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.
-------
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.
10
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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,
13
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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:
14
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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,
15
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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.
16
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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:
17
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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:
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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
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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
-------
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
-------
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
-------
,-MMCC
. LANZA AVE . • *-»mw^
. -VJ-'
•'. V-/
'. i'.-
, -v0:
. ~ii
I— tor or MIM
i._. tot ton or tun
cuncto srnAp MCTM. me sr
Jtn»t>
CSMI PROPERTY Mf
ten l.
-------
I-MUCI
LANZA
AVE
*- «.!»>•> -^
,- «rr*«s iMtiion
/ tf»oia««einib
/ (nit l**i»
•
CMUOf
O
I
-o-
08
(7)
«•« ->
• rir tar
u«ni
mmtittrri runttrl
•••IllOUK limonra
L Metal Fence
Installed May '90
incmn*rn Htmrri
/£^^~
'CIICH ••••!
WALTHER AVE
• «/•--• l«r Of •«!«
•«»i--- notion n» •MM
cnnrin stnap MCTAI. IMC SMC
sniMH.iUIIOOR, NKW Jtnsir
Approximate
Spill Locations
CSMI PROPERTY MAP
II Ml.
lun mi I ia«ci iN»n»iti i e
(•»"«MI • tl*K««taf»«
Revlnerl by CDM PPC
-------
Ut
t.«
O
oo
" G
LANZA
M.IW,,
•§•!•
— tin**. t«oin» • 11.M
/ run !•»• * ^"'
t::.:j ."••• / ^•-^
•tir i»r
MtIL
M 1
-J 1 ,.
I CBIKH
--.. \»X7
l» Hcmifrri rnnunt
1I±UI
mm.mm
in mr«rii*rrf MM
WALTHER AVE
I.COENO
« uorntodiM* wttl
• 101. (OMM
tM»— tor or *n«
.t.~—~ IOTTOU Of ItNII
cimno SCOAP UPIAI. INC snr
SAnill.F.nillKIH, NF.W JfllSf t
. PHASE I
REMEDIAL INVESTIOATIOI
SOIL BORING AND WELL
LOCATION MAP
mil.
lunmi louc. im«ttii,f.«.
IM*ll«f I «l«K4k*lll
-------
aw-ti-Uw © •••••
Q nun i RI uomTMM *i
»
0 flUtf 1 M U»M» UB»I«
VILL
•=>
O nun t M tarni
•ILL
Tr »tiur t M tiuMMif t
miiir .
0 rHtlt • N IM. tOM»
MKCtteil W fMMIM-td
coNsoin«Tcn tmimi emanui
cuncn scn»f MCIAL *K. 01.
SADOlEUnoUR, lltW J£H»n
PHASE 11
REMEDIAL INVESTIGATE
SOIL eoniNo AND wn
LOCATION MAP
FOR EAST LOT AMD
OFF-SITE
touci iMnnm >t
-------
LANZA AVE.
- «i»tmoc—^
D inucic SCALE D
LEflEMD
Mointonnin WEIL
BOIL aonnms
TOOEPIIIOf JfEtl
AnF«roflEt«c«v*i
tOUEMIIOf tfEU
lltUEOUNOII
S PPM EKCAVATKNI AREA
cimcto scrur UETAL nw.
PROPERir
.kAODlEBnOOK. HEW JEMSET
-------
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
oo
33 3C.I-
OO
c:
-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)
ir,
Ml)
4.0 .1
Ml)
Mil- II
(0-2)
.1000
Ml)
Ml)
Ml)
Gil- II
i
0..1I
Ml)
0.04.1 J
Hl»
sn 12
(0-2)
no
IIP
22
HI)
on- 12
(4-n)
2.1
III)
0.4.1 'J
Ml)
en- n
(0 21
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.
O
oo
CDO
-------
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, -D!chlorohunruriB
cr-Melhy Iphunol
4-Mwlliy Iphunol
Isophororie
2, 4-|>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
—
— —
—
O.OI7 J
0. 33 J
—
—
—
—
—
—
—
--•
—
O. 6
1
—
—
--
0.22 J
—
—
—
O.24 J
—
— —
O. 5
0. IS J
O. 411 l>
O. 72 »
1. 1 U
O. 3f» J
O. 44
0. l>2
ti.b 1)
—
O. 6«J U
O. 46
o. r.i
0.22 J
—
0.77
lill-fi
0. O'J.I
u. uny
tl. 017
O. UI5
0. 19
—
0. .1
0. oyy
--
—
—
0. O3II
O. 0/9
0. 079
—
0. II
—
—
0. 7.1
O. Ill
_..
0. 119
O. Ml
—
0. .15
o. ;n,
O. 47
--
O. .51
O. UP, 4
0. 31
U. 1
--
O. OHfl
»
.1
.1
J
J
J
J
.1
.1
J
J
J
J
a
b
.1
.1
U
JU
J
J
J
J
Hii-s
I4-&)
—
O. OO6
—
—
—
—
O. OO3
—
—
. —
—
—
—
O. O62
O. 0 17
O. O2H
o. or.5
O. I'Gfi
O. 0011
—
(i. O32
O. 62
O. OOII
0. O2b
O. 0 1 1)
O.O24
'. —
—
—
J
J
J
J
JU
JU
JB
J
J
11
J
JU
J
J
10-2)
0.36 .1
O.OI9 J
O.O7B J
0.041 J
1.7
1.2
— '
--
0.9
0.54
1. 4
i.a
—
2. 1
—
— —
13
2.11
7. 1 B
7.3 B
12 B
p. 44
"5. II
4.9
13 D
0. 42
7.3 B
1. 1
4.2
1. 1
0. 19 J
1. 1 •
HB-H 1511-11 BD-9
IO-2) 14-61 (O-2I
0. 13 J 0.24 J
O. 30
0. 63
0.071 J
1.2
O. 31
O. 46
—
—
—
0. 17 J
0.54
O. 43
—
O. 27 J
—
— —
— —
3.9
O. 19 JB
1.4 B
2. 3 I)
O. 4tt
1. 4
l.b
17 B
2.11
2 U
0.37
1.3
O. 34 J
—
0.44
—
1.6
1.3
— —
— —
—
0.56
1.9
£.4
—
3.8
—
'— —
9.6
3.5
O. 29
6.3
9.5
0.27
4.7
4.2
7. 1
0.52
5. 7
1. 1
3. 7
0. 47
--
0. 46
JB
B
B
J
B
B
)0fi QUALITY
ORIGINAL
-------
TA1H.K 3
(Conl'il)
CUHCIO SCIIAI' MlilAI. INC. SITU
SCMIVOLATILF.S IN SOIL SAMPLF.S
JULY • AIKUISI |'.ltl!)
Compounil I
Baiiipl u
Phenol
Darizyl alcohol
1 1 4-IM ch 1 oroliuntario
1 1 J-Ot ch 1 oroliunzeria
1 i 8- Dlch lorolmmanB
8-MBlliy I phuriol
i-ri- but yl phtha lain
F 1 our arithuriu
Pyi-une
Iliity Iliertiy 1 phhtalata
Uunio la) anlhracuna
ChryseriO
Dia IS-tthy IhBuyl >phthal*tB
III -n-ocly 1 pht ha 1 at n
Hunto (III f loiirarittiuriu
l
t.a
0. 36 J
6.6
IS
—
O. O43
O. 03 /
--
— —
— —
—
O. 03
— —
—
O. OS
-
—
O.O64
O.OI5
o. oa'i
0. 037
O. O36
—
—
—
o. a
--
O. OI3
o. oon
0.013
—
--
—
.1
J
J
J
J
J
JD
JU
JU
B
.11)
.1
J
nn- HI
(o-2i
0.66 J
O. 17 J
5. 1
0.37 J
O. 83 J
0. «JII J
H. 'J
:.
— —
__
0.27 J'
O. 54 J
—
—
—
5.6
—
a u
(> U
7.9 II
1.9 U
—
3. n u
19 1)
IX lif. JD
S
O. S2 .111
a. 6
O. <)4 J
—
O. 42 J
Sll-l I
—
5.9
II
— —
— —
—-.
—
—
__
8.3
—
—
—
__
—
8. 4
4.7
IO
5* 6
3.6
4. 6
41
1. l>
6.5
__
3
O. 7(i
—
—
fill-l 1
(5-71
—
J
—
— —
—
—
—
-r-
Jl) O. OI7 Jl)
—
—
—
— —
—
JD O.OI JU
JD
D O.009 JD
JB
J
JD
II O. 34 JD
JU
J
.._
J
J
—
--
fin-la
(o-ai
—
o. ys
O. 64
—
—
— -
—
0. 119
0. b/
—
1.6
--
—
n.6
8.5
3.9
14
17
£O
(i. 'I
/. S
37
O. 711
1 1
O. «JI>
:.
a. :i
i
2.2
.1
J
^
.1
J
J
.1
J
.10
H
U
D
.1
JU
li
JU
JU
.1
J
.1
.1
BU-13
(4-61
—
--
—
—
—
—
—
—
O. 009
0.018
O.OI6
—
—
o. la
O. O4 1
O. U3
O. 82
O. 34
0.016
O. 1 1
0. 1 1
O. 76
O. O.i4
0. l:i
o. oia
H. »I7I
U. U'l 1
--
O. 03(1
J
.ID
J
J
J
Jl)
.in
JD
JD
J
.ID
II
JU
.1
JU
.1
J
J
Bli-13
(0-81
—
0. 39 .1
0.87 J
—
— —
— -
O. 36 J
O. 6 J
0.39 J
—
O. 65 J
—
—
3.7
1. 1 J
o.a j
5. 7
x 6.5
O. 48 J
2. 3 J
2. 6 J
Id II
O. 3(1 J
2.4 J
2 J
a. 2 J
O. 7 J
0. 19 J
O. 65 J
BB-14
4O-8I
O. 70 J
O.37 J
0. 311 J
l.(. .1
1.9 J
— —
— —
1.8 J
—
8. 7 J
1.4 J
—
8.6 J
—
—
13 '
4.5
3 J
15
83
3. II J
7.3
n
3t» n
I.H J
r>. 3
1. 6 J
e. a
O. IIS J
--
O. 65 J
BU-14
(4-6)
0. IS
—
O. 32
O. 37
— —
— —
— _
O. O96
0. 36
0.23
—
O. 45
—
—
1.9
O. 62
U. 26
2. a
3.5
1
i.a
1. 3
6. 1
o. .ia
i.a
O. 3 1
1.2
O. 15
O. OIK!
O. 12
J
J
J
J
J
J
J
J
n
j
j
j
j
j
60-15
«O-£I
O. 41 J
O.5 J
O. 97 J
0.71 J
— —
-—
--
0. 3fi J
0.77 J
0.69 J
—
1.3 J
—
—
5.8
1.9 J
.16
3.9
(1
8.6 J
2. 6 J
2. 9 J
86 D
0. 611 .1
a. a j
0. 6 1 J
8.3 J
0. S3 J
—
0.44 J
OOR QUALITY
ORIGINAL
-------
TAIII.K 3
(Cncil'il)
HI:MI:I)IAI. INVIir.MGAllON
CUI1CIO SCIIAP MlilAI. INC. SITE
SEMivoi.Aru.ES IN noii. SAMPLES
JULY • Autiuui iuna
Compoundi
Bainpln I. I).
I'll a no)
Bunzyl alcohol
1 , 4-0 Ich loi-obanzanu
1, J-IM cli 1 oroliHrnunii
1 , a-l)lch 1 orotianzany
8-Matliy Ipltoc.ol
4-Muthy 1 phuriol
1 bc/plioronu
2, 4-lllinutliy 1 pliunol
banzolc acid
2, 4-DichlorophBnol
1,2, 4-Tr Ich 1 orobanzana
Naphthalene
2-Met hy 1 naphtha 1 ana
2, 4, 5-Ti-ich 1 oi-oplier.ol
2-Cli 1 or onaph t ha 1 ana
1)1 MB thy Iphthalate
ncenaplithy leria
Ocenaph t hune
Ul bunzof tn-ari
Olatliy Iplithalata
F lourur.o
N-Nl trosotllphany lamina It)
I'arilach lorophunol
I'lieriant hrunu
nntln-acunu
III -n-buly Iphthalate
1" lotiranthuriu
I'yi-anu
Hut y 1 benzy 1 pliht a 1 at a
banzolal anthracune
riirysenc
Ilia 12-ttliy Iliowy 1 ) pit thai at o
Hi -ri-oct y Iphthalala
lienzoihl f 1 ouranthane
ItunzolM f lonrarit liana
Ijenzo lat pyrunu
Inilenol 1,2,3-cill pyrana
Dlbanzo (a, hi anthracune
banzo l|j, h, ilparylena
Bli-15
12-41
—
—
—
—
—
—
—
—
— —
—
—
O. 511 J
O. 52 J
—
—
—
• 0. 3 J
o. m j
0. 54 J
—
1.2 J
—
--
4.n
a J
i . '• .1
4.3 J
9. 3
H. 3 J
2 J
2.5 .1
14 1)
0. O.I .1
3.6 .1
0. 43 J
1. U J
—
—
—
Hli-17
10-21
—
—
—
—
—
—
—
— —
—
6. 14 J
1. 7
1.0
—
—
5.7
— .
O. fid
O.II5
—
1.3
—
—
— _
—
—
__
11.11
1. 1
4.6
3.11
19 U
S. 4
6. 1
1.2
3.9
1
O. 2li J
1. 1
BH-IU
—
O. 52
—
O. O32
--
O. 0110
—
;
0.2
O.JO
O. 35
—
—
0. 13
O. 1 1
O. 3
0. 12
.
0.32
—
—
1.3
O. 53
O. S'.l
3
3.11
1. 1
1.4
1.5
1
O. 7 1
1.6
O. 26
1.2
—
—
—
J
J
J
J
J
J
J
J
J
J
J
J
J
.III
J
.1
.1
I)
J
J
J
J
till- 1 II
14-61
—
O.bl
—
—
—
0. 12 J
—
—
-—
—
0. 10 J
O. 37
0.34 J
—
—
0. 14 .1
O. 094 J
O. 22 .1
O. 12 J
—
0.27 J
0.4
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0. 93
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0.32 J
—
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0. 16 J
0. 056 J
—
0.23 J
—
0. &7 J
0.31 .1
0. 26 J
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0. 75
0.22 J
0. 45 J
0.26 J
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O. 46 J
Sli-19
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O. 19 J
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—
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2.3 J
O. (:.ll .1
0. 7 / .1
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4.2 .1
0.61 J
1.5 J
1.7 J
III U
O. 54 J
2 J
ft. 4 J
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—
—
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10-21
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12-41
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O. 16 J
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0.32 J
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4.2 U
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0. 76
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O. O97 J
—
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—
O. 04 J
—
0.074 J
—
—
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O.047 J
1.6
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0. IS J
O. 33 J
0.21 J
3.7
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2 B
3.9 B
O. 16 J
1.5
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O. 42
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POOR QUflUTV
0!
-------
TAlH.r. 3
(COMl'(l)
INVHSIIOAIION
CUnCIO SCHAP M«:IAI. INC. SHE
SEMIVOLATILHS IN SOU. SAMI'IHS
JULY - Aur.ua i iaii-i
Haiiipl u I.I).
Phunol
banzyl alcohol
1 , 4-IHch toroliunzanii
1 , 3-1) i th 1 oroliunzwriii
1 , 2-1)1 chloruhunzuna
2-Mathy 1 pliunol
4-Muthy 1 pliunot
1 aophoroiiB
«2, 4-1)1 methyl phenol
Durizolc acid
2, 4-Ulch lorophanol
1,2, 4- Irlch lorohanzane
Naphtha lunu
2-Mat hy 1 naphtha 1 orn»
2,4,11-lrlch loruphuriol
2-i:iilot*onaphtha 1 ana
Dli.iothy 1 pI'Ui* 1 alH •
Ocwnaphthy Iftnu
Ocanaplithufiu
IX banzof uran
Diuthylphthalata
l: lourunu
N III trouod i phony 1 aiiiiria III
I'er'it ach loro|ihunol
I'hanarithrunw
nnthraciinu
III -n-luil y 1 phtha latw
F loiiranlliunw
I'yrunu
l.
a
H. 3
5.5
44 B
1
5.5
6. «J
5.3
2. U
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4. 1
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IO-2J <4-bl 10-21
0.27 .1
2.7
14
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—
—
— —
—
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3.5
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11. r> i u
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1.3
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O. 44 JO
O. 5
0. 'JS
0. !>4
O. 73
—
0.71
1.4
2. 3
—
—
—
—
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—
—
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—
—
£
O. 49 J
O.62 U
K. 1
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3.2 U
1.6
1.2 B
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1.2
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1.5
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— —
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O. 0 1 7 J
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3.7
0.67 J
1.4
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1
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2.3
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O. 090 J
i.a
O. 23 J
0.53
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1.3
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0.36 J
1.2
0.03
0. 19 JD
I.S
—
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2. 4
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4. 3
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5.7 B
5. 1
3. 6 B
36 D
1. 6 D
2. 1
1.9
3.6
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3.2
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13-71
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0.36 J
O. 42 .ID
O. 063 J
0. 1 1 J
O. 097 J
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0. 43 B
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—
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—
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0. 15 J
0.89 J
— —
0.37 J
POOR QUALITY
-------
TAIU.K :i
(Cnnl'il)
INVIiSIIGAflON
CUHCIO SCIIAP MEIAI. INC. SITE
SHMIVOI.ATILF.S IN BOM. SAMPLES
JULY • AUOUSI |!UI!>
Bamptu I. IK
Phenol
buntyl alcohol
1 , 4-1) Ich I ore/hum uno
1 , 3-l>ich lorohunzana
1 , 2-lHch lorolianiunu
cf-Huthy 1 phuriol
4,-Mnthy 1 phunol
Itophoronu
2, phtlia 1 *t u
l)l-fi-ocly Iplithalatu
bwnzo (li) f louranthurtv
bunzolM) t lout-ant hvriu
banzo (a) pyruno
lntlano( I, 8, 3-cdl pyrvna
1)1 benzol a, h) anthracunv
Banzo 1 U> l>, II pury lunu
BB-29 BB-29
(O-cM (2-4)
—
O. 20 J 1.4
— —
— —
__ —
—
—
— —
— —
— —
1.4 I.I
0. 7 1 0.77
O. S3 O. 37
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— — — -
-- —
0.49
1. I
0.71
0.2 Jl)
1.5
—
— —
LIB 7. 1
2. 4
1.5 B I.H
i.a b u.2
1.6 B 7
1.6
Lit B 3.9
4. a
.19 B 30
O. :»7 O. 9
o. /a B s
O. 21 JB 1.3
1.4 B 3.9
O. 47 1.2
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0.25 JB
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—
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—
1.2 B
O. 14 JB
1.6 If
O. 67
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—
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—
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—
0.79
1.4
0.91
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1.6
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0.71 J
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0.61 J
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—
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1.4 J
1. 1 JB
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0.61 .1
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3. 9 J
3. I J
0.31 J
—
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BB-34
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0.73 J
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0.01 J
0.90 J
— —
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7
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12
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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
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t'l. Ob 9
u. OulJ
O. 0.17
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O. 4 8
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0.04(1 J
a .1
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O.030 J
POOR QUALITY
ORIGINAL
60-1
6. 7 J
19
U7
O. OBI
O. 13
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0. 1 4
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-------
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
—
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—
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0. SI
O. 411
1.5
0.52
—
O. 64
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0.36 J
£.3
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O. 37 J
O. 49
4.5
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—
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0. 15 J
O. 17 J
O.2I J
O. £2 J
—
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—
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1. t
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J
JD
J
JB
D
1)
JD
n
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JD
JD
J
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3
1.7
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— —
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1.2
0.79
—
t.a
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7.6
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1.7
n. i
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I.U
3.4
3.9
44
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2.6
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e. B
1.6
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1.6
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-------
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
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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
«;::;;,
9290
22. 7
7. 7
543
0. 72 »
I'irf. h
1 (i 1 On
ti2. B
1 4 . y '
IKi'iO
3.1200
4210
3'J'Jn
3O2
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
f. II
l.'o 1)
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
IM4OO
4O6
11. b
1 4£
Ii59
O. 9?
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
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17. 'i
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33'i
31.1
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1 3OOOU
2770
5II7O
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912 B
7.6
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O. 1 'i H
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27'iO
1. H
'i. 7'i
Bli-31
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31.9
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1 5. 3
ttt'iOO
a 1 3
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t'l'.IO
2O.JOI.iO
393(111
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12 'Hi
27. H
'toy
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2.7
£2.5
3HOO
0. I I U
51.3
50 1 i.i
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6. VJ
fid-3 1
(4. -61
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(III, •:)
31.5
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£1.1
365OO
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25. 1
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O.22 H
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IO. 3
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111.7
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ny. 3
0. 31
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363 B
O. 35 l»
O. 37 U
176 B
O. 12 II
1.1.2 .
55.2
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37. 3 B
O. 06 B
0. 'i B
693(1
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1 1 1
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107
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0. 1 U
£4. 9
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24.B B
0. 16 B
0. 3(1 II
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7.6
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6.9
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40. 6
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6. £ B
49R B
0. 1 1 II
0.51 II
133 B
0. 1 1 II
9.5 B
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2.6
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1 420
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11.5
291 B
". 3 B
0. 4H U
235 B
0. 1 U
13. 1
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0. 72
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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
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1. 1
1 HOO
£6.9
9. 1
35.6
I £3OO
03. £
. 953
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14. 3
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0. 34
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£09
0. 1 1
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176
0. 64
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B
B
B
B
B
B
B
U
B
U
U
( O-£ 1
£05OO
43. a
11.3
632
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£0. 7
30700
349
£9. 1
1940
119000
£770
707O
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11.2
305
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6.3
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1 £ 1 0
0. 1 1 II
34.5
349O
£.3
3.79
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6.3 II
3.5
1 17
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9. 6
6240
411. S
13.6
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1 1 40
£O9O
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4
53. £
450 B
15.3
3
366 D
0. 15 B
15. U
926
1.5
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436
45. 4
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153OOO
3O£0
64DO
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463
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6.3
16. 6
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0. 1 1 II
91.6
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3. £•
: 4.01
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36. (1
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196
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' ' ' 3
17.3
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O.£l U
43
I4£0
1.5
4.72
08
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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
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CoM|io>inil
i. iON
cunciu liciiAi' MI-IAI. mo. sun
INORGANIC CONSTITIH-NTS IN SOU. SAMPLES
fiaiiiple I.I).
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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
-------
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
-------
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
-------
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
.._
—
—
—
-------
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.
-------
RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
-------
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
-------
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.
-------
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.
-------
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.
-------
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.
-------
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.
-------
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.
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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.
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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:
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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.
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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.
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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
-------
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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