United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-92/187
September 1992
SEPA Superfund
Record of Decision:
Cosden Chemical Coatings,
NJ
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NOTICE
The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement but adds no further applicable information to
the content of the document All supplemental material is, however, contained in the administrative record
for this site.
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-92/187
3. Recipient's Accession No.
4. TOe and Subtitle
SUPERFUND RECORD OF DECISION
Cosden Chemical Coatings, NJ
First Remedial Action - Final
S. Report Date
09/30/92
7. Authors)
8. Performing Organization RepL No.
9. Performing Organization Name and Address
10, Project/Tssk/Work Unit No.
11. Contr»ct(C) or Grsnt(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 & Period Covered
800/000
15. Supplementary Notes
PB93-963818
16. Abstract (Limit: 200 words)
The 6.7-acre Cosden Chemical Coatings site is a paint formulation and manufacturing
facility in Beverly, Burlington County, New Jersey. Land use in the area is
predominantly residential, with some light industry. An estimated 800 people reside
within a 1-mile radius of the site. During the manufacturing process, pigments were
mixed with resins and solvents in both ball and sand mills prior to adding other
ingredients in mixing tanks to produce the final coating products. Mixing tanks were
then washed out with solvents, and the rinsate was transferred to drums. Until 1974,
organic solvents used in the manufacturing process were recycled; thereafter, drums
containing spent solvents were stored onsite. Some of these drums leaked onto the
ground and caused soil and ground water contamination. Additionally, solvents were
stored in underground storage tanks (USTs), which may have leaked. In 1980, a grass
fire onsite prompted state investigations that revealed the presence of surface spills
and several hundred unsecured drums. In 1985, the state ordered Cosden to clean up the
site; however, Cosden abandoned clean-up efforts after 88 of 695 drums were removed.
In 1986, the state undertook emergency removal of the drummed material and clean-up of
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Cosden Chemical Coatings, NJ
First Remedial Action - Final
Contaminated Media: soil, debris, gw
Key Contaminants: VOCs (benzene, TCE, toluene, xylenes), other organics (PAHs, PCBs),
metals (arsenic, chromium, lead), inorganics (asbestos)
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
58
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R02-92/187
Cosden Chemical Coatings, NJ
First Remedial Action - Final
stract (Continued)
surface spills around the drum storage areas. Paint manufacturing continued onsite until
1989, resulting in additional drums accumulating onsite. In 1989, EPA initiated a second
removal action by constructing a fence around areas of soil contamination and removing
the remaining drums, paint cans, pigment bags, mixing tanks, and UST contents. However,
as the removal action neared completion in 1990, a fire occurred inside the process
building, which consumed a majority of the building. This ROD addresses the final remedy
for the cleanup of contaminated soil, ground water contamination in the underlying
aquifer, and the Cosden building. The primary contaminants of concern affecting the
soil, debris, and ground water are VOCs, including benzene, TCE, toluene, and xylenes;
other organics, including PAHs and PCBs; metals, including arsenic, chromium, and lead/-
and inorganics, including asbestos.
The selected remedial action for this site includes treating 8,000 cubic yards of
contaminated soil onsite using in-situ solidification, and disposing of a small pile of
concentrated PCB-contaminated soil offsite; disposing of sludge generated during the
treatment process offsite; decontaminating and demolishing the contaminated building
onsite, and removing and/or recycling decontaminated debris and equipment offsite;
removing asbestos and PCB- contaminated debris offsite for disposal in an appropriate
offsite facility; treating ground water onsite using precipitation to remove inorganic
contaminants, followed by air stripping to remove VOCs, with recharge of treated ground
water to the underlying aquifer; treating air emissions using carbon adsorption, if
determined to be necessary during remedial design; and implementing institutional
controls including deed restrictions. The estimated present worth cost for this remedial
•action is $15,172,800, which includes an annual O&M cost of $585,500 for 1 year.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific soil clean-up goals are risk-based and include PCBs 1 mg/kg; chromium
390 to 78,000 mg/kg; and lead 500 mg/kg. Chemical-specific ground water clean-up goals
are based on state standards and SDWA MCLs and include toluene 1,000 ug/1; xylenes
44 ug/1; chromium 100 ug/1; and lead 15 ug/1.
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ROD FACT SHEET
SITE
Site name: Cosden Chemical Coatings Corporation
Site location: City of Beverly, Burlington County, New Jersey
ROD
Date Signed: September 30, 1992
Selected remedy:
- On-site ground water extraction with on-site treatment and recharge;
- In-situ stabilization of approximately 8,000 cubic yards of soil
contaminated with inorganic compounds and PCBs;
- Decontamination and demolition of the building on the site with disposal
of the building debris at an appropriate off-site facility;
- Appropriate environmental monitoring to ensure the effectiveness of the
remedy.
Estimated Capital cost: $6,116,600
Estimated Annual Operation and Maintenance (O&M) cost: $585,500
Estimated Present-worth cost: $15,172,800
United States Environmental Protection Agency
Primary Contact: Paul Marsenison - (212) 264-4593
Secondary Contact: Charlie Tenerella - (212) 264-9382
Main PRPs:
Cosden Chemical Coatings Corporation;
Mr. Louis Oiler, President, Cosden Chemical Coatings
Corporation
Waste type: Volatile organic compounds (VOCs), inorganic compounds,
polychlorinated biphenyls (PCBs).
Waste origin: Leaking drums on-site and on-site paint manufacturing operations
Estimated waste quantity: An estimated 8,000 cubic yards of soil is contaminated
with heavy metals and PCBs.
Contaminated medium: Soil, ground water, and the on-site process building.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Cosden Chemical Coatings Corporation
City of Beverly, Burlington County, New Jersey
STATEMENT OF BASIS AND PURPOSE
*
This decision document presents the selected remedial action for
the Cosden Chemical Coatings Corporation site, which was chosen
in accordance with the requirements of the Comprehensive
Environmental Response, Compensation and Liability Act, as
amended, and to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan. This decision
document is based on the administrative record file for this
site.
The New Jersey Department of Environmental Protection and Energy
concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the
Cosden 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 selected remedy represents the first and only planned
operable unit for the Cosden Chemical Coatings Corporation site.
It addresses contaminated soils and the building on the site and
ground-water contamination in the underlying aquifer.
The major components of the selected remedy include the
following:
• In-situ stabilization of approximately 8,000 cubic
yards of soil contaminated with inorganic compounds and
polychlorinated biphenyls;
• Decontamination and demolition of the building on the
site with disposal of the building debris at an
appropriate off-site facility;
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• Extraction of contaminated ground water with on-site
treatment and recharge to the underlying aquifer; and
• Appropriate environmental monitoring to ensure the
effectiveness of the remedy.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. The remedy utilizes
permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable, and it
satisfies the statutory preference for remedies that employ
treatment which reduces toxicity, mobility or volume as their
principal element.
Because this remedy will result in hazardous substances remaining
on the site above health-based levels (although in a stabilized
form), a review will be conducted within five years after
commencement of the remedial action to ensure that the remedy
continues to provide adequate protection of human health and the
environment.
Sidamon-Eristo/f£/' Efa'te
Regional Administrator r-£ /
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RECORD OF DECISION
DECISION SUMMARY
Cosden Chemical Coatings Corporation Site
City of Beverly, Burlington County, New Jersey
United States Environmental Protection Agency
Region II
New York, New York
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1
TABLE OF CONTENTS
PAGE
SITE NAME, LOCATION, AND DESCRIPTION 2
SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
HIGHLIGHTS OF COMMUNITY PARTICIPATION 3
*
SCOPE AND ROLE OF RESPONSE ACTION 4
SUMMARY OF SITE CHARACTERISTICS 4
SUMMARY OF SITE RISKS 6
DESCRIPTION OF REMEDIAL ALTERNATIVES H
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 17
SELECTED REMEDY 24
STATUTORY DETERMINATIONS 26
DOCUMENTATION OF SIGNIFICANT CHANGES 29
ATTACHMENTS
APPENDIX I. FIGURES
APPENDIX II. TABLES
APPENDIX III. ADMINISTRATIVE RECORD INDEX
APPENDIX IV. STATE LETTER OF CONCURRENCE
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SITE NAME, LOCATION AND DESCRIPTION
The Cosden Chemical Coatings Corporation Superfund Site (the
Site) is located in the southeastern corner of the City of
Beverly in Burlington County, New Jersey. The Site is at the
intersection of Manor Road and Cherry Street within a residential
area of Beverly. It is bounded on the north and east by
residential streets, on the south by Conrail tracks and farmland,
and on the west by undeveloped land. The nearest residence is
approximately 300 feet to the north of the Site. The Beverly
Elementary School is located 0.2 miles to the northeast. The
neighboring area is suburban with some light industry. The
Delaware River is approximately 4,000 feet to the. north, and
Rancocas Creek approximately 1.5 miles to the southwest of the
Site. Population within a one-mile radius of the Site is
approximately 800 people.
The Site encompasses 6.7 acres and consists of a single process
building that is situated in the eastern part of the property; a
concrete platform that was used as a drum staging area is west of
the process building (see Figure l). The western two-thirds of
the property is undeveloped and heavily vegetated.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Cosden Chemical Coatings Corporation was a paint formulation and
manufacturing facility which produced coatings for industrial
applications. In the manufacturing process, pigments were mixed
with resins and solvents in both ball and sand mills. The
material was then placed into a mixing tank where other
ingredients were added to produce the final coating products.
Mixing tanks were then washed out with solvents, and the rinsate
was transferred to drums. Organic solvents used in the
manufacturing process were recycled until 1974. After 1974,
drums containing spent solvents were stored on site; some of
these drums leaked onto the ground and caused soil and ground-
water contamination. Solvents were also stored in underground
storage tanks, which may have leaked.
A grass fire that occurred at the Site on April 22, 1980 prompted
the Burlington County Department of Public Safety to report the
Site conditions to the New Jersey Department of Environmental
Protection and Energy (NJDEPE). Subsequent site visits by the
NJDEPE revealed the presence of surface spills, and several
hundred unsecured drums. Various court actions and negotiations
undertaken by NJDEPE against Cosden Chemical Coatings Corporation
resulted in a judicial consent order on February 5, 1985 that
ordered Cosden Chemical Coatings Corporation to clean up the
Site. Cosden Chemical Coatings Corporation initiated the cleanup
in February 1985, but abandoned cleanup efforts after 88 of 695
drums were removed. In January 1986, the NJDEPE then undertook
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an emergency removal of the drummed material, and cleanup of
surface spills around the drum storage areas.
The Site was placed on the National Priorities List (NPL) in July
1987. On December 17, 1987, the Environmental Protection Agency
(EPA) issued a Special Notice Letter to Mr. Louis Oiler,
President, Cosden Chemical Coatings Corporation, informing him of
his potential liability under CERCLA, and provided him the
opportunity to undertake or finance the Remedial Investigation
(RI) and Feasibility Study (FS). No response was received. On
July 29, 1992, EPA issued General Notice Letters to*the Cosden
Chemical Coatings Corporation and to Mr. Louis Oiler, President,
Cosden Chemical Coatings Corporation, informing them of their
potential liability, providing them the opportunity to comment on
the Proposed Plan for the Site, and encouraging them to either
finance or voluntarily undertake the remediation at the Site. No
response was received by EPA.
Paint manufacturing continued on a small scale until May 1989,
during which time additional drums accumulated on site. The
plant owner ceased operations in May 1989. In June 1989, EPA
initiated emergency cleanup activities at the Site by
constructing a fence around areas of soil contamination; and
began removing the remaining drums, paint cans, pigment bags,
mixing tanks, and underground storage tank contents. On May 28,
1990, as the removal action was nearly completed, a fire occurred
inside the process building which consumed a majority of the
building. On May 31, 1990, the building was condemned by the
Beverly City building inspector.
Ebasco Services Incorporated was tasked by EPA to initiate an RI
and FS. The purpose of the RI was to define the nature and
extent of contamination at the Site. The FS evaluates
technologies to clean up the contamination identified at the
Site. Field activities for Phase I of the RI began in November
1988.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
Public availability sessions were conducted on November 11, 1988,
August 31, 1989, and February 20, 1991 to keep residents informed
of Site activities and progress. The results of the Phase I
field investigation and the scope of the Phase II field
investigation were presented in the public availability session
held on February 20, 1991. In January 1991, the Phase II field
investigation was initiated. The RI, FS and Risk Assessment
reports were completed in June 1992.
The RI report, FS report, and the Proposed Plan for the Site were
released to the public for comment on July 27, 1992. These
documents were made available to the public in the administrative
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record file at the EPA Docket Room in Region II, 26 Federal
Plaza, New York, NY and the information repositories at:
Beverly City Hall Burlington County Library
Municipal Building Woodlane Road
Broad Street Mt. Holly, NJ 08060
Beverly, NJ 08010
(609) 387-0205
The notice of availability for the above-referenced^documents was
published in the Burlington County Times on July 27', 1992. The
public comment period on these documents was held from July 27,
1992 to August 26, 1992.
On August 6, 1992, EPA conducted a public meeting at the Beverly
City Hall to inform local officials and interested citizens about
the Superfund process, to discuss the findings of the RI and FS
and the proposed remedial activities at the Site, and to respond
to any questions from area residents and other attendees.
EPA responses to the comments received at the public meeting and
in writing during the public comment period are included in the
Responsiveness Summary section of this Record of Decision.
SCOPE AND ROLE OF RESPONSE ACTION
As a result of the complex distribution of contaminants
throughout the site, EPA decided to address the Site by
segregating the three types of contaminated media (soils, ground
water, and the Cosden building). The three categories of
contaminated media are evaluated individually with regard to the
risk posed to human health and the environment, the potential for
contaminant migration, and the development of remedial
alternatives. Therefore, this Record of Decision (ROD) includes
remedial alternatives to address the soils, ground water, and the
Cosden building.
SUMMARY OF SITE CHARACTERISTICS
An RI was performed to determine the type and concentrations of
contaminants in the various media at the Site, and in the nearby
vicinity. Samples were collected from soils, ground water, and
in the building. Details of the sampling efforts may be found in
the RI report. The collected samples were analyzed using the EPA
Contract Laboratory Program (CLP) procedures.
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Site Geology and Hydrology
The Site is located in the Atlantic Coastal Plain physiographic
province of southern New Jersey. Unconsolidated sediments in the
shallow subsurface soil at the Site are alluvial deposits
consisting mainly of sand and gravel with minor amounts of clay.
It is difficult to distinguish these sediments from the lithology
of the underlying Raritan and Magothy formations; thus, these
units are typically combined when discussing Coastal Plain
Stratigraphy.
*
The most productive aquifers in the Beverly area, and a
significant source of municipal water, are part of the Potomac-
Raritan-Magothy (PRM) aquifer system. This system is composed of
three sandy aquifers (designated lower, middle, and upper) which
are separated by intervening confining units composed of silt and
clay. The middle aquifer exists beneath the Site. All but one
of the monitoring wells installed at the Site were completed in
the middle aquifer; one well was extended to bedrock to confirm
the absence of the lower PRM aquifer in the Site area. An EPA
well survey conducted in May 1991 found no private wells used for
drinking water in the vicinity of the site.
Water-level measurements taken from monitoring wells at the Site
indicate that there is a low hydraulic gradient at the site and
that it is not possible to clearly identify a predominant ground-
water flow direction. However, regional ground-water flow is
towards pumping centers in the southeast. The water table is
located approximately twenty feet beneath the ground surface.
Elevations of the water table across the Site generally vary
within one tenth of a foot.
There is no defined surface drainage at the Site. The major
surface water feature in the area is the Delaware River,
approximately 4,000 feet north of the Site. The 100-year flood
of the Delaware River is expected to occur no closer than 3000
feet north of the Site. The closest distance that the 500-year
flood is expected to occur is approximately 1900 feet to the
north.
Nature and Extent of Contamination
Volatile organic compounds (VOCs), polynuclear aromatic
hydrocarbons (PAHs), polychlorinated biphenyls (PCBs), inorganics
(metals), and asbestos were the primary contaminants detected at
the Site. The RI identified contaminants in the soil, ground
water, and in the building located on site (See Table 1).
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Soil
The predominant soil contaminants and respective ranges of
concentration detected, in parts per million (ppm), are: VOCs -
toluene (not detected (ND) - 1,600), ethylbenzene (ND - 1,600),
trichloroethylene (ND - 1.6), and xylene (ND - 7,900); PAHs - (ND
- 3), phthalate esters (ND - 17); PCBs - (ND - 120); and metals -
chromium (6 - 36,100), cadmium (1.1 - 2.6), lead (3.7 - 6580),
and beryllium (0.2 - 0.6). Metals contamination accounts for
approximately 8,000 cubic yards (yd3) of the contaminated soil;
of this amount, approximately 350 yd3 are also contaminated with
PCBs greater than 1 ppm (See Figure 2). Soil contamination, for
the most part, is limited to the top four feet of soil. The
manufacturing processes at the Site involved the mixing of
pigments with resins and solvents to make paints and industrial
coatings. A history of poor waste handling practices and the
presence of leaking drums contributed to the soil contamination
at the Site.
Ground water
The predominant ground-water contaminants and respective ranges
of concentration detected, in parts per billion (ppb), are: VOCs
- toluene (ND - 1,800), ethylbenzene (ND - 590), and xylenes (ND
- 1,340), trichloroethene (ND - 84); and metals - beryllium (ND -
3.4), and chromium (ND - 388). The estimated dimensions of the
contaminated ground-water plume are: 200 feet wide by 100 feet
long by 60 feet deep (See Figure 3). The contaminated aquifer at
the site is the middle PRM aquifer. The ground-water plume is
situated beneath the main area of the Site, and is the result of
contamination that has migrated through the soil to the ground
water.
Building
The predominant building contaminants are: metals - copper, lead,
chromium, and zinc; PCBs; and asbestos. Additionally, the
building has been condemned because of structural failure, and is
an imminent hazard to personnel involved in on-site activities.
SUMMARY OF SITE RISKS
Based upon the results of the RI, a baseline risk assessment was
conducted to estimate the risks associated with current and
future site conditions. The baseline risk assessment estimates
the human health and environmental risk which could result from
the contamination at the Site if no remedial action were taken.
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Human Health Risk Assessment
A four-step process is utilized for assessing site-related human
health risks for a reasonable maximum exposure scenario: Hazard
Identification—contaminants of concern at the Site are
identified based on several factors such as toxicity, frequency
of occurrence, and concentration (Table 2). Exposure Assessment-
-estimates the magnitude of actual and/or potential human
exposures, the frequency and duration of these exposures, and the
pathways (e.g., ingesting contaminated well water) by which
humans are potentially exposed (Table 3). Toxicity'Assessment—
determines the types of adverse health effects associated with
chemical exposures, and the relationship between magnitude of
exposure (dose) and severity of adverse effects (response)
(Table 4). Risk Characterization—summarizes and combines
outputs of the exposure and toxicity assessments to provide a
quantitative (e.g., one-in-one-million excess cancer risk)
assessment of site-related risks. The reasonable maximum
exposure was evaluated (Table 5).
EPA uses reference doses (RfDs) to calculate noncarcinogenic risk
and slope factors to calculate the carcinogenic risk attributable
to a particular contaminant. An RfD is an estimate of a daily
exposure level that is not likely to result in any appreciable
risk of deleterious effects during a person's lifetime. A slope
factor establishes the relationship between the dose of a
chemical and the response and is commonly expressed as a
probability of a response per unit intake of a chemical over a
lifetime. Although EPA has established RfDs and slope factors
for many chemicals, there are chemicals that currently do not
have RfDs, slope factors, or similarly accepted toxicological
parameters. Consequently, the risk due to such contaminants
cannot be quantified. This is of particular significance at the
Site since lead, a major contaminant of concern, does not have an
RfD or slope factor. Therefore, lead was qualitatively evaluated
independent of the other contaminants of concern.
The Baseline Risk Assessment identified contaminants of concern
which would be representative of site risks. These contaminants
included: methylene chloride, tetrachlorethane, trichloroethene,
acetone, benzene, ethylbenzene, toluene, xylenes, arsenic,
beryllium, cadmium, chromium, carcinogenic PAHs, pesticides,
asbestos, and PCBs. Several of the contaminants, including
arsenic, beryllium, methylene chloride, PCBs, and PAHs, are known
to be, or are, probable human carcinogens.
The Baseline Risk Assessment evaluated site-specific exposure
scenarios that represent situations in which humans may be
exposed to.contaminants originating from the Site under present
and future land use patterns. Under current conditions, the
exposure pathways of concern are trespassers' exposure to surface
soil both inside and outside the fenced area, and exposures of
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8
nearby residents and other receptors to volatile organic
contaminants released into the air from the Site surface and
subsurface soil. Under a potential residential development
scenario, the key routes of exposure which were identified are
on-site residential exposures to surface soils and volatilized
contaminants in air, and exposures through the consumption of
water from wells installed in the unconsolidated aquifer which
lies beneath the Site. In addition, it was assumed that future
workers at the Site could be exposed to subsurface soil during
excavation or grading activities. Current federal guidelines for
acceptable exposure are an excess carcinogenic risk in the range
of 10"* to 10"6 (approximately one in ten thousand to one in one
million).
s
Lifetime cancer risks were calculated for all of the various
pathways under the present and future land-use scenarios. Under
current conditions, the highest risks were those associated with
dermal contact and ingestion of Site soils. Estimated cancer
risks for soil ingestion and dermal contact under the present use
scenario were 2.1 x 10"* for children, and 1.9 x ID1* for adults,
which are well within the guidelines for acceptable exposure.
These risk numbers mean that two additional children out of one
million and two additional adults out of one million are at risk
of developing cancer if the soils outside the fenced area are
ingested. Under a potential future residential development
scenario, which is considered the most conservative exposure
scenario, the estimated risks due to dermal contact and ingestion
of Site soils is 2.7 x 10'5 (2.7 in a hundred thousand) for
adults, and 3.1 x 10"5 for children, which are also within the
guidelines for acceptable exposure. However, lead, which is not
included in the quantitative risk assessment because of technical
infeasibility, has been found at concentrations above EPA health-
based guidance levels.
Under future land use scenarios, the highest risks were those
associated with ingestion of ground water. Estimated cancer
risks for ingestion of ground water were 2.8 x 10"* (2.8 in ten
thousand) for adults, and 9.0 x 10'5 for children. In addition,
the concentrations of the following contaminants were found above
promulgated Federal and/or State Maximum Contaminant Levels
(MCLs): toluene, xylene, trichloroethene, chromium, and lead.
To assess the overall potential for noncarcinogenic effects
posed, EPA developed the Hazard Index (HI). This index measures
the assumed simultaneous subthreshold exposures to chemicals,
which could result in an adverse health effect. Current federal
guidelines for acceptable exposures are a maximum health HI equal
to 1.0. The results indicated that, in the present and future
use scenarios, direct contact and ingestion of contaminated soil
do not pose an unacceptable risk to human health. The His are
estimated to be 0.054 for children, and 0.015 for adults in the
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present use scenario; and 0.52 and 0.11, respectively, in the
future use scenario. However, ingestion of contaminated ground
water in the future use scenario does pose an elevated risk to
human health. The His were estimated to be 1.6 for children, and
1.1 for adults.
Lead, which was previously identified as not having an RfD or
slope factor, is present in the soil at a maximum concentration
of 6580 ppm, and on and in. the building at percentage levels
(greater than 10,000 ppm). Exposure to lead has bee/i associated
with human noncarcinogenic effects. The major adverse effects in
humans caused by lead include alterations in red blood cell
production and the nervous system. High concentrations in the
blood can cause severe irreversible brain damage and possible
death. EPA has also classified lead as a B2 carcinogen, which
indicates that it is considered a probable human carcinogen.
EPA has developed health based cleanup levels for lead in soil
based on a model that predicts blood lead levels in the most
sensitive populations (children) from exposure to lead
contaminated air, dust, drinking water, soil, and diet. EPA
guidance recommends using a soil cleanup level of 500-1000 ppm
until RfDs and slope factors are established. Considering the
potential future residential development of the site, the lower
end of EPA's recommended soil cleanup range (500 ppm) is being
applied at the Site.
EPA has also developed health based cleanup levels for PCBs in
soil. The recommended soil action level for sites in residential
areas with PCS contamination is 1 ppm.
MCLs have been exceeded in ground water underlying the Site. The
ground water is being contaminated with metals and volatile
organic chemicals from soils on the Site.
With regard to the on-site building, conventional Superfund risk
assessment methodology is not directly applicable. The
predominant contaminant in the building is lead and, as
previously identified, lead does not have an RfD. Additionally,
the EPA lead model used to develop acceptable levels in soils
would not be applicable to the short-term exposure scenario for
the building. Therefore, the levels of lead on the building
surfaces were compared to the maximum lead levels for interior
surfaces as defined by the Federal Department of Housing and
Urban Development (HUD). The HUD standard is 2.1 milligrams per
square meter (mg/m2). Wipe samples in the building measured from
140 to 450 mg/m2. These levels represent an unacceptable short-
term exposure risk (trespasser scenario); therefore, remediation
is warranted to reduce the risk associated with exposure to the
lead contaminated building surfaces.
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10
Actual or threatened releases of hazardous substances from the
Site, if not addressed by the preferred alternative, or one of
the other active measures considered, may present a current or
potential threat to public health, welfare, or the environment.
Environmental Risk Assessment
The environmental evaluation provides a qualitative assessment of
the actual or potential impacts associated with the Site on
plants and animals (other than people or domesticated species).
The primary objectives of this assessment are to identify the
ecosystems, habitats, and populations likely to be found at the
Site and to characterize the contaminants, exposure routes and
potential impacts on the identified environmental components.
There were no endangered species, sensitive ecosystems, or
sensitive habitats identified on the Site. The environmental
assessment concluded that adverse impacts to on-site plants and
animals from on-site contamination is not likely.
Uncertainties
The procedures and inputs used to assess risks 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
- 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
exposure would occur, and in the models used to estimate the
concentrations of the chemicals of concern at the point of
exposure.
Uncertainties in toxicological data occur in extrapolating both
from 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
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making conservative assumptions concerning risk and exposure
parameters throughout the assessment. As a result, the Risk
Assessment provides upper-bound estimates of the risks to
populations near the Site, and is highly unlikely to
underestimate actual risks related to the Site.
More specific information concerning public health risks,
including a quantitative evaluation of the degree of risk
associated with various exposure pathways, is presented in the
Risk Assessment Report.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human
health and the environment. These objectives are based on
available information, applicable or relevant and appropriate
requirements (ARARs), and risk-based levels established in the
risk assessment. The following remedial action objectives were
established for the Site:
• Prevent exposure to contaminant sources that present a
significant human health risk and;
• Restore contaminated ground water to drinking water
standards.
DESCRIPTION OF REMEDIAL ALTERNATIVES
The Comprehensive Environmental Response, Compensation and
Liability Act, as amended (CERCLA) requires that each selected
site remedy be protective of human health and the environment, be
cost effective, comply with other statutory laws, and utilize
permanent solutions and alternative treatment technologies and
resource recovery alternatives to the maximum extent practicable.
In addition, the statute includes a preference for the use of
treatment as a principal element for the reduction of toxicity,
mobility, or volume of the hazardous substances.
Fifteen remedial alternatives for addressing the contamination
associated with the Site were evaluated in detail in the FS.
These included for soils: thermal desorption, in-situ vacuum
extraction, capping, incineration, and stabilization; and for
ground water: air stripping, carbon absorption, and ultraviolet
treatment. The Risk Assessment, which was prepared concurrently
with the FS, showed that VOC contamination in the soils on the
Site does not pose an unacceptable risk to human health or the
environment. Accordingly, the remedial alternatives brought
forward from the FS for evaluation in the Proposed Plan and this
Record of Decision do not include the specific treatment of VOCs
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in the on-site soils, which include: thermal desorption, in-situ
vacuum extraction, and incineration.
The estimated capital cost, operation and maintenance (O&M) cost,
and net present worth costs of each of the alternatives are
provided below for comparison purposes. It should be noted that
the noted times for implementation reflect only the time required
for actual construction and does not include the time necessary
to design the remedy, negotiate with responsible parties, or
procure contracts for design and construction.
The alternatives that remain after screening are:
SOIL REMEDIAL ALTERNATIVES
The soil remedial alternatives discussed below were developed to
address metals and PCS contamination. The volatile organic
contaminants in the soil are not above the EPA risk based
remediation goals for direct contact or ingestion. Accordingly,
the soil remedial alternatives have been developed to effectively
reduce the potential ingestion and dermal contact risks
associated with metals and PCBs.
Alternative S-l: No Action
Estimated Capital Cost: $0
Estimated 5 Year Review Cost: $20,000 per review
Estimated Present Worth: $55,600 (includes six 5 yr reviews)
Estimated Construction Time: none
CERCLA and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) require the evaluation of a No Action
alternative to serve as a point of comparison with other remedial
action alternatives. The No Action alternative for the on-site
soils would allow the Site to remain in its present condition.
Because this alternative would result in contaminants remaining
on site, CERCLA requires that the Site be reviewed at least every
five years. If justified by the review, remedial actions may be
implemented to remove or treat the wastes. No other action is
proposed under this alternative.
Alternative 8-2: Limited Action
Estimated Capital Cost: $0
Estimated Annual Operation and Maintenance (O&M) Cost: $0
Estimated 5 Year Review Cost: $20,000 per review
Estimated Present Worth: $55,600 (includes six 5 yr reviews)
Estimated Construction Time: none
The Limited Action alternative would allow the Site to remain in
its present condition, but would require that the perimeter fence
be maintained and deed restrictions imposed to restrict access.
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Because this alternative would result in contaminants remaining
on site, CERCLA requires that the Site be reviewed at least every
five years.
Alternative 6-3: Capping
Estimated Capital Cost: $599,400
Estimated Annual O&M Cost: $121,000
Estimated 5 Year Review Cost: $20,000 per review
Estimated Present Worth: $2,515,100 (includes six 5 yr
reviews)
Estimated Construction Time: six months
In this alternative, approximately 135 yd3 of contaminated soil
outside the main area of contamination would be excavated and
moved to the main contaminated area. Following consolidation, an
area of approximately 51,000 square feet area would be graded and
capped with an asphalt cap. This alternative would require deed
restrictions to protect the capped area. Because this
alternative would result in contaminants remaining on site,
CERCLA requires that the Site be reviewed at least every five
years. Additional monitoring wells would be installed and
sampled to ensure the effectiveness of the remedial action.
Alternative 8-4: Excavation, Off-Site Stabilization and Disposal,
and Backfill
Estimated Capital Cost: $7,187,850
Estimated Annual O&M: $0
Estimated Present Worth: $7,187,850
Estimated Construction Time: six months
This alternative would require that a total of approximately
8,000 yd3 of soil be excavated and treated off site. Soil
excavation would be limited to approximately a 51,000 square foot
area. The soils, which are contaminated with PCBs, and metals,
would be excavated and transported off site to a permitted
stabilization facility. Clean soil would be used to backfill the
excavated area.
Alternative 8-5: Excavation, On-Site Stabilization, and On-Site
Backfill
Estimated Capital Cost: $2,098,950
Estimated 5 Year Review Cost: $20,000 per review
Estimated annual O&M Cost: $106,600
Estimated Present Worth: $3,793,250 (includes six 5 yr
reviews)
Estimated Construction Time: one year
The soil contaminated with PCBs and metals (approximately 8,000
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yd3) would be stabilized using solidification on site. The
contaminated soil would be excavated and loaded into a batch
plant and mixed with reagents such as portland cement, fly ash,
or silicate. The solidified material would be deposited back on
the Site. Additionally, a small pile of concentrated PCB
contaminated soil would be disposed of off site. Deed
restrictions would be imposed to ensure that the stabilized
material is not disturbed. Additional monitoring wells would be
installed and sampled to ensure the effectiveness of the remedial
action. .
Alternative S-6: In-Situ stabilization
Estimated Capital Cost: $1,573,700
Estimated 5 Year Review Cost: $20,000 per review
Estimated Annual O&M Cost: $106,600
Estimated Present Worth: $3,268,000 (includes six 5 yr
reviews
Estimated Construction Time: one year
The soil contaminated with PCBs and metals (approximately
8,000 yd3) would be stabilized using in-situ solidification. This
system incorporates mechanical mixing of the contaminated soil
and injection of reagents into the soil to immobilize both PCBs
and inorganic contaminants. The stabilizing additives create a
cement-like mass that would cure in place. Additionally, a small
pile of concentrated PCB contaminated soil would be disposed of
off site. Deed restrictions would be imposed to ensure that the
stabilized material is not disturbed. Additional monitoring
wells would be installed and sampled to ensure the effectiveness
of the remedial action.
GROUND WATER REMEDIAL ALTERNATIVES
Alternative GW-i: No Action
Estimated Capital Cost: $0
Estimated 5 Year Review Cost: $ 20,000 per review
Estimated Present Worth: $55,600 (includes six 5 yr reviews)
Estimated Construction Time: none
As stated under Alternative S-l, the NCP and CERCLA require the
evaluation of a No Action alternative to serve as a point of
comparison with other remedial action alternatives. Under the No
Action alternative, contaminated ground water would remain on
site. Because this alternative would result in contaminants
remaining on site, CERCLA requires that the Site be reviewed at
least every five years. If justified by the review, remedial
actions may be implemented to remove or treat the wastes. No
other action is proposed under this alternative.
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Alternative GW-2: Limited Action
Estimated Capital Cost: $ 231,400
Estimated Annual O&M Cost: $ 90,000
Estimated 5 Year Review Cost: $ 20,000
Estimated Present Worth: $ 1,670,500 (includes six 5 yr
reviews)
Estimated Construction Time: six months
The Limited Action alternative for the contaminated, ground water
underlying the Site would include a long-term monitoring program
and an institutional control program to regulate the use of the
aquifer. The monitoring program would include the installation
and sampling of additional monitoring wells.
Alternative GW-3: On-Site Ground-Water Extraction and Treatment,
and Recharge to the Aquifer
This alternative would provide for on-site extraction and
treatment of contaminated ground water at the Site. The ground
water would be extracted, treated, and recharged to the aquifer.
Available ground-water treatment technologies are presented as
options.
Option 1: Precipitation, Air Stripping, and Reinjection.
Estimated Capital Cost: $1,438,000
Estimated Annual O&M Cost: $478,900
Estimated Present Worth: $8,799,900
Estimated Construction Time: six months
This option would consist of a treatment system which begins
with precipitation of inorganic contaminants, such as
metals. After removal of inorganics, the treated stream
would be fed into an air stripping unit designed to remove
volatile organic compounds. It is anticipated that, for
organics, treatment would need to continue until the
volatile organic contaminants in the soil no longer
represent a source of ground-water contamination. However,
it is expected that the precipitation treatment would
continue, after the organics are removed, due to the
difficulty expected in removing the metals contamination
from the ground water. Organics in the air stream may
require that the air stream be passed through a carbon
absorption unit before emission to the atmosphere. This
would be determined during design. The sludge resulting
from the inorganics precipitation and the organics captured
in the activated carbon would be disposed of off site.
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Option 2: Precipitation, Activated Carbon Treatment, and
Reinjection
Estimated Capital Cost: $1,522,800
Estimated Annual O&M Cost: $494,200
Estimated Present Worth: $9,119,600
Estimated Construction Time: six months
This option would consist of a treatment system which begins
with precipitation of inorganics such as metals. The
treated stream would then be fed into a liquid phase carbon
absorption system designed to remove volatile organic
compounds. The sludge resulting from the inorganics
precipitation and the organics captured in the activated
carbon would be disposed of off site.
Option 3: Precipitation, Ultra Violet (UV) Oxidation, and
Reinjection
Estimated Capital Cost: $1,669,200
Estimated Annual O&M Cost: $666,900
Estimated Present Worth: $11,951,100
Estimated Construction Time: six months
This option would consist of a treatment system which begins
with precipitation of inorganics such as metals. Inorganics
removal would be followed by UV oxidation. The UV oxidation
process uses UV radiation, and hydrogen peroxide and/or
ozone, to destroy toxic organic compounds in water. Organics
in the off gases may require that the gases be captured
prior to release to the atmosphere. The sludge resulting
from the inorganics precipitation, and the organics
captured, would be disposed of off site.
BUILDING REMEDIAL ALTERNATIVES
Alternative B-l: No Action
Estimated Capital Cost: $0
Estimated 5 Year Review Cost: $20,000
Estimated Present Worth: $55,600 (includes six 5 yr reviews)
Estimated Construction Time: none
The No Action alternative would allow the building to remain in
its present condition. Because this alternative would result in
contaminants remaining on site, CERCLA requires that the Site be
reviewed at least every five years. If justified by the review,
remedial actions may be implemented to remove or treat the
wastes. No other action is proposed under this alternative.
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Alternative B-2: Limited Action
Estimated Capital Cost: $30,800
Estimated Annual O&M Cost: $10,200
Estimated 5 Year Review Cost: $20,000
Estimated Present Worth: $243,200 (includes six 5 yr
reviews)
Estimated Construction Time: none
The Limited Action alternative would allow the building to remain
in its present condition but would require that the perimeter
fence be maintained to restrict access. Because this alternative
would result in contaminants remaining on site, CERCLA requires
that the Site be reviewed at least every five years. No other
action is proposed under this alternative.
Alternative B-3: Decontamination/ Demolition, and On-site
Disposal
Estimated Capital Cost: $2,852,600
Estimated Annual O&M Cost: $7,700
Estimated 5 Year Review Cost: $20,000
Estimated Present Worth: $3,026,600 (includes six 5 yr
reviews)
Estimated Construction Time: six months
This alternative would consist of decontaminating the building to
secure a non-hazardous waste classification (NJAC 7:26 ID-27),
demolition and on-site disposal of the remaining structure, and
the construction of an asphalt cap over the remaining debris.
Decontamination would include: removal and off-site disposal of
asbestos and PCB contaminated debris piles; and hydroblasting
and/or grit blasting of contaminated floors, walls, process
vessels, and tanks. Any recyclable debris and equipment would be
recycled. The decontaminated building would then be demolished
and disposed of on site as clean fill. Material not suitable as
clean fill would be disposed of at an appropriate off-site
landfill. An asphalt cap would then be placed over the resulting
clean fill. This alternative would require land use
restrictions for the capped area.
Alternative B-4: Decontamination, Demolition, and Off-site
Disposal
Estimated Capital Cost: $3,104,900
Estimated Annual O&M Cost: $0
Estimated Present Worth: $3,104,900
Estimated Construction Time: six months
This alternative would consist of decontaminating the building to
secure a non-hazardous waste classification (NJAC 7:26 ID-27),
demolition and off-site disposal of the remaining structure.
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Decontamination would include: removal and off-site disposal of
asbestos and PCB contaminated debris piles; and hydroblasting
and/or grit blasting of contaminated floors, walls, process
vessels, and tanks. Any recyclable debris and equipment would be
recycled. The decontaminated building would then be demolished
and disposed of off site.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the NCP, a detailed analysis of each remedial
alternative was conducted with respect to each of nine criteria.
This section discusses and compares the performance of the
remedial alternatives considered against these criteria. All
selected alternatives must at least attain the Threshold
Criteria. The selected alternative should provide the best
balance among the nine criteria. The Modifying Criteria were
evaluated following the public comment period.
During the detailed evaluation of remedial alternatives, each
alternative was assessed utilizing nine evaluation criteria as
set forth in the NCP. These criteria were developed to address
the requirements of Section 121 of CERCLA to ensure all important
considerations are factored into remedy selection decisions.
Threshold Criteria
1. Overall Protection of Human Health and the Environment
addresses whether or not an alternative provides
adequate protection and describes how risks posed
through each pathway are eliminated, reduced, or
controlled through treatment, engineering controls, or
institutional controls.
2. Compliance with Applicable and Relevant and Appropriate
Requirements (ARARs) addresses whether or not an
alternative will meet all of the ARARs of the Federal
and State environmental statutes or provide a basis for
invoking a waiver.
Primary Balancing Criteria
3. Long-term Effectiveness and Permanence refers to the
magnitude of residual risk and the ability of an
alternative to maintain reliable protection of human
health and the environment over time once remedial
objectives have been met.
4. Reduction of Toxicity, Mobility, or Volume addresses
the statutory preference for selecting remedial actions
that employ treatment technologies that permanently and
significantly reduce toxicity, mobility, or volume of
the hazardous substances as a principal element.
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5. Short-term Effectiveness refers to the period of time
that is needed to achieve protection, as well as the
alternative's potential to create adverse impacts on
human health and the environment that may result during
the construction and implementation period.
6. Implementability is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
alternative.
7. Cost includes estimated capital and operation and
maintenance costs, and the present worth costs.
Modifying Criteria
8. State acceptance indicates whether, based on its review
of the RI/FS and the Proposed Plan, the State supports,
opposes, and/or has identified any reservations with
the preferred alternative.
9. Community acceptance refers to the public's general
response to the alternatives described in the Proposed
Plan and the RI and FS reports. Responses to public
comments are addressed in the Responsiveness Summary of
this ROD.
A comparative analysis of the remedial alternatives based upon
the evaluation criteria noted above follows.
Overall Protection
The soil No Action (S-l) and Limited Action (S-2) alternatives do
not offer adequate protection of human health and the environment
because the levels of metals and PCBs found in the soils would
remain. Alternatives S-l and S-2 would not reduce the human
health hazards associated with direct contact and ingestion of
metals and PCB contaminated soils. The capping alternative (S-3)
would effectively control the dermal contact and ingestion
pathways, and therefore provide adequate protection of human
health. Alternative S-4, by removing all contaminated soil for
off-site disposal, would offer the greatest level of overall
protection at the Site, but would move the potential threat to
another location. Alternatives S-5 and S-6 would offer adequate
overall protection by immobilizing metals and PCB contamination
in the soils.
On-site ground water is contaminated above Federal and/or State
MCLs; therefore, overall protection of human health would not be
accomplished with Alternative GW-1. Institutional controls
contained in Alternative GW-2 would provide minimal protection by
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restricting use of the contaminated ground water. The active
remediation outlined in Alternative GW-3 would restore the
contaminated ground water to drinking water quality, and would
provide overall protection of human health. It is expected to
also significantly reduce the level of volatile organic compounds
in the soil.
Alternatives B-l and B-2 would not adequately protect human
health from the hazards associated with the Cosden building.
Lead has been identified within the building at levels which pose
unacceptable risks during acute exposures (trespasser scenario);
therefore, institutional controls would not provide adequate
protection. Alternatives B-3 and B-4 would minimize hazards
associated with direct contact and ingestion of lead
contamination in the building. In addition, health risks to on-
site workers associated.with asbestos and the potential for
physical injury from the condemned structure would not be
addressed.
Compliance with ARARs
Alternatives S-l, S-2, and S-3 would not meet the risk-based
guidance for cleanup of lead or PCBs. Alternatives S-4, S-5, and
S-6 would meet them. On-site solidification in Alternatives S-5
and S-6 may also be required to comply with the Resource
Conservation and Recovery Act (RCRA) Land Disposal Restrictions
(LDRs), based upon metals content and leachability
characteristics. Waivers from ARARs are not anticipated for any
of the active cleanup alternatives. If the selected treatment
technology cannot meet the LDR standards for characteristic
wastes, a treatability variance may be required.
Contaminant levels in the ground water are above established
MCLs, which are the applicable requirements for drinking water,
and would not be expected to appreciably attenuate. Therefore,
Alternatives GW-1 and GW-2 would not meet contaminant-specific
ARARs. Alternative GW-3 would treat the ground water until
promulgated State and Federal MCLs are attained; ARARs for
extraction and recharge of ground water would also be net.
Contaminant-specific ARARs for building remediation do not exist;
therefore, Alternatives B-l and B-2 would not have to meet any
ARARs. However, specific ARARs do exist for asbestos removal and
building demolition. Since the building is structurally unsafe,
contaminant-specific ARARs for disposal of construction debris
will be used. Based on this, Alternatives B-3 and B-4 would meet
all ARARs.
Long-Term Effectiveness
The No Action and Limited Action alternatives (S-l, S-2, GW-1,
GW-2, B-l, and B-2) would, not provide an acceptable reduction in
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risk in the soil, ground water, or the building. Each of these
alternatives would result in hazardous substances remaining on
site; this would require that EPA review the Site at least every
five years.
Alternative S-3 would provide an acceptable reduction in risk by
eliminating direct contact exposure; however, hazardous
substances would remain on site, requiring long-term maintenance
and deed restrictions to preserve its protectiveness. Each of
the treatment alternatives (S-4, S-5, and S-6) would remediate
the soil for metals and PCB contamination, and therefore, would
represent permanent solutions. However, Alternatives S-5 and S-6
would require long-term monitoring and deed restrictions to
ensure the integrity of the stabilized material on the site.
Alternative GW-3 would be consistent with the long-term
effectiveness goals for the Site by treating the ground water
until MCLs are achieved, or until it becomes technically
infeasible to attain remediation goals. Ground-water treatment
objectives would be equally well served by any of the three
treatment options.
Alternative B-3 would provide an adequate reduction in risk by
protecting against health hazards associated with direct contact
and ingestion of lead and PCBs, and physical injury from the
collapsed building. Since this alternative would include on-site
capping of the building debris, it would require long-term
maintenance and deed restrictions to preserve its protectiveness.
Alternative B-4 would permanently reuove the contaminants and
physical hazards associated with the building, and would be the
most effective long-term solution.
Reduction of Toxicity, Mobility or Volume of Contaminants
The No Action and Limited Action alternatives (S-l, S-2, GW-1,
GW-2, B-l, and B-2) would achieve only minimal reduction in
toxicity of organics, through natural biodegradation and
volatilization; while metals and PCBs would persist at high
concentrations.
Alternative S-4 would reduce the toxicity and volume of the
metals and PCBs. Alternatives S-5 and S-6 would achieve
effective reduction in mobility of the metals and PCBs through
stabilization. The stabilization process, however, would
increase the volume of the contaminated matrix up to 40 percent,
because of the addition of the solidifying reagents.
Alternative GW-3 and the associated options are all equally
effective in the reduction of toxicity, mobility, and volume of
contaminants in the ground water.
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Alternatives B-3 and B-4 would be equally effective in the
reduction of the toxicity, mobility, and volume of contaminants
to acceptable levels.
Short-Term Effectiveness
The No Action and Limited Action alternatives (S-l, S-2, GW-1,
GW-2, B-l, and B-2) would have no short-term impacts.
All of the soil treatment alternatives involve disturbing the
soil, which will generate dust and volatile emissions to some
degree. Alternative S-3 would have minimal short-term impacts
during the construction of the cap. The excavations planned in
Alternatives S-4, S-5, and S-6 would have the greatest short-term
impacts; these alternatives may require air monitoring and
engineering controls to reduce airborne dust and emissions. Since
Alternative S-6 would be conducted in-situ, it would have fewer
short-term impacts than S-4 and S-5. Preliminary modeling of the
emissions that can be expected during the excavation activities
in Alternatives S-3, S-4, S-5, and S-6, indicates that the
short-term impacts would be minimal. The amount of time until
protectiveness is achieved is approximately six months, and is
about the same for all of the soil treatment alternatives. All of
the soil alternatives would require the implementation of a
health and safety plan to minimize any risks to on-site workers
and nearby residents.
The installation and sampling of extraction and monitoring wells
in Alternative GW-3 would have a minimal short-term impact. A
health and safety plan would be implemented to minimize the well
installation and sampling risks. The estimated time to restore
the aquifer to drinking water standards is approximately thirty
years, and is the same for all three treatment options.
The asbestos removal, decontamination, and demolition activities
in Alternatives B-3 and B-4 have the-potential for adverse short-
term impacts. An air monitoring program would be required to
evaluate the type and degree to which engineering controls are
implemented. The health and safety plan would incorporate
procedures to minimize risks to on-site workers and off-site
residents.
Implementability
There are no difficulties with respect to implementing the No
Action alternatives (S-l, GW-1, and B-l), as they would only
involve five year reviews. The Limited Action alternatives (S-2,
GW-2, and B-2) are also easily implementable, as they only
involve fence maintenance, five year reviews, and deed
restrictions.
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The capping under Alternative S-3 is readily available .and easily
implemented. However, Alternative S-3 may not be consistent with
future residential use of the property. Alternative S-4 may be
difficult to implement due to the limited availability of an off-
site facility that is permitted to stabilize and dispose of the
hazardous substances contained in the on-site soils. The
solidification of metals and PCS contaminated soil is common to
Alternatives S-5 and S-6, and is an easily implemented and proven
technology. -However, some active treatment of volatile organic
contaminants will likely be necessary to ensure that the in-situ
stabilization process is not adversely affected. This may
include a soil vapor extraction process to remove high
concentrations of volatiles below the ground surface. The need
for organics removal will be based on treatability studies during
design.
The ground-water extraction and recharge systems in Alternative
GW-3 are easily implementable. Precipitation, and the air
stripping and carbon absorption treatment options are well proven
technologies. The UV oxidation technology, on the other hand, is
relatively new. The UV treatment option may experience problems
in start-up and require treatability studies to determine
effectiveness in achieving effluent limitations.
Asbestos removal in Alternatives B-3 and B-4 is widely done and
relatively easy to implement. Decontamination of the building
surfaces, which is common to these alternatives, is also easily
implementable. Demolition is a routine practice and should not
pose any problems.
A common implementation problem in remediation at Superfund sites
is the increased traffic resulting from the transport of
equipment, materials, and substances designated for off-site
disposal. Therefore, traffic control programs will be required.
Another common implementation problem may be the availability of
an on-site staging area. Any planned ground-water and/or soil
remediation alternatives will require various staging areas for
materials, equipment, decontamination, and support services. The
limited availability of a staging area would likely require that
the building demolition materials be disposed of off site.
Additionally, any intrusive soil remediation and/or building
demolition would require the removal and disposal of the four
underground storage tanks.
Cost (Also, see Table 6)
Estimated present worth costs for stabilization range from
$3,268,000 for Alternative S-6 (in-situ stabilization) to
$7,187,850 for Alternative S-4 (off-site stabilization).
Alternative S-6 is the most cost-effective alternative for metals
and PCB soil contamination that is protective of human health and
the environment.
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The estimated present worth of the treatment options in
Alternative GW-3 is $8,799,900 for Option 1, $9,119,600 for
Option 2, and $11,951,100 for Option 3. Alternative GW-3 with
Option 1 (air stripping) is the most cost-effective alternative
that will be protective of human health and the environment.
The estimated present worth of the building alternatives is
$3,026,600 for Alternative B-3 (decontamination, demolition, and
on-site disposal), and $3,104,900 for Alternative B-4.
Alternative B-4 (decontamination, demolition, and off-site
disposal) is the most cost-effective alternative that will be
protective of human health and the environment.
State Acceptance
The State of New Jersey concurs with the selected alternatives
presented in this Record of Decision.
Community Acceptance
Community acceptance was evaluated after the close of the public
comment period. Written comments received during the public
comment period, as well as verbal comments during the public
meeting on August 6, 1992, were evaluated. The response to those
comments are addressed in the Responsiveness Summary.
Comments received during the public comment period indicated that
the local residents were satisfied with the preferred alternative
for the building, however, recommended different alternatives for
the soil and ground water. The residents, in a letter to EPA,
were not supportive of the in-situ stabilization process or the
ground-water pumping and treatment system. The residents
proposed off-site disposal of the contaminated soil and no action
for the contaminated ground water.
SELECTED REMEDY
After review and evaluation of the seven remedial alternatives in
accordance with Section 121 of CERCLA and Section 300.430 of the
NCP, the EPA and NJDEPE presented Alternative GW-3 with Option 1,
Alternative S-6, and Alternative B-4 to the public as the
preferred alternative. The input received during the public
comment period is presented in the Responsiveness Summary, which
is part of this document. The public comments that were received
encompassed a wide range of issues, but did not necessitate any
major changes in the general remedial approach proposed for the
Site. Accordingly, the preferred alternative was selected.
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The major components of the selected remedy include the
following:
For soils:
In-situ stabilization of 8,000 yd3 of inorganic and PCB
contaminated soil.
For ground water:
• On-site ground-water extraction, precipitation,
treatment by air stripping, and recharge to the
aquifer.
For the building:
• Decontamination, demolition, and off-site disposal of
building debris.
The goal of the ground-water portion of the remedial action is to
restore the ground water to its beneficial use, in this case, a
potential source of drinking water. However, EPA recognizes that
the selected remedy may not achieve this goal because of the
technical difficulties associated with achieving ground-water
cleanup levels. It may become apparent, during implementation or
operation of the ground-water extraction/treatment system that
contaminant levels have ceased to decline and are remaining
constant at levels higher than the remediation goal. In such a
case, the system's performance standards and/or the remedy may be
reevaluated. Performance monitoring of the ground-water
extraction and treatment system will be implemented. The data
collected would be used to suggest system adjustments or
modifications to provide more effective or efficient attainment
of cleanup levels. Such adjustments or modifications may
include: increasing or decreasing the extraction rate, initiating
a pulsed pumping schedule, installing additional extraction
wells, or ceasing extraction at wells where cleanup levels have
been achieved. Monitoring data will be used to assess the
effectiveness of the modifications implemented and may be used to
re-assess the time frame required to achieve cleanup levels.
The levels of volatile organic contamination in the soils do not
pose unacceptable dermal contact or ingestion risks;
consequently, no active remedial Treasures are necessary to
address these risks. However, the volatile organic contaminants
in the soil represent a continuing source of ground-water
contamination; it is expected that these volatile contaminants
would be gradually reduced through natural soil flushing and the
ground-water pumping and treatment program. In addition,
although no active treatment of volatiles in the soil are
necessary to address direct contact or ingestion risks, treatment
-------
26
will be necessary of some of the more contaminated soils, if it
is confirmed during design that the in-situ stabilization process
may be compromised.
The soil and ground-water cleanup levels for the Site are listed
in Table 7. NJDEPE has requested that soil and ground-water
contamination at the Site be remediated to the levels specified
in its Proposed Cleanup Standards for Contaminated Sites
(February 1992). These proposed standards are not recognized as
ARARs
•
The EPA and NJDEPE have agreed that site-specific risk-based
cleanup levels will be used for soil and ground-water
remediation. EPA recognizes NJDEPE's request that soil and
ground water be remediated to the levels specified in its
Proposed Cleanup Standards for Contaminated Sites (February
1992). These proposed standards are not recognized as ARARs
under Section 121(d) of CERCLA because they are not yet
promulgated. However, EPA has determined that further
remediation of the soil and ground water at the Site to the
levels requested by NJDEPE, would not conflict, or be
inconsistent, with the selected remedy. The NJDEPE may agree to
undertake, and fund the incremental cost associated with this
additional cleanup.
In summary, the selected remedy achieves ARARs more quickly, or
as quickly, and at less cost than the other options. Therefore,
it will provide the best balance among alternatives with respect
to the evaluating criteria. EPA and the NJDEPE believe that the
preferred alternative will be protective of human health and the
environment, will comply with ARARs, will be cost effective, and
will utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable. The remedy also will meet -the statutory
preference for the use of treatment as a principal element.
STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that are
protective of human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory
requirements and preferences. These specify that when complete,
the selected remedial action for this 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 also must be
cost effective and utilize permanent solutions and alternative
treatment technologies or resource-recovery technologies to the
maximum extent practicable. Finally, the statute includes a
preference for remedies that employ treatment that permanently
-------
27
and significantly reduce the volume, toxicity, or mobility of
hazardous wastes. The following sections discuss how the
selected remedy meets these statutory requirements.
Protection of Hunan Health and the Environment
The selected remedy is protective of human health and the
environment, dealing effectively with the threats posed by the
contaminants which were identified.
The principal threat posed by the Site is the contaminated soils.
Stabilizing the contaminated on-site soil will protect against
future direct contact, ingestion, and inhalation hazards.
Additionally, the stabilization will prevent the infiltration of
soil contaminants into the ground water.
Capturing and treating the contaminated on-site ground water will
protect against future ingestion hazards. The contaminants in
the ground water will be reduced to levels that are acceptable
for drinking water.
Decontamination of the building will protect against future
inhalation and ingestion hazards. Demolition and off-site
disposal will eliminate the physical hazards, associated with the
condemned building, for on-site workers.
Compliance with ARARs
The selected remedy will comply with the substantive requirements
of the following statutes and regulations.
Chemical-specific ARARs (Tables 7 and 8)
The contaminants of concern in the ground water will be reduced
to levels that meet Federal and/or State MCLs.
"~s
The contaminants of concern in the soil will be treated to reduce
the direct contact, ingestion, and inhalation exposure risks to
1 x 10*6 for carcinogens, and to an HI less than 1.0 for
noncarcinogens.
Action-specific ARARs (Table 9)
The ground-water treatment system will be designed to treat the
extracted ground water to MCLs prior to recharge to the aquifer.
All sludge produced by the ground-water treatment system will be
handled and disposed of in accordance with the Resource
Conservation and Recovery Act, the Hazardous and Solid Waste
Regulations of 1984, the Hazardous Materials Transportation Act,
and the Occupational Safety and Health ACT.
-------
28
The air stripper element of the ground-water treatment system
will be designed to meet the New Jersey Air Pollution Control
Regulations for VOC and toxic emissions (NJAC 7:27-16 & 17).
The stabilized soil will meet RCRA standards for leachability and
toxicity.
PCB contaminated soil will be disposed of in accordance with the
Toxic Substances Control Act.
The decontaminated building debris will be disposed of in
accordance with the New Jersey Regulations for the Identification
of Hazardous Waste.
Location-specific ARARs
There are no location-specific ARARs associated with the soil,
ground water, or building remedies.
Advisories. Guidance and Criteria To Be Considered (TBCsl
The shipment of hazardous wastes off site to a treatment/disposal
facility will be conducted in accordance with EPA's Office of
Solid Waste and Emergency Response Directive No. 9834.11,
"Revised Procedures for Planning and Implementing Off-site
Response Actions". The intent of this directive is to ensure
that facilities authorized to accept CERCLA-generated waste are
in compliance with RCRA operation standards.
Cost-Effectiveness
Of the alternatives which most effectively address the threats
posed by Site contamination, the selected remedy provides for
overall effectiveness in proportion to its cost. The estimated
total project cost is $15,172,800.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
Contaminants in the ground water will be removed and treated
before reinjection and/or surface discharge. Hazardous wastes
generated by the treatment process will be disposed of at an
approved off-site facility. This will significantly reduce the
toxicity, mobility and volume of the contaminants, and offer a
permanent solution to the risks posed by the contaminated ground
water.
The treatment of soils and debris contaminated with PCBs over
50 ppm at an approved off-site facility will significantly reduce
the toxicity, volume and mobility of the contaminants.
-------
29
The stabilization of soil contaminated with metals and PCBs less
than 50 ppm will reduce the mobility of these contaminants and,
therefore, represents a permanent solution to the risks posed by
the contaminated soil. However, the toxicity and volume of the
contaminated soil will not be reduced. Considering the
relatively large volume of metals and PCB contaminated soil
(8000 yd3), EPA believes that the selected remedy represents the
maximum extent to which the toxicity, mobility, and volume can be
reduced in a cost-effective manner.
Decontamination of the building and off-site disposal of the
building debris will permanently remove the physical and health
hazards associated with it.
Preference for Treatment as a Principal Element
The selected ground-water remedy satisfies the preference for
treatment as a principal element. The on-site contaminated
ground water will be extracted and treated, using precipitation
for metals and air stripping for VOCs, to reduce the levels of
contaminants, thereby reducing the risk to human health.
The statutory preference for remedies that employ treatment as a
principal element will also be satisfied for the contaminated on-
site soil. The metal and PCB contaminated soil will be
stabilized in-situ, thereby reducing risk to human health.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Site was released to the public on
July 27, 1992. The Proposed Plan identified the preferred
alternatives for ground water, soil, and the building
remediation. EPA reviewed all written and verbal comments
received during the public comment period. Upon review of these
comments, EPA determined that no significant changes to the
selected remedy, as it was originally identified in the Proposed
Plan, were necessary.
-------
30
APPENDIX I
FIGURES
-------
-------
Figure 2
PRINCIPAL AREASX)F SOIL CONTAMINATION
RESIDENTIAL
AftCA
Cherry Street
'.'<.« .!•; I.«. I. I . l.i .1 I.I.I
CONRAR.
ft AN.-ROAD
Open
-------
Figure 3
PRINCIPAL AREASXJEJ6ROUND-WATER CONTAMINATION
RESIDENTIAL
AREA
«. i. t .>< < i.»
CONRAIL
RAIL-ROAD
TRACKS
-------
31
APPENDIX II
TABLES
-------
Table 1
Predominant Site Contaminants and Range of Concentration Detected
CONTAMINANT
Toluene
Ethylbenzene
Xyfene
Trichloroctriene
Lead
Cadmium
Chromium
Beryllium
Po/ychlorinated Biphenyls
(PCBs)
SOIL (ppm)
ND • 1,600
^^ND- 1,600
.— «^jD . 7|900
ND - 1.6
3.7-6,580
1.1 • 2.6
6-36,000
0.2 - 0.6
ND - 120
GROUND WATER (ppb)
KID- 1,800
ND-590
ND- 1,340
ND-84
ND - 29.5
ND
ND-388
ND - 3.4
ND
ppm =
ppb =
ND •=
pans per million
parts per billion
Not Detected
-------
Table 2
SUMMARY OF COSDEN CHEMICAL SITE
CONTAMINANTS OF CONCERN
Chlorinated Volatile Organics
Chloroform . SO
Chlororoethane ' SO
cis-l,2-Dichloroethene SC
Methylene Chloride SG
Tetrachloroethene . — .•• SI, SS, SG, GAS
1,1,2-TricUoroethane SG
Trichloroethenr SI, SS, SG, GAS
Nonchlorinated Volatile
Acetone SG
Benzene SG
Carbon Disulfide SG
Ethylbs.nztne SI, SS
Toluene SI, SS, SG, GAS
Xylenes SG ' '
CPAHs SI, SO, SS
BEHP SI, SG
2,4-Diniethylphenol . SG
2-Meihylphenol SG
4-Methylphenol SG
Naphthalene SI, SG
N-Nitrosodipropykmine SS
Pestj'cidg^CBs
Aroclor 1254 SI, SS
4,4'-DDT SO
-------
Table 2 (cont'd)
SUMMARY OF COSDEN CHEMICAL SITE
CONTAMINANTS OF CONCERN
stals
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Manganese
Mercury
Nickel
Selenium •
Silver
Thallium
Vanadium
Zinc
SI, SO,
SI, SO,
SI, SO,
SI, SO,
SI, SO,
SI, SO,
SI, SO.
SI, SO.
SI, SO.
SI, SO,
SG
SG
SI, SS
SI, SO,
SI, SO,
SS, SG
SS, SG
SS, SG
ss, s6
SG
SS, SG
SS, SG
SS. SG
SS, SG
SG
SS.SG
SS, SG
SI ~ Surface Soil Inside Fence
SO = Surface SoiJ Outside Fence
SS = Subsurface Soil
SG = Shallow Aquifer Groundwater
GAS * Soil Gas Survey
-------
Table 3
COSDFN CHEMICAL SITE
POTENTIAL EXPOSURE PATHWAYS AND POPULATIONS
PATHWAY
POPULATION
CURRENT SITE LAND USE
o Surface Soil
Incidental Ingestton QrwMe and outside fence)
Dermal Contact (Inside and outside fence)
o Air
Inhalation of Airborne (vapor phase) chemicals (offslte)
j. Trespassers on site
II Trespassers on site
nosiooms wving now site
FUTURE SITE LAND USE
o Surface Son
Incidental Ingestton
Dermal Contact
Inhalation of Airborne (vapor phase) chemicals
o Subsurface Soil
Incidental Inojestlon
Dermal Contact
Inhalation of Airborne (vapor phase) chemicals
o Groundwater
Ingestton
Residents IMng onslte
Residents living onslte
Residents IMng onslte
Construction workers
Construction workers
Construction workers
Residents living onslte
-------
Table 4
TOXICTTY DATA FOR NONCARCINOGENIC EH-kClS>
DOSE RESPONSE EVALUATION
COSDEN CHEMICAL SITE
For Groundwater
Oral RID Inhalation RiD
Chemical Name (me/kp/dav) fme/rn)
acetone 1.0 E01
carbon disulfide 1.0 E' 1-0 E"02
chloroform 1.0 E02
methylene chloride 6.0 E*2 3.0 E*°°
4-methyl-2-pentanone 5.0 E02 8.0 E*1
Tetrachloroethylene 1.0 E*2
toluene 2.0 E01 2.0 E*"0
1,1,2 - trichloroethane 4.0 E05
mixed xylenes 2.0 E*° 3.0 E01
bis (2-ethylhexyI) phthalate 2.0 E02
2,4-dimethylphenol 2.0 E02
o-cresol 5.0 E"01
p-cresol 5.0 E"02
naphthalene 4.0 F08
antimony 4.0 E°*
arsenic 1.0 x KT5 3.0 E"
barium 5.0 x Ifr2 5.0 E°
beryUium 5.0 E05
cadmium 5.0 E01
chromium 5.0 E03
copper 3.7 E*
DDT 5.0 E04
Ethylbenzene 1.0 E01 1.0 E*°°
manganese 1.0 E01 4.0 x
mercury 3.0 E04 3.0 x
nickel 2.0 E02
selenium 5.0 E03
silver 3.0 E°
vanadium 7.0 E03
zinc 2.0 E01
Note: Toxicity values are from "Risk Assistant", 1992.
-------
Table 4 (cont'd)
TOXICITY DATA FOR CARCINOGENIC EFFECTS
DOSE RESPONSE EVALUATION
COSDEN CHEMICAL SITE
Cancer Potency
Chemical Name Slope Unit Risk
(ing/kg/day)-1 (^9/m3)'1
benzene 2.9 x Ifr2 83x10*
chloroform 6.1 x 104 23 x 10's
methyl chloride 13 x 10'2 1.8 x 10*
methylene chloride 7.5 xlO"3 2.1 x Ifr7
perchloroethylene 5.1 x 10'J 52 x 10'7
l,U-trichk>roethane 5.7 x 10"1 1.6x10*
bis (2-etiylhocyl) phthalate 1.4 x 10~:
beryllium 43 x 10°
tricholoroethylene 1.1 x Ifr2 1.7 x 10*
3,4-benz (a) pyrene 5.8 E*°°
N-nitrosodi-n-propylamine 7.0 x 10°
Pofychlorinated biphenyls 7.7 E400
-------
Table 5
COSOfN CHEMICAL SHE
SUMMARY OF RISKS ACROSS PATHWAYS
PATHWAY
CARCINOGENIC MSK9
ADULTS
CHILDREN
NONOWONOOENIC HAZARD fJCTCCT
ADULTS
CMUJWCH
Omni OonM «*h Ml. M* *
Ow Ml Contort trfhSol
2.ME48
a.ocxn
4.4C-08
1.1M9
S.9&4C
9.0E49
S.4C-02
-------
Table 5 (cont'd)
COSDEN CHEMICAL SITE
SUMMARY OF RISKS ACROSS PATHWAYS
FUTURE-USE
CARCINOGENIC RISKS
NONCARCINOQENIC HAZARD INDICES
RECEPTOR
PATHWAY
ADULTS
CHILDREN
ADULTS
CHILDREN
SollngMlon.MctoFtno*
Sol (ngwfan - OuWcto Nno» (
ato)
Dwiml Contort vrffc Sol -
DwiMl CantaotwWi Sol •
1.4E-08
8.8E-07
7.1E-08
1.8E-08
2.0EXM
7.7E-08
4.8E-06
9.8E-06
*
8.6E-06
e.oe-05
B.6E-09
3.3E-03
3.7E-04
1.2E-03
Q.2E-02
1.1E+01
2.2E-01
0.9E-08
2.2E-03
6.9E-03
1.9E-01
1.66+01
3.1E-04
12E-04
1.1E+01
1.7E+01
•kxiMsd Mlno aol gm data to wfln
-------
Table 6
Summary of Estimated Capital and Present Worth Costs
Alternative 6-1: No Action.
Estimated Capital Cost: $0
Estimated 5 Year Review Cost: $20,000 per review
Estimated Present Worth: $55,600 (includes six 5 yr reviews)
Estimated Construction Time: none
Alternative 8-2: Limited Action.
Estimated Capital Cost: $0
Estimated Annual Operation and Maintenance (O&M) Cost: $0
Estimated 5 Year Review Cost: $20,000 per review
Estimated Present Worth: $55,600 (includes six 5 yr reviews)
Estimated Construction Time: none
Alternative 8-3: Capping.
Estimated Capital Cost: $599,400
Estimated Annual O&M Cost: $121,000
Estimated 5 Year Review Cost: $20,000 per review
Estimated Present Worth: $2,515,100
Estimated Construction Time: six months
Alternative 6-4: Excavation, Off-Site Stabilization and Disposal,
and Backfill.
Estimated Capital Cost: $7,187,850
Estimated Annual O&M: $0
Estimated Present Worth: $7,187,850
Estimated Construction Time: six months
Alternative 8-5: Excavation, On-8it« Stabilization, and On-Site
Backfill
Estimated Capital Cost: $2,098,950
Estimated 5 Year Review Cost: $20,000
Estimated annual O&M Cost: $106,600
Estimated Present Worth: $3,793,250
Estimated Construction Time: one year
Alternative 8-6: In-Situ Stabilization
Estimated Capital Cost: $1,573,700
Estimated 5 Year Review Cost: $20,000
Estimated Annual O&M Cost: $106,600
Estimated Present Worth: $3,268,000
Estimated Construction Time: one year
-------
Table 6 (cont'd)
GROUND WATER REMEDIAL ALTERNATIVES
Alternative GW-l: No Action.
Estimated Capital Cost: $0
Estimated 5 Year Review Cost: $ 20,000 per review
Estimated Present Worth: $55,600 (includes six 5 yr reviews)
Estimated Construction Time: none
Alternative GW-2: Limited Action.
«
Estimated Capital Cost: $ 231,400
Estimated Annual O&M Cost: $ 90,000
Estimated 5 Year Review Cost: $ 20,000
Estimated Present Worth: $ 1,670,500
Estimated Construction Time: six months
Alternative GW-3: On-Site Ground Water Extraction and Treatment,
and Recharge to the Aquifer.
Option 1: Precipitation, Air Stripping, and Reinjection.
Estimated Capital Cost: $1,438,000
Estimated Annual O&M Cost: $478,900
Estimated Present Worth: $8,799,900
Estimated Construction Time: six months
Option 2: Precipitation, Activated Carbon Treatment, and
Reinjection.
Estimated Capital Cost: $1,522,800
Estimated Annual O&M Cost: $494,200
Estimated Present Worth: $9,119,600
Estimated Construction Time: six months
Option 3: Precipitation, Ultra Violet (UV) Oxidation, and
Reinjection.
Estimated Capital Cost: $1,669,200
Estimated Annual O&M Cost: $666,900
Estimated Present Worth: $11,951,100
Estimated Construction Time: six months
-------
Table 6 (cont'd)
BUILDING REMEDIAL ALTERNATIVES
Alternative B-l: No Action.
Estimated Capital Cost: $0
Estimated 5 Year Review Cost: $10,100
Estimated Present Worth: $13,400
Estimated Construction Time: none
Alternative B-2: Limited Action.
Estimated Capital Cost: $30,800
Estimated Annual O&M Cost: $10,200
Estimated Present Worth: $243,200
Estimated Construction Time: none
Alternative B-3: Decontamination/ Demolition, and On-site Disposal.
Estimated Capital Cost: $2,852,600
Estimated Annual O&M Cost: $7,700
Estimated 5 Year Review Cost: $20,000
Estimated Present Worth: $3,026,600
Estimated Construction Time: six months
Alternative B-4: Decontamination, Demolition, and Off-site
Disposal.
Estimated Capital Cost: $3,104,900
Estimated Annual O&M Cost: Not Applicable (N/A)
Estimated Present Worth: $3,104,900
Estimated Construction Time: six months
-------
Table 7
SUMMARY OF CHEMICALS OF CONCERN AND
CORRESPONDING ARARs/TBCs
GROUND WATER
Site Contaminant
Toluene .
Trichloroethene
Ethylbenzene
Xylene
Chromium (total)
Lead (at tap)
Maximum Concentration
Detected (ppb)
1,800
84
590
1,340
388
29.5
ARAR
(PPb).
1.0001-2
12
700 1'2
442
100 1>2
15 (TT)
TBC3
(ppb)
1,000
N/A
700
N/A
100
N/A
TT
N/A
Federal Drinking Water Standard (MCL) (40 CFR Part 141)
New Jersey Safe Drinking Water Act (SMCL) (NJAC 7:10-16)
Non-zero Maximum Contaminant Level Goals (MCLGs)
Treatment Technique
Not Applicable
SOIL
Site Contaminant
Beryllium
Chromium
Lead
PCB
Maximum Concentration
Detected (ppm)
1.5
36,100 (total)
6,580
120
ARAR4
1s
78,000 (+3)6
390 (+6)6
5007
18
Defines the aerial extent of soil to be stabilized (approximately 8000 yd3)
Calculated from 1x10* risk, then deferred to the practical quantification limit.
Calculated from 1x10* risk
Established by OSWER directive #9355.4-02
Established by OSWER directive #9355.4-01
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Table 8
CONTAMINANT-SPECIFIC ARARj, CRITERIA AND GUIDANCE
Sheet I of 2
REGULATORY LEVEL ARAR IDENTIFICATION
STATUS
REGULATORY SYNOPSIS
FS CONSIDERATION
Federal
Federal
Paten)
Federal
Federal
Federal
RCRA Mnimum Contaminant1
Levels (MCLs)
SDWA Maximum Contaminant1
Levels (MCLs)
SDWA MCL Goals'
Toxic Substance Control Act
(TSCA) PCB Regulations
(40 CFR 761)
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
RCRA Identification of Relevant and
Hazardous Waste (40 CFR 261) Appropriate
RCRA Land Disposal Restriction Applicable
(LDR) (40 CFR 268)
National Ambient Air Quality Applicable
Standards (NAAQS) (40 CFR SO)
Applicable
Provides standards for 14 toxic com-
pounds and pesticides for protection
of groundwater. These standards are
equal to the MCLs established by
SDWA.
Provides standards for toxic
compounds for public drinking
water.
EPA has promulgated contaminants levels
and has proposed others for public
water system. The MCLGs are health
goals and are set si levels that
would result in no known or anticipated
adverse health effects with an adequate
margin of safety.
Provides regulations concerning
identification and classification of
RCRA Hazardous Waste.
Limits land disposal options and provides
treatment standards for contaminants
prior to disposal.
These standards provide acceptable
limits for paniculate matter, sulfur
dioxide, nitrogen dioxide, carbon
monoxide, ozone, and lead that must
not be exceeded in ambient air.
Requires materials containing PCB concen-
trations greater than SO ppm to be incin-
erated, disposed of in a TSCA landfill or
alternate treatment to reduce PCBs to 2 ppm.
The promulgated values are included
in the SDWA MCLs. The combined
standards are compared with the
maximum contaminant levels at the
site to determine the level of
contamination.
The promulgated values are used as
standards to determine the level of
treatment for groundwater discharge.
MCLGs are used as reference values to
indicate contaminant levels for the
site.
Will be used to determine RCRA b'sted
and characteristic waste present at
the site.
Treatment standards or BDAT require-
ments must be met prior to land dis-
posal. Effective for CERCLA soil
and debris as of November 1990.
»
Remediation technologies that could
release contaminants into the air
will be designed to meet these
standards.
Treatment standards will be used for PCB
remediation and disposal.
EI208.LYN
-------
Table 8 (cont'd)
CONTAMINANT-SPECIFIC ARARs. CRITERIA AND GUIDANCE
Sheet 2 of 2
REGULATORY LEVEL ARAR IDENTIFICATION
STATUS
REGULATORY SYNOPSIS
FS CONSIDERATION
Federal
PeQenJ
New Jeney
New Jeney
New
New Jeney
New Jeney
TSCA PCB Spill Cleanup
and Disposal Regulations
(40CFR761)
EPA Risk Reference Doses
(RfDs)
New Jeney Regulation*
for the Identification of
Hazaidotis Waste (NJAC 7:26-8)
New Jeney Oroundwater'
Quality Standards
New Jeney Safe Drinking '
Water Act Maximum Contaminant
Levels (MCU) (NJAC 7:10-16)
New Jeney Ambient Air
Quality Standards (NJAC 7:27-13)
New Jeney RCRA MCLs
(NJAC 7:14A-6.15)1
Applicable
To Be Considered
Applicable
Applicable
Relevant and
Appropriate
Applicable
Relevant and
Appropriate
These regulations provide requirements and
cleanup levels for PCB spills and disposal
of PCB contaminated media.
RfDs are considered to be the levels
unlikely to cause significant adverse
health effects associated with a
threshold mechanism of action m
human exposure for a lifetime.
Provides regulations concerning the
identification and classification of
Hazardous Waste
Provides quality standards for
groundwater based on aquifer
characteristics and use.
Provides quality standards for
drinking water.
Provides guidance regarding
air emissions.
Provides standards for toxic
compounds for the protection
of groundwater.
Remediation of soil contaminated and
PCBs will comply with these regulations.
EPA Reference Doses are used to
characterize risk associated with
non-carcinogens in various media.
WiD be used to determine listed and
characteristic hazardous waste at the
site.
The levels win be compared to levels
at the site to determine
contaminant migration.
These levels will be compared to
contaminant levels at the site
to determine contaminant
migration.
Remedial activities which cause
sir emissions will conform to
»these standards.
These standards win be compared with
contamination levels at the site to
determine the level of contamination.
1) Applies to alternatives including graundwater monitoring
ILYN
-------
Table 9
ACTION-SPECIFIC ARARs
Page 1 of 3
REGULATORY LEVEL
ARARS
STATUS
REGULATORY SYNPOSIS
A. Common to ill Alternative!
OSHA - General Industries Standards
(29 CPR 1910)
OSHA - Safety and Health Standards
(29 CFR 1926)
OSHA - Recordkeeping. Reporting and
Related Regulations
(29 CPR 1904)
RCRATSDP Regulation
(40 CFR 264 and 263 subparH A, B. C,
D, B, P, O, L, and N)
RCRA Requirements
for Transporting Waste for
Off-Site Disposal (40 CFR 263)'
RCRA Standards for Generators of
Hazardous Waste (40 CFR 262)
RCRA Nonhazardoos Waste Management
Standards (40 CPR 237)*
RCRA Groondwater Monitoring Requirements
(40CFR264SubpartP)4
National Emission Standards for
Hazardous Air Pollutants (NESHAPS)
(40 CPR 61)
Applicable These standards regulate the 8-hour time weighted
average concentration for worker exposure to various
compounds. Timing requirements for workers at hazardous
wastes operations are also specified.
Applicable This regulation specifies the type of safety
equipment and procedures to be followed during site
remediation.
Applicable Tins regulation outlines the recordkeeping and
reporting requirement* for an employer under OSHA.
Relevant and Provides standards for hazardous waste treatment facilities
Appropriate with regard to design and operation of treatment, storage and
disposal systems (ie, general facility standards, landfills,
incinerators, containers, etc.)
Relevant and Provide* manifest and record keeping requirements for
Appropriate generators of hazardous waste.
Relevant and General standards for generators of hazardous waste.
Appropriate
Relevant and Provides standards for the management of nonhazardous
Appropriate waste under RCRA Subpart D.
Relevant and This regulation details requirements for
Appropriate groundwater monitoring programs.
Applicable Provides standards for acceptable limits for
specific chemicals in air emissions. Requirements
address operational, record keeping, and general emission
standards (hat apply to air pollution control equipment
BI2M.LYN
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Table 9 (cont'd)
ACTION-SPECIFIC ARARs
Sheet 2 of 3
REGULATORY LEVEL
ARARS
DOT Rules for Hazardous
STATUS
Applicable
REGULATORY SYNPOS1S
Provides requirements for the transportation
Materials Transport (49 CFR 171)'
New Jersey Department of Transportation
Regulations for Transport of Hazardous
Waste (NJAC 7:26-3 and 7)
New Jersey Standards for the
Design and Operation of Hazardous
Waste Treatment Faculties (NJAC 7:26)
New Jersey Noise Pollution
Regulations (NJAC 7:29)
Relevant and
Appropriate
Applicable
of hazardous waste.
Provides requirements for the transportation of
hazardous waste.
This regulation outlines general waste facility
requirements with regard to waste analysis.
security measures, inspection and training requirements.
Provides standards for (he control of noise pollution.
B. Orotmdwaler
C. Soil and Building
NPDES Regulations
(40 CFR 122)
New Jersey Pollution Discharge
Elimination System Regulations
NJAC (7:14A)
RCRA Closure and Post-Closure
Standards (40 CFR 264. Subpart 0)
RCRA Subtitle D Nonhazardous
Waste Management Standards
(40 CPR 257)1
Relevant and Provides regulations for discharge of the treatment
Appropriate system effluent and stormwater runoff. Refers to effluent
limitations for discharge to surface water.
Relevant and Provides regulations for discharge of pollutants
Appropriate to surface water of the State.
Relevant and This regulation details specific requirements for
Appropriate closure and post-closure of hazardous waste
facilities.
Relevant and Provides regulations for the management of non-
Appropriate hazardous waste.
El
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Table 9 (cont'd)
ACTION-SPECIFIC ARARs
Sheet 3 of 3
REGULATORY LEVEL
ARARS
STATUS
REGULATORY SYNPOSIS
RCRA Land Disposal Restrictions
(LDRs) (40 CPR 268)
TSCA PCB Spill Cleanup and Disposal
Regulations (40 CPR 761)
New Jersey RCRA Closure and Post-
Closure Standards (NJAC 7:26)
New Jersey Asbestos Regulations
(NJAC 12:120 and 8:60)
New Jersey Standards for Generators
of Hazardous Waste (NJAC 7:26)
New Jersey Air Pollution Control
Requirements (NJAC 7:27)
New Jersey Soil Erosion and Sediment
Control Act Requirements'
Applicable Regulates land disposal of hazardous waste. Provides
treatment levels which must be met before land disposal of
hazardous waste may occur.
Applicable Remediation and disposal of PCB contaminated soils will be
in compliance with these regulations.
Relevant and This regulation details specific requirements for
Appropriate closure and post-closure of hazardous waste facilities.
Relevant and Remediation of asbestos will comply with pertinent sections
Appropriate of these regulations.
Applicable General Standards for generators of hazardous waste.
Applicable Provides guidelines for the control of Air
contaminants.
To Be Considered Provides guidelines for soil erosion and sediment
control plans.
1) Applies to alternatives involving excavation only.
2) Applies to alternative which involve on-sfte disposal.
3) Applies to alternatives which involve off-she transportation
4) Applies to gnnmdwater monitoring.
GI2M.LYN
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33
APPENDIX IV
STATE LETTER OF CONCURRENCE
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SEP 2
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SEP 29 '32 12:03PM NAT'L GOVERNORS'ASSOCIATION
P. 4
Tha State of K«v Jersey appreciates the opportunity to participate in this
decifion making proces* and looki forward to future cooperation with th»
UlIfA.
Sinctrely
Scott A. Walnar
Conmitsionar
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