas do not warrant the
expenditures which would be needed for thermal treatment.
However, if required, the contaminated soil will be treated to
meet the Land Disposal Regulations prior to landfilling in a RCRA
approved facility.
The principal threats of IOC/CC, found at the site itself, will
be addressed under a separate ROD.
5. Cost-Effectiveness
Of the alternatives which most effectively address the threats
posed by the off-site contamination, the selected remedy affords
the highest level of overall effectiveness proportional to its
cost. Based on the information generated during the FFS, the
estimated total project cost is $6,889,000.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the IOC/CC site was released to the public
in July, 1990. The Proposed Plan identified the preferred
alternative. NJDEP reviewed all written and verbal comments
submitted during the public comment period. Upon review of these
comments, it was determined that no significant changes to the
selected remedy, as it was originally identified in the Proposed
Plan, were necessary.
37
-------
APPENDIX A
MJDEP LETTER OP CONCURRENCE
-------
STATE OF NEW JERSEY
•——* —-•-^- -•--
Post.ir brand lax
n»mo 7S?i
.si.
fSTT
Mr. Constantine Sldamon-Erietoff
Regional Administrator
I'SEPA - Ragion II
Jacob X, Javica Federal Building
New York. Kiw York 10278
Dear Mr. Erlatoff:
Tht Department of Environmental Protection haa evaluated and concura with
che eelected remedy for the Imperial Oil Company Inc./Champion Chemicals
(IOC/CO Superfund Site outlined below:
"The remedial action described in this document la the firat planned
operable unit for the site. It will addreas contasiinated aoil within the
wetlands adjacent to Che site which pose a sufficiently Imminent hazard tc
require expedited remediation. The principal threats poaed by the
conditions on the sice itself are not addressee by this operable unit, but
will be the subject of a future Record of Decision.
Subseqenc operable units for long-tern reaediation of the site will be
determined as appropriate. A comprehensive remedial investigation to
determine the nature and extent of contamination is underway. Areae of
concern include soils, surface water, groundvacer, sediments, air quality,
and other remaining contaminant sources.
The major components of the selected remedy for this first operable unit
include:
Installation of fencing to control access to the contaminated aoil
areas;
Excavation and appropriate off-site diaposal of contaminated toil
from within the wetlands; and
Restoration of tha affected vctlands.
Prior to lane filling, ;or>taoinat%c soil will be analyzed to determine the
vaece'a leachasiVlty characteristics. If required by the RCRA Land Diaposal
Rcbtrlctiona, th* soil will be properly treated prior to disposal."
A/«<« ] 11 tn Equal Oppor:*nit,
-------
- O £ f r. Of iNv.
The Department reserves lea final coma«nc« on th« eonplct* R«eerd of
Decision pending on opportunity to r«vi«w tha ccnplacad docuatntd including
the documents raiponaiveneea auonary.
Sincerely,
A. Yatfcin
aioner
7
-------
APPENDIX B
ADMINISTRATIVE RECORD INDEX
-------
IMPERIAL OIL COMPANY INC./CHAMPION CHEMICALS SITE
ADMINISTRATIVE RECORD FILE *
INDEX OF DOCUMENTS
REMEDIAL INVESTIGATION
Sampling Plan
P. 0001 - Report: Phase II Sampling PlaTi. Imperial
0046 Oil/Champion Chemical RI/FS. Monraouth County.
New Jersey, prepared by E.G. Jordan Co., Revised
7/89.
Health and Safety Plan
P. 0047 - Report: Health and Safety Plan. Imperial Oil Co.
0185 Inc./Champion Chemicals Site. Monmouth County.
New Jersey, prepared by E.C. Jordan Co., 1/87.
Quality Assurance Project Management Plan
P. 0186 - Report: Quality Assurance Project Management
0274 Plan. Imperial Oil Co.. Inc./Champion Chemicals
Site. Monmouth County. New Jersey, prepared
by E.C. Jordan Co., 1/87.
Remedial Investigation Report
Note: The Remedial Investigation for the site has not
been finalized. The Focused Feasibility Study
Report for Offsite Areas 1 & 2 contains the
information from the Remedial Investigation that
pertain to the two off-site areas.
FEASIBILITY STUDY
Feasibility Study Report
P. 0275 - Report: Focused Feasibility Study. Offsite
0721 Areas 1&2. Imperial Oil/Champion Chemical Site.
Morcranville. New Jersey, prepared by New Jersey
Department of Environmental Protection, Division
of Hazardous Site Mitigation, 7/90.
* Administrative Record File available
Note: Company or organizational affiliation is mentioned only
when it appears in the record.
-------
Correspondence
P. 0722 Memorandum to Distribution from Mr. Anthony J.
Farro, New Jersey Department of Environmental
Protection, re: Draft Proposed Plan, 6/28/90.
P. 0723 Letter to Mr. George Kulick, Jr., Imperial Oil
Company from Mr. Michael J. Lukas, Site Manager,
Bureau of Site Management, New' Jersey Department
of"Environmental Protection, Department of
Hazardous Site Mitigation, re: Final Focused
Feasibility Study Report, 8/1/90.
P. 0724 Letter to Mr. Peter Baker, E.G. Jordan Company
from Mr. Michael J. Lukas, Site Manager, Bureau of
Site Management, New Jersey Department of
Environmental Protection, Department of Hazardous
Site Mitigation, re: Final Focused Feasibility
Study Report, 8/1/90.
P. 0725 Letter to Mr. Colin R. Sweeney, Jersey Central
Power & Light Company from Mr. Michael J. Lukas,
Site Manager, Bureau of Site Management, New
Jersey Department of Environmental Protection,
Department of Hazardous Site Mitigation, re: Final
Focused Feasibility Study Report, 8/1/90.
P. 0726 - _ Letter to Mr. H. Scott Stevens, President,
0728 Imperial Oil Company from Mr. Richard L. Caspe, P.
E., Director, Emergency and Remedial Response
Division, U.S. Environmental Protection Agency,
Region II, re: Notice Letter, 8/3/90
P. 0729 - Letter to Champion Chemical Co. Corp. from Mr.
0731 Richard L. Caspe, P. E., Director, Emergency and
Remedial Response Division, U.S. Environmental
Protection Agency, Region II, re: Notice Letter,
8/3/90
P. 0732 - Letter to Mr. Richard Sacca, Jersey Central Power
0734 and Light from Mr. Richard L. Caspe, P. E.,
Director, Emergency and Remedial Response
Division, U.S. Environmental Protection Agency,
Region II, re: Notice Letter, 8/3/90
* Administrative Record File available
Note: Company or organizational affiliation is mentioned only
when it appears in the record.
-------
Correspondence fcont.i
P.
0735 -
0737
P.
0738 •
0739
P.
0740
Letter to Mr. Herman Zell, J&M Land Company from
Mr. Richard L. Caspe, P. E., Director, Emergency
and Remedial Response Division, U.S. Environmental
Protection Agency, Region II, re: Notice Letter,
8/3/90
Letter to Ms. Grace L. Singer, Chief,
Bureau of Community Relations,' New
Jersey Department of Environmental Protection,
Department of Hazardous Site Mitigation from Mr.
George Kulick, Imperial Oil Company, Inc., re:
Response to Notice Letter, 8/24/90.
Letter to Dr. Mel Danzig from Ms. Grace L.
Singer, Chief, Bureau of Community Relations,
New Jersey Department of Environmental
Protection, Department of Hazardous Site
Mitigation, re: Final Focused Feasibility
Study Report, 8/6/90.
Letter to Mr. Lester Jargowsky, Health
Officer, Monmouth County from Ms. Grace L.
Singer, Chief, Bureau of Community Relations,
New Jersey Department of Environmental
Protection, Department of Hazardous Site
Mitigation, re: Final Focused Feasibility
Study Report, 8/6/90.
HEALTH ASSESSMENT
Health Assessment Report
P. 0742 - Report: Health Assessment for Imperial Oil
0755 Co.. Inc./Champion Chemicals. Marlboro Township.
Monmouth County. New Jersey, prepared by the
Agency for Toxic Substances and Disease Registry,
U.S. Public Health Service, 7/90.
P. 0741
* Administrative Record File available
Note: Company or organizational affiliation is mentioned only
when it appears in the record.
-------
PUBLIC PARTICIPATION
Community Relations Plan
P.
0756 -
0771
Public Notice
P. 0772
Report: Community Relations Plan for
Imperial Oil Company Superfund Site. Marlbpro
Township. Monmouth County. New Jersey, prepared
by NJDEP, 12/84.
Public Meeting Notice inviting public
comment on the Proposed Plan for the
Imperial Oil/Champion Chemical Site,
Morganville, New Jersey, 8/90.
Public Meeting Minutes and Transcripts
P. ^-0773 - Meeting Minutes: Public Meeting. Imperial
0776 Oil/Champion Chemical Site. 5/87.
P. 0777 - Transcript: Public Meeting. Imperial Oil/
0856 Champion Chemical Site. 8/14/90.
Fact Sheets and Press Releases
P. 0857 - Fact Sheet: "Initiation of Remedial
0865 Investigation/Feasibility Study for Imperial
Oil/Champion Chemical Superfund Site", prepared by
NJDEP., 5/13/87.
P. 0866 - Press Release: "NJDEP to Hold Public
0867 Meeting on the Remedial Investigation/Feasibility
Study for the Imperial Oil/Champion Chemical
Superfund Site", prepared by NJDEP., 5/1/87.
P. 0868 - Fact Sheet: "Focused Feasibility Study for
0880 Imperial Oil/Champion Chemical Superfund Site,
Offsite Areas 1 & 2", prepared by NJDEP., 8/14/90.
P. 0881 - Press Release: "NJDEP to Hold Public
0882 Meeting on the Results of the Focused Feasibility
Study for the Imperial Oil/Champion Chemical
Superfund Site", prepared by NJDEP., 7/27/90.
* Administrative Record File available
Note: Company or organizational affiliation is mentioned only
when it appears in the record.
-------
proposed Plan
P. 0883 - Report: Proposed Plan. Imperial; Oil
0898 Company/Champion Chemical Site. Offsite Areas 1 &
2 Soil Contamination. Monmouth County. New Jerseyr
prepared by NJDEP, 7/90.
Correspondence
P. 0899 _ Letter to Ms. Peggy Ganza, Marlboro Township
Municipal Building, from Ms. Grace L. Singer,
Chief, Bureau of Community Relations, New
Jersey Department of Environmental
Protection, Department of Hazardous Site
Mitigation, re: Documents for the
information repository, 7/27/90.
* Administrative Record File available
Note: . Company or organizational affiliation is mentioned only
when it appears in the record.
-------
APPENDIX C
RESPONSIVENESS SUMMARY
-------
Attachment C
Responsiveness Summary
Imperial Oil Company, Inc./Champion Chemicals superfund site
Marlboro Township, Nonmouth County, Nev Jersey
I. Introduction
In accordance with the U.S. Environmental Protection Agency's
(EPA) Community relations policy and guidance and the public
participation requirements of the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act (SARA), the New
Jersey Department of Environmental Protection (NJDEP) held a
public comment period from July 26, 1990 to August 25, 1990 to
obtain comments on the Proposed Plan for the Imperial Oil
Company, Inc./Champion Chemicals (IOC/CC) Superfund site.
The IOC/CC site is a 15-acre facility located in the Morganville
section of Marlboro Township, Monmouth County. The site is
currently active with an oil blending operation which occupies
approximately 4.2 acres. Champion Chemicals is the owner of the
real property and leases the premises to the Imperial Oil
Company, Inc.
On August 14, 1990, the NJDEP held a public meeting at the
Marlboro Township Municipal Building to receive public comment on
the Proposed Plan and the agencies' (NJDEP and EPA) preferred
alternative to remediate Off-site Areas 1 & 2 (Operable Unit 1).
Approximately 20 community officials, residents and interested
persons attended the meeting. Copies of the Proposed Plan were
distributed at the meeting and had been previously placed in the
information repositories for the site.
Public comments received during the comment period are documented
and summarized in this Responsiveness Summary. Section II
presents a summary of questions and comments expressed by the
public at the August 14 public meeting, while Section III
addresses comments received in writing by the NJDEP. All
questions and comments are grouped into general categories,
according to subject matter. Each question or comment is
followed by the NJDEP's or the EPA's response.
This section contains questions and comments presented at the
August 14, 1990 public meeting. Comments contained in this
section are grouped according to subjects discussed.
-------
construction contract is awarded, the construction
contractor will be responsible for identifying a landfill
and obtaining appropriate approvals from the NJDEP and the
receiving state. Short-term storage is anticipated only for
bulking and loading purposes; long-term storage (i.e.,
exceeding 90 days) is not anticipated.
5. Monitoring
One resident questioned whether the NJDEP was continuing to
monitor the ground water flowing from the site.
NJDEP Response:
The ground water flowing from the site is being studied as
part of the on-going RI. Contaminated ground water will be
addressed by the FS to be conducted for the remainder of the
site. Additional ground water monitoring will be conducted
throughout the Remedial Design, Construction and
Operation/Maintenance phases.
6. Preferred Alternative
Several residents voiced their agreement with the NJDEP's
and the EPA's choice of preferred Alternative 3, excavation
of contaminated soil with off-site disposal at a licensed
hazardous waste landfill.
7. Drinking Water Supply
A Senator's Aide asked if the underground drinking water
supply had been affected in the area surrounding the site.
NJDEP Response;
The ground water in the immediate vicinity of the off-site
areas has been sampled and does not exceed New Jersey's
ground water standards.
The ground water on the site and down-gradient has been
found to be contaminated. A localized "floating product" of
oil has been identified in the vicinity of the waste filter
clay pile. At NJDEP's request, EPA will be performing a
Removal Action to attempt to remove this floating product in
advance of the full-scale ground water remediation.
The residences down-gradient of the site are not affected by
the contaminated ground water because they are connected to
a municipal water system. Monitoring of off-site wells has
-------
not identified contaminants that could potentially threaten
existing private wells.
III. Response to Written Comments
Mr. George Kulick, Vice President of Imperial Oil Company, Inc.
submitted the following written comments to the NJDEP:
1. The Imperial Oil Company, Inc. asserts that the company
has never handled PCB's and inorganic compounds at the
site and, therefore, could not be responsible for those
contaminants in Off-site Areas 1 & 2. Also, they state
that the company never disposed of hazardous substances
in the two areas and, therefore, should not be liable
for cleanup costs.
NJDEP Response:
A determination of responsible parties for contamination in
the off-site areas will be identified as part of future
enforcement and cost recovery actions.
2. The Imperial Oil Company, Inc. asserts that petroleum
hydrocarbons (PHCs) are not hazardous substances under
CERCLA and, therefore, liability for associated cleanup
costs could not be imposed.
NJDEP Response;
The statement that PHCs are not regulated as hazardous
substances pursuant to CERCLA is true. However, the soils
in the off-site areas are not 'only contaminated with PHCs,
but are also contaminated with PCBs, lead and arsenic. As a
result, the contaminated soils in the off-site areas fall
within the jurisdiction of CERCLA which thereby triggers the
liability for cleanup costs.
3. New Jersey soil action levels are unpromulgated, informal
guidelines which do not qualify as ARAR's according to the
Imperial Oil Company, Inc.
NJDEP Response;
As identified in the FFS report, the New Jersey soil cleanup
levels have been determined "To Be Considered" as defined by
SARA and the National Contingency Plan (NCP); they have been
consistently applied to other remedial actions conducted in
New Jersey.
-------
The risk assessment in the draft FFS report indicated that
the health risks are within the risk ranges deemed
acceptable by the EPA. However, the NJDEP is recommending
excavation of soil containing an excess of 1 parts per
million (ppm) of PCBs, which the Imperial Oil company, Inc.
asserts is unwarranted based upon health considerations.
NJDEP Response:
As identified in the FFS report and the Proposed Plan, the
soil cleanup level for PCBs is 5 ppm. For the purposes of
estimating the soil volume, the 1 ppm contour for PCBs has
been used due to the unknown concentrations of carcinogenic
polycyclic aromatic hydrocarbons. Sampling for these
compounds will be performed during the design phase for the
off-site areas. The soil volume to be remediated will be
adjusted based on the results of the analyses.
As identified in the FFS report and the Proposed Plan, the
risk associated with direct contact and ingestion of
contaminants detected in the soil by children, under a
residential scenario, has been calculated to be 8xlb" (eight
in ten thousand). This risk is deemed unacceptable by the
EPA and the NJDEP as it falls outside the acceptable risk
range.
The Imperial Oil Company, Inc. states that a more cost-
effective solution, which was not considered by the NJDEP,
would be to cap Areas 1 & 2.
NJDEP Response;
As identified in the FFS report, capping the areas was not
found to be viable since the contamination is within a
wetlands area. The National Environmental Protection Act
(NEPA) sets forth the EPA's policy for carrying out the
provisions of the Wetland Executive Order (EO 11990) which
states that an alternative located in a wetland may not be
selected unless a determination is made that no practicable
alternative exists outside the wetland. Since alternatives
exist to remediate the contaminated soil and to restore the
wetlands, capping is not an acceptable solution as it would
irrevocably alter the natural water drainage in the area
creating the wetland.
-------
Chronology of C(
05/01/87
05/13/87
10/01/87
10/26/88
12/07/88
09/28/89
04/18/90
07/26/90
07/27/90
08/14/90
Press release issued announcing that a public
meeting would be held by NJDEP to discuss the
RI/FS.
Public meeting held at Marlboro Township
Municipal Building to discuss RI/FS. Fact sheet
prepared and distributed at public meeting.
BFB/IO CAC meeting held to discuss Phase I RI
results.
BFB/IO CAC meeting to update committee on RI
activities and to discuss the EPA's "SITE"
Program.
EPA held a "SITE" demonstration at the IOC/CC
site - committee members invited.
BFB/IO CAC meeting to discuss Phase II RI
sampling and other issues.
BFB/IO CAC meeting held to discuss expected
completion of RI for May 1990 and anticipated
goal of a Summer 1990, in-house FFS.
Public comment period opened.
Press release issued announcing availability of
Proposed Plan and study documents for Off-Site
Areas 1 & 2 and public meeting scheduled for
August.
Public meeting held at Marlboro Township
Municipal Building to present preferred
alternative for Off-Site Areas 1 & 2.
08/25/90
Public comment period closed.
------- |