United States        Office of
        Environmental Protection   Emergency and
        Agency           Remedial Response
EPA/ROD/R02-91/143
June 1991
EPA   Superf und
        Record of Decision:
        Curcio Scrap Metal, NJ

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50272-101
 REPORT DOCUMENTATION
        PAGE
1. REPORT NO.
     EPA/ROD/R02-91/143
                                           3. Recipient's Accession No.
 4. nfleindSubWIe
   SUPERFUND  RECORD OF DECISION
   Curcio Scrap Metal, NJ
   First Remedial Action
                                                                     5. Report Dite
                                                      06/28/91
 7. Aumor(a)
                                           8. Perfonning Organization Rept No.
 9. Performing Organization Name and Address
                                           10. Pro|ect/T«sk/Worti Unit No.
                                                                     11. Contract(C) or Gr»nt(G) No.

                                                                     (C)

                                                                     (G)
 12. Sponsoring Organization Name and Address
   U.S.  Environmental Protection Agency
   401 M Street, S.W.
   Washington, D.C.   20460
                                           13. Type of Report ft Period Covered

                                                     800/000
                                                                     14.
 15. Supplementary Notes
 16. Abstract (Umlt: 200 words)
  The 1-acre Curcio Scrap  Metal site  encompasses  two active  scrap metal  recycling
  businesses and associated warehouses  in Saddle  Brook Township,  Bergen  County, New
  Jersey.  Land use around the site is  mixed industrial and  residential.   Surface water
  drainage from the site empties into Schroedat's Brook, located a few hundred feet  from
  the property,  which drains into a nearby la^js.   The site is  situated above the Brunswick
  Formation which is a sole source aquifer,  ifhis formation  supplies potable water to the
  public and private wells in the area.   Since!  1975,  Curcio  Scrap Metal,  Inc.  (CSMI)  and
  Cirello Iron  and Steel Company  (CISC)  have Recycled scrap  metals products onsite.   In
  1982,  the State identified cut electrical transformers stored onsite,  and pools of black
  oily fluid, which had collected on  the ground under and near the transformers.  Samples
  taken from this area and from onsite  soil in  1984  revealed contamination by VOCs,
  organics, and metals.  In 1985, the State discovered an oil  spill in a nearby pond,
  approximately 200 feet from the Property.  The  State determined that CISC was
  responsible for the spill of approximately 200  gallons of  hydraulic fluid on the
  Property and  directed CISC to remove  contaminated  soil.  CISC reportedly removed the
  bulk of the soil and stored it in another onsite area.  EPA  issued an  Administrative

  (See Attached Page)
 17. Document Analysis a. Descriptors
   Record of Decision - Curcio Scrap Metal,  NJ
   First  Remedial Action
   Contaminated  Medium:  soil
   Key Contaminants:   other  organics  (PCBs),  metals  (lead)
   b. Identifiers/Open-Ended Terms
   c. COSATI Held/Group
 18. AvallabUty Statement
                             19. Security Class (This Report)
                                      None
                                                      20. Security Class (This Page)
                                                      	None
21. No. ofPagea
       106
                                                                                 22. Price
(SeeANSI-239.1B)
                                      See Instruction* on Reverse
                                                      OPTIONAL FORM 272 (4-77)
                                                      (Formerly NTIS-35)
                                                      Department of Commerce

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EPA/ROD/R02-91/143
Curcio Scrap Metal, NJ
First Remedial Action

Abstract (Continued)

Order on Consent to the PRPs on May 27, 1988.  Remedial Investigation activities were
initiated in 1989 by the PRPs under the terms of this Order.  In 1989, CISC caused a
spill of PCB-contaminated oil into onsite soil,  and the State required CISC to excavate
and drum the resulting contaminated soil.  During the RI/FS, PCBs and vinyl chloride, as
well as other contaminants were detected in the onsite groundwater.  This Record of
Decision (ROD)  provides a final remedy for the first operable unit (OU1), the
approximately 1,800 cubic yards of contaminated onsite soil.  Future RODs will address
other ground and surface water contamination.  The primary contaminants of concern
affecting the soil are PCBs and metals including lead.

The selected remedial action for this site includes excavating,  incinerating, and
disposing of 1,800 cubic yards of PCB- and metal-contaminated soil above action levels at
an offsite RCRA/TSCA incineration facility, along with any resulting ash.  The estimated
present worth cost for this remedial action is $7,500,000.  There are no O&M costs
associated with this remedial action.

PERFORMANCE STANDARDS OR GOALS:  All soil contaminated in excess of soil action levels
for metals and greater than PCB 1 mg/kg will be excavated and treated offsite.
Chemical-specific goals for soil are based on State soil action levels, and include
lead 250 mg/kg to 1000 mg/kg.

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                          ROD FACT SHEET
SITE

Name:
Location/State:
EPA Region:
HRS Score  (date)
NPL Rank (date):

ROD

Date Signed:

Selected Remedy

Soils:

Groundwater:
Capital Cost:
0 & M:
Present. Worth:

LEAD
Curcio Scrap Metal, Inc.
Saddle Brook, Bergen County, New Jersey
II

July 1987
June 28, 1991
Excavation with Off-Site Incineration

The nature and extent of groundwater
contamination will be characterized during
operable unit two.

$  7,500,000
$
$  7,500,000
Enforcement, EPA
Primary Contact (phone):  Mary Anne Rosa  (212-264-1301)
Secondary Contact (phone):  Kim O'Connell (212-264-8127)
WASTE

Type:


Medium:

Origin:
Soil - PCBs mixed with heavy metal (i.e.,
lead) contamination.

Soil

Pollution originated as a result of salvaging
approximately 50 transformers.  The PCB fluid
inside the trasnsformers was drained onto the
dirt lot.

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                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

        JUL 111991                REGION"

SUBJECT: Curcio Scrap Metal,  Inc. Record  of  Decision  Information

  FROM: Mary  Anne Rosa/ Remedial Project Manager

    TO: Peter Moss,  Program  Support
      The Curcio Scrap Metal, Inc.  Record of Decision (ROD) was signed by
      the  Regional  Administrator  on  June  28,  1991.    It  addresses
      contamination  in  the  soil  on and  around  the East Lot of the  Site.
      The  selected  remedial alternative  is   Excavation  with  Off-Site
      Incineration of approximately 1800 cubic  yards of soil contaminated
      with PCBs and  heavy metals.

      As you requested, the following information has  been provided:
           1 Disk with  the  following  files;
                FACTSHEE.CUR
                DECLARE.STM
                DECISION.SUM
                RESPONSE.SUM

      The file entitled FACTSHEE.CUR  is the information that I filled in
      from the G drive  questionnaire.  The DECLARE.STM file is only the
      Declaration Statement of the ROD.   The DECISION.SUM file holds the
      body  of  the ROD,  which discusses the  nature and  extent of  the
      contamination, the remedial alternatives and the selected remedial
      alternative.  The RESPONSE.SUM  file is EPA's response to both oral
      and written comments  received during the Public  Comment period.

      The  tables and   figures  for the ROD were  not  computer drawn,
      therefore  are  not on disk.   However,  a "hard  copy" of the  ROD
      complete with  tables,  figures,  attachments and the  Responsiveness
      Summary has also  been provided.

      Should  you need  any  further  information,  please  feel free to
      contact me at  x-1301.
 REGION II FORM 132O-1 (9/85)

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                  DECLARATION STATEMENT

                     RECORD OF DECISION

                  CURCIO SCRAP METAL. INC.
SITE NAME AND LOCATION;

Curcio Scrap Metal,  Incorporated
416 Lanza Avenue
Saddle Brook, Bergen County,  New Jersey

STATEMENT OF BASIS AND PURPOSE:

This decision document presents the selected remedial action for
the Curcio  Scrap Metal,  Inc.  Site  (Site),  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 document explains the
factual and legal basis for selecting  the remedy for this Site.

The New Jersey Department of Environmental Protection concurs with
the selected  remedy.   The  information  supporting this remedial
action decision  is contained in 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
threat to public health,  welfare,  or the  environment.

DESCRIPTION OF THE SELECTED REMEDY;

The remedial action described in this document represents the first
of two planned operable units for the site.  It addresses the risks
associated  with  contaminants   (e.g.,  polychlorinated  biphenyls
(PCBs) and  heavy metals) present  in soil on and around the East
Lot.   Other  contamination,  including ground and surface water
contamination, will be addressed by the second operable unit and
documented in a  subsequent  Record of Decision.

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                              - 2 -


The major components of the selected remedy include:

     o    Excavation of soil contaminated with PCBs and heavy
          metals above applicable cleanup standards; and

     o    Transportation of the excavated soil to an appropriate
          incineration facility for treatment and/or disposal.


DECLARATION OF STATUTORY DETERMINATIONS;

The selected remedy is protective of human health and the environ-
ment, 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 practic-
able, and it satisfies the statutory preference for remedies that
employ treatment that reduce toxicity, mobility, or volume as their
principal element.   ^.

Because  this  remedy  for  soils  will  not result  in  hazardous
substances remaining on  the site above health-based  levels, the
five year review will not apply to this remedial action.
Constahtine Sidamon-Eristoff     /                 jpate'
Regional Administrator
U.S. EPA Region II

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                      DECISION SUMMARY


                  CURCIO SCRAP METAL. INC.

SITE LOCATION and DESCRIPTION

The Curcio  Scrap Metal,  Inc. Site  (the  Site)  is located at  416
Lanza Avenue,  Saddle Brook Township,  Bergen County, New Jersey (see
Figure  1) .   The  Site  includes,  but is  not  limited to the  real
property  (Property)  where  two  active  scrap  metal  recycling
businesses  operate, Curcio Scrap Metal,  Inc.  (CSMI)  and  Cirello
Iron and Steel Company (CISC).   The  Property is approximately one
acre  in  size and  is partially occupied  by  two  single  story
buildings which are used primarily as warehouses.  It is bordered
by a concrete company  on the north,  Walther  Avenue  on the south,
Midland Avenue on the west and a drainage ditch on the east.   The
area surrounding  the  Property  is a  mixed industrial  residential
district, which includes single unit housing, light industry,  and
shops.   The  nearest  residential and  commercial businesses  are
located  adjacent to  the  Property on  the east  side of  Midland
Avenue.  West of  Midland Avenue  is primarily a residential  area.
Approximately 30,000 people live  within a three mile radius of the
Property.

The Property  is  subdivided  into three  lots: the East, West  and
South Lots.   CSMI and  CISC  conduct their administrative operations
from the buildings  located on the West and  South Lots.   With the
exception of two narrow passageways,  all the  areas of the West and
South Lots  are paved.   The East Lot, the area where  scrap  metal
salvaging operations  of CISC and CSMI occur, is not  paved.   The
active  section  of  the East Lot  is  relatively  small,  measuring
approximately 90 feet by 100  feet.  The metal cutting area and the
metal compacting area are also located on the East Lot.   A ditch,
located near this metal cutting area, drains surface water runoff
from the  Property and empties into  a  small  pipe that runs  in  a
north-easterly direction under  the   concrete company's  property.
This drainage empties  into Schroeder's Brook,  a  few hundred feet
away from the Property (see Figure 2).  The brook flows freely for
approximately eight hundred feet before it e iters  a pipe leading to
a nearby lake.  The remainder of  the  East Lot is occupied by piles
of scrap metal in various stages  of salvage.  The locations of the
piles are changed frequently as scrap metal  arrives daily.

A large crane with a magnet operates in the center of the East Lot,
moving scrap metal to various piles  and containers for recycling.
Two roll-off  containers are usually located in  the southeastern
section of the East Lot.  These containers are removed and replaced
as they are filled  with scrap metal.   Bulldozers and other  heavy
equipment are also  used to move  the  scrap metal  piles around the
Property.

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Topography and Hydrogeology:

The topography of the  Property  is  constantly changing due to the
extensive  use  of  heavy  equipment.    Due  to  daily  operating
procedures, the crane often leaves tracks which are approximately
three feet deep and require regrading  of  the Property.   Although
the topography changes each day,  there  is generally a slight grade
toward  the east.      Red  weathered Brunswick sandstone,  which
consists  of  primarily gravel-size  fragments with some  sand and
silt, is the naturally occurring soil type on the Property.

The Property is situated above the Brunswick Formation which is a
sole source aquifer.  This  formation supplies potable water to the
public and private wells in the area.   The Brunswick Formation is
characterized by fractured red sandstone and occurs at a depth of
approximately sixteen feet  underlying the Property.  The Brunswick
Formation aquifer is a consolidated formation in which ground water
is  stored and  moves  through  interconnected fractures in  the
bedrock.   A  water  table  aquifer exists  above  the  Brunswick
formation.    Ground  water  was  encountered  during  subsurface
investigations at depths ranging from  five  to eight feet.   The
ground water gradient in this  surficial  aquifer is relatively flat
in the East Lot and throughout the Site.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

In  1975,   Frank  and  Mary   Curcio  purchased  the  area  presently
occupied  by the  West and  East  Lot.   Prior  to their  purchase of
those lots, the lots were  used  for  dairy  farming  and contained a
number of  small structures.   Initially, CSMI's operations at the
Property were associated with recycling paper and rags.   As the
business began to grow, copper and aluminum also were collected for
recycling.  In 1977, the main  building was  constructed on the West
Lot (see Figure 3).

In 1978, the truck  scale and  scale  house  were constructed on the
northeast section of the Property.   In 1981,  Curcio purchased the
South Lot; from 1982 to 1985,  the South Lot was used for employee
parking only.  In 1985, a one-story warehouse (as seen  in Figure 3)
was erected  on the  South  Lot.   Both  CSMI  and CISC  are active
corporations nresently operating at the Property.

On October 4,  1982,  the  Division  of  Water  Resources   (DWR) of
the New Jersey  Department of  Environmental  Protection (NJDEP)
received  a citizen  complaint  alleging, among  other  things,  that
electrical transformers were  being stored  and  cut  up at  the
Property.  NJDEP inspected  the Property on  October 27, 1982.  This
inspection revealed that electrical  transformers had been cut into
pieces and that pools of black oily fluid were  located directly
under and adjacent to the transformers (see Figure  4).  Sampling of
that fluid indicated  the presence of Arochlor  1260  and Arochlor
1242, two types of polychlorinated biphenyls (PCBs).   The average

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concentration of Arochlor 1260 and Arochlor  1242 was 105 parts per
million (ppm) and 47 ppm,  respectively.  Liquid samples taken from
the drainage ditch  in  the eastern corner  of the  Property also
indicated the  presence  of PCBs with an average  concentration of
462.4 ppm of Arochlor 1260 in the oil layer, and  25.1 parts per
billion (ppb) in the water layer.  Following  this inspection, NJDEP
informed Mr.  Curcio  of  the potentially dangerous  PCB compounds
sampled and issued a NJDEP Directive ordering him to cease further
discharge of waste oils.

At NJDEP's  request,  the  United States Environmental  Protection
Agency (EPA) performed a Preliminary Assessment (PA) of the Curcio
Property in April  1984.   In September  1984, EPA  performed a Site
Inspection (SI).  The SI revealed that at least three types of PCBs
were present on the  Property.  In addition,  lead, copper, nickel,
and trichloroethylene were detected in soil samples.

On May 15,  1985,  NJDEP  discovered an oil  spill  in  a nearby pond,
approximately 200 feet east of the Property.  In June 1985, NJDEP
inspected  the  Curcio  Property  and  determined  that  CISC  was
responsible for the spill of approximately 200 gallons of hydraulic
fluid  on the  Property  (see Figure 4).    According  to  NJDEP's
findings, the fluid flowed off the Property,  into the pond, through
the storm drain  on  the  East Lot.  Sampling  of the  soil where the
spill occurred  indicated  PCBs in the range of 30 ppm  to 80 ppm.
Pursuant to the NJDEP Directive,  CISC was to remove and dispose of
all contaminated soil.   CISC reportedly removed the bulk of the
contaminated soil and stored it on the East Lot.  On  June 18, 1985,
NJDEP conducted a follow-up  Site inspection that revealed that some
oil remained in the  soil.

In 1986,  EPA conducted a Potentially Responsible Party (PRP) Search
to identify any party  that was involved with the contamination
present at  the  Site.   On  January 28,  1988, EPA  issued noticed
letters to the  following parties; Curcio Scrap Metal, Inc., Cirello
Iron and Steel Co., Consolidated Edison Company of New York, Inc.,
SECO Corporation and Grimaldi and Grimaldi,  Trustee.  In addition,
on December 29,  1989, EPA notified Frank Curcio and Anthony Cirello
of their potential liability under CERCLA.  The Consolidated Edison
Company of New York, Inc.  (Con Ed) was determined to be the former
owner of the transformers  which were the source of the oil spill in
1982.   Con Ed sold the transformers to SECO Corporation, which in
turn  transported the transformers  to  Curcio Scrap Metal,  Inc.
Cirello Iron and Steel  Company,  which  is  located on Curcio Scrap
Metal, Inc.  Property, was determined to be responsible  for the May
1985 hydraulic oil spill.

In July 1987, the Site was placed on EPA's National Priorities List
(NPL).

EPA entered into an  Administrative Order on Consent, Index No. II
CERCLA-80107 (the "AGO"),  on May 27,  1988 with Con Ed, Curcio Scrap

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Metal,  Inc.,  and  SECO  Corporation  (hereinafter  collectively
referred  to  as  AGO  Respondents) .    The  AGO  required the  AGO
Respondents   to,   among   other  things,   perform   a   Remedial
Investigation and Feasibility  Study  ("RI/FS")  at the Site, under
EPA oversight.  A public meeting was  conducted  on June 14, 1989 to
discuss the scope of the RI/FS.  The RI field activities  started on
July 19, 1989.

On August 8, 1989, CISC caused a spill of PCB contaminated oil at
the Site.  On August  14, 1989,  the contaminated soil that resulted
from that spill was excavated and drummed by the AGO Respondents'
contractor under EPA's  supervision.

Samples of soil and oil, from the August 1989 spill were obtained
and analyzed  for  PCBs  and  volatile organic compounds ("VOCs") in
the on-site mobile laboratory.  The analysis indicated the presence
of PCBs  (Arochlor 1254) ranging from 400 ppm to 700 ppm.

On August 14, 1989, upon EPA's  request, the  contaminated soil that
resulted from the August 1989  spill  was  excavated and drummed by
Respondents' Contractor under  EPA's  direction  (as seen on Figure
4).  The excavated soil ranged in  depth  from six inches to three
feet.

Due to unauthorized moving of contaminated soil  within the Property
and  the damaging of  two  monitoring wells by employees  at  the
Property, EPA issued  a  Unilateral Administrative  Order (UAO) Index
No. II  CERCLA-00101  under  Section 106(a) of CERCLA,  42 U.S.C.
§9606(a) on  December 29,  1989.  Respondents to  this  UAO include
CSMI, CISC, Mr. Frank Curcio, and Mr. Anthony Cirello.  The Order
required the following  from the Respondents:

   a}  refrain from taking any other actions  which might  in any way
      interfere with EPA's investigation or remediation of the
      Site;
   b)  not to conduct any activities which may constitute
      inconsistent response actions;
   c)  not to release  or contribute to the release of any hazardous
      substance at the  Site;
   d)  implement provisions for eliminating any future active
      releases of any hazardous substances at the Site;  and
   e)  sample and properly dispose of  the contaminated soil mound
      located at the border of the area designated as the East Lot.

In July 1990, Phase II  of the Remedial Investigation was performed
to determine the extent  of the  soil contamination  and on-site
ground water contamination.  This work was conducted to  supplement
the data which  was  collected  during  the  initial investigatory
phase.   The Phase II investigation  revealed that on-site ground
water   is   heavily  contaminated   (e.g.,   vinyl  chloride   in
concentrations up to 160 ppb).

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In December 1990, EPA performed a Risk Assessment for the Site to
determine the potential risk posed by  the  Site to public health.
The  risk  was estimated to be extremely high  (5  x  10~2 [5  in a
hundred]  for  workers).   This  risk  is primarily  attributable to
contaminated soil.  Due to the high concentration of contaminants
found in the soil and the correspondingly high risk associated with
this contamination, EPA determined that soil remediation should be
addressed on an expedited basis.   Consequently, the Site has been
divided into  two operable units.   The first  Operable  Unit will
address contaminated soil in and around the East Lot.  The second
will  address other contamination,   including  ground  water  and
surface water contamination, after further characterization.

EPA issued a Proposed Plan for  the first Operable Unit on February
8, 1991.  The Proposed  Plan presents EPA's preferred alternative
for the remediation of soil in and around the East Lot.

On February  21,  1991, EPA held  a Public Meeting  to discuss the
findings  of  the Focused  RI/FS and  to propose the  alternatives
considered for the  remediation of the Property.   The public comment
period closed on April 16, 1991.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

The Focused RI/FS  Report,  the Proposed Plan  and  other  documents
which comprise the Administrative Record have been made available
to the  public at the following  information  repositories:  Saddle
Brook Free Public  Library  in Saddle  Brook, New Jersey  and at the
U.S.  EPA,  Region  II offices.    On  February  8,  1991,   EPA also
published a notice  in the Bergen Record  which contained information
relevant  to  the public comment  period, the  date of the  public
meeting and availability of the  Administrative Record.   A public
comment period was  held from February  8, 1991 to  April  16, 1991.
During this time period, the public  was  given the opportunity to
comment on the documents  contained  in  the  Administrative Record.
EPA granted a  35 day extension  of  the public  comment  period in
response to a request.  In addition,  a public meeting was held on
February 21, 1991 at the Saddle Brook Free Public Library.  At this
meeting, representatives from EPA answered questions related to the
Site  and  the remedial alternatives  under consideration.  EPA's
responses to verbal and written comments received during the public
comment period are  included in the Responsiveness Summary, which is
an attachment to this Record of Decision (ROD).

SCOPE AND  ROLE OF THIS RESPONSE ACTION WITHIN OVERALL  SITE STRATEGY

Due to the high concentration of contaminants found in the soil and
the corresponding high risk associated with  this contamination, EPA
determined  that  soil  remediation   should be addressed  on  an
expedited basis.  Consequently, the Site has been divided into two
operable units.   The first Operable Unit will address contaminated

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soil in and  around the East Lot.  The  second  will  address other
contamination.    EPA  is  aware  of ground  water  contamination,
however, the nature and extent of this contamination has not been
fully characterized. This contamination will be fully addressed in
the second Operable Unit.

The remedial action presented in this Record of Decision addresses
an estimated  1,800 cubic yards  (yd3)  of contaminated  soil.   The
remedial action will achieve EPA's  soil cleanup level of 1 ppm1 for
PCBs.  In  addition,   the   remediation   will  address  inorganic
contamination detected on the Property.

SUMMARY OF SITE CHARACTERIZATION

Soil Contamination:

Phase I soil sampling was conducted in July 1989.  The subsurface
investigation  included  48   subsurface  soil  borings  and  the
installation  of  four  monitoring wells.   Thirty-six  of  the  48
subsurface soil borings and two of the four monitoring wells were
located in the East Lot.   In the West Lot,  seven subsurface soil
borings and one upgradient  monitoring well were installed.  In the
South Lot, five soil borings and one downgradient monitoring well
were installed.  The location of each subsurface soil boring and
monitoring well installed during this investigation is presented on
Figure 5.   The soil borings were terminated at the water table, at
a depth of approximately six feet.   The  soil samples were analyzed
at two foot intervals.

The Phase I sampling revealed the presence of PCBs throughout the
soil in the East Lot.  The highest PCB concentration was detected
at soil boring 19 (SB-19),  at a level of  6,200 ppm.  Table 1 lists
     1  The Proposed Plan contained a soil cleanup level of 10 ppm
for PCBs.  This level was based upon current commercial use of the
Property.  Since  that time,  it has been  brought to the Agency's
attention that the area where the site is located is  in the process
of being rezoned.   At the public  meeting,  the  Chairman  of the
Planning Board summarized the Township of  Saddle  Bzook Master Plan
for the rezoning.  The Township is in the process of implementing
the ordinance necessary to rezone  the  area to moderate residential
use.    The change  in zoning to residential  use  requires  a more
stringent cleanup level. Accordingly,  EPA has modified the cleanup
level  to 1 ppm  for  PCBs  in accordance  with EPA's Guidance  on
Remedial  Actions  at  Superfund   Sites  With  PCB  Contamination,
Directive: 9355.4-01 FS, August 1990,  and  in accordance with NJDEP
Soil Action Levels.   This  modification  in the cleanup  level does
not significantly effect EPA's estimate of the volume of soil to be
remediated.

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the types  of PCBs detected  on-site,  the concentrations  and the
locations of the soil borings where the soil was sampled. PCBs at
3,600 ppm  were detected at  soil  boring 11  (SB-11),  (as  seen in
Figure 5) at a depth ranging from 0-2 feet.

Various volatile organic compounds were detected in  the East Lot
soil.  Table 2 lists  the VOCs,  such as vinyl chloride, acetone and
trichloroethylene, detected  on the Property.   The semi-volatile
organic  compounds   (semi-VOCs)   detected,   including  fluorene,
naphthalene,  fluoroanthene and pyrene,  are  listed  on Table 3.
These tables also indicate the location, depth and concentration at
which each  contaminant  was found.  Both VOCs and  semi-VOCs were
detected  in  levels  above  NJDEP  Soil  Action  Levels  for  these
compounds of 1 ppm and 10 ppm, respectively.

Inorganic   constituents  were  detected in  the  soil  in  high
concentrations.    Aluminum,   arsenic,   copper,   lead,  magnesium,
mercury and zinc, among other compounds, were found to be present
on the Property.  Table 4 lists the inorganic constituents found in
soil  samples  taken  from  the Property,  along  with the  depth,
location and concentration of each contaminant.   Many of the metal
contaminants were detected at concentrations above the NJDEP Soil
Action Levels (as seen in Table 5).  Lead has been detected in high
levels throughout the Property and is of particular concern.  Lead
at 39,300 ppm was detected at soil boring 31  (SB-31), (as seen in
Figure 5) at a depth ranging from 0-2 feet.  The concentrations
of lead detected  on the Property are significantly greater than the
NJDEP Soil Action Level range of 250 ppm to 1,000 ppm.

During Phase II,  in July 1990, additional sampling was conducted in
the  East   Lot   to   further   characterize   the  extent  of  soil
contamination.  High concentrations of PCBs were detected at soil
boring 11.   At a  depth of 0 - 2 feet, the concentration of PCBs was
3,600 ppm.   Also, at this depth, PCBs were detected at soil borings
17  and  19  at  concentrations  of  4,100  ppm  and  4,500  ppm,
respectively.  At  a  depth of  2 - 4 feet,   PCBs  were detected at
levels up  to  2,400 ppm.   Table 1 lists the  PCBs  present on the
Property, the concentration  and the location of the  sample.  The
concentrations of PCBs detected were above  the NJDEP Soil Action
Level and EPA action level of 1 ppm for residential areas.

Two representative  samples,  consisting  of  a composite of soils
collected from five different locations, were collected within the
East Lot.  One sample was  a composite of soil collected  from 0-2
feet; the other was a composite of soil  collected from 2-4 feet.
These samples  were evaluated  in  accordance  with  EPA's Toxicity
Characteristic Leaching Procedure (TCLP) test.  This test is used
to determine if dangerous concentrations of contaminants, present
in the soil, will leach  (or  seep)  into ground water, if the soil
remains untreated.  TCLP testing  also  determines whether soil is
characterized  as   a  hazardous   waste  subject  to  Resource,
Conservation and Recovery Act  (RCRA) regulation.  Results of TCLP

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testing indicate that the composite sample collected at a depth of
2-4 feet is characterized as a RCRA hazardous waste due to high
concentrations of lead.  TCLP results are presented in Table 6.

An estimated 1,800 yd3 of soil is contaminated with PCBs and metals.
Contamination  extends to  the  water  table  in  approximately  two
thirds of the East Lot.   The remaining one  third of the East Lot
contains contamination to a depth of two feet.  The general area of
the lot is  90  feet  by 100 feet and  is  approximately  six feet in
depth to the water  table.  The potential pathways  for migration
pertaining  to  the   soil  are  inhalation,   ingestion  and  dermal
contact.

Extent of Ground Water Contamination:

Ground water monitoring wells (as shown on Figure 5) were installed
in August 1989.   Ground water  monitoring wells were installed on
the Property in order to determine:

        . the horizontal and vertical extent of the plume
         of migration and contaminant concentration gradients;
        . rate  and direction of contaminant  migration; and
        . the changes in contaminant concentration.

The monitoring wells were placed upgradient,  on and downgradient
from the Property.  The upgradient wells were installed to detect
contamination  from  possible   background sources  which  may  be
impacting the Property.  The wells placed directly on the area of
concern were installed to determine ground water quality  at the
Property.  The downgradient wells were used to determine the extent
of ground water contaminant migration.   Ground water  flows in an
easterly direction.   Monitoring well (MW-l)  was installed in the
West  Lot  on  Lanza  Avenue and is  upgradient  of the  Property.
Monitoring Well (MW-2) was installed in the South Lot and is also
upgradient of the Property.  Monitoring wells MW-3  and MW-4 were
installed as downgradient  wells in the  East lot.  All wells were
subsequently developed and then sampled. In June 1990, monitoring
wells MW-l and MW-4  were  decommissioned due to damages.   In July
1990, as part of  Phase II activities,  five  temporary well points
(TW-1 through TW-5,  shown on Figure 6) were  installed downgradient
in the East  Lot.   A monitoring well cluster  downgradient  in the
East  Lot,  MW-5U  and MW-5L  (as   seen  in  Figure  6) ,  was  also
installed.    The most frequently detected compounds found  in the
ground water at  the  Property were  determined to be:  volatile
organics,  semi-volatile organics,  PCBs, metals and inorganics.

PCB contamination in ground water is notable due to the relatively
immobile nature of these compounds.  It is believed that Property
soils are a source of this contamination.
                                8

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The remediation of ground water will  be addressed in detail in a
subsequent  ROD  dealing  with ground  water  and  surface  water
contamination.

SUMMARY OF SITE RISKS

EPA conducted  a baseline  Risk Assessment  (RA)  to  evaluate  the
potential risk to human health and the environment associated with
the Curcio Scrap Metal, Inc. Site in its current state.  For this
OU, the RA  focused  on the Site contaminants which  are likely to
pose the most significant risk to human  health and the environment
(contaminants of concern).

The risk assessment began with selecting contaminants of concern
(COCs).  These chemicals were identified based on factors such as
potential for exposure  to receptors,  toxicity,  concentration and
frequency of occurrence.  These contaminants include PCBs, metals,
VOCs  and  semi-volatiles.   Several  contaminants detected  at  the
Property, including PCBs, are known to cause cancer in laboratory
animals and are  suspected to be human carcinogens.  The COCs, their
indices of toxicity and  Site concentrations are presented in Tables
7, 8 and 9.  Those substances which do not contribute significantly
to the risk associated with the Site have been excluded.

Currently, two active scrap metal recycling businesses operate on
the Property.  The land is  used as  a  industrial setting.   Future
use of  this land could entail the  development of  a residential
community.

In general, contaminants will only present a risk to receptors if
there is a pathway of exposure.  An exposure pathway is comprised
of a  contaminant  source (such as a chemical spill),  a transport
medium (such as soil), a potential for human contact, and a means
for exposure (such as ingestion).

The RA identified several potential  exposure pathways by which the
public may be exposed to contaminant releases from the Site.  These
pathways and  the populations  potentially  affected are  shown in
Table 10.  The potential routes identified in the RA include:
                                                             •
        .  Dermal contact with soil;
        .  Incidental ingestion of soil;
        .  Inhalation of  contaminated dusts;
        .  Dermal exposure to VOCs resulting from domestic
          use of contaminated ground water;
        .  Ground water ingestion resulting  from  the
          domestic use of the contaminated  aquifer,  in  the
          future; and
        .  Inhalation exposure resulting  from the domestic
          use of contaminated ground water,  in the future.

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Under  current  EPA guidelines,  the  likelihood of  carcinogenic
(cancer causing) and  non-carcinogenic  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  non-carcinogenic  risks associated  with
exposures to individual indicator compounds were summed to indicate
the  potential   risk   associated  with  mixtures   of   potential
carcinogens  and non-carcinogens.    Non-carcinogenic 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
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).  Table 11 lists the RfDs for the chemicals of concern
associated with  this  Site and Table 12  lists  the  slope factors.
Estimated intakes of chemicals from environmental media (e.g., the
amount of a chemical ingested from drinking  contaminated 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
non-carcinogenic  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 estimated
hazard indices for non-carcinogenic risks are found on Table 13.

Potential  carcinogenic  risks were  evaluated  using the  cancer
potency  factors  (CPFs)  developed by  the  EPA  for  the indicator
compounds.    CPFs have   been  developed  by  EPA's  Carcinogenic
Assessment  Group  for  estimating excess   lifetime  cancer  risk
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 risk
calculated  from  the  CPF.     Use of  this  approach  makes  the
underestimation of the risk highly unlikely.

For known  or suspected carcinogens,  EPA considers  excess upper
bound individual lifetime  cancer risk of between 1 x 10"* to 1  x 1CT6
to be acceptable.  This  level indicates that an  individual has not
greater than 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.
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The primary current risk associated with the Property is incidental
soil and sediment  ingestion  and dermal contact with contaminated
soil/sediment  by  workers  and  visitors.    Two  scenarios  were
developed; the first pertains to the ingestion of the soil by the
workers,  while  the  second  scenario   deals  with  the  exposure
following  illegal  entry  by young  adults.   The illegal  entry by
young adults was considered relevant due to the inquisitive nature
of teenagers  and the close  proximity  of residential homes.   In
addition,  children reportedly bring items to the Property  to be
scrapped during working hours.

The results of the risk assessment  indicate that contaminated soil
poses an unacceptable risk to human health,  as seen in Table 14.
The carcinogenic risk to workers was estimated to be  5 x 10'2, while
the carcinogenic risk to trespassers was estimated to be 3 x 10'2.
These risks  are significantly higher  than EPA's  acceptable risk
range.

Uncertainties

The procedures and inputs used to assess risk in this evaluation,
as  in all  such assessments,  are  subject 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; and
        . 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.   Environmental chemistry  analysis  error can stem
from  several  sources  including  the  errors  inherent  in  the
analytical methods and characteristics of the  matrix being sampled.
Uncertainties  in the exposure assessment are related to estimates
of how often an individual would actually  come in contact with the
chemicals of concern, the  period of time over which such exposures
would occur, and in the modnls used to  estimate the concentrations
of the chemicals of concern at the point of exposure.

Uncertainties  in  toxicological data occur in  extrapolating both
from animals to humans 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.  As a result, the RA is highly unlikely
to underestimate the actual risk related to the Site.
                                11

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An ecological assessment was not performed for this operable unit,
however, such  an  assessment will be conducted during  the second
Operable Unit.

Actual  or  threatened  releases of hazardous substances  from this
Site, if not addressed by the selected remedy may present a current
or potential threat to public health, welfare, or the environment.

DESCRIPTION OF ALTERNATIVES

At the time the focused RI/FS was submitted to EPA, the suggested
remedial alternative options went through a screening process where
they were evaluated.  These included the following alternatives: no
action;    in-situ    vitrification;    on-site    solidification/
stabilization;   surface  pavement;   excavation   with   off-site
landfilling; and excavation with off-site incineration.  Based on
initial    screening,     in-situ    vitrification,     on-site
stabilization/solidification   and   excavation   with   off-site
landfilling were not considered to be viable remedial alternatives
for  this  operable unit  and were  not  considered for  detailed
analysis.

Considering the magnitude of the risk to human health presented by
the Site,  it was  critical  for the  focused RI/FS  to result in the
selection  of  a  remedial  alternative  that  could  be  readily
implemented; thereby,  alleviating the  current risks  to  on-site
workers, visitors, and nearby residents.   Given the risk scenario
at the  Curcio  Scrap Metal,  Inc.  Site,  it would be  imprudent to
select  a remedial alternative that would require  many months of
additional  Site characterization,  treatability  and pilot  scale
studies  to  determine  the  viability  of the  remedy.    Further
rationale for screening out these alternatives is presented below.

In-situ vitrification:

In-situ  vitrification is  a thermal treatment  process by  which
contaminated soil  is  converted into chemically  inert  and stable
glass and crystalline  materials.  On-site application requires the
insertion  of  large electrodes into contaminated  soil  containing
significant levels of  silicate material and the generation of heat
(up to 6,500 °F) by passing electric current through the electrodes.
Because  dry soils are  not electrically conductive,  a layer of
flaked graphite and glass  frit is  placed between the electrodes;
this  transfers the electrical energy  and acts  as a  starter to
increase the temperature of the soil and waste material.  At this
temperature, any soil  or rock components of the waste material will
melt  (the  melting temperature of soil  is  2,000  °F to 2,500  °F),
organic compounds will  be pyrolyzed  in the  glass matrix,  and the
metallic materials will either fuse or  vaporize.   Any gases or
vapors produced can be collected by placing a hood above the entire
Site.   After the process  is  terminated  and the ground has been


                               12

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cooled, the fused waste material will be dispersed in a chemically
inert and crystalline form.

The  unproven  nature of  this  technology would  require extensive
testing and pilot scale studies.   The capital cost  for In-situ
Vitrification  is approximately $1,670,000  and it would require
approximately fifteen months to implement after the remedial design
has been completed.   To date, no Superfund site has been treated by
this technology in the field.

The vitrification process requires specialized equipment and highly
trained personnel.  This  technology also has the potential to cause
contaminants to migrate to  the  outside boundaries of the treatment
area instead of to the surface for collection.

The  implementation   of  this  process  would result  in the  waste
remaining in  place  in the form of  a  solid, glassy matrix.   The
vitrification  process  would not  allow for use  of  the  land for
residential purposes in the future.  In addition, the small size of
the usable land available on this Property precludes the use of the
large  machines  and numerous   instruments  required  in order  to
implement this  process.  These limitations make this alternative
impractical in dealing  with  the  principal  threats  in  a  timely
manner.

On-site Solidification/Stabilization:

Solidification techniques eliminate the free liquid,  increase the
bearing strength and produce a  monolithic solid product.  Chemical
interactions  do not generally occur  between the wastes and the
solidifying agents,  but the waste  is mechanically bound within the
solidified matrix in such a way that the release rate of hazardous
substances is decreased upon exposure to air, water, soil, or mild
acidic conditions.  This process has been widely used in low-level
radioactive waste disposals.   Application  to hazardous wastes is
becoming more common and many vendors are studying and developing
processes  that   are  directly applicable  to  hazardous   waste
contaminated soil and sludges.

Various   solidification/stabilization   techniques  involve   the
addition of reagents such as pozzolan-portland cement and lime fly-
ash   pozzolan.      Processes   of    this   technique   include
microencapsulation  and  sorption.   The  pozzolan-portland process
uses  portland   cement   and  pozzolan   materials   to  produce  a
structurally stronger waste/concrete composite.  The lime-fly ash
pozzolan process  uses  a  finely divided,  noncrystalline silica in
fly  ash  and  the  calcium  in  lime  to  produce  low  strength
cementation.  The microencapsulation process involves blending fine
particulate waste  with  melted asphalt.    The sorption  process
involves adding a solid to  soak up any  liquid which may be present.
The major use of sorption  is to  eliminate  free-liquid.   Typical
forms of sorbents are:  clays, zeolites, anhydrous sodium silicate,

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and  various forms of  gypsum.    Prior  to implementation  of this
process, lengthy testing and pilot scale studies would have to be
performed.   The  capital  cost  for  the On-site  Solidification/
Stabilization  process  is  approximately  $900,000  and it  would
require approximately eleven months to implement after the remedial
design has been completed.

This treatment  methodology is not  a proven technology  for soil
contaminated with high levels of PCBs, such as the East Lot soil.
Many of the additives used in the solidification process may  not be
effective in immobilizing organic contaminants such as PCBs.   In
addition,  the  small size  of  the usable  land available  on this
Property precludes the use of  the large machinery and variety of
instruments required in  order to implement this  process.   These
limitations make this alternative impractical in dealing with the
principal threats in a timely manner.

Excavation with Off-Site Disposal at a Landfill:

This treatment alternative calls for the  excavation of the soil,
transportation and disposal to an appropriate landfill.  The soil
is considered to be a mixed waste due to the presence of both PCBs
and heavy metals.  RCRA regulates the management of hazardous waste
and  the  Toxics and  Substances  Control Act  (TSCA)  regulates  the
management of PCBs.    Under TSCA regulations  (40  CFR 761.60  (a)
(4)) , soil contaminated with PCBs at concentrations greater than or
equal to 50 ppm can be incinerated, treated by an equivalent method
or disposed of  in a RCRA/TSCA regulated landfill.  RCRA regulations
include land disposal restrictions (LDRs) for non-liquid hazardous
waste that  contains  total halogenated  organic compounds (HOCs),
including PCBs, at  concentrations  greater than 1,000  ppm.   HOCs
subject to the LDRs  are  listed  in 40 CFR Part 268, Appendix III.
Hazardous wastes containing HOCs in total concentrations greater
than or equal to 1,000 ppm must be incinerated in accordance with
existing RCRA regulations.  The  capital cost for Excavation with
Off-Site Disposal at a Landfill  is approximately $1,650,000  and it
would require approximately eight months to implement.

PCBs have been detected in East Lot soil at levels above 1,000 ppm.
Furthermore, the high levels of lead detected renders the soil "RCRA
characteristic uaste, based on TCLP testing.   Based on these two
findings, RCRA LDR regulations apply, therefore, disposal of this
soil, without appropriate treatment, in a landfill is restricted.

The two viable  alternatives  for the remediation  of the Property
were evaluated in the focused  RI/FS  for dealing with soil which is
heavily  contaminated  with PCBs and   other   contaminants.    In
addition,  the  No   Action  alternative  was   evaluated.     The
alternatives for  the  soil  in and  around the  East Lot  are  the
following:
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Alternatives;

       1: No Action
       2: Surface Pavement
       3: Excavation with Off-Site Incineration

Alternative 1;  NO ACTION

Superfund regulations  require  that the No Action  alternative be
evaluated at  every  site to establish a baseline  for comparison.
Under  this   alternative,   deed   restrictions  prohibiting  soil
excavation and the construction of buildings would be instituted.
Furthermore, this would preclude any further scrap metal operations
at the Property.  There is no capital cost associated with the No
Action alternative.  This alternative would not achieve the cleanup
level  of Site  soil to 1  ppm PCBs,  nor would   it  effectively
remediate inorganic contamination to acceptable levels.

Alternative 2;  SURFACE PAVEMENT

This alternative  involves the  placement of a reinforced concrete
pad  over the East Lot soil (approximately  10,900  square feet).
Under this alternative, deed restrictions prohibiting activities
that would damage the  integrity of the  surface  pavement would be
placed on the Property.   For example, soil excavation  and  the
future construction of buildings  would not  be  allowed.   Routine
inspection  and   repairs   would  be  performed  as  maintenance
activities.  The capital cost for Surface  Paving is approximately
$232,000 and it would take approximately three and a half months to
implement.  Although the contaminated soil would  be covered,  the
waste would not be contained.  This alternative does not involve
the treatment  of  the  contaminated soil,  therefore,  it  would  not
attain the accepted cleanup  level for PCBs  of 1 ppm  as is stated in
the EPA  Guidance  on  Remedial  Action at Superfund  Sites With  PCB
Contamination,   nor    would  it   effectively  remediate   metal
contamination to acceptable  concentrations according to NJDEP Soil
Action Levels.

Alternative 3;  EXCAVATION WITH OFF-SITE INCINERATION

This alternative involves excavation of the contaminated East Let
soil  (approximately  1,800  yd3  -  see  Figure  7),  followed  by
transportation to an off-site RCRA/TSCA permitted incinerator for
treatment and disposal. Confirmatory sampling will  be performed at
the  boundaries  of the excavation  in  order  to ensure  that  the
cleanup level of 1 ppm PCBs is met.  The actual volume of soil to
be excavated will be based upon an action  level of 1 ppm for PCBs
in unsaturated soil  and may  be  further refined during the Remedial
Design/Remedial Action phase.  The excavation would  also remove all
soil contaminated with metals detected above  the NJDEP Soil Action
Levels.  Due to the presence and concentration of PCBs in the soil,


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incineration facilities may require that the soil be drummed prior
to incineration.   Thus,  the excavated  soil would  be placed into
drums, on-site, and transported to a RCRA/TSCA incinerator facility
for remediation.  The capital cost associated with this alternative
is approximately  $7,500,000 and  it would take  an estimated eight
months to implement.  The off-site shipment of hazardous substances
to a treatment, storage or disposal facility would be subject to
EPA's policy  for  off-site management of  Superfund wastes (i.e.,
Revised Procedures for Planning and Implementing Off-Site Response
Actions, November 13,  1987,  as updated).  After  excavation,  the
East Lot would be backfilled and graded with clean soil.

The process  of incinerating hazardous  wastes  involves oxidizing
chemical  compounds at  high temperatures and  reducing them  to
innocuous substances such as carbon dioxide,  water, and inorganic
ash.  Wastes  to be incinerated are investigated  for suitability
prior to treatment.   Several factors affect the suitability of a
waste.    These factors  include  BTU content,  viscosity,  water
content, metal content,  halogen content,  and  ash content.   For
complete combustion of the waste, temperatures in the incinerator
may range from 700 °F to 2,000 °F.   Technology has proven that PCBs
are  effectively  destroyed  in  high  temperature  incinerators.
Residue metals will be contained in the incinerator ash, which is
properly treated and disposed.  Incinerators are equipped with wet
scrubbers or bag  houses to control particulate emissions such as
sulfur dioxide.  For halogenated wastes,  air pollution devices are
installed to control inorganic acid emissions to the atmosphere.

SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

In  accordance with  the  National   Oil  and Hazardous  Substances
Pollution Contingency Plan (NCP), a detailed analysis was performed
on the three proposed remedial alternatives with respect to each of
the nine evaluating criteria.   The criteria are:

*.  Overall Protection of Human Health and the  Environment;   This
   criterion 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;   This criterion addresses whether or not
   a remedy  will  meet all  of  the applicable  or  relevant  and
   appropriate  requirements   (ARARs)    of  Federal   and   State
   environmental  statutes  (other   than  CERCLA)  and/or  provide
   grounds for invoking a waiver.

   There are  three types  of  ARARs:    action-specific,  chemical
   specific,  and  location-specific.   Action-specific  ARARs  are
   technology  or  activity-specific  requirements  or limitations
   related to various activities.
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   Chemical-specific  ARARs are  usually  numerical  values  which
   establish the amount or concentrations of a chemical that may be
   found in, or discharged to, the ambient environment.

   Location-specific requirements are restrictions  placed on the
   concentrations  of  hazardous   substances   or  the  conduct  of
   activities solely because they occur in a special location.

±  Long-term Effectiveness and Permanence;  This criterion 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 cleanup levels have been met.

±  Reduction  of Toxicity.  Mobility  or Volume;   This  criterion
   addresses the degree  to which a remedy utilizes treatment to
   reduce the toxicity, mobility,  or volume of contaminants at the
   site.

±  Short-Term Effectiveness;  This criterion  refers  to the time in
   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;    Implementability  is  the  technical  and
   administrative   feasibility   of   a   remedy,   including   the
   availability of materials and services needed to implement the
   selected alternative.

±  Cost;  Cost includes capital and operation  and maintenance  (O&M)
   costs.

i.  State Acceptance;   This  criterion  indicates whether,  based on
   its review of the Focused RI/FS and the  Proposed Plan, the State
   concurs  with,  opposes,  or has  no comment  on  the  preferred
   alternative.

i.  Commun ity  Acceptance;    This  criterion  evaluates,  based  on
   comments received,  the reaction of the public  to the remedial
   alternatives  and EPA's  Proposed  Plan.   Responses to public
   comments are addressed in the Responsiveness Summary section of
   this Record of Decision.

The following section summarizes  and  compares the performance of
the  three  remedial  alternatives against   the  nine  evaluating
criteria which  apply to remedial action.

1: OVERALL PROTECTION  OF HUMAN HEALTH AND THE ENVIRONMENT: The No
Action alternative would not provide adequate protection of human
health.    Current   risk  posed  by  the Site far   exceeds  EPA's
acceptable  risk range of  10"4 to 10"6.   Although Alternative 2:


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Surface Pavement, will reduce the potential for direct contact, it
is not considered to  be  protective  of the environment since soil
would continue to act  as a source of  ground water contamination and
surface water  migration  would continue to occur.   This  is not a
permanent remedy,  since  contaminants would remain  untreated on-
site.  Alternative 3,  Excavation with Off-Site  Incineration, is the
alternative  that is  most protective  of public  health  and the
environment.   This alternative  involves  the removal of all waste
with  contamination  above cleanup levels from  the  East  Lot for
permanent treatment.

2: COMPLIANCE  WITH ARABS:    The  No-Action and  Surface  Pavement
alternatives would not meet  ARARs.   Upgrading the  cap design to
conform with a RCRA approved  multi-layer  design surface cover used
for hazardous waste landfills would not completely eliminate this
concern,  since  a  bottom  liner  would  not  be  installed.    The
Excavation with  Off-Site  Incineration alternative would meet the
applicable or relevant and appropriate requirements  of Federal and
State environmental laws.

RCRA regulates the management of hazardous waste and  TSCA regulates
the management of  PCBs.   RCRA  regulations include  land disposal
restrictions  (LDRs)  for  non-liquid hazardous waste that contain
total  halogenated organic  compounds  (HOCs),  including  PCBs  at
concentrations greater than  1,000 ppm.   HOCs  subject to the LDRs
are  listed  in 40  CFR Part  268,  Appendix III.   The  final rule
specifies  that   hazardous   wastes  containing   HOCs   in  total
concentrations  greater  than  or equal   to   1,000  ppm  must  be
incinerated  in accordance with existing  RCRA regulations.   TSCA
regulates PCBs at concentrations of  50 ppm or greater.  Under TSCA
regulations (40 CFR 761.60 (a) (4)),  soil contaminated with PCBs at
concentrations greater than  or equal to 50 ppm can be incinerated,
treated by an equivalent  method or disposed of in a  chemical waste
landfill.  When TCLP was  performed on the soil at the Site, it was
determined to be a RCRA characteristic waste due  to the presence of
lead.  Therefore, since the soil contains PCBs at a concentration
over 1,00.0 ppm and is a  RCRA characteristic waste  (based on TCLP
testing  results),  the  soil  is subject  to  LDRs  and cannot  be
disposed  of  in  a  landfill  without  appropriate treatment.   The
Excavation with Off-Site  Incineration alternative  is >.n accordance
with the proposed (July 1990) RCRA Subpart S rule.   The NJDEP Soil
Action Levels  are regarded as "to be considered" (TBC) criteria.
Alternative 3  is the  only alternative that meets the  NJDEP Soil
Action  Levels,  and  is  in  compliance with  both  TSCA  and  RCRA
regulations.

Action-Specific ARARs  are technology or activity based requirements
related  to  the  specific  activities  being   considered   for the
remediation process.   The following Federal ARAR that applies to
the capping aspects of Alternative 2; under RCRA  Subtitle  C (40 CFR
264.310(a))  requires  the design  and  construction parameters for
placement of a cap.  The cap would provide long-term minimization

                                18

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of migration of liquids from the Property and have a permeability
of  less  than or  equal  to the  permeability  of the  bottom liner
system or natural subsoil present.  The cap proposed in Alternative
2 does not  comply with RCRA regulations  and does not  attain the
NJDEP Soil Action Levels for metals.

In  Alternative  3,  Excavation  with  Off-Site  Incineration,  the
incinerator facility is RCRA/TSCA permitted, therefore, it will be
in  compliance  with ARARs.    Alternative 3   also  requires  the
transportation of the drummed contaminated soil to a RCRA permitted
incinerator facility.   The Hazardous Materials Transportation Act
(HMTA) (49 CFR Part 173) sets requirements for the transportation
of hazardous materials.

3:  LONG-TERM   EFFECTIVENESS   AND  PERMANENCE:  The   No  Action
alternative would not provide  a permanent or effective remedy.
Surface  Paving may not be  effective in the long  term.    This
alternative would rely heavily  upon maintenance activities  and
institutional  controls  regarding future  use  of  the Property to
ensure its  effectiveness.   In addition,  contaminated  soil would
continue  to  act  as  a  source  of  ground  water  contamination.
Therefore,  Surface  Paving  is  not  a permanent  remedy.    The
Excavation  with Off-Site  Incineration Alternative  is  the  only
alternative with demonstrated long-term effectiveness.   Since the
PCB contaminants are  destroyed and  the  metal contaminants  are
treated, the Excavation with Off-Site Incineration alternative also
attains the greatest degree of permanence.

4: REDUCTION OF TOXICITY, MOBILITY OR VOLUME:   Both the No Action
and Surface Pavement  alternatives  do not  utilize  treatment to
provide  a  reduction in the toxicity,  mobility or volume  of the
contaminants in soil on and around  the East  Lot.  Excavation with
Off-Site  Incineration  will  attain  the  greatest  reduction  of
toxicity, mobility and volume of hazardous  constituents because the
quantity of hazardous substances would be significantly destroyed
or treated  during incineration.   A  significant reduction  in the
toxicity, mobility and volume  of the PCBs  will be achieved through
the incineration process.  As a result of the incineration process,
the metal contaminants, which  may  remain  in  the  incinerator ash,
will be solidified, thereby reducing the mobility and toxicity of
these contaminants.

5:  SHORT-TERM  EFFECTIVENESS:    Since  it  involves no  protective
measures, the  No Action alternative would not create additional
short-term risks.   However, this alternative  leaves  current Site
risk unabated.  The short-term risks associated  with the Surface
Pavement alternative involve the potential exposure to vapors and
fugitive dust emissions during surface grading activities.  There
is an increased risk of short-term exposure during implementation
of  the  Off-Site  Incineration  Alternative,   since  it  involves
excavation of  contaminated  soil.   Engineering controls,  such as
periodically wetting  the  ground  surface with  water,   would be

                                19

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implemented in order to mitigate the release of contaminants into
the air through fugitive dust.  These control technologies are used
to  contain the  existing area  of  contamination  and to  prevent
further dispersion of the contamination  from  the  source.   An air
monitoring program would monitor for volatile organic emissions and
respirable dust emissions.    Since  the  implementation  of  proper
health and safety procedures would be followed, the potential for
such risk would be minimized.

6:  IMPLEMENTABILITY:   To implement the  Surface Pavement  or the
Excavation with Off-Site  Incineration options,  the Site would have
to cease operation for a  period of time sufficient to successfully
implement  either  remedial action.   The  surface  pavement  option
entails the use of machinery to  place reinforced  concrete  in the
center of the  East Lot where the working crane is located.  This
option does not require extensive use of machinery.  Approximately
thirteen  weeks  are  needed  to   implement   this   alternative.
Excavation with Off-Site  Incineration requires detailed planning
and execution.   It will consist of excavating the soil, drumming it
on-site, packing  the drums  on  trucks and  transportation  to the
incinerator  facility.    While not  difficult  to  implement,  this
alternative  requires  coordination  amongst  the  personnel  and
operators of the machinery.   Approximately eight months is needed
to implement this alternative.

7: COST:  The No Action alternative is the least costly, but most
detrimental  to human health and  the  environment.    The  cost
associated with the No Action alternative is zero because a fence
currently surrounds  the  Property.   In addition,  no  ground water
monitoring  will  be  performed  as  part  of this  operable unit,
therefore,   this  monitoring  cost  is not  included.     The costs
associated  with  the  Surface Pavement  alternative  are for  the
concrete and liners to be placed on top of the  soil.  The operation
and  maintenance  cost for  this  alternative   is  a  conservative
estimate providing that the concrete cap will be inspected yearly
and a written report submitted.  The yearly review,  over a period
of ten years,  is  to  inspect  for  cracks or any other damage which
would be detrimental  to the  integrity of  the cap.  In addition, as
part of the daily  activities of the operating scrap metal yardf> the
owners would be responsible  to report, to local authorities and/or
NJDEP, any structural damage which might  befall the cap. The costs
associated with the  incineration process  take into  account the
excavation,  drumming  and transportation  of  the drums   to  the
incinerating facility. Since the contaminated soil will  be removed
from  the  East  Lot,  no  long-term  operation  and  maintenance
activities  need  be   performed.     The   estimated  costs   of  the
alternatives are shown in the Cost Chart Table below:
                                20

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                         COST CHART TABLE
Alternative
No Action
Surface Pavement
Excavation with Off-
Site Incineration
Capital
Cost
($)
0
232,000
7,500,000
Operation &
Maintenance
($)
0
1,500
0
Present
Worth Value
($)
0
242,000
7,500,000
8:  STATE ACCEPTANCE:   The  State  of New  Jersey, Department  of
Environmental  Protection,  concurs with  EPA's selected  remedial
alternative.

9: COMMUNITY ACCEPTANCE:  Based on the comments received during the
public  comment  period,  the community  accepts  Alternative  3,
Excavation with Off-Site Incineration, as a remedial action.

SUMMARY OF THE SELECTED ALTERNATIVE:                .......

The combination of PCBs and high metal contamination, particularly
lead, pose  a formidable  situation.   Based on the results  of the
focused  RI/FS report,  and  after  careful  consideration of  all
reasonable alternatives,  EPA  selects Alternative 3; Excavation with
Off-Site Incineration as the preferred choice for addressing soil
contamination at the  Site.  Approximately 1,800 yd3 of  soil with PCB
concentrations  greater  than 1  ppm  will  be  remediated.    This
alternative provides the best balance among the alternatives with
respect  to  the   criteria  that  EPA   uses  to  evaluate  remedial
alternatives.   The following section provides a  summary  of the
evaluation   of  each  alternative   against   the  Comprehensive
Environmental Response, Compensation, and Liability Act criteria.

In order to  ensure the complete  removal  of PCB contaminated soil
over the 1 ppm cleanup  level  (as seen in  Figure  7)  the soil will be
excavated  to a depth  of,  at least,   six feet from  the  existing
surface in two thirds of  the  Lot, and the remaining portion of the
soil will  be excavated to approximately two feet.  Confirmatory
sampling will be conducted  to ensure  that all soil  containing PCBs
above 1 ppm and metals  above  the NJDEP action levels  are removed.

PCB  contamination   coupled   with   heavy   metal  contamination,
especially lead,  presents  limited remediation  technologies which
would  be applicable.   After  detailed  evaluation,  it  has been
determined that the excavation and incineration of soil down to the
water table  will  effectively clean up the  PCB  contamination to 1
ppm and remediate the various metal contaminants on the Property.
This  action  addresses  the principal  threats  posed   by  the
                                21

-------
contaminants in soils on and around the East Lot.

In summary, Alternative 3, Excavation with Off-Site Incineration,
would achieve substantial risk  reduction  through the removal and
treatment  of  soil contaminated with PCBs above 1 ppm  and metal
contamination above  acceptable  levels.    This reduction would be
permanent  since the  PCBs  would  be destroyed through incineration
and the  inorganic contamination  would  be contained  and treated
properly in the  incinerator ash.   This process  also attains the
most significant reduction in toxicity, mobility  and volume.  This
alternative attains  ARARs.   Alternative 3 is believed to provide
the  best  balance among  the alternatives  with  respect  to  the
evaluation criteria.  Based  on  the information  available at this
time, EPA believes the selected alternative will be protective of
human health and  the environment,  comply  with ARARs, and utilize
treatment  and   permanent   solutions   to  the   maximum  extent
practicable.

STATUTORY DETERMINATIONSI

Under  its legal  authorities,  EPA's primary responsibility  at
Superfund  sites   is  to  undertake  remedial  actions  that achieve
adequate  protection of  human health  and the  environment.   In
addition,  Section 121 of  CERCLA,  as amended, establishes several
other statutory requirements and preferences.  These specify that,
when complete, the selected remedial action for a site must comply
with applicable or relevant and appropriate environmental standards
established under Federal and State environmental  laws unless a
statutory waiver  is  justified.  The selected remedy must also be
cost  effective  and  utilize  permanent  solutions  and alternative
treatment technologies to the maximum extent practicable.  Finally,
the  statute  includes  a preference for remedies  that  employ
treatment which permanently and significantly reduces the volume,
toxicity, or mobility of  hazardous substances as their principal
element.    The following sections  discuss  how the selected remedy
meets these statutory requirements.

Protection of Human Health and the Environment

The  selected  remedy,  Excavation  with  Off-Site  Incineration,
provides for  protection of  human health  and the  environment by
removing the contaminated soil.   The soil will then be treated to
effectively destroy or treat hazardous constituents.

Compliance with Applicable or Relevant and  Appropriate Requirements

Alternative 3, Excavation with Off-Site  Incineration,  meets the
applicable or relevant and appropriate requirements of Federal and
State environmental  laws.   It complies  with RCRA regulations for
the treatment of HOCs, TSCA regulations for the management of PCB
soil, and with RCRA requirements.


                                22

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Cost Effectiveness

The selected remedy is cost effective since it has been determined
to provide the greatest overall effectiveness in reducing the risk
to human health and the environment in both the long term and short
term.   It is the  only  alternative  that will attain  the cleanup
levels  deemed  by EPA to  be protective of  human health  and the
environment.

Utilization of  Permanent  Solutions  and  Alternative  Treatment for
resource recovery) Technologies to the Maximum Extent Practicable

Alternative 3,  Excavation with Off-Site Incineration, represents
the  maximum extent  to  which permanent solutions and  treatment
technologies  can  be  utilized in  a  cost-effective   manner  with
respect  to the  principal threats  posed  by  the soil.   Of the
remedial action alternatives evaluated, EPA has determined that the
selected alternative provides the best  balance  in terms of long-
term effectiveness and permanence, reduction in toxicity, mobility,
and volume  achieved  through treatment,  short-term effectiveness,
implementability  and cost, and  considering  State and  community
acceptance.

Preference for Treatment as a Principal Element

The statutory preference  for treatment  as a  principal element is
satisfied in the selected remedy.

Documentation of Significant Changes

During the public comment period, the Saddle Brook Planning Board
expressed concern that the area where the Property is located  is in
the process of  being rezoned.   The area  is to  be rezoned from a
light industrial area to a residential/townhouse area.  In light of
this fact, EPA has decided to remediate to  a more stringent cleanup
level of  1 ppm, rather than the cleanup level  discussed  in the
Proposed Plan of 10 ppm.  A 1 ppm level  is  more protective of human
health  and the  environment in  a  residential  use  area.    This
modification of  cleanup  levels will not  significantly  alter the
volume of soil to be remediated.

Detailed analysis based on information received during the public
comment  period,  has determined  that the capital cost estimate
stated in the Proposed Plan was approximately 25% too low.  EPA has
revised its cost estimate of the capital cost associated with the
selected  remedial alternative.   The  cost  associated with the
Excavation with Off-Site  Incineration  alternative has increased
from approximately $6,000,000 to approximately $7,500,000.
                                23

-------
Since EPA  has  modified the cleanup  level  to 1 ppm PCBs,  due to
rezoning of the Property for residential use,  the cap identified in
the Proposed Plan will no longer be part of the selected remedial
alternative.  The cap is not necessary for this alternative to be
protective of human health and the environment under a residential
use scenario  with such protective  cleanup levels.   However,  if
commercial/industrial operations resume at the Property after the
selected remedial alternative is implemented, it may require that
preventative  measures be  implemented  in  order  to protect  the
remediated  soil  from any  possible  future releases of hazardous
substances from any business operations at the Property.
                                24

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FIGURES

-------
SITE LOCATION
              CUSCIO SCRAP METAL INC. SITE
                SADDLESnOCK, NEW JEHSEY
                SITE LOCATION  MAP.
               zoco
                        SCiLE

                         0
2SSC'  _
                POOR CfflM-VN

-------
                   PROPERTY
 C'JSCIO SC=A? METAL INC. S!T£
  SAOOLE5ROOK, NEW JESSEY
VICINITY OF  CSM1  SITE
       FIGURE 2
ORIGINAL

-------
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-------
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-------
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-------
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-------
TABLES

-------
Compound
                                                                    TA1»T,K I


                                                                        HIVRRTinATinil
                                                            cuncio ncnAp  MICTAI, inc.  BITE


                                                             Pen's /  Pesticides - Soli
Damp I a  I.I).

AROCI.OR-1242
AROr;i.nil- 124(1
AROCI.OR-1254
AROCI.OR-1260
mi- 1
(0-0)
2.1
nn
nn
nn
on- 2
(0-2)
22
nn
4.7
nn
nn-2
(2-fi)
2.0
nn
Ml)
nn
nn-4
(2-4)
nn
nn'
3.2
nn
sn-5
(0-2)
nn
nn
0.23
nn
fill- 5
(4-B)
nn
nn
nn
nn ;
on- B
(0-2)
nn
im
nn
i.r,
r.n-7
(0-2)
nn
. nn
nn
no
so n
(0-2)
n.s
nn
nn
.i.n
nn n
(4-r.)
4.fl
nn
nn
4.2
 IIOTE:
        All concenlrnllons reported In mn/Ug.  (ppm).


        J - Compound  rlel.ermlned l-o be pfeaent  at an nntlmnbeil value less l.lian  the  minimum ilnl.ecLlon .limit.


        llo peatlclilnB were found to he praoent above detection limits  In nny of  the  monitoring wells.
      o
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       -H
       -<

-------
                                                                    TABLE 1

                                                               IIKIIPIDIAI, IHVEfJTIOATIOH
                                                                 10 HCIIAP HETAI,  1 110.  HITR


                                                                rn / Pesticides -  Doll
                                                                                                                        Pnpn ?.
Compound
Snmplo  l.D.

AltOCl.Oll-1242
Anoi;i,oii-mn
Anoni.on-i254
Annchon-i2no
sn-o
(0-2)
2.1
HP
4.B
Ml) '
Hii-n
M-fi)
MO
Ml)
Ml)
Ml)
nn-io
(0-2)
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Ml)
4.0 .1
Ml)
Mil- II
(0-2)
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Ml)
Ml)
Ml)
Gil- II
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0..1I
Ml)
0.04.1 J
Hl»
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(0-2)
no
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22
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(4-n)
2.1
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0.4.1 'J
Ml)
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140
MD
4.1 J
Ml)
!W- 14
(0-2)
440
HP
1GO ,1
Ml)
r.ii H
(4-0)
2 no
Ml)
MO ,1
HP
 MOTE!
        All conceriLral.lona reported  In mn/ha,  (ppm).


        J - Compound  ilotormlnod bo be prnnont al. an oal.lmoted  vnluo lens than l.lie minimum clotecl.lon limit.


        Mo pQBtlcltlas Mere round l.o  1)4 present nhova deteollon limits hi mix of the monitoring wnlln.
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Compound
                                                               TABLE 1
                                                        CllltCin fiCRAI1 IIGTAIi IIIC. r,ITE


                                                         PC'll's / l>«.nU aides - Soli
Sample 1,1).

AHOCI.QII-
Anoci.on-
AROCLOK-
Aiioci,on-

1242
1240
1254
1260
011-15
(0-2)
000
nn
350 J
III)
nn- 15
(2-4)
1300
HO
200
HI)
mi-in
(G-0)
5.6
tin
1.2
nn
Bfl-17
(0-2)
4100
nn
3150
nn
WM-UI
(0-2)
61
III)
19
Ml)
nn-in
(4-6)
30
ND
0.0
HO ..'
Hii- in
(0-21
4500
IIP
1700
III)
r.n-19
(?.-4)
2400
tin
000
nn
Sll 21 •
(0-2)
4.7
nn
7.0
nn
nn 21
(34)
7.5
nn
5.f>
nn
  IIOTE:
        All cancenlrallon.i reported In  ma/kg,  (ppm).

        .)  - Compound 
-------
                                                                  TABLE 1
                                                             HKIIKWAI, IHVK.r.THlATIOH

                                                           CHUCK) KCHAP III5TAI, lilt,'.  fllTR
                                                            PCn'n / Pnatlcldes - Boll
                                                                                                                   I'np,* 4
Compound
Bfttnple l.|).

Anoci,on-

1242
AROC'l,On-l24n
AROChOll-
Aitnchon-
1254
I2RO
(0-2)
29
HD
HD
42 .
J5D-22
(4-G)
20
HD
ND
12
fJM-2.1
71
HD
. 33
HD
BII-24
(0-2)
120
III)
BO
HI)
811-26
(0-2)
04
HD
1.10
IIP
SI1-2B
(2-4)
16
HD
21
Ml) '
SH-27
(0-4)
2.100
HD
HI)
Hit
fill- 27
(4-fi)
4
HI)
HD
HI)
Rll- 20
(0-2)
44
HI)
0.0
HD
n-'K
24
HD
20
HI)
 IIOTF.:
        All  concentration1! reported In wn/l
-------
                                                                     TABLE  1




                                                                IIKNKPIAI,  IMVKJ3TIGATIOII





                                                              CHIICIO nCHAI' IIISTAI,  IMC. RITE



                                                               roll's / I'eslloldos  -  Goll
Compound
nample  I.D.

Anoo,.on-m2
Aiioci.nn.-i 24 n
AHOCI.On-1254
AIIOCI.On-1260
RII-2H
(6-7)
III)
IIP
. Ml)
MP
MOTE'.
All concentrntlons reported In
J ' Compound
Ho peatlclden
08
do to mil nod to be
worn found to bft

r,n-2!>
(0-2)
2.10
HP
no
IIP
mg/Un.
present
present

BII- 20 RII-. 10 yn-.io sn-.ii sn-.ii nn-32 sn-33
(2--I) (0-2) (2-K) (0-2) (
-------
Compound.
I.I).
                                                                     TAniE  1
                                                              cunoin r.cnAP HETAI, inc. GITE
                                                               PCII's /  PQ9l.lntilRH - Roll
6U-34
(4-0)
RU-37
(0-2)
BH-37
(4-0)
r.n-4o
(0-2)
sn-4o
(4-0)
Hii-42
(0-2)
fin- 4 3
(0-2)
80-43'
(4-ro
nn- 4 4
(0-2)
AROCI.nn-1242
Annci.nii-1240
Anoi:i.nn-i254
AHoci.on-i2no
nr>
HI)
.in
til)
nn
nn
0.15
nn
HI)
no
0.025
no
                          0.21       0.65
                             no        nn
                          0.15  .1     III)
                             III)        I . I
00
HI)
40
im •
1.2
HI)
2
no
HI)
III)
0.12 .1
III)
fr.O
HI)
a.n
HI)
  in >ri:;
        All concent, ml I OH a  raporl;ml In mn/Uri.  (ppm).
        J - Hompounil i.lotei-mliietl to do present at an oatlmoteil vnlno  loan  l.linn l:h« minimum elotectlon limit.
        Ho peatluldoi) wrire  found to be prenonl. above detection limits  In  any of tbe monltorlnn nellfl.
 oo

-------
                                                                TABLE 1


                                                           1IKMEDTAI,  INVERTtnATlOII



                                                         CURCIO SCRAP HETAI, INC. filTE


                                                          PCD's / Pesticides - Soil
                                                                                    Page 7
Compound
Hnmple I.D.

AnOCI,On-1242
AROcuiR-1240
Anoni,oR-i264
AROCI,OR-I260
MW-2
(0-41
tin
1.4
0.0
NO
MW-2
(0-n)
ND
HO
ND
NO
HW-3
(0-2)
7
HO
2.7
HO
HW-3
(2-4)
n
NO
3.0
ND
HW-3
(4-G)
12
NO
2.1
NO
HW-4
(0-2)
130
NO
31
NO. .
HW-4
(4-G)
. 23
NO
MO
24
 HOTE:
       All concentrations reported In mg/kR,  (ppm).


       J - Compound determined to ho present at an estimated vnlue lesa than tlie minimum detention limit.


       'No peatlolden were found to he prenent above detection limits In nny of the monitoring wella.
        -o
    08
     CDC

-------
                                                         TAIH.E 2
                                                            INVESHOAIION
                                                CUnUlO SCI'AP MtlAL  INC. SUE

                                                    VOC« IN  SOU. SAMPirS
                                                     JULY  • AUQUSI  1UII!)
CoMpound
Bai.iplo I.I).
Vinyl Chi 01- 1 till
Cli lorou thane
MuthylariB Uilorlda
lie* ton*
Carbon I) 1 aul f Ida
1, l-nichloro*t liana
I, l-IHchloroatlian*
1,2-Bichloroatltarialkotall
ChlorororM
2-butanc-na
1 , 2-1) 1 ch I or opropan*
Trlcliloroatlty l*n*
Banian*
4-Mothyl-2-P«ritariori«
2-11* Marion*
1,1, l-lrichloroathana
T*trachloro*tliyl*n*
Tolu*r>*
Cli 1 orotaen tan*
E I liy 1 li*rtz*n*
Btyrana
total Xylan**
BO-I
»O-B)
—
O. OO2 -J
0.014 B
—
__
—
O.005
— —
—
--
—
— —
—
— —
— _
—
__
— —
—
—
—
nn-2 Bi»-2
__ —
0. 1X14 .IB O.OO2 B
O. OI9 B O. O22 D
—
_ — —
—
O. O03 J
— _ — -
—
—
—
__ __
—
— — — —
_— _—
O. OOB --
— —
— — —
— —
__ —
~ —


0.
0.





o.


0.




0.

0.

o.
^£-4» ™-l
— —
003 Jl»
030 B 0. OSf,
—
— —

—
__ : 	
OO3 JB O. OO2
—
— _ —
OO7
—
-— — —
__ — _
—
0£3 B
__ — —
052
— —
820
BB-5
) «4-6
— —
O. OO6
B O. 1 IO
,|
i' —
—
O. OO3
_—
J 0. 013
—
O. OO3
O. OOUB
—
— —
— —
--
0. 002
— —
. —
—
— —
BB-6
— —
B
B 0. 007
—
—
—
J
_-
B
—
J
J

"•••
—
—
JB
— —
—
— —
™
BB-B
> (O-2)
—_
0. 003 B
B O. O24 B
—
—
—
O. 004 J
_—
O.004 JB
—
—
O.OO7
—
•*—
— —
O. O04 J
O.012 B
— —
O.OI4
O. OO6
0. O4 1
BB-B
(4-B)
— -
—
O. IOO B
O. OO3 J
--
—
o.oni
—
O. 022- B
—
—
O. OO3 J
O.OI4
•*••
—
O. 009
0.003 JB
— —
0.012
O.OO6
O. 069
.

6.
0.



0.

o.

0.
0.
0.


o.
o.

o.

0.
BB-9
IW-2
-—
O"6
O93
—
--
—
OO6
— —
014
—
002
OO3
047
•••"
— —
O07
OO9
— -
003
— —
010
1

B
B





B

J
J



J
B

J


 Not*«i
        (III conorilrat lon« reported In MO/MO I  pptn. •

        J  " Compound d*t*rMlriad to b* pr*«ent at  an BitlMatad  value  l«o« titan the MlnlMUM det*ctlon Hull.

        B  • Cohipound dutarkilnnd to b« proannt In  tha blanks  •• null  an  In tha
      -o
   08
   OD

-------
                                                           TA1W.K  2
                                                           (Coni'il)
                                                             INVHSIIUAHON
                                                CUMCIO SCIIAP MU1AL  INC. SHE

                                                    VOCt  IN SOIL SAMPLES
                                                     JULY  . AUGUST I'JIID
Compound ' f

•
Vinyl Clilor Ida
ChlcroalhariM
Methyl ana Chi or Id*
ncatona
Carbon UlaulMd*
1, l-UtcMoro*lheri*
1, l-Dlchloroathan*
1,2-Dlcltloroathar.altotal)
Chloroform
a-Butanona
1 , a-U 1 cli 1 oropropana
1 r 1 ch 1 oroatliy 1 *n*
Bantarm
4 -Mot hy 1 -B-f'ent anon*
a-llananona
1,1, 1- Vr luhloroathana
lutrachloroutliy lana
loluunu
CMorotianiana
Ethyl bant *ria
Bt yrana
lotal Xylanaa
laMplu I.It
Sll-9
14-61
—
__
O. O03 JO
0.009 Jb
—
__
—
~
--
— -
—
—
— —
• •«
__
--
— .
—
..*.
—
—
~

BD-IO
10-21
——
—-
O. OOD B
0. 830 B
O. O03 J
«*•»
••<•*
O. O03 J
—
—
—
—
o. ooa j
O. OS6
__
~
—
O. Oil
—
o. oao
—
O. O30

61)- II
«o-ai
—

—
--
—
— —
—
--
~
_- .
~
—
— —
•^™
'— —
1.4
—
«
—
—
-—
1.7

6D-II
J5-7I
__
__
0.005 JO
O. O46 D
—
— —
—
~
~
—
—
—
— —
O.OIB
— —
J
—
—
— —
—
—
J

Bit- 12
Ul-ifl
O. OlO J
_-
—
O. 200 B
O. OO6
—
—
o. aso
—
—
—
0.023
O. 0011
O. O57
— -
_..
o. a..
..^ •
— —
— —
— —
*••
--
O. 790 J
— —
——
—
"—
—
•
60-19
(o-ai
WM
__
— .
—
—
__
—
— —
__
~
—
O. 94O
••••
•—
••••
^ ••
7.4
0. 29O J
—
—
— f
— —
Notam*
           concentration* raportud  In MD/I
-------
                                                            TABLE 2
                                                             (CnnIM)
                                                              INVESTIGATION
                                                  CUnCIO SCIIAP  MUIAI. INC. SITE

                                                      VOCt IN SOIL  SAMPIHS
                                                       JULY  •  AUGUS1 I'JUP
CoMpound Bat«p 1 • I . D.
•
.
Vinyl Cli lor Ida
Chloroetharia
MathyloriB till or Ida
ncetona
Carbon Olmul flila
1, l-Olcli loro»thena
1, l-l)tchloroathana
l.a-DlchloroBthana (total 1
Chloroform
£-but ar«ona
1 , 3-D 1 ch 1 oi-opropana
Trlcl\loroa thy tana
banmna
4 -Mat hy 1 -2-Par.t anona
3-HaManona
1, 1, l-Trichloroathana
T«tr«ch loroothy lanu
1 o 1 uana
Ch 1 ornltanxana
Ethylliariiana '
Btyrana
Total XylanBB
BIJ-IS
«a-4i
__
--
—
— •
__
--
_ _
—
1.3
—
--
o. a40 J
-—
—
— —
~
2.6
— —
—
—
—
—
GB-17

~ — —
— —
—
0.9SO JD
—
—
—
—
—
—
— -
	 	
— —
—
—
__
O. 39O J
— —
—
o. a.io >
O. 3HO J
— —
61)- 1 H
 reported  in wg/l
       O " Compound datarwlnoil  to ba praaant  In tha btanlia a« Mall as  In tlia mampla.
     O
  00
  OO


-------
                                                             TAH1.K  2
                                                             (Conl'il)
                                                     	kl.  INVi;r,?IGAllON
                                                  CUHCIO  8CIIAP MLIAL  INC. SITE

                                                      VOCt  IN SOIL  SAMPirS
                                                       JULY • AUGUST HUH)
CoMpotind Samp IB 1.1).
Vinyl CM lor lila
Ch 1 oi'CB t hantt
Matliylana.Chlorlda
Heat on*
Carbon DlaulMda
1, l-Dlch toroathana
1, l-IHchloroathana
I.a-Olchl oroa than* (tot all
Chloroform
a-But anona
1 , a-n 1 ch 1 oropropana
T r 1 ch 1 oroa t liy 1 aria
Baniana
4-Mat hy 1 -8-f>ar»t anon*
2 -Ma M anona
1,1, l-Tr Ichloroathana
Tat rachl oroa thyl ana
Toluaria
Chlorobani ana
Ethyl bans ana
Btyrana
Total Xylanaa
KB-23
(0-ai
0.023 JB
O. 130 B
__
—
—
O. 049
__
O. O23 J
—
O. 070
O. OO3 J
—
— —
-_
O. 330
o.ote j
— —
o. oao j
—
0.039

-------
                                                             TABI.K 2
                                                              (Cnnfcl)
                                                      fU:MP.ntAI. INV
                                                  CUHCtO SCIIAI»  MUAI. INC. SHE
                                                      VOCs IN SOU. SAMIM P.S
Compound Bainplu
Vinyl Oh lor I do
Chloroatlianu
Mutt\ylanv Chloride
llcvtona
arbon UlsulMtla
, 1 -Uichloroe tliune
, I -Dlcl»loroetli»na
, 2-Dlchloroath«na (total 1
:iiloroform
2-But anona
1 , 2-I)lcli loropropane
1r tch lorouthy lunu
Bani^na
4-Mat Ity 1 -e-Por.t a none
2-lla>t*nor>»
1,1, 1-Tr icl>lorooth»riB
letrachloroatlty lana
ToluanB
Cli 1 orolianzana
Ktltylbanzanw
Btyriirin ,
Total Xylenea
1.1).
BB-29 Bli-.'JO
—
—
O.H.1O
0.009
—
—
o. 022
—
0. 03O
—
O. O32
0. O03
0.017
— -
—
O. 130
O. 014
—
0. OO9
O. OO7
O. O23
—
0. OOS JB
B O. 070 B
—
—
—
0. 006 J
— —
0. O06 J
—
O. O36
J
—
— —
—
O. ISO
—
__
—
—
--

SH-.KI
—
0.00*1 JB
O. O37 B
—
—
—
0.01 1
_—
O. OO2' J
—
0.009
—
—
— —
—
O. IOO
O. OO3 J
—
o. 002 j
—
O. OO9

BH-31
—
o.oos jn
O. OSO B
0. 003 J
—
—
0.330
—
O. O06 J
—
0. MO
3 J
—
—
—
O. 210
0. 006 J
—
—
—
O. OO7 J

BH-31
14-lil
—
o. oon ju
O. OcTU B
0. OO2 J
—
—
O. 022
— —
0. 005 J
—
O. O32
O. OOl J
—
—
—
O. 0311
O. OO2 J
—
—
O. OO 1 J
—

BD-32
—
O. OO4 JB
O. 13 B
—
—
—
0. 110
—
O. 003 J
—
O. 013
O. OOO9 J
— .
—
—
O. I«JO
O. O04 J
O. OO2 J
—
—
O. OO3 J


SB-33
O.04I J
—
O.O32
O. HOO
O.OIO
—
—
0.560
— —
0. 040
0.015
0. 2OO
O. OO7
— —
— —
— -
I. 1
0. 026
—
o. 000
—
0.017

B
B
J




J
J

J




J

J

J

60-34 80-34 BB-37
 <4-t» 
-------
                                                   TABLE 2
                                                   (Cniil'il)
                                                     INVESTIGATION
                                        CUHCIO  SCIIAP Ml£!AL INC. SITE

                                            VOCi  IN  SOIL  SAMPLES
                                             JULY  • AUGUS1 I'JO'J
Compound f
Vinyl Chi or Ida
Ch loroot liana
Hathylana Cltlorlda
ftcatona
Carbon Dlbulfida
1, 1-Olclil oronllinriB
1, 1-nichloroBthana
l,2-nichloronUtimB( total)
Jahip IB 1 .
BU-37
(4-61
—
O. OO7
O. 0 1 7
—
—
«
—
D.

611-40 BU-40 HM-42
(O-E» 14-6) (O-2I
— —
O. OO3 JU O.OI9
O. OI5
— —
—
— —
—
—
n o. 005 jn
0 O.OU7 JU
—
—
o. oon
0.012

(O-£>
—
' O. OM9 0
O. O.tb
--
.
—
—

BD-43 BB-l
(4-6)
— —
O. UO5 JD
o. oia J
— —
— ™
— —
— ~

BU-I
—
—
—
~
--
—
~
Chloroform
8-Butanon*
I,S-0IchIoropropana
T i* I cli I oroa t l»y 1 Bna
Beniano
4-M«tt»y I -a-Pant anona
2-llaManons
1,1, 1-Tr icliloronthar.a
latracliloroathylana
ToluanB
Clilorobaniana
EtUylbarizana
Btyrann
Total Xylenaa
0.007
                               O.O06   J
                               O. OI6
                               O. O44
55. O
                                                                sa.o
Noturn I
        All  concantrat Ions  report Bd In Mg/ltQ  tppm. )

        J  "  Coinpound Uetarinlried  to ba present  at  an eatlinatad value  IBBB  than the Minimum detection limit.

        B  •  Compound da tur Mined  to bo prusent  In  the blanlta as Mall  an  In the
           O
        OQ
            C-
            ?

-------
                                             TABLE 2
                                             (ConlM)
                                     REMEDIAL INVESTIGATION
                                  CUnCIO SCRAP  METAL INC.  SITE

                                      VOCt IN SOIL  SAMPLES
                                       JMLY- AUGUST  IQU'J
Compound
Sample 1. D.
Vinyl Chloride
ChloroethariB
Methyl ana Chloride
Mw-a
io-a»
0.003 JB
0. 067 B
MW-2
(b-B)
0.003 JB
O. O36 B
MW-3
(o-ai
0.0*7 B
MW-3
0.011 JB
MM- 3
<<•-&>
O.OIS B
MW-t
O. OOS JB
MM-'*
(4-6).
0.006 JB
O.OI9 B
       Dlaulride
l(t-Dlchloroathene
I,l-UlchloroBthana
t,2-UlchloroethBna(total)
Chloroform
2-Butanone
I,8-Uichloropropana
Trlchloroethytana
Bern ana
4-Mathy I -3-Pent anona
ti-llaxanonB
I, I, l-Trichloroethane
TBtrachloroethylene
Toluene
Clt loroliuntune
Etliy Ibaniunu
Utyrana
Total
   "O
   O
                           O.OO7  J  O.OO3  J
                           o.003  J  o.ooa  j
                                                          O. 006
                                                          o. ooa
                                O. O67
                                                                              O. 03*
                                                    O. OIO
                                                    o. 002
o. too
                                               O. OO6
                                                O. 007
   0.009





J  O.003  J



   O. OI5-
   O. OOA  J

   O.OO4  J

   O.OIO
         II  concent rat ton» reported  in MO/I•-%  f~\ J « Compound detenu Ined to be preaent  at  an estimated valuo leaa than the Minimum detection  lim

 ^P_ t— B • Compound determined to be present  in the blanUa aa woll a3 in tho
 7>>

-------
                                        TAUI.K '.I
                                  ItFMIHMAt. INVISIIOAIION
                               CUnCIO SCIIAI' Ml: (At. ING. Sill:

                               SL'MIVOI AMLI-S IN SOU UAMI'LtS
                                    JULY •  AUQUSI Itlll'J
Coiiipounil 1 1
l>hii not
baniyl alcohol
1 , 4-lllcli lorohuniunu
1 , 3-Olcit laroliarnitriu
1, iMuthy Iphunol
daniolc aciil
2, 4-l)lchlorophanal
1,2, 4-1 r ii.-liloi-obaniBriB
Naphthalanu
S-MB thy 1 naphtha 1 er.o
2, 4, 5-Tf Ichloi-ophunol
2-ChIoronaphtha limit
Dlmathylphthalata
Hcanaphtliy luna
rtcanaphtliunu
1)1 tiansof tiran
Diathy Iplithalata
Ft cur ana
N-NI tronoill plieny 1 amlnu Cll
pant ach 1 oropliano 1
Ptumant hrunii
flnthracana
IM-n-l»ity 1 plillial at H
f loiiranthunit
PyruriB
t«uly lliBr.i y Iphhtal at a
buruolal anthracuna
niiryscne
lilt 12-Elhy Ilionyl 1 phthalata
1)1 -n-c/cly 1 plil ha la I u
liunio 1 1»> f 1 our*nthune
liamolli ) f 1 ouranthuna
banio < a ) pyrenn
InUunol 1,2, 3-cd> pyrer.B
Ditaansota, hi anthracana
Daniolg, h, 1 1 pary leno
BaMpla
1.1)
.

HU-l Sll-2
tO-6> (0-21
— .
—
—
—
--
—
—
—
—
—
—
—
__
0.22
—
—
. o. 32
0.32
O. Ollll
o. ia
0. 19
3. S
O. O94
0. 3 1
O. 19
0.2
0. 12
—
0. 13













J


J

J
J
J

J
.1
J
J
J

J
O. tiOD
—
O. Ol
—
—
—
—
—
—
—
—
—
— —
0. O27
O. 007
O. OSII
O. 062
0. 1 1
O. O36
—
O. O.I.1
O. 77
—
O. O44
O. O53
O. O42
O.O1O
—
--
J

J










J
.1
.1
.1
J
J

J


J
.1
J
J



811-2
—
O. OO5 .1
—
—
_.' —
—
—
—
—
—
—
—
——
— —
—
—
0.019 J
—
— —
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                                                    TA1H.K 3
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                                                         TAIII.K 3
                                                          (Cncil'il)
                                                   HI:MI:I)IAI.  INVIir.MGAllON
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                                               TAlH.r. 3
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                                                 INVHSIIOAIION
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                                          TAIU.K :i
                                          (Cnnl'il)
                                            INVIiSIIGAflON
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—
Ifi B
O. 7'J
4.S 1)
3.2 H
4.b 1)
1.4
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1.6
(O-2I
0.31 J ,«
—
• —
—
—
—
—
—
— —
0.3 J
—
6. 7
1
O. 72 .1
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O. 34 J
O.9
—
—
O. «J2
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7. 1 b
1.9 b
2. 2 b
(.. b b
(i . 6 b
\.a \t
7. fi b
6 b
r>'.\ b
O. 29 .1
4.1 b
O. 32 Jb
2. 3 B
2
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(4-61
0.54 J
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2.3
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—
—
. —
—
— —
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1.7
1.3
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1.2
O. 21
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1 1
3. 7
1. 4
1 1
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ii
130
2. 7
1 1
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J

J



J

J
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li
b
JB
b
b
b
b
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BB-33
(0-4}
0.44 J
—
2.6 J
--
—
— —
—
—
• —
.' . -—
—
0.95 .1
0. 7.1 J
0.74 J
—
*•—
--
—
0. !17 .1
o. 39 j
—
0.73
—
—
a. 3
xl.3 J
l. 3 JB
9.2
12
I..I J
4.S J
4.11
26 B
1 J
5.11
O. (Ill J
4. 1 J
—
— -
—
BB-33
IO-4I
—
1.5 J
—
—
— —
—
—
— —
— —
— •
0.73 .1
0.711 J
0.71 J
— —
••—
— —
0. 16 J
0.61 J
— —
—
0.92 J
—
—
a. 3 J
1.4 J
1. 1 JB
U. 9
1 1
120
—
4 J
1C. 1)
0.61 .1
2.11 J
3. 9 J
3. I J
0.31 J
—
O. 34 J
BB-34
(O-H>
0.73 J
—
2.5 J
--
3.6 .t
— —
—
0. 13 J
—
0.06 J
—
--
0.01 J
0.90 J
— —
~~
--
0.34 J
1. 1 J
0.66 J
—
1 J
—
—
4.7
1.5 J
7
6.6
9.7
7.2
3.9 .1
4.6
2(1 B
&.6 J
10
1.2 J
4.6
1. 1 J
_—
—
BB-34 i
(4-6)
0. II J
—
—
—
—
— —
0. 12 J
—
—
0.33 J
—
— •
4.4
a. a
--
— —
—
2. a
3. I
4. 1
—
5.9
—
— •
14
—
0.33 J
12
16
0.27 J
B. a
6. 1
4.9 B
O. IS J
n. 4
e. 1
a. 7
0.79
0.^3
O. 63
R QUALITY
R1GINAL

-------
                                                          TA1H.E  3
                                                            (Cnnl'it)
                                                              INVESTIGATION
                                                CUnCIO SCIIAP METAL  INC. SUE

                                                SEMIVOI ATILES IN  SOU. SAMITES
Compoundi
                              Sample  I. I).
Phenol
benzyl alcohol
1 , 4-l)lchlorubunzanu
I , J-l) Icli I oroliuriiunu
I , 2-IHch loroliuntuna
E-M«thy I iilumol
4-Mulhy I phunol
I Kopliorunu
ti, 4-l)lntuthy I phanol
btinxoic  acid
2, 4-Dichlt>roph«nol
1,2, 4-TrichioroUuruana
(Japhtha I ana
£-Mathy I naphtha 1 ana
a, 4, 5-Tr Ichloraiihanol
2 -r>hlcroriaphtha luna
hi Methyl plitlialata
flcuriapli t hy I aria
lie ur>4 plil hit nu
III Imniof u ran
Illuthylpltthalala
f I onmri«
N HI Irouoiliphuny I aidlne
t'anl achlorophuriol
I'liurianthruna
ftrttliracana
Ili-n-liutylphthalata
F louranthuna
I'yruriB
 but y I hur.iy I phht a I at a
 Uunio(a) anthracuna
                         ( 1 )
 1MB (cJ-Elhy Ihany I ) phthalata
 hi -ri-octyl phthal alu
 liurixolh) rtouranthuna
 Uunzoltil f I ouranlhuna
 llunio I a > pyrunu
 Inilunot I , if, J-uill pyrune
 l> tlivnxola, h) anthracuna
 Uanxo ( U< l>i It pai-y I una
                                 8H-.17
                                  10-2)
                                            BI1-.17
                                            ft-6)
                                                                 UB-'iO
                                                                             BS-I
                                                                            (O-2I
                                                                                       Ui-2)
                                                                                                 (A-61
                                                               O.O't2  J
                                                               O. OS/  J
                                                                            7. 6 J
                                                                             at
                                                                             at
                                                                             34
                               O.
                                o.oia jo  o.uis  JB
                                O.U2B J
O. OO9
U. (159
O.ulll
O. Ol<(

 O. O5
 u. ?y
 («. (i i
t'l. Ob 9
u. OulJ
O. 0.17
 O. OJ
.18
JO
Jit
Jit

.ID
It
JV
J
JO
J
J
                                             O. 4 8
                                o. 0:12 j
                                                      O. 12  .!
                                                                0.04(1 J
                                                                               a  .1
                                                                                      O. IS J
                                                                                               O.030  J
            POOR QUALITY
                ORIGINAL
                                                                                 60-1
                                                                                                                      6. 7 J
                                                                                 19
                                                                                 U7
O. OBI
O. 13
O. OS7
—
O. 25
O..5&
—
0. 1 4
O. 17
1. £
—
O. IS
O. O97
O. Iti
O. lii
J
J
J

.in
.10

j
JO
u

j
.in
j
j
0.01
o. ooo
O. OI4
o. la
O. O£B
—
o. it
o. 1:5
—
O. 07
O. OO3
1. 4
O. Ol 1
O. O 7
O. 049
O. Otiti
0. O44
J
•
J
J
J
J

JU
JO

J
.in
u
JU
j
.in
j
j
1. U
g. s
17
4. 3
a. 4
in
Hi
5.6
l>. .1
fc. 1
J4
1
y. ;>
o. y;i
4. 1.
fe. 3
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n
u
.in
j
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O. 30
O.OII
O.iiM
0. tifi
O. £9
O. 113
__
O. 49
4.4
O. rti
0. «J(1
__
o. 4 a
0. 17
J
J
JU
JU
JU
JU

.III
u
J
J

J
J
O.OI3
. 0. 056
0. p 1.1
O.O.I
0. 1 1
O. 13
O. O36
O. O7H
O. O'J7
O. 4U
—
o. «ir>n
0. 0 1 4
0. O75
o. o.m
JO
j
j
.in
.IB
JU
JU
.1
.IB
U

J
JD
.1
J
13
—
7
12
— -
— .
1 1
ISO
—
1 1
—
7. 1
—-
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JO
JU


jn
u

j

j

3. 8 J
33
7.9 JO
—
7.S JO
__
-„
£.6 jn
^u u
—
--
6.3 jr»
—
— —

-------
           TAm.P. 3
            (Cnnl'il)
             INVESTIGATION
cunnio SCIIAP  METAL INC.
SCMIVOt.ATII.CS IN SOIL SAMPLES
     JULY  -  AUGUSUMU
CwMpourul i
Phunol
Uiinzyl alcohol
1 , 4-Dicli loroliunzona
1 , 3-l)icliloi-cliuriiunu
1 , if-Ulchloraliunzuna
2-Muthy 1 pliwnol
4-MuthyipliBnol
IsophororiB
2, 4-UlMttthylphttnol
liurizolc acid
2, 4-1)1 ch lorophunol
1,3, 4-TrichlorolianieriB
Naphtha 1 ana
H -Ha iliy 1 naphtha 1 ana
S, 4, 5-1 rich lorophunol
2-i:h loronaphtha 1 ana
Hhiuthy 1 phi ha 1 atu
Icunapht hy 1 «r.»
tcunaphthenu
Illiuniof tiran
HuthylphthalatB
1 our «r, o
rill t ronotl 1 phony 1 amlnu III
unt ach 1 oroplititiol
hunanthrana
nttiracenu
i -n-huty 1 phthal at B
lourantltunit
'runa
it y 1 beniy 1 pltht a 1 ata
iniolal anthracwna
rybane
• IH-EthylhiiMyll phthal at o
-fi-octy 1 phthal at M
nib 111) f lotiranthunB
MO (U> f lour ant huriu
iio(a) pyrunu
!• not 1 , &, 3-ctll pyranB
lanxo la, hi anthracuna
«o(Q,Vi, llparylnriB
6 amp In
I.I).
MW-3
10-41
0. O49 J
—
O. 05
O. 03
—
—
O. 0 1 5
o. oun
0. 1 1
O. it'll
—
0. It
—
— —
0. B|
0. SI
O. 411
1.5
0.52
—
O. 64
0. Ii7
2.6
—
o. sa
—
O. Ii7
—
— -
—

J
J


JU
J
J
J

J


B
jn
JU
u
B

D
It
U

D

U



»
mi
MM-2
C6-U)
™
--
™
—
—
0. 1 1 JD
— —
—
—
—
— —
—
— —
O.OIt JB
—
O.OI3 JD
O. Ol JU
—
—
—
—
O. .j'j D
—
—
— —
•
•- «»
f**"
—

MW-.T
JO-21
—
O. 38 J
0.41 J
—
—
—
—
—
—
—
O. 13 J
—
-—
O.50
—
—
0.36 J
£.3
—
O. 37 J
O. 49
4.5
—
0.47
O. 46
O. 4 J
O. 33 J
—
o. en

MM-:I
0. 15 J
O. 17 J
O.2I J
O. £2 J
—
— —
—
— —
0. 12 J
—
—
0. 13 J
—
— —
1. t
O. £4 J
—
1.2
1. 7
—
o. yn
i
4. y
—
O. 77
— .
1. 4
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12-6)
T — ,
o.oia .1
O.OI7 J
U. O2 4 J
—
—
— —
— .
— —
—
—
—
—
—
O. 034 J
—
—
O. O46 J
1.1. 1 / J
—
—
O. 046 J
O. Uli
--
ft. O«HI
O.Ubl
O.O/I
—
—
—

O. 13
4.S
U
4. 1
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—
— —
— —
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0.36
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5. 1
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O. 41
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n
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14-61
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t. 1
3
1.7
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— —
— —
O. 3
1.2
0.79
—
t.a
—
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7.6
.,,1.7
1.7
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I.U
3.4
3.9
44
O. 61J
2.6
' O. 43
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1.6
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J
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J
J
J

J
.1
J
.1
J

J

-------
                                                      TATU.E 3
                                                       (Coiifd)
                                                REMEDIAL INVKSTIGATION
                                            CUOCIO SCOAP  METAL  INC. SITE

                                            SCMIVOI.ATILCS IN  SOU. SAMI'I.IES
                                                 JULY •  AUOUS1  limit
Noteoi

       nil  concentrations raportarl In inn/l  dry weluht  (ppial.

       J -  Compound  ilotorhiinud to ho present  at an BEtltiiatotl value IBBB titan the iiilnlmutii detection limit

       D -  CoMpound  datarralriBd to be proaont  In the blanlie  »m wall aa In tha
               were  analyzed at varying dilution factors. Concentrations aro reportod  for tha lowast  dilution factori
              idvntiflBd  with a "•".
        POOR QUALITY  *
           ORIGINAL

-------
    •u
08
CDC
                                                                            TAIir.F.  A
                                                                    IIEMEDIAI. INVIfSIIOAMON
                                                                 CtlllCIO  SCIIAP  MF.rAl.  INC. SITE

                                                           INORGANIC CONSTITUENTS  IN  SOU.  SAMPLES
                                                                      .llll.Y  -  AlKiUST  IJIMS!
                                     Sainpl e  I.I).

Ill ui.il nuiii
(Int ihic.ny
Mi Bum t:
liar i u MI
liucy 1 1 1 DM
:ailifli uiii
la Ic i MM
:iiroi.ii MM
:ohal t
lopper
1 ron
I.eail
Miilirttial u i.i
Haniiariu&u
Mercury
Nicliel
pot ass 1 11 w
!iu 1 erii mil
Hi 1 vtir
Hoil i uiii
Hid 1 1 i Hill
Vctnjjil i uiii
/ i in:
Cyitr.l ilii
fliur.ol (total)
KB- 1
BB2O
:-i. £ ii
2. 1
ic?7
O. (IB B
3. 1
1 SOOO
4B. 3
9.£ B
257
S4IOO
2:50
6970
4 OH
1.3
47.5
Bll'i B
2 .
1 . .1 B
5H6 n
O. 1 II
24.9
iyso
n. 56 U
2.27
BIJ-2
12200
127
ti. 3
537
1. 1
1 1 . 5
331100
2IO
14.3
H99
345OO
I77d
B230
45 I
yino
9. 9 n
2. B
1 t^d
O. HI. II
(,. y
S4IOO
tili. 11
12. 3
e.oy
20 1 OO
704
1 4 1 OO
3O 4
3. 2
S.I. H
9 i.i 1 B
0. 1 1 11
3. 3
UI'J Ii
O. 1 1 U
30. y
1 OliO
O. HV 1 1
l.2ti
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9290
22. 7
7. 7
543
0. 72 »
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1 (i 1 On
ti2. B
1 4 . y '
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3.1200
4210
3'J'Jn
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14. 7
1 10
692 B
1 13
3. 4
4'*! B
O. 1 1 U
32
45 I"
n. till II
<•:. fall
8B-H
(O-2)
9.1BO
IB. 1
3.y
79. 1
O. ,TJ B
J
(14 40i.i
22
4.11 II
20 1 .
I47OO
I'JB
2.1.100
263 -
7.4
111. 3
1 4 1 O
1.5
0.52 II
742 B
O. 1 1 B
19.11
22G
O. f..i
1. l.'l
SIJ-S
I122O
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C.5. 6
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o. n/ n
Ko 1 0
14.11
4.y u
IE.
n 1 r.io
1 1. y
H9O B
45. B
O. 15
5.5 B
752 B
O. 1 1 II
O. 54 II
304 B
0. 1 1 U
III. 2
70. 7
0. Ii2 11
. 1 7 B
37
I5OH .
£.6
.1.112
Note I
       nil consent rat I oifiB repot-teil  In iitii/lir|i eli-y  viel||hk  Ippm).

       I) - Coiiipoiirul determined  to  tic present  in  tin? hl.Anlcs  »IH well at>  In  the

       II — CC'iiipoorul vias analyiuil  For but not  ili;etl,  concent rat I on II el eel  Is detection  level.

-------
                                                                        TAIM.K  '•
                                                                         (CllMl'd)
                                                                           INVItSHOATION
                                                             CHUCK) SCIIAP  MI-IAI., IMC. Sill:

                                                       INC MOANK:  COM!;|||1)|-|.||S  IN  !!0|l.  SAMI'IT.S
C:,,.,,,c,.,r,d
H 1 'llill niliil
lint i i.ior.y
fli'Buni t:
lu>ri MM
hury 1 1 1 MM
IcUll.li MM
'. a Ic i mil
Jtt'OM 1 Mill •
;ol»i. 1 1
IO|lpk?r
1 rdfl
Lead •
Ma(|nos 1 um
Han||iirietin
Murcury
hlicUul
T'ot ass i MM
!iu 1 erii MM
H i 1 vur.
Boel i IIM
Illdl 1 (Mill
Vanail i VIM
Z Inc
f'yani lie
l-liunol (lot all

KB- IS
<£-
7£7O
36. 11
II. 11
35 '/
0. 14 I)
4O. 4
ivyaoo
ISO
la. 4
6R3
' safi-oo
1 6OO
3SUOO
576
III. S
131
nia B
3.6
3.3
9oa B
0. 1 1 U
£6. '»
1 1'>4O
£. S
a. lii

SB- III
< 4 - It >
7S30
3!i. 6
(.. II
'ml.
O.i Hi U
14.4
1 HHOi'i
373
la. M
1 4 HO
64300
1710
51 in
49£
13. 1!
a/a
73O B
1.2
7. 5
1 1 HO
O. 1 II
££
3540
3. :;
a. va

SB- 1 9
(O-£l
7!i. 4 I
17. /
i>H5
O. O/ II
35. 1
aaaoo
4 4 4
3«i. II
t &OO
aiiiooo
43£O
soao
1 £9O
a/, a
457
7O5 B
a. 4
ia
1 39O
i.i. 1 4 B
3£. 4
7oao
4. £
11.4

*•» l*( — i *'|
( ^J — /| J
£/. 11
1 1 . £
1191
O. Ill B
III
4 4 Soil
i n:;
ai
551 •
9330O
59 7 O
7/30
637
a. i
£33
(UK B
i. a
6
093 B
O. I.I b
30. £
' 27 IO
1. 3
4 . !53

SB-3 1

1 O9OO
1 (i. 4
4 . 1 .
Ili5
O. £7 B
II. S
43500
37. 4
IU.6
££9O
8O30O
536
1 5£OO
3113
4.6
311. 5
I03O B
£. 3
1.6 B
f-H£ B
O. 1 1 U
£(i. 1
1 0 /O
O.59 tl
fi. 59

nii-a i
6 7 SO
53. 7
r,.r.
3/7
O.O7 U
us. a
3OI1OO
1119
5. 4 B
1 350
4 1 9HO
1310
H7(iO
443
£. £
6I:.. 7
fc£ll B
0. 911 B
5
407 B
o. aa B
aa. i
£O5O
0. 77
7. 911

BB-aa
44. 4
i a. 9
1 4 2O
1.5
4£. 5
£1400
£77
£5. 9
1 57O
1 3 7OOO
4960
7540
937
£1.11
a4a
1110 D
a. 7
9.9
1 990
0. 1 1 U
7£.6
S550O
4. a
4. Illi

7 £60
l£
9. t.
3IIII
«:i. / 1
££.5
HiniKi
133
15. £
7/1(1
47400
l3E.li
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4O6
11. b
1 4£
Ii59
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9. tt
7£3
O. 1 1
110. 7
£090
3. 1
£. 39


B


B











B
d

B
U




   —rt     Not ei
    O
00
 oo
nil  concont rat long  reported In hii|/lti|,  ilry  welt]ht  (ppiii).

B -  Compound ileturnilrted  to be present in  the lilanliu au well  as In the  sample.

II -  Compound was  analyzed for but  not detected,  r:oni;eritrat Ion listed  la detection level.

-------
Compound
                                                             TAIH.K /i
                                                              (CoiilM)
                                                      nt:MrniAi  INVESTIGATION
                                                   CUnCIO  SCHAI* MlilAI. INC.  Sill:

                                             INORGANIC COMS1IMII-MTS  IN SOU  SAMPI HS
                                                        ,mt Y :.AUGUST., twin
                        tJampti: I.I).


Ol tun! ruiiii
(Inl inicny
Hi-mini i:
l«««r i MM
I'ury 1 1 1 IIM
Cadiui IIM
Cdluint.i
Chronii IIM
Cobalt
r.opper
1 ron
l.uad
Mdl|neB|lllil
Mariijaneuu
Mareiiry
Michel
I'Ol rtfatil Mill
!iu 1 ern MM
li i 1 vur
Hod t IIM
Ilia 1 1 i'li.i
Vanadium
/ i nu
Cyanide
I'hunc.l (total)
HU-23
(0-2)
1 1 2OO
79. 2
2O. 2
1710
0. Oli II
11. I
26i'.OO
IfcU
17.3
1 IbO
1 OSOOO
III17O
759O
751
166
fell
in no
i. i
II. 7
1/eo
O. 1 3 U
3II. £
6 I I 0
3.9
6. l»5
W.-21
(0-2>
1 22OO
I I O
23. (I
161
. 0. 07 U
13. 9
i ayoo
BIS
3B. 1
1 2SO
2 1 SOOO
1 1 300
S31O
1 H&O
13.0
393
635 B
O. 12 B
7.6
nan B
O. 1 1 11
36. 9
237O
1. U
1.5
ni»-25
(2-',)
915O
1 1 . fi
7.5
7 Oil
O.oy II
19. 9
S3I1OO
129
2O
26 1 OO
U11OO
3(130
(it, 10
73H
12.3
111
Io5o n
O. 03 B
1
1 1 so n
O. 12 II
37. li
372O
1.9
li. 6
HM-S7
(0--1I
5970
21. 1
5. 2
21 1
O. 13 IJ
17. B
39700
113. 3
12. 1 li
7O7
8030O
11(17
2 1 BOO
3111
10.2
MS. 3
1130 U
O. 2 U
22. 1
132 l<
0. 13 II
30. II
1 3110
1.5
B. ni
HD-S7
(1-f.>
R 1 Oi i
5. n ij
.1. 3
f.11. £
O. 2 U
O. 39 II
511 /O
19. 5
10.3 B
10. 1
1 5 1 OO
13. 3
291O
163
O. 23
1 1
52O U
O. 1 1 II
O. 61 li
2O1 B
0. 2 l'>
£.'5. 3
19II
O. &II II
3. IIV
HO-flll
(0-2)
I1700
I 53
21. y
2fcOM
0.07 U
17.1
I51OO
716
5 1 . II
1 93O
83SUOO
132O
BI15O
1 6HO
(ill. II
191
1 620
3. 5
I. 1
5fc6O
0. 1 1 II
f,3. 9
6630
B. 2
2. 12
HB-811
(3-51
1 1 2OO
5/.H
22. »
1 110
0. 07 U
115. 2
1O.10O
10/»
25.5
1 39O
• I7700O
(illiili
I 1 700
I&1O
7ll. I
673
H67 B
3 1. 1
1.M
1310
0. 1 1 II
71.9
7 1 2O
5.5
1.9IJ
!in-29
IO-2)
I195O
57. I
22. 9
656
O. Oli 1 1
3 I. 5
3O70O
211
30. II
I ifiO
I I IIOO<;i
I 630
1 6OOO
I O2O
I 9. 2
£30
919 B
&. 3
3. 7
2 1 00
0.22 I)
31.9
2170
1.2
3. 9 'i
BH-23
(2-11
1 3ROO
1 1 0
11. 7
2130
0.31 t)
61. 7
297OO
inn
10. II
1 5110
IB7OOO
6 1 61.1
1 19OO
1 1 no
21. 1
£90
1 b(10
1.3
3.9
43UU
O. 12 B
1 311
11700
2.9
1. 71
SM-30
(O-2J
97OO
511. /
16.11
1 920
O. 07 U
35. U
S 1 000
196
III. U
925
1 1 UOOO
51 1O
5510
ni:6
I 3
I 67
1 7 2O
I. 0
1.2
559O
0. 1 3 B
52. 5
6320
I. II
I I. 9
-a
O
O
  Mole i
         (III concnnt rat Ions  report ail  In iii||/lii|| dry  «ul||ht  (ppiii).

         0  - CoMpound ilateriiitncd to ba present  In  the li lands as well  as In tbc sample.

         U  - Compound was analyzed  for but not  detected,  concentration lintel)  io iletectlon level.

-------
               IJotii|ioiintl
                                                                              TAHI.K  l\
                                                                               (Cmil'il)
                                                                       nnMi-niAi. INVI;SIIO/UION
                                                                   CUPCIO SCIIAP  MI-IAl.  INC. SUE

                                                             INOMOANIO  cni-iniiTiirMir.  IN  son.  SAMTI.FS
                                                                         JULY • AtKuii'il_itiny
                                              i.D.


11 1 inn 1 ri< ii.i
Ont iiiiony
Ill-sen i i;
Bar i mil
beryl 1 1 >n,i
Cailiiii tiiii
Kalci ui.i
Uliroi.ii niii
Cc.l.dl I
(°.o|i|iur
1 ron
1 uatl
Mdl|IHIU 1 MM
Maniiariusi!
Murcury
NicUttl
potasa 1 mil
Beluni in,i
Bi Ivui-
Uod i IIM
Dial 1 iitiit
Vanadluhl
J i nc
Cyuniclu
Hiunol I tota 1 )
si:.-30
(2-li)
73 1 0
57.5
19.6
1 1 10
O. O6 II
17. 'i
•2 1 1 OO
33'i
31.1
1 02O
1 3OOOU
2770
5II7O
yo/
l'i. 7
£'|O
912 B
7.6
'1.6
1 5 1 U
O. 1 'i H
'|S» 7
27'iO
1. H
'i. 7'i
Bli-31
(0-21
H62O
1 I 1
31.9
1 6BO
0.07 U
1 5. 3
ttt'iOO
a 1 3
'lO. 9
t'l'.IO
2O.JOI.iO
393(111
. S3OO
12 'Hi
27. H
'toy
1 5MO
2.7
£2.5
3HOO
0. I I U
51.3
50 1 i.i
'i. £
6. VJ
fid-3 1
(4. -61
1 39OO
(III, •:)
31.5
i 69O
O.O7 II
£1.1
365OO
B££
'Hi. 'i
£1 'Hi
aiiHiou
'• ':)::.!!
1 05i 10
1 1 .30
22. (i
2'J5
lO'H.I l'i
'1.5
5
£35O
O.23 B
6O. 6
Gfcyo
3.2
6. 1)11
!il,-32
I 0 - <\ \
111 120
62
2'J. 5
1 'lOO
ii.il/ II
i 'i . y
1 fc'H II 1
654
36. /
£'H 10
232i i' HI
!-iii6o
Iv'l'lO
c: i : ,i i
311.6
;»yi
I3'i0
c'.2
5.5
337O
O. 12 II
(12. 7
'i 1 2O
2. 7
'i . 112
KB -.i:i
(O-'D
99 'i 0
91). 1
25
lO'iO
0. 13 lii
1 2. 1
2 l'i 00
I5MO
91). 2
1 990
2'i3"OO
3'iOO
7/00
III. Ill
22. 3
1 260
IO60 B
25. 1
12. 2
1 7'|0
O. 12 II
611. (1
311 1O
'i. 5
'i. 21
Hll-3'i
(M-2)
9 1 20
t,n
19
1 S90
O. 1 1 B
HO. 2
2 1 IIOO
353
H/
« /'JO
a 1 31 mo
yiioo
7"':IO
l.i'io
311. 7
'|3O
'J5£ B
1 U
2O. 5
£36O
O. 12 B
25. 2
7O'iO
3. 3
5. 16
SD-.Vi
«.-6)
G73O
6.3 11
1.5 li
A7. 5 B
O.22 H
O. 'i£ 1)
13 '10
In. 1
6. y B
IO. 3
61100
111.7
1)35 B
ny. 3
0. 31
6. 1 B
363 B
O. 35 l»
O. 37 U
176 B
O. 12 II
1.1.2 .
55.2
-
-
BB-37
di-2)
793O
7. (1 B
O. 35 b
37. 3 B
O. 06 B
0. 'i B
693(1
16.4
/.» B
1 1 1
1 H'Ji ii.i
107
6620
£30
O. I'J
Z.\. \
529 B
•s.
'o. 'i5 n
7119 B
0. 1 U
£4. 9
1 43
0.55 U
(o. a
BB-37
(',-61
47110
5. 7 II
O. 46 B
24.B B
0. 16 B
0. 3(1 II
579 B
7.6
5. 5 B
6.9
6920
4.1)
762 B
40. 6
O. Oil II
6. £ B
49R B
0. 1 1 II
0.51 II
133 B
0. 1 1 II
9.5 B
14.1)
0. 6 1 U
(O. 5
BB-'iO
(0-21
6/7O
5. 4 U
2.6
4?. 6
0, 2 B
O. 36 U
1 420
1 4
a. a B
S/.2
1 2i i' ".I
9.1. .1
1 <|5H
1 36
O. 1 '»
11.5
291 B
". 3 B
0. 4H U
235 B
0. 1 U
13. 1
B'l. 3
0. 57 11
0. 72
    O
00
 oo
                 Mot 01
nil  concent rat Ions  reportod In in||/lini  rtry  wuli|l>t  (ppm).

B —  rc.hipourifl iluteruil notl  to lie present In  the liKtrida a» vie I I  an I r>  the saiiiple.

II —  Hoiiipotiricl Has  analyzed for lint  not tlett-ct c.-il, concentration llsteil  I a ilctectlon leva).

-------
                                                          (Conl'il)
                                                          I.  INVESTIGATION
                                              CUnCIO SCRAP MP.IAI.  INC. SIT"

                                         INORGANIC  CONSTITUENTS  IN  SOIL  SAMPLES
                                                    JULY - AUGUST mil?)
                              Raiiipl t>  I. I).
BB-4O BIJ-42
<4-6>
Ml uiiii n'liii
flnt iinony
Ill-son tc
liar i uin
Bury) 1 1 MM
Cadiiii MM
t '.a lei vim
Chroiiii MM
Coba 1 t
Coppur
1 ron
Lead
hlai|neitl MM
Mantjanetiu
MercMry
NicUel
P'OtaSHl Mill
Belenium
(ill ver
Botl i MM
Dial 1 IIIM
Variadi MM
1 1 no
Cyanide
Phenol (total)
734O
5.9
£.3
5(1
O. 3
1. 1
1 HOO
£6.9
9. 1
35.6
I £3OO
03. £
. 953
B6. 7
O. 47
14. 3
£6O
0. 34
o. as
£09
0. 1 1
16. £
176
0. 64
I. OS

B


B
B


B



B



B
B
U
B
U


U

( O-£ 1
£05OO
43. a
11.3
632
O. O7 U
£0. 7
30700
349
£9. 1
1940
119000
£770
707O
B54
11.2
305
037 B
6.3
' 11.4
1 £ 1 0
0. 1 1 II
34.5
349O
£.3
3.79
BM-43
(O-£> '
I1S4O
6.3 II
3.5
1 17
O. £4 D
9. 6
6240
411. S
13.6
S430
1 36OO
1 1 40
£O9O
goa
4
53. £
450 B
15.3
3
366 D
0. 15 B
15. U
926
1.5
1.69
. J5B-43
BB-I
BD-l
(4-61
fill/0
5. II
£
6 1 . 5
O. SB
1. 1
1 4£0
17. 7
15. 4
££7
76/0
191
9117
ioa
O. 9£
l£
41 /
1. 1
O. 61
tMi
O. 1 1
IO. 9
I6£
O. 6
O. '3'»

II
It

li







1)



B
II
H
H
1.1
tt

I)

9H70
Ml. 7
&•:?. 3
674
0.65 »
35. 7
£O4OO
436
45. 4
I64O
153OOO
3O£0
64DO
1 ISO
SS.3
463
1 1 6O
6.3
16. 6
1060 It
0. 1 1 II
91.6
4 1 5O
3. £•
: 4.01
i gnoo
36. (1
6.6
3c?£
O. 95 »
17
£67OM
tSO
2£. 5
1)96
,711 OO
I£6O
I64UO
57(1
6. £
196
11)60 B
' ' ' 3
17.3
65O B
O.£l U
43
I4£0
1.5
4.72
08
OO
          Not a t
nil conbentrat lonn  reported  In iiiu-/l|fli llrV weli|ht (ppi.i).

B - HoMpoMnd doturmlned to bit present In tltn  hlanhu as noil  an In thn aaiiiple.
                                                                         *s
II - CoiiipoMnil viau analyzed  for bMt not detected,  concentration listed  la detection Invol,

-------
    O
oo
                 CoM|io>inil
                                                                                i.   iON
                                                          cunciu  liciiAi'  MI-IAI.  mo. sun


                                                    INORGANIC CONSTITIH-NTS  IN SOU.  SAMPLES
fiaiiiple  I.I).

n 1 'mi 1 nu M
(Iril iinony
HrBRni c
Har 1 MM
L«t?i-y 1 1 I mil
Cailmi ti in
('.a ICIMM
I'.lircMiii inn
Cc.lia 1 1
rop|ii-M-
1 ron
Lead
Maununl uui
l'lan||unu!>u
•Moroiry
Nlcliul
I'olnua i uni
130 1 Bill "III
HI 1 vtir
Bod 1 (iiii
VI III I 1 i Mill
V/anail i MM
I i nu
Cyan! ilu
(•hen.;. 1 (total >
MW-S
(U-'ll
6910
5. 6 0
3. 7
IO6
O. 34 13
1.5
9'ifiO
21.2
n B
fifl. 9
1 &3OO
1 4 1 0
434O
242
O. 75
19.9
521 D
O. 1 1 U
O.Sfl 13
2 4 ii 13
O.21 13
s-r. f. ;
S7O
O. 5U U
5. 6(i
MW-S
43BO
ti. 3
1. 7
4U. 1
O. 24
O. 35
nun
II. 2
13. 1
IO. 5
1 1 70O
K.6
I 3/O
123
O. Oli
S. 4
452
0. II
O. 4fl
143
O. 1 1
9. 7
21
O. H9
11.91

II
13

13
U
U







U
r<
I)
II
U
13
II
1)

U

Mil- 3
(O-2I
VBHi-i
7. 'i n
ii. i
327
O. 112 II
23. 1
1 119OO
(ill. 2
IS. 0
f.42O
3M9OO
1 1 110
4O4O
39!i
9. 1
74B
ti92 13
1.9 M
1.6 U
4S5 1)
O. 29 »
29. 7
433O
1
6. 311
MW-3
1 4 1 I'll!
£4. 3
9. 3
n/:.
1. 7
?&* y
235i>0
146
14.1
079
4 SHOO
979
77OO
491-j
IE.
95. B
IO5O B
O. 94 B
1. 7 B
1 3',id
O. 1 1 U
51
i yno
0. fcS
3. VI
MH-3
(4-fc)
10900
a. v u
4.6
106
1. 1 13
6. 4
1 23OO
•^-1« C
4 . h U
2(12
2 1 900
2OH
3 1 50
345
3.4
42.5
494 B
O. 32 H
1 . fi ' B
25tt 13
0.21 B
32.2
434
O. '.",':» U
2. IS
MH-4
(0-2)
niioo
95. 2
2li. 5
1 1160
O.O7 II
9. 0
1 2UOO
954
1ft. !5
£9(10
31 10(10
4 1 70
4 1 20
20SO
16.2
5(11
9'HI I)
2
24. 6
2240
O. 1 1 U
36. U
5/fAI
3. 1
2.9
MM-4
(4-61
I47OO
74.5
17.7
1127
O. 23
77.11
1 6 1 OO
1 07O
3 1 . 9
5560
1 73OOO
52IIO
6 4 2O
1 0 1 O
12. 3
2HO
9(19
2.2
13
075
O. 1 1
37. 3
7'i9O
2.9
5




n











B


B
U




                    M-..IC-I
                           fill  coneuntrat Ions  report eil  in Mi|/l*!l< (ii.i).



                           U  •• (*onipoimil iletoi-iitl neil  to (HI  pi-uuniiL  In tlin hlariliu  as noil  au  In tlm



                           II  — I'-oiiipOMtnl Hao analyznil for  but  not il(>liM:ti*il, i.-oncciritrat i on  li
-------
                                 TABLE 5
                                  ACTION LX7ZL3
                                            SOIL
Total P»trsl«ua Hydroc*rbcci  CTPHC)        100 pjrs,

Friority Pellu:t&ts>
  Acid Extri=t*U«i (AZ)                     —
  Bis* Ktutr&ii (BK)                       10 pya
  Ftsticidti                       ..        —
  DDT                                •    2-10 ppa
  Chlsrdasi                            -    1  p?a
  Pslychlcristtii Bip&tsyla C?CB)     '     1-3  ppa
  Veltsilt Critsici (VCx:)          ,         1  pj»
  Phtcol                                    •—
       d«                          •        12
  Fricrity Fcllytast K»t*li (PPX) i

    Ar.ti=cr.y                               10 pya
    Ars«-ie                                20 pps
    larius       •                         400 p?s
    Birylliua    .                           1 p?s
    C*dsiu=                                 3 ppc
    Chrcriur                              100 p?a
    Ce??tr                                170 p?a
    Litd                            250-1,000 ppa
    Kiekil                                100 p?a
    K«rsury                                 1 ppa
    Kolybtsdus                    .          1 p?a
    Stltsiua            '                    4 ppa
    (ilvir                                  3 ppa
    ThilUra                                5 pp%
    Vtn«iiu£                              100 ppa
    Zi&e                                  350
Folytyclic Arsiitic fiydreeartwsi (FAS)       10 ppa
    » Ptrti Fir XilUes
    » First Ftr Billion
    • Izcic«:ti So Cl«tau? Uvtl Prsrid.d  la K.J.A.C, 7(9-f .6

lit  actisa l«vilt  «r§  rifiriiwi  auebiti  vttd  ee  Idtstify  prtnoct  of
      istticn.    All c«tt=i2*tion  Idistifiid *t  « iit«  tbovi th§ tcties
       ihould  b«7t  heriicacal  «sd  Tirtietl  *zttnc 4alia«
-------
                                              TABLE   6

                                          REMEDIAL INVESTIGATION
                                     CURCO SCRAP METAL INC. SITE

                             TOXJCITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)
                                              JULY 1590
Constituent                        Sample I.D.

                                   COM?'       COMP1       LEACH.  REGULATORY
                                     fQ-21         tZ-U       ELANK     CRITERIA^
METALS:	

  Arsenic                                 _           _           —             5
  Barium                             O.ZS3         1.54           -           100
  Cadmium                           0.122        0.2S3           -             1
  Chromium                              -         0.04           -             5
  Lead                               1-37         10.6           -             5
  Mercury                                -           -           -           02.
  Selenium                               _           _           —             1
  Silver  .                       -.__-             5

PESTICIDES:
  gamma-SHC                           _           _           —
  EncTin                         '                    -           -
  Metf-.cxycr.icf                           _           _           -            10
  Tcxachene                             _           —           —           0.5

HERBICIDES;
  2,4-D                                 _           _           _            10
  Siivex (2,4.5-T?)                        -    .       -
Notes:
All c=ncent;a!ic.-.s reported in mcA (ppm).
-   - Not detected.
NA - Not anafyzed.
1  « Soil samples are composites cbtaned from the TWP tecab'cns,
    0 Co 2 ft and 2 to 4 ff
8  - Federal Rosier (E5 FR 11798) March 29. 1S90

-------
TABLE?
SURFACE SOILS
CONTAMINANTS OF CONCERN
SUBSTANCE
Amimonv
Arsenic
Barium
Cadmium
Chromium
Mercury
Nicksl
Zinc
Poiychiorir.ates Biphsayis (PCBs)
Benzsse
Teirzchiorotthene
PAHs (carc:nog:r.s)
Lead
MAXIMUM CONCENTRATION
mg/kg
127.0
55.6
2600.0
89.5
1*30.0
466.0
1260.0
25500.0
4500.0
3.0
lf.0
6.3
39300.0
TABLE 8
GROUNDWATER
CONTAMINANTS OF CONCERN
SUBSTANCE
Ami— ony
Arsenic
Bariu.T.
CacrrJu-
Chrorr.iu.-n
Mercury
Nicks!
Zinc
Sele.-Jum
Polychiorinatsd Bipheayls (PCBs)
Benzene
PCE
Vinyl CsJorice
Lead
MAXIMUM CONCENTR,\TION
ms/kg
O.iOS
0.0436
1J25
O.S19 i
0.269 !
0.007
0.237
1.438
0.004
0.008
0.005
0.032
0.160
0.872
TABLE 9
SEDIMENTS
CONTAMINANTS OF CONCERN
SUBSTANCE
Antimony
Arsenic
Barium
Cadmium
Chromium
Beryllium
MAXIMUM CONCENTR-^TION
mg/kg
27.9
5.6
110.0
3.1
35.9
1.1
N'idcei
Zinc
Polychlorinated Biphenyis (PCBs)
P.AHs (crcnozens)
-166.0
12.0
10.8 !

-------
                                                 TAWLE 10

                                        liDTPOSURE PATHWAY ANALYSTS
MEDIUM
Groundwater




Soil

*
Sediment
Mr
ROUTE
Ingestion

Inhalation
and
dermal contact
Ingestlon

Inhalation
Ingestton
Inhalation
RECEPTORS FREQU1TMCY OCCURnPNCE COMMENT
Residents
Visitors
Workers
Residents
Visitors
Workers
Residents
Visitors
Workers
Residents
Visitors
Workers
Residents
Visitors
Workers
Residents
Visitors
Workers
I
I
I
I
I
I
I
I
F
I
I
F
I
I
I
I
I
I
UN
UN
UN
UN
UN
UN
T,
I,
L
UN
T,
L
UN
UN
UN
UN
UN
L
The fjroundwater Is not currently
used Cor domestic or commercial
purposes. However there Is a
potential for its use In the future.


-
•

The primary site contaminants arc
metals, volatlles anrl PCRs.
Future studies are necessary to
complete the air pathway.
Limited opportunity for exposure to
sediments. Sediment contact unlikely.
Surface soil contamination Is
primarily "metals and pens.
Ii   Infrequent occurrence
F:   Frequent occurrence
Li   Likelihood of: exposure*
UN: Unlikely to  occur

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            TARLEJi
NON-CARCINOGENIC TOXICITY VALUES
CHEMICAL OF CONCERN
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CHROMIUM
NICKEL
ZINC
POLYCI ILORINATED
BIPHENYLS (PCBs)
PAIIs
MERCURY
BENZENE
TETR ACI ILOROETI IENE
LEAD
VINYL CHLORIDE
ORAL REFERENCE
DOSE (RfD)
(Mg/Kg D)
4.0 x KT1
1.0x10*
5.0 x 10*
NA
5.0 x 10^
1.0
2.0 x 10'2
2.0 x 10'1
NA
NA
3.0 x 10^
2.9 x 10 2
NA
NA
NA
INHALATION
REFERENCE
CONCENTRATION
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

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       TABLE 12
CANCER TOXICITY VALUES
CHEMICAL OF CONCERN
ARSENIC
BERYLLIUM
CADMIUM
CHROMIUM
NICKEL
POLYCHLORINATED
BIPMENYLS (PCBs) ,
PAMs
BENZENE
TETRACHLOROETHENE
LEAD
VINYL CHLORIDE
ORAL SLOPE FACTOR
(Mg/Kg D)-1
1.75
4.3
6.1
NA
NA
7.7
11.75
2.9 x 10 2
5.1 x 10 2
NA
1.9
INHALATION SLOPE
FACTOR
(Mg/Kg D)'1
NA
NA
NA
NA
NA
7.7 .
NA
2.9 x 10'2
5.1.x. 10*
NA
x 1.9

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                                         TABLE 13




                                   NON-CARCINOGENIC RISKS
Estimated Hazard Indices
EXPOSURE PATHWAY
GROUND
WATER
SOILS
Ingestion
Inhalation
Dermal
Contact
TOTAL
Tngestion
Inhalation
Dermal
Contact
TOTAL
Current Scenario
Adult Worker
—
-T-
	
	
1.07
—
—
1.07
Adolescent
Trespasser
—
—
—
—
0.4
—
—
0.4
Future Scenario
Child
Resident
81.6
—
.
81.6
—
—
—
's
Adult
Resident
57.14
—
—
57.14
.._
—
—
—

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                                           TABLE 14
                                    CARCINOGENIC RISKS
Cancer Risk Estimates
EXPOSURE PATHWAY
GROUND
WATER
SOILS
Ingestion
Inhalation
Dermal
Contact
TOTAL
Ingestion
Inhalation
Dermal
Contact
TOTAL
Current Scenario
Adult Worker
.
/ —
.__
.
5.0 x lO'2
*
—
5.0 x lO'2
i
Adolescent
Trespasser
•
—
—
—
3.0 x 10'2
—
—
3.0 x lO'2
Future Scenario
Child
Resident
2.0 x lO'2
1.0 x 10'3
2.0 x 10'7
2.0 x lO'2
...
—
's
—
Adult
Resident
1.0 x lO'2
2.0 x lO'3
1.0 x lO'5
1.0 x lO'2
—
—
—
—
 * Risks related to inhalation of soil dusts by site workers are potentially significant, but were not evaluated
  quantitatively.

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RESPONSIVENESS SUMMARY

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RESPONSIVENESS SUMMARY

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                      RESPONSIVENESS SUMMARY

                  CURCIO SCRAP METAL, INC. SITE

                         OPERABLE UNIT I
INTRODUCTION

This  Responsiveness Summary provides  a summary of  the public's
comments  and  concerns  and the U.S.  Environmental  Protection
Agency's (EPA's) responses to those comments regarding the Proposed
•Plan  for the  Curcio Scrap Metal, Inc. Site.  At the time of the
public comment period,  EPA had selected a preferred alternative for
controlling soil contamination at the Site.

EPA held  a public  comment  period from February 8,  1991 through
April 11, 1991 to provide interested parties with the opportunity
to  comment on the Proposed  Plan  and  other  documents in  the
Administrative Record  for the Curcio Scrap Metal, Inc. Site.  The
required comment period would have closed March  11, 1991; however,
at the request  of the  public,  EPA extended the comment period an
additional 35 days, to April 16, 1991.

EPA held a public  information  meeting to  present EPA's preferred
remedial alternative  for controlling  soil contamination at  the
Curcio Scrap Metal,  Inc. Site.   The meeting was  held  at the Saddle
Brook Free Public Library, Saddle Brook, New Jersey on February 21,
1991 at 7:00 pm.

Based on the oral comments received during  the public meeting, the
residents and town  council of Saddle Brook were responsive to the
Proposed Plan and  would support the preferred alternative  for
controlling soil contamination.   The  New Jersey  Department  of
Environmental  Protection (NJDEP) also concurs  with the selected
alternative.   No objections  to the  Proposed  Plan  or preferred
alternative were raised  at the public meeting.

This  section  of the Responsiveness  Summary is divided into the
following sections:

I.   RESPONSIVENESS  SUMMARY  OVERVIEW:    This  section  briefly
     describes   the  Site  background  and  preferred  remedial
     alternative for controlling soil contamination.

II.  BACKGROUND  ON  COMMUNITY  INVOLVEMENT  AND  CONCERNS:    This
     section  provides  the  history   of community   concerns  and
     interests regarding the Curcio Scrap Metal, Inc. Site.

III. COMPREHENSIVE  SUMMARY OF MAJOR QUESTIONS,  COMMENTS, CONCERNS
     AND RESPONSES:   This  section  summarizes  the  oral• comments
     received  by EPA  at the public  meeting  as well  as written

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     comments received during the public comment period, and EPA's
     responses.

I.   OVERVIEW

The Curcio Scrap Metal, Inc. Site (the Site) is located in Saddle
Brook, New Jersey.  The Site includes, but is not limited to, the
real property at 416 Lanza Avenue (the Property), approximately one
acre in  size.   The  two active scrap metal  recycling businesses
operating on the  Property  are  Curcio Scrap Metal  Inc. (CSMI) and
Cirello Iron and Steel Company (CISC).   The Property is surrounded
by residential homes and industrial complexes.

The  land was  used for  dairy farming  prior to  being used for
salvaging operations in the early 1950s. Initially, rags and paper
were  recycled;  later  aluminum  and copper  were  stored,  cut,
compacted,  and recycled  at the  Property.   Today,   scrap  iron,
copper,  aluminum, and  other  ferrous  and  nonferrous metal  are
collected and compacted at the Property.           /

The Site was discovered in October 1982, due to a citizen complaint
alleging noxious fumes coming from the Property.  NJDEP discovered
several transformers cut into pieces and pools of black oily fluid
directly  under  and  adjacent   to  the   transformers.     High
concentrations of polychlorinated biphenyls (PCBs) were detected in
the fluid.  In December 1982,  NJDEP  sampled two wells  located on a
nearby  resident's property  and  a  commercial lot adjoining the
Property.   Volatile  organic  compounds (VOCs),  total  petroleum
hydrocarbons (TPH) and PCBs were detected in the well water.

At NJDEP's request, EPA performed a  Preliminary Assessment (PA) in
April 1984,  and a Site inspection in September 1985.   Based on the
findings, the Site was placed on the National Priorities List  (NPL)
in July 1987.  EPA entered  into an Administrative Order on Consent
(AOC) with CSMI, SECO Corporation, and Consolidated Edison Company
of New York, Inc. to perform a Remedial Investigation/Feasibility
Study  (RI/FS)  on  May  27,  1988.    In  August  1989, during  RI/FS
activities,  a spill occurred at the  Site.  EPA issued  a Unilateral
Administrative Order  (UAO) in  December  1989 to  CSMI  and CISC to,
among other things, terminate any activities which may obstruct or
interfere with the RI  or result  in  further releases  of hazardous
substances into the environment.

Subsequent to the issuance of the UAO, a Focused FS for the soils
was completed and ground water data was analyzed.  EPA  released the
FS findings and presented  the  preferred remedy in EPA's Proposed
Plan on February  8,  1991.  This  marked the opening of the public
comment period on the Proposed Plan.  A public meeting to present
the Proposed Plan to the public and  address questions  and comments
was held on February 21, 1991.

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EPA's preferred alternative, specified  in  the Record of Decision
(ROD) as Alternative 3, involves excavation of contaminated soil,
followed by transportation to an off-site incinerator for treatment
and disposal.  The  excavated area  would be backfilled and graded
with clean soil.

A subsequent ROD will address other contamination, including ground
water treatment as  a separate operable unit.   By  establishing a
second operable unit, EPA  will be able to begin soil remediation on
an  expedited basis  at the  Site,  while  other contamination  is
further  characterized.   Additional  ground  water sampling  and
analysis  will  allow  EPA to  select the  most appropriate  and
effective treatment technology for the Site.


II.  BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

A public meeting was held on June 14,  1989,  at the  Saddle Brook
Free  Public  Library,   to  discuss  the scope of .'the  Remedial
Investigation/Feasibility  Study   (RI/FS)   workplan,   the  RI/FS
process,  and  respond   to  questions from local  officials  and
interested residents.

III. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS.  COMMENTS. CONCERNS.
     AND RESPONSES

This section summarizes verbal and written comments received during
the  public  comment period and   EPA's responses.    Section - A
summarizes verbal comments received  during the February 21, 1991
public meeting and EPA's responses.  Section B summarizes written
comments  received  during the public comment  period and  EPA's
responses.

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SECTION III A. SUMMARY OF VERBAL QUESTIONS AND RESPONSES

A public  meeting was held February 21, 1991  at the Saddle Brook
Public Library in Saddle Brook,  New  Jersey.    Following  a brief
introduction,  the  Remedial  Project   Manager,  Mary  Anne  Rosa,
presented  the Proposed  Plan and  preferred alternative  for  the
Curcio Scrap Metal,  Inc.  Site.    Comments  raised by  the public
following  Ms. Rosa's presentation are  categorized by  relevant
topics and presented  as follows:

Remedial Alternatives

Comment:  Citizens  asked  how long  it  will  take to  implement
Alternative 3  (excavation and off-site incineration).

EPA Response:  EPA estimates the total time to implement the plan
will take approximately 1 year.  The ROD for the soils on Site is
expected  to  be signed in May.   A four month period  of "special
notice moratorium" will  follow the signing  of the RpD to conduct
negotiations with the potentially responsible parties (PRPs).   At
that time, EPA staff will focus on entering  a  consent agreement
with the responsible parties.  The remedy will take approximately
8 months to implement.

Comment:  One  citizen asked if the cost for Site cleanup would be
greater than $6 million if the pollutant flow is to be traced.

EPA Response:   Yes,  total  cost  for  remediation at the  Site  may
exceed  $6  million,   if   ground  water  studies  indicate  that
contamination  exceeds EPA's action level.  The cost of the ground
water operable unit,  however,  remains separate from the  cost of
soil treatment.  Ground water contamination is being studied as a
separate operable unit that  will follow the same process as soil
contamination, i.e.,  signing of a ROD, etc.

Comment:  Several citizens inquired if the proposed plan includes
deed restrictions.

EPA Response:  The chosen remedy  will  remove PCBs to a level of 10
ppm1, which will satisfy  residential use of  the land.   Therefore,
no deed  restrictions  are  necessary.    Deed restrictions  may be
included  if  the buildings  are  raised in the future.    EPA will
address this during the remedial design phase.
     1  Due to  the  information  provided by  the Chairman  of the
Planning  Board of  the Township  of Saddle  Brook  at  the  public
meeting,  concerning the pending  rezoning of  the  area, EPA has
modified the cleanup level of PCBs to 1 ppm.

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Comment:  A  citizen asked  how  EPA will  ensure  that the  soil
incineration is safe for the environment and the public's health.

EPA Response:  The contaminated soil will be shipped, off-site, to
an EPA-approved, licensed, permitted PCB high-efficiency, chemical
waste incinerator.  The byproducts of PCB incineration are carbon
dioxide, water, and chlorine.  A scrubber installed at the facility
retains chlorine  from the resultant gases  so  that it  will not be
released into the environment.   There are also processes to reduce
metals to acceptable levels.

Comment:  A  citizen inquired how  long it will  take  for  EPA to
conduct ground water testing for the second operable unit.

EPA Response:  EPA anticipates  that it  will be ready to assess the
results of testing in approximately a year.  This allows the Agency
time to develop the most effective  treatment systems available for
its proposed plan.
                                                    /

The Superfund Process and the Trust Fund

Comment:  A citizen asked how Superfund is funded.

EPA Response:   Superfund revenues  are  primarily  made  up of taxes
paid by the petroleum and chemical industries, as mandated by the
Comprehensive Environmental Response,  Compensation, and Liability
Act of 1980  (CERCLA).   Other revenues  result from  interest earned
on the fund balance, and cost recoveries from responsible parties.
Superfund revenues totaled $1.5 billion in 1989 and approximately
$1.4 billion in 1990.

Comment:  Several citizens expressed frustration over the amount of
time involved with  studying and planning remediation  at the Site
since it was first reported.

EPA Response:  According to CERCLA Section 104, a hazardous waste
site is not eligible for remedial funding until the site has been
listed on the  National  Priorities List (NPL).   The Curcio Scrap
Metal, Inc.  Site  was added to  the NPL in  July 1987  and  at that
point was  placed under EPA  jurisdiction.   Following  the Site's
inclusion on  the NPL,   the  Site followed the  standard Superfund
process. Extensive studies ensure that the extent of contamination
is known and that the chosen treatment  technology will be the most
effective remedy  available to maintain the safety of  the Site in
future years.

Comment:  One citizen asked why the NPL includes sites that are not
emergencies.   Another citizen  added that EPA  should  address the
"non-emergency" sites first so that those sites do not develop into
emergencies.

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EPA  Response:    CERCLA responses  are divided  into two  groups:
Removal Actions and Remedial Actions.  Remedial Actions take place
at  those sites  that, based on  a score  assigned following  an
investigation under the Hazardous Ranking System,  are included on
the NPL.  Those  sites pose  long term  health threats that require
remediation.  EPA conducts investigations at those sites to confirm
ihe  extent  of contamination, and  remediates the sites  based  on
results of the investigations.

Removal Actions  take  place  at those sites  that  pose an immediate
threat to human health and the environment.  A removal action can
be an emergency response or  a planned removal.  Emergency response
actions are immediate responses  that generally take place at sites
where  accidents  have  occurred  (i.e.,  explosions,  large  spills,
etc.).  Planned removal actions are short term responses, such as
drum  removal,  that  take place  at non-emergency  sites.    These
actions, generally occur during  a 6-month time period.  Both types
of removal sites are not  necessarily included on the NPL; however,
many  of  those sites  are  added  to the NPL because/of  long term
health threats,  and  are  then studied to  establish a  long term
remediation plan.

Investigation/Studies

Comment:  Several  citizens  asked  if  EPA  has conducted off-site
testing for contamination.

EPA  Response:    The remedial investigation conducted  at  Curcio
included off-site sampling.   Although the Site area is at greatest
risk of contamination because Site operations took place there, EPA
is aware that contamination can migrate by means of surface water
runoff  and  sedimentation.     All  off-site  sampling,  however,
indicates that  off-site  concentrations are below  federal  action
levels.

Comment:  A  citizen  asked  if  EPA  has  tested  for  radiation
byproducts at the Site.

EPA Response:  No.   No radioactive  chemicals have been disposed of
at the Curcio Scrap Metal, Inc.  Site to warrant concern for those
contaminants.   Radioactive  chemicals  are  rarely  associated with
scrap metal operations Sites, such as Curcio's.

Comment:  A citizen asked whether EPA has studied the likelihood of
contamination from Maywood, a neighboring Superfund Site, migrating
to the Curcio Scrap Metal, Inc.  Site.

EPA  Response:   No.   Contamination at the Maywood Site was not
included in the Curcio investigation.  EPA studies contamination at
its respective source.  Should studies indicate that contaminants
from Maywood were  migrating, that issue would  be  addressed with
containment and remediation plans for the Maywood Site.

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Comment:  A citizen asked whether the studies at the Curcio Scrap
Metal,  Inc.  Site have indicated that contamination  is spreading
further.

EPA Response:  In  order  to determine this,  monitoring wells were
installed on-site  and down gradient  of  the  Site,  to characterize
the nature and extent of ground water contamination.  The results
of  sampling  from  these  wells  indicated  elevated  levels  of
contamination on-site and minimal off-site contamination.

Comment:  Citizens asked if they may review the Agency's sampling
results and other Site-related information.

EPA Response: Yes.  The Freedom of Information Act grants citizens
access  to all  Site information, unless the  information  has been
categorized business confidential or privileged information.  EPA
establishes  an  information repository  for  each Superfund Site,
where Site documents are  filed for  public review.  The information
repository for the Curcio Scrap Metal, Inc.  Site is'at the Saddle
Brook library.

Miscellaneous

Comment:  A citizen asked how PCBs came into use if the substance
is known to be hazardous.

EPA Response:  When first used, the hazards of PCBs were unknown.
PCBs, noted  for  their ability to absorb heat,  were most commonly
used in transformers.  PCBs are now regulated by  EPA and are no
longer permitted in manufacturing processes.

Comment:  Several citizens  asked if  work  conditions and workers'
safety at the Curcio Scrap Metal, Inc. Site are being addressed by
EPA.

EPA Response: Matters of workers' health and safety are outside of
EPA's   jurisdiction.    EPA  has   referred   the  matter  to  the
Occupational Safety and Health Administration (OSHA), the federal
agency established to ensure safe working conditions for employees.
OSHA is investigating the Site and has conducted tests there.  More
information about the workers' health and safety at  the site may be
obtained by contacting OSHA.

Comment:  How much of the cleanup will be paid by PRPs?

EPA Response: EPA will soon start negotiations  with the PRPs about
the cost of the cleanup.

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Comment:  How much will ground water remediation cost?

EPA Response:  EPA does not know at this time how much ground water
treatment will cost.  During the second operable unit, ground water
contamination  will   be  fully  characterized.    If  treatment  is
required, EPA will develop treatment options with cost estimates at
that time.

Several citizens requested that EPA conduct additional sampling of
floor borings,  drains,  the  sump  area, and the  dry well  of  the
facility.  They also  requested that EPA consider in its remediation
plan:   (1) the  possibility of  runoff  from the property traveling
through the culvert and into the neighboring stream contaminating
ground  water;  and (2) contamination  migrating  from the  Site  by
means  of trucks  using the  Lanza street entrance.   A  citizen
suggested a  catch basin with  grates  to catch Site soils before
trucks exit from the Site.
                                8

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SECTION III B. SUMMARY OF WRITTEN COMMENTS AND RESPONSES

During the public  comment period, two parties  submitted written
comments  regarding EPA's  preferred  alternative for  the  first
operable  unit as  presented in  the  Proposed  Plan.   The  first
operable unit remedy is the excavation with off-site incineration
of contaminated soil in and around the East  Lot.  These comments
are summarized and responded to as follows:

COMMENT 1.     EPA's decision to address the East Lot's soils in
               two operable units should have been  evaluated and
               discussed in the Proposed Plan.

EPA's Response;

     Throughout the Proposed Plan,  it is clearly noted  that the
     Proposed  Plan was formulated  using  the  Focused  Feasibility
     Study for the soils.  After  thorough  evaluation  of the data
     available, EPA concluded  that  separating the Site  into two
     operable units would be the safest and most effective way to
     remediate.   In this  way,  the  soil  contamination  would be
     remediated in an expeditious manner and the  risks posed to the
     human health and the environment would be lessened.  On page
     four of the Proposed Plan, after the description of the Site
     history and the Site characterization, the separation of the
     Site into two operable units  is clearly  stated under the
     heading,  'Scope  and  Role Of Action.'  The reason  for the
     ground water to be treated as a component of an operable unit
     apart from the soil is, as stated on page four of the Proposed
     Plan, that  the  "data concerning the  ground water  is  still
     being analyzed."   Currently,  data collected at  the Site with
     respect  to groundwater  contamination  is  not  adequate  to
     support  a final  decision  for  remediating  this  media.   In
     addition,   since   soil   is   a  source  of  ground  water
     contamination, it is judicious to remediate this media first
     to  prevent   further  migration  of   contamination  through
     groundwater.

     The commenter expressed concern  regarding  the  effect of the
     selected  remedy  on  future  remedial  actions  for  saturated
     soils.     Specifically,  the  commenter  expressed  concern
     regarding whether re-excavation would be required  for clean
     unsaturated soils after the  contaminated,  unsaturated soils
     have been  excavated  and the Site  has been backfilled with
     clean soil.

     Implementation of the selected remedy for the  first operable
     unit  includes  excavation  and  off-site   incineration  of
     contaminated,  unsaturated soils  in and  around  the  East Lot.
     Any residual  contaminated  soils remaining in  the  saturated
     zone will be  addressed  as part of the  second  operable unit

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     remedial  investigation.    Since  contamination present  in
     saturated soils are in direct contact with groundwater,  it  is
     likely that these soils will be remediated through appropriate
     groundwater treatment.  Therefore,  it  is not expected  that
     backfilled, clean soil would need to be  excavated in order  to
     address contaminated saturated soils.


COMMENT 2.     Commenters stated  that the Proposed Plan is  based
               in part on an inadequate and misleading health risk
               assessment and  questioned the accuracy of such  an
               assessment.   Specifically, the commenter pointed
               out that the methodology to determine the  values  to
               be  used  in calculating   risks  were in  error.
               Several other errors in  the  risk assessment  were
               also  pointed  out  including  errors  made  in the
               calculation  of  the  chronic   daily  intake   (GDI)
               values  used.   In  addition,  discrepancies  in the
               toxicity values used were  identified.'

EPA'a Response;

     The   National   Oil   and  Hazardous Substances   Pollution
     Contingency Plan (NCP)  requires EPA to conduct a baseline risk
     assessment for  sites  listed  on the National Priorities  List
     (NPL).  EPA conducted the risk assessment for the Curcio  Scrap
     Metal, Inc. Site.  After reviewing written comments, EPA re-
     evaluated its Risk  Assessment with respect to  concerns  that
     were  raised.   In so doing,  EPA  has detected several errors
     made  in the calculations of  Site risks.

     When EPA performed the  risk assessment, the reasonable maximum
     exposure  scenario was evaluated.   The  reasonable maximum
     exposure scenario is the highest exposure that  is reasonably
     expected to occur at a site.   The concentration value used  in
     characterizing risks at the Site was the 95% upper confidence
     limit on the arithmetic mean.  EPA has  determined that  it  is
     more appropriate to characterize risks  at this  Site based  on
     the maximum Site surveyed concentrations  detected,  as stated
     in USEPA guidance entitled Risk Assessment Guidance for Superfund  (RAGS),
     Human Health Evaluation Manual, Page 6-22, (Part A)  (December 1989) .

     The Risk Assessment  contained a technical error in calculating
     the Chronic Daily Intake  (GDI)  values for adult workers and
     adult residents.  As  a result of  this  re-evaluation of the
     risk  assessment,  the  risks  associated with workers at the
     Site  increased from 2 X 10'2 to 5 x 10'2.  The risks associated
     with  trespassers  to  the   Site increased   from 6  x  10"3 to
     3 x 10'2.  These values represent a reasonable maximum exposure
     to those people present on Site.
                                10

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     The commenter pointed out that discrepancies in the toxicity
     values  for chemicals  such as  chlorobenzene,  copper,  1,1-
     dichloroethane,  and   1,1,1-trichloroethane  exist  in  the
     original risk assessment document.  Since these chemicals were
     not  used in  characterizing Site  risks,  any  discrepancies
     presented for these values have  no effect on the overall Site
     risks.

     The Risk Assessment report has  been revised to  correct any
     errors based  on the commenters  concerns.   Consequently, the
     risks  associated  with the Site have  increased and  remain
     higher than EPA's  acceptable risk range.  The increase in the
     risks associated with the  Site further support EPA's selected
     remedy.  The  revised Risk Assessment will be  available for
     public review in the information repository.


COMMENT 3.     Written  commenters  expressed  concern  that  EPA
               screened out certain  alternatives  in an  arbitrary
               manner.
EPA Response;

     Given the results of the RI, it was EPA's concern for public
     health  that  resulted in the  Focus Feasibility  Study (FFS)
     approach employed at the Curcio Scrap Metal, Inc. Site.  The
     purpose of the FFS was to address the principal threats (PCB
     and metal contaminated soils)  in  a thorough and expeditious
     manner,  consistent with CERCLA and the  NCP.   The principal
     threat  at  the  Curcio  Scrap  Metal,  Inc.  Site  presently
     represents a risk of 5 x 10"2 to on-site workers.  This risk is
     extremely high by  Superfund  standards.   Accordingly,  EPA
     decided to  expedite remediation  of the  contaminated soils
     through a FFS;  while studies continue in support of a remedial
     decision for the surface water and  ground water contamination.

     Considering the magnitude of the risk  to human health, it was
     critical for the FFS to result  in  the  selection of a remedial
     alternative  that  could  be readily  implemented;  thereby,
     alleviating the current risks  to  on-site workers,  visitors,
     and nearby residents.  Given the risk scenario at the Curcio
     Scrap Metal,  Inc.  Site,  it would be  imprudent to  select a
     remedial  alternative that would  require  many  months  of
     additional Site characterization, treatability and pilot scale
     studies to determine the viability of the remedy.

     The following is a synopsis of pertinent data obtained during
     the remedial investigation and EPA's  screening  analysis for
     the In-situ  Vitrification,  Solidification/stabilization and
     Excavation with Off-Site Landfilling alternatives:


                                11

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     • The Remedial Investigation revealed that a significant
     number  of soil  samples contained halogenated organic
     compounds  (HOCs),  including PCBs,  in excess  of 1,000
     parts per million (ppm).  RCRA regulations mandate that
     these soils must be incinerated;

     m Composite soil samples  in the  2  to  4 foot range were
     found,   through  the  TCLP   testing,  to   be   RCRA
     characteristic hazardous waste  based on high lead levels
     and  are thereby subject to RCRA Land  Ban  Regulations.
     Land  Ban requires  treatment of these soils  prior  to
     landfilling;

     • The Curcio East Lot Property  is small, 90 by  100 feet,
     and has undergone disruption of surficial (0 to 2 feet)
     soils from on-site operations since the RI sampling; and

     • Finally,  PCBs which  are  relatively immobile  in the
     environment  have been  detected  in the  ground  water
     beneath  the Site.   The  presence  of  volatile organic
     compounds  (VOCs)  in  soils, in  conjunction with  Site
     specific  hydrogeology  may  have  contributed  to  the
     enhanced mobility of PCBs.

In-situ Vitrification;
The  vitrification  process  involves the use  of high  power
electrical  current  transmitted  into  the  soil  by  large
electrodes  which  transform  the treated   material  into  a
pyrolyzed  mass.    In  order  to  support vegetative growth,
overburden backfill soil  would have to be placed on top of the
vitrified mass.  Vitrification of soils contaminated with a
mixture of  PCBs, metals  and VOCs is  an unproven technology
that   would   require   lengthy   and   technically   complex
treatability and pilot scale studies prior to determining its
applicability  at   the  Curcio  Scrap  Metal,   Inc.   Site.
Vitrification  is  not considered  an   equivalent  treatment
technology to incineration for areas of the Site which contain
soil contamination greater than 1,000 ppm HOCs and therefore,
could not be implemented  in these areas.  A  detailed analysis
of all known soil data indicated that the segregation of the
contaminated soil would be difficult to implement.   The size
of the Site does not lend itself well to the large machinery
and variety of instruments required in order  to implement this
process.   These limitations make  this alternative impractical
in dealing with the principal threats in a timely manner.

Solidification/Stabilization;
Prior  to  implementation  of a  solidification/stabilization
remedy, lengthy testing and pilot scale  studies would have to
be performed.  While solidification/stabilization is a proven
technology for the treatment of metals,  the presence of PCBs
and  VOCs  raise  concerns  regarding  the  viability  of  a

                           12

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     solidification/stabilization remedy.  PCBs, which are normally
     immobile in the environment,  have migrated through Site soils
     and have  been detected in the  ground water.   PCBs,  in the
     presence  of  VOCs,  tend to be  more mobile.   Therefore,  the
     applicability  of   stabilization/solidification  is   highly
     questionable  given  Site specific conditions.   Furthermore,
     areas of HOCs with contamination greater than 1,000 ppm would
     have to be segregated and incinerated.

     Due to these constraints, this process was not considered to
     be a viable  alternative. Also,  the small  size of the usable
     land available on this Property precludes the use of the large
     machines  and  numerous  instruments   required   in  order  to
     implement this process.

     Landfillinat
     The excavation with  off-site  landfilling alternative has been
     screened out due to the fact that HOCs, including PCBs, have
     been detected  in soil  in and around  the East  .Lot at levels
     above 1,000  ppm.  Furthermore,  high  levels of lead detected
     render the soil RCRA characteristic waste, as established by
     Toxicity Characteristic Leaching Procedure  testing.  Based on
     these two findings,  RCRA Land  Disposal  Restrictions apply,
     therefore,   disposal  of  this  soil,  without  appropriate
     treatment, in a landfill is restricted.

     With  respect  to  the  commenter's  concern  regarding  the
     preferred remedy, EPA believes that it appropriately evaluated
     this  alternative based on  all  pertinent  criteria.    The
     evaluating  criteria  include  long-term  effectiveness  and
     permanence, reduction of toxicity, mobility or volume, short-
     term  effectiveness,  cost,,  implementability,  protection  of
     human health and the environment,  and compliance with ARARs.
     These  criteria  are considered  to  provide  the  basis  for
     concluding  that a  particular  alternative  represents  the
     practicable extent to which permanent solutions and treatment
     can be used at a given site.

     The excavation with off-site  incineration  alternative was
     evaluated, along with other alternatives, with respect to each
     criteria.  The capability and availability of the incinerating
     facility for the management of this soil has been confirmed.
     EPA believes that this alternative is the most protective of
     human health and the environment, has  long-term effectiveness
     and permanence and achieves the greatest degree of reduction
     of toxicity, mobility and volume.

COMMENT 4.      EPA's preferred remedial alternative for the East
               Lot soils  is at odds with the remedies that the EPA
               has    selected    at   other   Superfund   Sites.
               Incineration   is   not  consistent  . with.  USEPA's
               approach used in. Region II.

                               13

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EPA's Response:

     EPA  chooses  each remedial  alternative on  a site  specific
     basis.   No two sites are  exactly alike,  therefore, no  one
     treatment  technology  can  be employed  to  every site.   Each
     situation  must be carefully evaluated and after  a  thorough
     analysis  of  the complexities  of  the  nature  and extent  of
     contamination present  on Site are evaluated, a remedial action
     is proposed.   The commenter cited remedial action at two other
     Superfund Sites,  in particular, the Pepper's Steel and Alloy
     Site  in  Medley,  Florida  and the  Commencement  Bay Site  in
     Tacoma,  Washington.    Both, the  Pepper's  Steel  and  Alloy
     Company and the Commencement Bay  Sites are  approximately 30
     acres  in  size.   One must remember that CSMI is a  one acre
     Site.  The Pepper's Steel and  Alloy Site  in Medley, Florida
     used a solidification/stabilization  treatment  technology of
     PCB contaminated soils with  a cement-type mixture and on-site
     placement of the treated material.  The Commencement Bay Site
     in Tacoma, Washington also used solidification/stabilization
     treatment  for PCB-contaminated soils with  a  polymer-cement
     type mixture and on-site placement of the treated material.

     The Pepper's Steel and Alloy Site required the remediation of
     48,000 cubic yards of soils, whereas the Curcio Scrap Metal,
     Inc. Site has approximately  1,800 cubic yards of contaminated
     soil.  The Pepper's Steel  and  Alloy Site in Florida  had a
     significantly  greater   amount   of   soil  which   required
     remediation.      Also,  the  sheer  size   of  these   Sites
     (approximately 30 acres each) made  it possible to accommodate
     the  solidified  treated  material  on-site,  therefore  this
     treatment  technology  was  utilized.  The size of  the  Curcio
     Scrap Metal,  Inc. Site  places several  limitations  upon  any
     treatment technologies which would result in the placement of
     residuals on-site.   In addition, the  size of the Site impedes
     the implementation of an  on-site  treatment  technology which
     necessitates  a large  area for  the  staging of  processing
     equipment.

     Of the other  Sites  that  the commenter cited to be  "at odds
     with the  selected remedy"  for the Curcio Scrap Metal, Inc.
     Site, there are major differences  present.   Briefly, for the
     Burnt  Fly Bog Site  in  Monmouth  County,  New Jersey;  while
     portions of this 10  acre Site were excavated and disposed of
     in approved landfills, 1,000 tons of PCB contaminated material
     is on-site awaiting removal and incineration. For the 87 acre
     Pijak  Farm  Site,   in  New  Egypt,  New  Jersey;   the  soil
     contaminants include VOCs such as  xylene,  organic acids,  and
     low concentrations of  PCBs.  Since the PCBs are at low levels,
     they can be disposed  of in  an  approved landfill,  unlike the
     high concentrations are present on the Curcio  Scrap  Metal,
     Inc. Site which are subject to RCRA LDRs and must be treated
     prior to being landfilled.   For the remaining Superfund Sites

                               14

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     listed, differences such as the degree of PCB contamination,
     size  of  the particular  Site,  presence of  various  other
     contaminants driving the remedial action, the physical state
     of the PCB contamination (oil, sludge,  etc...) and location of
     contamination (off-site,  on-site)  existed.  All these factors
     add to the complexities  of determining which  one remedial
     alternative  is  appropriate for that  particular Site.   So,
     while other Sites in Region II may not  utilize incineration as
     a  preferred alternative,  it  does not  preclude the  use  of
     incineration for the  Curcio Scrap Metal, Inc.  Site.   Other
     factors which come into consideration for this  Site are:  1)
     the relatively small size of the Site;  2)  the pending rezoning
     of  the  area  into a residential  area;  3)  the  everyday
     activities of the operating scrap  metal business, such as the
     crane  constantly churning the  surficial  soils daily;  and 4)
     the elevated risks to human health.

COMMENT 5.      The   commenters  expressed   concern   about   EPA
               improperly  including   capping as  part  of  its
               preferred alternative.

EPA's Response;

     Since EPA has modified the cleanup level to 1 ppm PCBs, due to
     rezoning  of  the  Property  for  residential  use,  the  cap
     identified in the Proposed Plan will no longer be part of the
     selected remedial alternative.  The cap is not necessary for
     this alternative to  be protective of human health  and the
     environment  under a  residential use   scenario  with  such
     protective cleanup levels.  However, if commercial/industrial
     operations resume at the Property  after the selected remedial
     alternative is implemented, it may require that preventative
     measures be  implemented  in order to  protect the remediated
     soil from any possible future releases  of  hazardous substances
     from any business operations at the Property.
COMMENT 6.     The EPA  has  not complied with  the administrative
               record requirements of the NCP.

EPA's Response;

     EPA's general policy is  to make available an administrative
     record in a public  office,  such as  a library,  nearby the
     community where the Site  is located.  This affords the public
     the  opportunity to  read and/or comment  on the  documents
     concerning  the Site.    A full and  complete  copy of  the
     administrative record is  open to the public at the EPA offices
     in New York City.   EPA complied with the requirements of the
     NCP with regard to  the Administrative Record.  Unfortunately,
     by human  err,  several  pages of the appendices of  the risk

                               15

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     assessment were left out of the document,  but when pointed out
     by the commenters, these pages were added to the document in
     question with little delay.


COMMENT 7.     The commenters expressed concern that EPA has made
               no apparent effort to  identify other PRPs for the
               CSMI Site of to notify them of the issuance of the
               Proposed Plan.

EPA'8 Response;

     In 1986, EPA conducted a Potentially Responsible Party (PRP)
     Search  to  identify parties  that  were   involved  with  the
     contamination present on the Site.  Based on the information
     obtained during  the course of  this search, five  PRPs were
     identified;  Mr.   Frank  Curcio,  Curcio  Scrap  Metal,  Inc.,
     Cirello Iron and  Steel Co., Consolidated Edison  Company of New
     York, Inc., and  SECO Corporation.   In conjunction  with this
     investigation, the  Consolidated  Edison Company of  New York,
     Incorporated (Con Ed) was determined to be the former owner of
    - the transformers  which  were the source of  the oil spill in
     1982.  Con Ed sold the transformers to SECO Corporation, who
     in turn transported the transformers  to  Curcio Scrap Metal,
     Inc.   Curcio Scrap  Metal,  Inc.  and Cirello Iron  and  Steel
     Company, which is located  on the  Curcio Scrap Metal Property,
     are both operating facilities on the property.   Cirello Iron
     and Steel Company was determined to be responsible for the May
     1985 hydraulic oil spill.

     EPA notified all  identified potentially responsible  parties of
     EPA's preferred  remedial  alternative  and details  concerning
     the public comment period at the time of the issuance of the
     Proposed Plan.

     EPA has  no  further  information  in  its possession  regarding
     additional parties that may have  sent hazardous substances to
     the  Site.    Any  party   with  information  regarding  the
     involvement of additional  parties that may be responsible for
     Site contamination,  should forward this information  to EPA for
     evaluation.

COMMENT 8.     The commenters  stated  that EPA should evaluate a
               hybrid  remedial alternatives for  the soils in the
               East Lot's unsaturated zone.

EPA's Response;

     EPA has conducted an in depth analysis of the hybrid remedial
     alternative  for  the soils  in  or  around  the  East  Lot's
     unsaturated  zone.   This  hybrid remedy  would involve  the
     segregation of certain  areas  of this Site  to  be   remediated

                                16

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     through  different treatment  methods;  some  soils would  be
     incinerated and some would be sent to  a RCRA/TSCA regulated
     landfill.   EPA does not believe  that  such a  hybrid remedy
     would comply with ARARs.  Further, such  a hybrid remedy is not
     practicable at this Site.
     The soils on this Site  contained both high levels of PCBs and
     metals, therefore, treatment  is required by RCRA.   The high
     levels of  lead detected at  the  Site  render  soils  as  RCRA
     hazardous  waste.    RCRA Land Disposal  Restrictions  (LDRs)
     require treatment of both HOCs, including PCBs, detected above
     the  level  of  1,000   ppm  and RCRA  characteristic  waste.
     Incineration   of   Site  soils  will   meet  all   treatment
     requirements.

     In general,  EPA agrees that off-site landfilling may  be an
     acceptable  alternative for  soils containing HOCs at levels
     below  1,000  ppm,  if   other   contaminants  do  no  preclude
     landfilling.   Levels   of PCBs detected  throughout  the  Site
     varied, and some samples contained PCBs in levels lower than
     1,000 ppm.   However,   based on an in depth analysis  of PCS
     levels detected throughout the Site, EPA has determined that
     no area  of the Site can  confidently be segregated  for the
     landfilling alternative. The  distribution of PCBs throughout
     the Site indicate  that  treatment of Site soils by incineration
     is justified.

     In  addition,  the  Site soils are  characterized  as  RCRA
     characteristic hazardous waste based on TCLP  results.   The
     TCLP test  was performed on two composite  samples collected
     from five locations at different depths.  The five locations
     represent different areas on the Property and therefore, the
     composite samples are considered representative of Site soils.
     One of these composite  samples, collected from five different
     locations  at  a depth  of  2  to 4  feet  was characterized as
     hazardous waste based on test results.   RCRA LDR regulations
     require  treatment of  such waste prior to  land  disposal.
     Therefore, landfilling without prior treatment does not meet
     ARARs.

     The selected  remedy,  excavation  with  off-site incineration
     will  effectively  destroy   PCBs.      After   incineration,
     significant levels of metals remaining in the incinerator ash
     will be properly treated and disposed of, in accordance with
     RCRA regulations.

COMMENT 9.      The  Site characterization  data  are  limited  in
               scope,  and   do  not  support   either  the  proposed
               remedial  action  goal   of 10  ppm  PCBs  nor  the
               proposed excavation  of  the Site to  a depth of six
               feet.
                                17

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EPA's Response;

     EPA has determined that the data collected on the Site,  thus
     far,  has  adequately  determined the  nature  and extent  of
     contamination in soils in and around the East Lot addressed in
     this operable unit.  This data therefore provides an adequate
     basis for  EPA's selection of a remediation alternative for the
     Site.  For  an area  of concern approximately  90  feet  by 100
     feet, a total of forty eight  subsurface soil borings  were
     sampled at  depths ranging  from 0-2 feet, 2-4 feet, and 4-6
     feet.  In addition,  two composite samples were collected for
     TCLP analysis.

     To select the PCB cleanup level at the Site, the EPA Guide on
     Remedial Actions at Superfund Sites With PCB Contamination was
     followed.   This  guide states that  the cleanup range for PCB
     contamination in light industrial areas should be  10 ppm to 25
     ppm.   Therefore,  initially  EPA  selected  10  ppm  as  the
     appropriate cleanup level.  However, due  to  new  information
     presented at the  public meeting, EPA learned that the Township
     of  Saddle Brook  is   in  the process  of  rezoning the  area
     comprising the  Site  to a  residential area.   The change  of
     zoning to  a  residential area requires a more stringent cleanup
     level.  In accordance  with  the above-mentioned EPA Guide, and
     NJDEP soil  action levels,  the  soil cleanup  level  has  been
     modified to  1 ppm PCB.     EPA  expects that this  level  will
     reduce risks posed by the  Site  soils to  an acceptable level
     and be protective of human health and the environment.
                               18

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PROPOSED REMEDIAL ACTION PLAN

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SUPERFUND PROPOSED PLAN
                 CURCIO  SCRAP METAL, INC.
                SADDLE BROOK, NEW JERSEY
USEPA  •  REGION  II
       FEBRUARY 8, 1991
PURPOSE OF PROPOSED PLAN

EPA ANNOUNCES PROPOSED PLAN

This proposed plan describes the preferred
optbn for addressing soils contaminated with
hazardous substances including,but not limited
to-porychlorinated biphenyls (PCBs), metals and
volatile organic compounds (VOCs),  at the
Curcio Scrap Metal, Inc., site (Site).  This Site is
located in the township of Saddle Brook  in
Bergen County, New Jersey. This document is
issued by the United States Environmental
Protection Agency (EFA), the lead  agency for
Site activities, and the New Jersey Department
of  Environmental  Protection  (NJDEP),  the
support agency.   EPA, in consultation  with
NJDEP, will select a final remedy for the Site
onry after the public comment period has ended
and the information submitted during this time
has been  reviewed  and  considered.  This
proposed plan outlines the remedial alternatives
evaluated  for  addressing contaminated  soils
and provides the rationale  used to  determine
EFA's preferred alternative.
            Site Location Map .
                         Figure  l
 EPA is issuing this Proposed Plan as part of its
 public  participation   responsibilities   under
 Section   117(a)   of   the   Comprehensive
 EnvironmentaJ Response, Compensation, and
 Liability Act -of 1930, a* amended (CERCLA).
 This Proposed Plan summarizes information that
 can be found in greater detail in the Focused
 Remedial Investigation/Feasibility Study (RI/FS)
 Report  and other documents contained in the
 Administrative Record for this Site.

 iiiiiiimimiiimmiiiiiiiiiimiiii
    DATES TO MARK YOUR CALENDAR.

.FEB. 8 - MARCH 11. 1991:  Public comment
 period on proposed remedial alternatives.
 FEB. 21,1991: Public meeting at Saddle Brook
 Free Public Library.

 IIIIIIIHIIIIUIIIIHIIIIIIIIIIIIIIIIIII

 EPA and NJDEP encourage the public to review
 these   and   other   documents   in   the
 Administrative Record in order to gain a more
 comprehensive understanding of the Site and
 the Superfund  activities  that  have  been
 conducted there. The Administrative  Record,
 contains  the information  upon which  the
 selection of the response action will be based.
 The record will  be available at  the following
 locations:

 Saddle Brook Free Public Library
 340 Mayhill Street
 Saddle Brook, New Jersey  07662
 (201) 843r32B7
 Hours: Mon • Thurs: 9:00am - 5:00pm,
                 7:00pm - 9:00prh
        Fri - Sat:  9:00am - 3:00pm

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and can also be found at:

U.S. EPA - Region II
26 Federal Plaza
New York, New York  10278
(212) 254 - 1301
Hours: Won - Fri, 9:00am - 5:00pm
COMMUNITY    ROLE    IN    THE
SELECTION PROCESS:

EPA and NJDEP  rely on public input to ensure
that the remedy  selected for each Superfund
site is fully understood, and that the agencies
have considered the  concerns of the local
community,  as  well  as ensuring that the
selected remedy  provides an effective solution.
EPA has set a public comment  period from
February  8,  1991  to  March  11,  1991   to
encourage public  participation in the selection
process.   The comment  period  includes a
public meeting during which EPA will discuss
the focused  RI/FS report, the Proposed Plan,
answer questions, and accept  both oral and
written comments.   The  public  meeting  is
scheduled for  February 21, 1991  and will be
heio at the Saddle Brook  Free Public Library in
Saddle Brook, New Jersey.

Co.-ments wi!! be summarized and responses
provided  in  the  Responsiveness  Summary
section of the Record Of  Decision (ROD).  The
ROD is the document that presents EPA's final
selection   for   response   action.     Written
comments on this Proposed Plan should be
addressed to:

         Mary Anne Rosa,  Project Manager
    U.S.  Environmental Protection Agency
          Region II • Room 13-100
             26  Federal Plaza
        New York, New York  10278
SITE BACKGROUND

The Site includes, but is not limited to the real
property  (Property)  where two  active scrap
metal recycling  businesses  operate,  Curcio
   Scrap Metal, Inc., (CSMI) and Cirello Iron and
   Steel  Company  (CISC).    The  Property  is
   approximately one acre in size  and contains
   two single story buildings which  are used
   primarily as warehouses.  It is bordered by a
   concrete   company  on  the  north,  WaJther
   Avenue on the south, Midland Avenue on the
   west and  a drainage ditch on the east  The
   area surrounding the Property is comprised of
   residential homes and industrial properties.

   The Property is subdivided into the East, West
   and South Lots.  CSMI and CISC conduct their
   business  from the  buildings  located on the
   West and South Lots (see Figure 1).  With the
   exception  of two narrow passageways, all the
   areas  of the West and South Lots are paved.
 .  The East  Lot, the   area  where scrap  metal
   salvaging operations of CISC and CSf.'I occur,
' ~~~»s not paved. The active section of the East Lot
   measures  approximately 90 by 110 feet  The
   metal  cutting  area and the metal compacting
   area are also located on the East Lot.  A ditch,
   located near  this metal  cutting area, drains
   surface water from the Property  into  a culvert
   that  runs  under  the  concrete  company's
   property.      This   drainage   empties  into
   Schroeder's Brook,  a few  hundred feet away
   from the Property.  The remainder  of the East
   Lot  is occupied by piles  of  scrap  metal  in
   various stages of salvage.

   The  locations of  the  piles  are  changed
   frequently  as scrap metal arrives  daily. A large
   crane  with a magnet operates in the  center of
   the  East  Lot, moving scrap metal to various
   piles and containers  for recycling.  Two roll off
   containers are located in the  southeastern
   section of  the East Lot  These containers are
   removed and replaced as  they  are filled with
   scrap  metal.   Bulldozers  and  other heavy
   equipment are also  used to move the scrap
   metal  piles  around  the  Property.    The
   topography of the  East  Lot varies  as scrap'
   metal  piles and surficia! soil is moved.

   Salvaging  operations began at the Property in
   the early 1950's, prior to this time the land was
   used for  dairy farming.  The  East and West
 .  Lots were purchased in 1952 and the South Lot
   was purchased in 1981.  Initially,  only rags and
   paper were  recycled.   Later, aluminum and

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 copper were stored  and  recycled  at the
 Property.  Today, CSMI and CISC deal with the
 collection  and compaction of scrap iron, copper
 aluminum, and other ferrous and non-ferrous
 metals.

 From October 1982 to August 1989 at least
 three documented PCS spills have occurred on
 the  Property.   Samples  of  the  spilled oil
 indicated concentrations of PCB Arochlor 1260
 at 105  pans per million (ppm) and Arochlor
 1242 at 47 ppm  Further investigation revealed
 that    transformers  containing PCBs  were
 purchased   by   SECO  Corporation   from
 Consolidated Edison  Company of New York,
 Inc.  and subsequently sold to and transported
 to CSMI by SECO.  Soil samples indicated the
 presence   of  hazardous   substances;   for
 example, tetrachloroethene  and heavy -metals
 such as lead, copper and nickel were detected.
 The presence of these contaminants  on the
 Prooerrv indicate the potential for ground water
 and surface water contamination.

 The Site- is situated  above a fractured bedrock
 aquifer  called the  Brunswick Formation.   An
 aquifer is  a geological formation composed of
 materials such as sand, soil or gravel capable
 of supplying ground water to wells and springs.
 The   Brunswick   Formation  aquifer,   which
 supplies water to public and private wells in the
 area, is a  consolidated formation  in  which
 grcur.d wstsr is stored in, and moves through
 interconnected fractures in the  bedrock.

 The  Site was placed on the  National Priorities
 List (NPL)  in July 1987. On May 27,1988,  EPA
 entered  into  an   Administrative   Order  on
 Consent (ACO)  with  the  respondents  being
 CSMI, SECO  Corporation  and Consolidated
 Edison  Company of  New  York,   The ACO
 required  the  performance  of  a  Remedial
 Investigation and Feasibility Study (RI/FS) at the
 Site.  The  RI field activities started on July 19,
 1983. The Phase I RI characterized the extent'
 of soil contamination through the collection of
 soil samples from 47  soil borings obtained at
two foot vertical  intervals.  Thirty six of those
 samples were collected from the  East  LoL
 Each sample was  analyzed  for  organics,
 inorganics, pesticides/PCBs and Total Petroleum
 Hydrocarbons (TFHs).  Each boring extended
 to the water table (approximately six feet). The
 soil samples contained a variety of organic and
 inorganic hazardous substances with a wide
 range of concentrations.   The Phase II  RI
 supplemented  the  results of  Phase  I  and
 included the installation of seven borings off the
 Property.  These additional off-Property borings
 were installed to determine if the contamination
 migrated  off the Property.  The  highest  off-
 Property level of PCBs found was 3.6 ppm at
 0 - 2 feet

 SITE CHARACTERIZATION:

 The  highest  concentrations  of VOCs  were
 detected in the East Lot  Overall, one-third of
 the soil samples taken from the zero to two foot
 interval exceeded 1  ppm for  total  volatiles.
 Chloroform was detected  at  op to 2.2 ppm;
-total  xylenes at 23 ppm; «thylbenzene at  4.1
 ppm;  tetrachloroethylene  at  28  ppm;  1,2-
 dichloro-ethane at 4.9 ppm; trichloroethylene at
 6 ppm and 1,1,1-trichloroethane at 1.4 ppm.

 The  highest  concentrations  of semi-volatile
 organic compounds were also detected in  the
 East  Lot  Overall, three-quarters  of the  soil
 samples taken from the zero to two foot interval
 exceeded  10  ppm  for  total  semi-volatiles,
 Fiuoroanthene was detected at  up to 15 ppm;
 pyrene at 23  ppm benzo (a) anthracene at  7.3
 ppm; benzo(a) pyrene at 6.2 ppm; chrysene at
 8 ppm; benzo(b)fluoranthene 11 ppm; fluorene
 22  ppm and phenanthrene 17 ppm.

 Metals contamination  was  detected in borings
 drilled in the East Lot At a depth of 0 - 2 feet;
 mercury  was detected at 466 ppm, arsenic at
 55.6 ppm and lead at 39,300 ppm.  At a depth
 ranging from 2 - 4 feet, barium at  2,600 ppm
 and cadmium at 133 ppm and copper at 26,100
 ppm, were detected.

 The maximum  concentrations  of PCBs in  the
 soil and the depth at which they were detected
 in the East Lot are as follows:

 PCBs:   Depth    Concentration
         0-2 feet  - - 6200 ppm
         2-4 feet  - - 3200 ppm
         4 - 6 feet  - -  124 ppm

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The  borings were terminated when the water
table was encountered.  The off-Property soil
results  yield a maximum concentration  of
Arochlor 1242 to be  3.6  ppm. Four  ground
water monitoring wells were installed as part of
the Phase I Rl.  The samples from these wells
revealed vinyl chloride at levels of 160 parts per
billion (ppb) and PCBs in filtered samples at 7.6
ppb.  Sediment samples from a surface water
outfall  pipe  revealed the  presence of VOCs,-
semrvolatiies ana PCBs.  The concentration of
PCEs ranged up to 12 ppm in the culvert. The
water  from  the off-Property discharge  point
flows into Schroeder's Brook,  where further
sampling  will be performed  downstream  to
determine the extent of contamination.

SCOPE AND POLE OF ACTION; - —

The Focused Feasibility Study (FFS) for soil has
tr:r:  c:±tci   and  is   available   in  the
Administrative Record.  The data concerning the
ground water is still being analyzed.

The   remedial  action for--.addressing  the
contamination at the Site will be addressed in
two  operable units (OUs).  The first OU will
address soil contamination. The second OU, to
be  evaluated at  a later  date, will  address
ground water and surface water contamination.
Any residua' contaminated soil in the saturated
zone wiii be addressed as part of the second
OU remedial investigation.

SUMMARY OF SITE RISKS:

EPA conducted  an Endangerment Assessment
to estimate the risks  associated with  current
Site  condteons.  The baseline risk assessment
estimates  the health  and environmental risk
which  could result from the  contamination at
the Site if no remedial action is takea

The assessment began with selecting indicator
chemicals which would be representative of Site
risks.  These chemicals were identified based
on factors such as potential for exposure to
receptors, toxic'rty, concentration and frequency
of occurrence.  These contaminants included
PCBs,  metals, VOCs and semrvolatiies. Several
of the contaminants including PCBs are known
to cause cancer in laboratory animals and are
 suspected to be human carcinogens.

 This Endangerment Assessment evaluated the
 health effects which could result from exposure
 to contamination as a result of contaminated
 soil coming in contact with the skin (dermal
 contact) and from incidental ingestion of the
 soil.  Two  exposure scenarios were evaluated,
 the first was  related to on-Site workers, the
 second to trespassing by young adults.  The
 risk assessment also considered the effect to
 passers-by to the area surrounding the Site.
 Drinking water pathways were  also evaluated
 because contamination was detected in ground
 water monitoring wells.

 The results of the risk assessment indicate that
 the contaminated soils and ground water at the
.Site pose an .unacceptable  risk to human
 health.  The carcinogenic risk to workers was
 estimated to be 2 x 10"2 while the carcinogenic
 risk to trespassers was 6 x 103.  The Hazard
 Index, which reflects noncarcinogenic effects for
 a human receptor, was estimated to be 1.0.
 Current  Federal  guidelines  for  acceptable
 exposures are a maximum health Hazard Index
 equal to 1.0 and an individual  lifetime excess
 carcinogenic risk in the range of 1.0 x 1CT4 to
 1 x 10*.

 In establishing remedial action goals for this
 Site, EPA has  determined that the unsaturated
 soils contaminated with PCBs greater than or
 equaJ to 10 ppm should be remediated.  EPA
 has developed guidelines for remedial actions
 at Superfund sites with PCB contamination.  A
 cleanup range, for a mixed residential and light
 industrial  area, of 10 to 25 ppm  has  been
 established for  PCBs in soils  by  EPA.   In
 determining the appropriate cleanup level within
 this range, EPA must consider factors such as
 exposure  assumptions  and threat to ground
 water. Since the potential for exposure to PCBs
 is substantial due to the current operations at
 this Site and  data indicates that PCBs  have
 already migrated into the ground water, EPA
 has concluded that it would be prudent to use
 the tower end  of this range. Therefore, a PCB
 action level of 10 ppm has been selected as a
 remedial action goal.

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 SUMMARY OF ALTERNATIVES:
 Alternative 1:
 The alternatives for remediation of the principal
 threats present orvSite were evaluated in the
 focused  FS report, which is  available in the
 information repositories  noted above.  Since
 construction  of  a  treatment facility  on the
 Property  is precluded by the small size of the
 Property  and limited amount of space available
 on the Property, such options were eliminated
 from consideration.  In addition, the Resource,
 Conservation  and   Recovery   Act   (RCRA)
 regulates the management of hazardous waste
 and the Toxic Substances Control Act (TSCA)
 regulates the  disposal  of  PCBs.    RCRA
 regulations include land disposal restrictions for
 non-liquid hazardous waste that contain total
 haJogenated   organic  compounds  (HOCs),
 Including PC5s, 2! concentrations greater than
-1,000  ppm.    TSCA   regulates  -PCBs  -at
 concentrations of 50 ppm or greater.  Under
 TSCA.  soils  contaminated  with   PCBs  at
 concentrations greater than or equal to 50 ppm
 can be incinerated in an incinerator, treated by
 an  equivalent method or disposed  of in a
 chemical waste landfill.

 Although   in-situ   vitrification   and   in-s'rtu
 stabilization/solidification  technologies  were
 evaluated in  the focused FS, EPA eliminated
 these  processes from consideration  because
 under TSCA these methods are not considered
 to   be   equivalent   treatment   methods  in
 comparison  to incineration.  Also,  excavation
 with   off-Site   disposal    and    ex-situ
 stabilization/solidification processes were initially
 evaluated by the PRPs but were eliminated, by
 EPA, from consideration since they would not
 comply with  the  Land  Disposal Restrictions
 established by RCRA. These processes have
 also  been  tested and documented  on PCB
 contaminated media at EPA's Risk Reduction
 Engineering  Laboratories and  it  has  been
 concluded that additional testing needs to be
 performed  to ensure their  reliability.   The
 remedial  alternatives for the East Lot soil that
 have been selected for detailed evaluation are
the following:

       1: No Action
      2: Surface Pavement
      3: Excavation with Off-Site Incineration
                 NO ACTION
 Capital Cost
 Time to Implement
       $  0
 Superfund  regulations  require that the  No
 Action alternative be evaluated at every she to
 establish a baseline for comparison. Under this
 alternative,  deed  restrictions  prohibiting soil
 excavation  and the construction of buildings
 would  be  instituted.     Furthermore,  this
 alternative would  preclude any further scrap
 metal operations  on  the  Property.   Fencing
 presently exists around the East Lot which limits
 access by animals and the genera! public.  The
 PCB action level of 10  ppm will not be achieved
• -with the implementation of this  alternative. - -
 Alternative 2:
            SURFACE PAVEMENT
 Capital Cost
 Time to Implement
$232,000
 3.5 months
 This alternative, as described in the focused FS
 report, involves the placement of a  concrete.
 pad and asphalt cover over the  East Lot soil
 (approximately  2500   square  feet).    This
 altemat'rve does not involve the removal of the
 contaminated soil, therefore, the action level of
 10  ppm will not be  achieved.   Under this
 alternative, deed restrictions prohibiting activities
 that would damage the integrity of the surface
 pavement would be placed on the Property.
 For   example,   soil   excavation  and  the
 construction  of  buildings  would  be  not  be
 allowed.  Routine inspection and repairs would
 be performed as maintenance activities.

 Alternative 3:

       EXCAVATION, OFF-SITE INCINERATION
 Capital Cost
 Time to Implement:
  $ 6.000,000
    8 months
 This alternative  involves  excavation  of  the
 contaminated East Lot soil (approximately 1800
 yd3), followed by transportation to an off-Site

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 RCRA/TSCA  incinerator  for treatment  and
 diSDOsal.  The actual volume of contaminated
 sol! will be based upon an action level of 10
 ppm  for  PCBs   in  unsaturated  soils,  (as
 discussed in the Summary of Site Risk Section,
 above)  and  may be  further refined during
 Remedial Design/Remedial Construction. Using
 an action level of 10 ppm for PCBs, determined
 from the EPA Guide on  Remedial Actions at
 Superfund  Sites   with  PCB  Contamination,
 should   reduce   the  presence  of  other
 contaminants in unsaturated soils to acceptable
 levels.  Due to the presence  of PCBs in the soil,
 the incineration facilities require that the soil be
 drummed  prior  to incineration.    Thus,  the
 excavated soil would be placed into 55-gaIlon
 poly or  fiber drums, on the Property,  and
 transported to the  RCRA/TSCA  incinerator
 fscilify  for treatment.  The off-she shipment of
 hazardous  substances to a treatment, storage
 or disposal facility would  be subject to EPA's
.pc.'Iry  for  off-site  management of  Superfund
 wastes (i.e., Revised Procedures for Planning
 and Implementing Off-Site Response Actions,
 November  13, 1987,  as  updated).    After
 excavation, the East Lot  would be  backfilled
 and graded with clean soil.  A surface cap, as
 described in Alternative 2 would be placed over
 it  This  measure would be implemented to
 reduce the potential for any future releases of
 hazardous  substances into the soil from scrap
 metal operations on the Property.

 EVALUATION CRITERIA:

 This section  describes  the  requirements of
 CERCLA  in  the  remedy selection process.
 Remedial treatment alternatives are evaluated
 using the following seven criteria:

 Overall Protection of Human Hearth  and the
 Environment:  This criterion 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:    This  criterion
 addresses whether or not a remedy will meet all
 of the  applicable  or  relevant and appropriate
 requirements (ARARs)  of Federal  and State
  environmental statutes  (other than CERCLA)
  and/or provide grounds for invoking a waiver.

  Long-term Effectiveness: This criterion 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 cleanup goals have been met

  Reduction of Toxfcitv, Mobility or Volume:  This
  criterion addresses the degree  to which  a
  remedy utilizes treatment to reduce the toxicity,
  mobility, or volume of contaminants at the Site.

  Short-Term Effectiveness:  This criterion refers
  to the  time  in  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 tfie-
—construction  and implementation period. .	

  Implementabilirv:    Implementability  is  the
  technical and administrative feasibility of  a
  remedy, including  the  availability of materials
  and services  needed to implement the selected
  alternative.

  Cost: Cost includes capital and operation and
  maintenance costs.

  State Acceptance:   This  criterion  indicates
  whether,  based  on its review of  the  focused
  RI/FS and the Proposed Plan, the State concurs
  with, opposes,  or  has no  comment on the
  preferred alternative.    This  criterion will be
  addressed  when  State  comments  on the
  Proposed Plan are received.

  Community Acceptance:  This criterion will be
  assessed  in  the  Responsiveness Summary
  section  of the Record  of Decision following  a
  review of the public comments received-on the
  focused RI/FS reports and the Proposed Plan,

  COMPARATIVE    ANALYSIS    OF
  ALTERNATIVES:

  This  section provides  a  summary   of the
  evaluation of each  alternative against the first
  seven CERCLA  criteria described above.  The
  criteria  which address  state and community

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 acceptance  will  be  evaluated  following the
 public comment period

  1: OVERALL PROTECTION:   The No Action
 alternative  would   not   provide   adequate
 protection of  human health by eliminating,
 reducing,   or   controlling   risk   due  to
 contaminated   soils  through   treatment,
 engineering controls, or institutional controls.
 The No Action alternative is not  an acceptable
 remedial alternative given the current risk posed
 to Site workers exceeds the recommended risk
 range of  KT4 to 1CT6.  Although  Alternative 2:
 Surface  Pavement, will  reduce  infiltration of
 water, It is not considered to be protective of
 the environment because impermeable bottom
 liner  which prevents the  contaminants  from
 leaching into  ground water is not associated
 with the design.  This would still be the  case
 even if the proposed surface pavement  were
 replaced by a muni-layer design surface cover
 used fcr hazardous waste landfills.  Alternative
 3, Excavation with Off-Site Incineration, is the
 only 'alternative that  is  protective of public
 health and the environment

 2; COMPLIANCE WTTH ARARS:  Each of the
 three  alternatives  could  be   performed  in
 compliance with  ARARs   (although  the  cap
 associated with Alternative 2: Surface Pavement
 might need to be upgraded to  be consistent
 with RCRA requirements).  However, Alternative
 3: Excavation with Off-Site  Incineration is the
 only  alternative which  complies with EPA's
 Guide on Remedial Actions at Superfund  Sites
 with PCB  Contamination.

 3:  LONG TERM  EFFECTIVENESS  AND
 PERMANENCE:  The No  Action  alternative
 would not provide  a  permanent or effective
 remedy.  Surface paving may not be effective in
 the  long  term.   This alternative would  rery
 heavily upon maintenance  activities to  ensure
 its effectiveness.  Therefore, Surface Paving is
 not a permanent option.  The Excavation, Off-
 Site   Incineration  Alternative   is  the  only
 alternative   with    demonstrated  long-term
effectiveness.   A concrete pad  and  asphalt
cover will also be placed  over  the East Lot
Since the contaminants are destroyed, it also
attains the greatest degree of  permanence.
  4: REDUCTION OF TOXJOTY,  MOBILITY  or
 VOLUME: Both the  No  Action  and  Surface
 Pavement alternatives do not utilize treatment to
 provide a reduction in the toxicrty, mobility  or
 volume of the chemicals in the East Lot soil.
 Excavation with Off-Site Incineration will attain
 the greatest reduction of toxicity, mobility and
 volume of hazardous substances because the
 quantity  of hazardous  substances would be
 significantly reduced during incineration.

  5: SHORT TERM EFFECTIVENESS:   Since ft
 involves no protective measures, the No Action
 alternative would  not create  additional  short
 term risks. The short term risks associated with
 the Surface  Pavement  alternative involve the
 potential exposure to vapors and fugitive  dust
• -emissions during surface  grading activities..
. There  is an  increased /isk  of  short-term
 exposure during implementation of the Off-Site
 Incineration  Alternative  since   it   involves
 excavation of contaminated soils.   Engineering
 controls,  such  as  periodically  wetting  the
 ground surface with water, will be implemented
 in order to mitigate the fugitive dust release of
 contaminants into the air.  An air monitoring
 program will  monitor  for  volatile   organic
 emissions and respirable dust emissions. Since
 the implementation of proper health and safety
 procedures will be followed,  the potential for
 such risks will be minimized.

  6: IMPLEMENTABIUTY:  To   implement  the
 Surface Pavement or the Excavation  with Off-
 Site Incineration options the She would have to
 cease operation for a period of time sufficient to
 successfully  implement either remedial action.

 7: COST: The No Action alternative is the least
 costly,  but  most detrimental to human health
 and the  environment    The cost  of  the
 alternatives are as followr.: *
 1: No Action          $ 0
 2: Surface Pavement  $ 232,000
 3: Excavation with Off-Site
        Incineration    $ 6,000,000

  8: STATE ACCEPTANCE:  The State of  New
 Jersey concurs with the preferred alternative
 described in this Proposed Plan.

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ft COMMUNITY ACCEPTANCE "'Community
acceptance of the preferred alternative will be
evaluated after the public comment period ends
and will be described in the Record of Decision
for the Site.

SUMMARY   OF   THE   PREFERRED
ALTERNATIVE:

The preferred alternative for cleaning up the
PCB contaminated soils  at the Curcio Scrap
Metal, Inc. site is Alternative 3; Excavation with
Off-Site Incineration of approximately 1800 yd3
of soils with PCB  concentrations ranging up to
6200 ppm

In order to ensure the complete removal of PCB -
contaminated soils greater than or equal to the
10 ppm action level,  unsaturated. soil will  be
excsvstea to the water table, where existing
data indicates contamination into the saturated
zone.      Where   data   demonstrate  that
unsaturated soils above the water table are less
than 10 ppm,  confirmatory sampling will  be
conducted to ensure  that all  soils containing
PCSs above this action level are removed.

In summary, Alternative 3: Excavation with Off-
Site Incineration would achieve substantial risk
reduction through the removal of unsaturated
soils contaminated with PCBs  above 10 ppm.
 "This reduction would be permanent since the
- - -PCBs and organics would be destroyed through
  incineration.  Incineration also offers the most
  significant  reduction in toxjcity, mobility and
  volume that  has been demonstrated.   This
  alternative also attains ARARs. This alternative
  is believed to provide the best balance among
  the alternatives with respect to the evaluation
  criteria.  Based on the information available at
  this time, EPA believes the preferred alternative
  would be protective of human health  and the
  environment,  would comply with ARARs and
  would satisfy  the statutory  preference for
... remedies which utilize treatment and permanent
  solutions to the maximum extent practicable.
   EPA, in consultation with NJDEP,
   may modify the preferred after-
   native or select another response
   action presented in the Proposed
   Plan and the FFS Report based on
   new information or public comments.
   Therefore, the public is encouraged
   to review and comment on an the
   alternatives explained here.
Unftee Stses
Environmental Promotion Agency
                         Rtgen II
                         26 Federal Plaza
                         New York. NY 10278
Official Business
Penally tor Private Usa
$300

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SIGN-IN SHEET OF ATTENDEES AT PUBLIC MEETING

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   UNiTliU STATUS  IvNViKONMENTAL fl(. . liCTION AGENCY
                      KliUlON (I
             I'UIJLIC INFORMATION MINTING
                         FOK
The Curcio  Scrap Metal,  inc.  (CSMl) Superfund  Site

                  February 2 I ,  199 I

                  Meeting Attendees

                   ( 1' 1 e u s e  1* r i n t )
Name
Slreel
                                                             Representing

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                           UNITED STATES  ENVIRONMENTAL PKC/ . liCTl ON AGENCY
                                               REGION  11
                                      PUBLIC  INFORMATION  MEETING
                                                  FOR
                         The  Curcio  Scrap Metal,  Inc.  (CSML)'Super fund Site

                                           February  21,  1991

                                           Meeting Attendees

                                            (I'lejse  Print)

                                     V.
Name               Street                 City          Stale     Zip        Phone          Representing
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                          UNITED  STATES  ENVIRONMENTAL PROTECTION AGENCY
                                             REGION II
                                    PUBLIC  INFORMATION MEETING
                                                FOR
                        The  Curcio Scrap Metal,  Inc.  (CSMI) Superfund  Site

                                         February 21,  1991

                                         Meeting Attendees

                                           (Please  Print)
Name
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   Street
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City
State
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