PB94-963841
                                EPA/ROD/R02-94/236
                                March 1995
EPA  Superfund
       Record of Decision:
       Dayco Corp./L.E. Carpenter Co.
       Wharton Borough, NJ
       4/18/1994

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       SUPERFUND RECORD OF DECISION
 I.E. CARPENTER/ DAYCO CORPORATION SITE
            WHARTON BOROUGH
              MORRIS COUNTY
                NEW JERSEY
Prepared by:
N.J. Department of Environmental Protection and Energy
Site Remediation Program
Bureau of Federal Case Management
April 1994

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                           L. E. CARPENTER SITE
                           RECORD OF DECISION

                           TABLE OF CONTENTS
Declaration Statement for the Record of Decision	1

Decision Summary  	3

Glossary  	25

Responsiveness Summary  	27

Appendices
Appendix A       Discharge Numbers
                 NJ Ground Water Quality Standards                         A-1
Appendix B       Soil Remediation Cleanup Goals                            A-4
Figures
Figure 1          Location Site Map
Figure 2          Map showing contaminated area
Figure 3          Areas of Concern
Figure 4          Alternative #4 Schematic

Tables
Table 1           Chronology of Investigative Remedial Activities
Table 2           Potential ARARs and TBCs
Table 3           Risk Assessment Summary
Table 4           Remedial Technologies Evaluated
Table 5-1         Summary of Technical Screening for Soil
Table 5-2         Summary of Technical Screening for Ground Water
Table 6           ARARs Compliance Summary
Table 7           Preliminary Cost Estimates

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                 Declaration Statement for the Record of Decision
                               L. E. Carpenter Site

Site Name and Location

L. E. Carpenter / Dayco Corporation
Wharton Borough, Morris County, New Jersey

Statement of Basis and Purpose

This decision document presents the selected remedial action for the L. E. Carpenter Co./
Dayco Corporation site  (hereinafter L E. Carpenter  site or site),  in Wharton Borough,
Morris County, New Jersey, which was chosen in accordance with the requirements of the
Comprehensive Environmental  Response, Compensation, and Liability Act of 1980,  as
amended (CERCLA) by the  Superfund Amendments and Reauthorization Act  of 1986
(SARA) and, to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) and New Jersey Public Law 1993,  Chapter  139.  This decision
document explains the factual and legal basis for selecting the remedy for this site.

Assessment of the Site

Actual or threatened releases of hazardous substances from  this site,  if not addressed by
implementing the response action selected in this Record of Decision (ROD), may present
an imminent and substantial threat to public health, welfare, or the environment.

Description of the Selected Remedy

The ROD addresses all contaminated media at the site including the soil and ground water.
The selected remedy is "Ground Water Treatment with Reinfiltration/Soil Bioremediation".

The major components of the selected remedy include:

•     Floating product/ground water extraction system installation and operation.

•     Remediation via biological treatment of extracted ground water.

•     Excavation and consolidation of bis(2-ethylhexyl)phthalate  (DEHP) contaminated
      soils into soil treatment zone.

•     Reinfiltration of a portion of  treated ground water (with added oxygen and nutrients)
      into the unsaturated soil treatment zone via  perforated piping to allow in situ
      bioremediation of contaminated soils.

•     Recirculate a larger  portion of treated water within the capture zone.  Remaining
      treated ground water will be discharged into a  deeper aquifer  in accordance with
      ground water discharge criteria.

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•     Provide vegetative soil cover for the area of ground water infiltration system.

•     Spot excavation and disposal of soils containing polychlorinated biphenyls (PCBs),
      lead and antimony where levels exceed the soil cleanup levels in locations other
      than the east soils area designated as the disposal area. Excavation and disposal
      of disposal area sludge/fill, which may inhibit in situ treatment.

•     Environmental use restrictions on property.

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.  This 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 that
reduce toxicity, mobility,  or volume as their principal element.

This remedy will  result in hazardous substances remaining on site while the remediation
is in process. Therefore, a review may need to be conducted pursuant to CERCLA every
5 years after commencement  of remedial action to ensure that the remedy continues to
provide adequate protection of human  health and the environment until the soil remediation
goals  and ground water  quality standards are met.
Signature                                                     Date
Lance Miller, Assistant Commissioner
NJDEPE
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                              DECISION SUMMARY

                    Decision Summary for the Record of Decision
                               L. E. Carpenter Site
                          Wharton Borough, New Jersey
1.    SITE DESCRIPTION

The L E. Carpenter Co. / Dayco Corporation site (hereinafter L. E. Carpenter site or site)
is located at 170 North Main Street, Borough of Wharton, Morris County, New Jersey. The
site occupies approximately 14.6 acres northwest of the intersection of the Rockaway River
and North Main Street.  The Rockaway River borders the site to the south; a vacant lot lies
to the east; a compressed gas facility (Air Products Inc.) borders the site to the northeast.
Residential properties are located on the northwestern side of the site, separated by Ross
Street. Facility operation ceased in 1987. Presently the western portion of the site is used
as warehouse  space, the eastern portion is access restricted by a fence.

The Rockaway River provides recreational value (fishing, swimming and boating) from the
Washington Forge Pond through to the Route 46 Bridge located in Dover Township. This
section is currently classified as trout maintenance by NJDEPE.

Shallow ground water in the general vicinity of the  site is not used as a potable water
supply nor is it hydraulically linked to the city water supply wells.  Potable water is supplied
by the Wharton Borough Water Department.  A search of available well records indicate
that there are no private wells or public community water supply wells in the general area
of the site.

The Borough of Wharton encompasses an area of approximately 2 square miles, with a
population  of approximately 5400 (Census data,  1990).  The town of Dover, Mine Hill
Township, Rockaway Township, Jefferson Township, and Roxbury Township are in close
proximity of Wharton Borough. Approximately three quarters of the  borough is zoned
residential whereas the remaining is zoned commercial industrial.

2.    SITE HISTORY

L E. Carpenter manufactured vinyl wall coverings from 1943 to 1987. The manufacturing
process involved the generation of waste solvents including xylene and methyl ethyl ketone,
the collection of solvent fumes via "smog hog" condensers, the collection of particulate
matter via a dust collector and the discharge of non-contact cooling water to the Rockaway
River. From 1963 to 1970, waste material relating to the manufacturing operations were
disposed of into an  on-site impoundment. The active production of vinyl wall coverings
ceased in 1987.  Since that time, the portion  of the facility east of the rail road tracks has
been inactive and access restricted by a fence.  The  buildings west of the rail road tracks
have been subleased as warehouse space and manufacturing operations.
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NJDEPE conducted soil and ground water sampling on August 18, 1980 and March 3,
1981. Sampling results indicated the presence of volatile organic compounds, base neutral
compounds, metals and polychlorinated biphenyls (PCBs). In addition, NJDEPE observed
immiscible chemical compounds floating on the ground water table.

In response to the findings indicated from the sampling efforts, in 1982 L E. Carpenter and
NJDEPE entered  into an Administrative Consent Order (AGO) which Carpenter agreed to
delineate and remove soil and ground water contamination at the site.  On February 24,
1983, an Addendum was added to the 1982 AGO to clarify its provisions.

In April of 1985, LE. Carpenter was listed on the National Priorities List (Superfund). On
September 26,  1986, the  NJDEPE and  Carpenter entered into and Amended AGO which
superseded the previous Orders.  Under the terms of the Amended  1986  AGO,  L E.
Carpenter initiated a Remedial Investigation/Feasibility Study (RI/FS).
3.    ON GOING OR COMPLETED REMEDIAL PROGRAMS

L. E. Carpenter implemented several remedial programs which have  addressed some
sources of contamination discovered at the site.  In 1982,  L. E. Carpenter removed
approximately 4,000 cubic yards of sludge and soil from a former surface impoundment;
excavated and removed starch drying beds; instituted, and has continued, a ground water
monitoring program in 1984; and  initiated a passive recovery system for the floating
compounds on the ground water table.  The passive recovery system has been upgraded
twice, most recently in October 1993 to maximize its efficiency.  In 1989, an extensive
asbestos removal was completed in former Buildings 12,  13 and 14. These buildings were
razed in January 1992.  All underground and inactive aboveground storage tanks were
decommissioned and removed from the facility in 1990 and 1991 pursuant to NJAC 58:10A.
Table 1 summarizes chronology of investigation and completed remedial activities.

Figures 1, 2, and 3 show site location; areas of contamination; and areas of study.

4.    HIGHLIGHTS OF COMMUNITY PARTICIPATION

The following documents were made available to the public for review:

      Revised Report of Remedial Investigation Findings (June 1990)
      Supplemental Remedial Investigation (November 1990)
      Baseline Risk Assessment (January 1992)
      Bioremediation  and Soil  Flushing Treatability Study Report (July 1992)
      Final Supplemental Remedial Investigation Report (September 1992)
      Rockaway River Sediment Ecological Assessment (March 1993)
      Final Feasibility Study (October 1993)
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The RI/FS Reports and the Proposed Plan for the L E. Carpenter site were released to the
public for comment on December 1, 1993. These documents were made available to the
public in both the administrative record and an information repository maintained at the
Wharton Borough Municipal Building and  the Wharton  Public Library.   The notice of
availability for these documents was published in the Daily Record on December 1, 1993.
A public comment period on the documents was held from December 1,1993 to December
31, 1993.  In addition, a public meeting was held in the Borough of Wharton on December
8,  1993.  At this meeting, representatives from NJDEPE,  L. E. Carpenter and Roy F.
Weston Inc., L E. Carpenter's consultant, answered questions about problems at the site
and the remedial alternatives under consideration. A response to the comments received
during this period is included in the Responsiveness Summary, which is part of this ROD.

A public meeting was held on  June 28,  1989 in Wharton Borough which informed the
public of the initiation of the RI/FS at the site.  The community  expressed concerns
regarding suspected "satellite" dumping locations which are presently being investigated
by the potential responsible party. NJDEPE also held a meeting with local officials on June
5,  1992 to brief them on the progress of the site investigation.
5.    SITE CHARACTERISTICS
SOIL

To facilitate remedial investigations, the site was divided into three areas of study based
upon former operations, specifically Area I, Area II, and Area III.

Figures 1, 2, and 3 show site location; areas of study; and areas of contamination which
are applicable to the following discussion.

Area I  is bounded by former Buildings 12, 13, and 14 and extends northeast along the
railroad Right-of-Way (ROW), east across the site to include the drainage ditch and which
is part of the Air Products property, across to the adjacent property approximately 500 feet
north east into the Wharton Enterprises property to encompass the abandoned sewer line,
and along the Rockaway River to the steel penstock.  Shallow soil samples were collected
in approximately 26 locations. Deep soil samples were collected from a depth immediately
above  ground water (2 to 8 feet below ground surface (BGS)) at 63 locations.

Shallow soils indicate levels of bis (2-ethyl-hexyl) phthalate (DEHP) at concentrations up to
15,000 ppm.  Three surface soil samples collected at the  Wharton Enterprises property
indicated levels of  PCBs up to 45 ppm.  Metals, specifically antimony and lead, were
detected at the southeast perimeter of former Building 13 and south of monitor well MW-9.
at concentrations up to 413 ppm and 2230 ppm respectively.

Analysis of deep soil samples indicate levels of DEHP in concentrations up to 30,000 ppm
in the area extending from former Buildings 13 and 14 in the west to the terminus of the

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abandoned  sewer line in the east,  and from the drainage ditch in the north  to the
Rockaway River in the south.  VOCs, namely xylene at  levels  up to 460 ppm,  and
ethylbenzene up to 43 ppm were also detected.   Lead and Antimony were detected  at
concentrations of 765  ppm and 423 ppm respectively.

Area II encompasses  the western edge of Building 15 to  the western edge of  former
Buildings 13 and 14 and the northern edge of Building 15 to the Rockaway River.  A total
of nine (9) shallow soil samples and four (4) deep (directly above the water table) were
collected.  Results indicate no contamination above the NJ soil cleanup criteria with the
exception of one soil sample which indicated the presence  of lead at a concentration  of
2230 ppm.

Area III encompasses Buildings 2, 8 and 9, which border Ross Street and the Washington
Forge Pond. A total of 18 shallow and 21 deep soil samples were collected. Area III deep
soils investigation indicated elevated  levels  of base neutrals (BNs), mainly  DEHP,  at
concentrations at 6,302 ppm west of Building 8. Shallow soil sampling results indicated
concentrations of PCBs from non-detect (ND) to 2.9 ppm in the starch drying bed area at
the northern portion of the site. Elevated levels of Antimony were found at a concentration
of 828 ppm adjacent to the loading dock at Building 9.

GROUND WATER

Results of the ground  water investigation at the site have determined that the extent  of
contamination is located in Areas I and II and  restricted to the shallow aquifer which flows
in a northeasterly  direction, towards the Air Products  drainage ditch.  Ground water
contamination exists in both a floating product and dissolved phase and has migrated onto
the neighboring property, Wharton Enterprises. The predominant volatile organic chemicals
are xylene at levels up  to 120,000 ppb, and ethylbenzene at levels up to 26,000 ppb. The
predominant base neutral is DEHP in concentrations from ND to 62,000 ppb. The existing
floating product is being reduced using an on site passive recovery system. Metals, such
as Arsenic and  Antimony were  detected in some of the ground  water samples  at
concentrations up to an estimated concentration of 21.3 ppb and 540 ppb respectively.

ROCKAWAY RIVER AND AIR PRODUCTS DITCH

As part of the Remedial Investigation, surface water and sediment samples were taken  to
determine  possible site impacts on the Rockaway River and sediments located adjacent
to the river and the Air Products drainage ditch.

Air Products Drainage  Ditch

The Air Products  Drainage Ditch borders the L. E. Carpenter property on the north eastern
portion of the property. The standing water located within the ditch eventually leads into
the Rockaway River or percolates into ground water during periods of low water table.
Sediment sample results indicate detectable levels of Total Base Neutrals and Metals. The
predominant BN was DEHP  found in concentrations from ND to 520 ppm.   The

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predominant Metals were  arsenic at concentrations  up to 25.7 ppm, chromium at
concentrations  up to 34.7 ppm,  lead at concentrations  up to 503 ppm, mercury at
concentration up to 21 ppm, and zinc at concentrations up to 336 ppm.  Surface water
samples indicate elevated levels of Volatile Organic Compounds. The predominant volatile
organic compound was xylene at a detected concentration of 44 ppb.

Rockaway River

The Rockaway River  borders the site from the south western  portion up through the
eastern portion.  Sediment sampling results indicate elevated levels of Total Base Neutrals
and Metals in samples on the eastern portion of the site. The predominant BN was DEHP,
found in concentrations from 1.6 ppm to 76 ppm. The predominant Metals were antimony
at concentrations up to 718 ppm, copper at concentrations up to 711 ppm and lead at
concentration up to 339 ppm. Surface water samples indicated volatile organics at trace
levels,  below the Surface Water Quality Standards.

6.     SUMMARY OF SITE RISK

Based upon the results of  the Remedial Investigation,  a baseline risk assessment was
conducted to estimate the risks associated with current and future site conditions. The
baseline risk assessment estimates the potential human health and ecological risk which
could result from the contamination at the site if  no remedial action  were taken.  Site risks
are expressed in exponential terms when estimating the cancer risk.  Excess lifetime cancer
risks are determined by multiplying the intake level with the cancer potency factor. These
risks are probabilities that are generally expressed in scientific notation  (e.g., 1x10'6 or 1E-
6).  An excess lifetime cancer risk of 1x10'6 indicates that, as a plausible upper bound, an
individual has a one in one million chance of developing cancer as a result of site-related
exposure to a carcinogen over a 70-year lifetime under the specific exposure conditions
at a site.

Potential concern for noncarcinogenic effects of a single contaminant in a single medium
is expressed as the hazard quotient (HQ) (or the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the contaminant's reference dose).
By adding the HQs for all contaminants within a medium or across all media to which a
given population may reasonably be exposed, the Hazard Index (HI) can  be generated.
The HI provides a useful reference point for gauging the potential significance of multiple
contaminant exposures within a single medium or across media.

Cancer potency factors (CPFs) have been developed by EPA's Carcinogenic Assessment
Group for estimating excess lifetime cancer risks associated with exposure to potentially
carcinogenic chemicals.   CPFs, which are expressed in  units of (mg/kg-day)"1, are
multiplied by the estimated intake of a potential  carcinogen, in mg/kg-day, to provide an
upper-bound estimate of the excess lifetime cancer risk associated with exposure at that
intake  level.  The  term "upper  bound" reflects the conservative  estimate of the  risks
calculated from the CPF. Use of this approach makes underestimation of the actual cancer
risk highly unlikely.  Cancer  potency factors  are derived from the  results of human

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epidemiological studies or chronic animal bioassays to which animal-to-human extrapolation
and uncertainty factors have been applied.

Reference doses (RfDs) have been developed by EPA for indicating the potential for
adverse health effects from exposure to chemicals exhibiting noncarcinogenic effects.
RfDs, which are expressed in units of mg/kg-day, are estimates of lifetime daily exposure
levels for  humans,  including sensitive individuals, that  is not  likely  to  be without an
appreciable  risk  of  adverse  health  effects.   Estimated intakes  of chemicals  from
environmental media (e.g., the amount of a chemical ingested from contaminated drinking
water) can be compared to the  RfD. RfDs are derived from human epidemiological studies
or animal studies to which uncertainty factors have been applied (e.g.,  to account for the
use of animal data to predict effects on humans). These uncertainty factors help ensure
that the RfDs will not underestimate the potential for adverse noncarcinogenic effects to
occur.

HUMAN HEALTH RISK ASSESSMENT

A  four-step  process  is utilized  for assessing site-related human health risks  for  a
conservative estimate of reasonable maximum exposure scenario:  Hazard Identification-
identifies the contaminants of concern at the site based on several factors such  as toxicity,
frequency of  occurrence,  and concentration.   Exposure >4ssessmenf--estimates  the
magnitude of actual and/or potential human exposures, the frequency and duration of
these exposures, and the pathways  (e.g., drinking contaminated well-water) by which
humans are potentially exposed.  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).  Risk  Characterization-
summarizes and combines  outputs of the exposure and toxicity assessments  to provide
a quantitative (e.g., one-in-a-million excess cancer risk) assessment of site-related risks.
The baseline risk assessment selected site related contaminants of concern based on
frequency of detection, toxicity and comparison to background levels.  These contaminants
included DEHP, antimony, PCBs, methylene chloride, benzene, ethylbenzene, polynuclear
aromatic hydrocarbons (PAHs), chromium (hexavalent), 1,1 -dichloroethane, 1,1 -dichloroeth-
ene, tetrachloroethene, tricholoroethene, toluene, xylene, arsenic, lead, nickel.  All of the
above contaminants, except lead,  antimony, ethylbenzene, xylene, and nickel are known
to cause cancer in laboratory animals and are suspected to be human carcinogens.  The
chlorinated solvents such as 1,1,-dichloroethane, 1,1-dichloroethene, tetrachloroethene,
tricholoroethene, are considered to be off-site related from the Air Products property and
are above ground water quality  standards.

The baseline risk assessment evaluated the health effects which could  result from exposure
to contamination if no action is taken to remediate sources of contamination as a result of:

* the ingestion, inhalation and skin contact with surface soil;
* ingestion, inhalation and skin contact with ground water

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 * incidental ingestion and skin contact with stream  sediments;
 * incidental ingestion and skin contact with surface water; and
 * the consumption of contaminated animals (fish) from the Rockaway River.

 Ground water is not  currently used as a potable source at or within a 1 mile radius of the
 site. Therefore, human health risks associated with ingestion, inhalation and skin contact
 with contaminated ground water represents the hypothetical future use by a resident living
 on  or directly adjacent to the site and using the  ground water as a potable  source.

 Table 3 summarizes  the risk estimates evaluated in the Risk Assessment.

 Summary of Health Risks

 Through a quantitative assessment of exposure pathways for the contaminants of concern,
 specific health risk levels were calculated to enable  an evaluation of potential health risks
 for  human receptors. The risk of cancer from exposure to a chemical is described in terms
 of the probability that an individual exposed for  an  entire  lifetime  (70) years will develop
 cancer.  The carcinogenic risk, then, is a function of the estimated average daily intake
 over a lifetime and the cancer slope factor (SF)  for the chemical of concern.  Under the
 present use scenario, workers were assumed to spend 25 years at a job on site, therefore,
 an  exposure duration of 25/70 years was used. In the future use scenario for resident
 exposures, carcinogenic risk was calculated based on the  assumption that the resident is
 spending 30 years in one house, located within the site boundary. This represents 6 years
 of exposure as a child and 24 years exposure as an adult, therefore,  exposure durations
 of 6/70 years  and 24/70 years were used to calculate child and adult carcinogenic risk,
 respectively.  Exposure duration considered in  the child wader/swimmer scenario was
 based on a 6  month exposure per year over 6 years.  Thus exposure durations  of 6/12
 months and 6/70 years were used.  The  quantitative health risk evaluation  identified the
following potential health risk for  each media:

 Soil

 A cancer risk of 8.2 x 10'" was established for an on-site employee; a cancer risk  of 2.6 x
 10"5 for a trespasser; and a cancer risk of  1.9 x 10"3 for a hypothetical  future  resident who
 is exposed to soil via incidental ingestion,  inhalation and skin contact.  The Hazard Index
 (HI) which reflects non carcinogenic effects for a human receptor was  estimated to be 11
for  an on-site employee, 2.1  for a trespasser, and 79 for a future resident.

 Ground Water

A cancer risk was established for a hypothetical future resident for the ingestion, inhalation,
and skin contact with ground water from the shallow, intermediate and deep zones who
uses well water as a  sole potable water source over a lifetime.  The risks calculated are 4
x 10"*; 1.3 x 10"4; 4.0  x 10'4; for shallow, intermediate and deep ground water respectively.
The Hazard Index which reflects non-carcinogenic effects for the  hypothetical future
resident which ingests, inhales or has dermal contact with the ground water, was estimated

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to be 413 for shallow ground water, 4.4 for intermediate ground water and 6.2 for deep
ground water. The carcinogenic and non carcinogenic risk for both intermediate and deep
ground water have been determined to be an over estimation of the true conditions of the
site because DEHP was only found to exceed the Ground Water Quality Standards in one
well in each respective aquifer.

In the intermediate ground water, DEHP and arsenic exceeded the 10"6 carcinogenic risk
levels and exceeded a  HI of 1.0.  DEHP was detected in one well (MW-12! at 77 ppb)
above the Ground Water Quality Standard.   Arsenic was detected in  1 of 14 samples
below the Ground Water Quality Standard.

In the deep ground water, DEHP and 1,2-dichloroethane (1,2-DCA) exceeded carcinogenic
risk levels and/or a HI of 1.0. Each compound was detected in only 1 of 10 samples.  1,2-
DCA was detected as an estimated value and is below the Ground Water Quality Standard.
The DEHP concentration has only been reported in one deep well (MW-11d at levels of ND,
3600 ppb and 820 ppb) in the area were ground water contamination is the highest. Since
DEHP has only been detected at levels which exceed the Ground Water  Quality Standard
in one well, deep ground water does not warrant  remediation,  unless further studies
conclude otherwise.

River Sediments

A cancer risk of 7.9  x 10"6 was  established for a wader/swimmer who incidently ingests
river sediments or through skin contact. The Hazard Index which reflects non-carcinogenic
effects for a human receptor was estimated to be 0.32. An assessment of the Air Products
drainage ditch determined that the ditch is inaccessible to the trespasser and too shallow
to be used for wading and swimming.  The potential  risks due to exposure to these
sediments are negligible. Thus the sediment samples taken at the drainage ditch were not
included  in this evaluation.  Any potential contamination  from the sediments will  be
captured by the proposed ground water recovery system.

River Surface Water  and Fish Ingestion

A total carcinogenic  risk of 2.1 x 10'7 was established for dermal contact of river surface
water.  A carcinogenic risk of 5  x 10"8 was established for the incidental -ingestion of river
water by waders and swimmers  The Hazard Index which reflects non-carcinogenic effects
for a human receptor was 0.013.

A total carcinogenic risk of 6.3 x 10'4 for consumption of fish (by both child and adult) was
developed. The Hazard Index which reflects non-carcinogenic effects for a human receptor
was estimated to be 1.6 (child).  However, arsenic was the only identified carcinogenic
substance present in surface water. Arsenic was detected in two of four of the surface
water samples from the Rockaway River at an estimated value. These estimated (J) values
were used in the baseline risk assessment.  The risk estimate is  based on consumption of
a large amount (54  g/day)  of fish caught from the  river.   It was further  assumed that
consumption occurred daily over a 30-year period. This approach results in a conservative

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overestimation of risk.  Based on available information and the conservative evaluation,
control of fish consumption does not appear to be warranted.

Conclusion

These calculated health risks represent a reasonable maximum exposure which represent
a summation of the chemical-specific risks associated with each medium being evaluated.
EPA has established a carcinogenic risk range for cleanup of contaminated sites of 1 x 10~4
to 1 x 10~6 excess  cancer risk and a Hazard  Index greater than 1.0 for non-carcinogenic
risks.  N.J.P.L 1993 c139 requires that any proposed remedy must meet the  cleanup
criteria of 1  x 10'6 for each contaminant and a Hazard Index greater than 1.0 for non-
carcinogenic risks. The more conservative 1 x 10"6 is used for achieving final remediation.

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

Based on the scenarios presented, the contaminants identified in soil and shallow ground
water exceed the acceptable risk established by NJDEPE of 1  x 10'6 and the EPA target
risk range of 1 x 10"4 to 1 x 10"6 for carcinogenic risk and the Hazard Index  of 1.0.  Other
scenarios that exceed the hazard index; fish consumption, intermediate and deep ground
water exposure, do not indicate a need for remediation based on NJDEPE evaluation (see
discussions  under  Ground Water and River Surface Water and Fish Ingestion on  pages 9
and 10).

Estimated risk levels presented in the Risk Assessment (presented in section 5) were used
to  identify the primary soil  contaminants.   Potential risk  due  to  exposure to  soil
contaminants results from ingestion of, inhalation  of, or  dermal contact  with the soil.
Exposure via each of these potential pathways would  be eliminated if direct contact with
the soil was  prevented. The present indoor operations of the tenants at the site and any
probable future use scenarios do not create a significant risk of direct soil contact by on-
site workers, and the site is fenced to prevent trespassing.

If contact with the contaminated soil is not precluded, specific locations on site would have
to be remediated.  Hypothetical future residential use (using 95 % limit concentrations)
resulted in estimated carcinogenic risks exceeding 1x10'6 or HI exceeding 1.0 for DEHP,
Aroclor 1254, methylene chloride, benzene, ethylbenzene, five  PAHs, antimony, and
chromium (assuming hexavalent). Ninety percent of the carcinogenic risk was attributed
to DEHP, which was  found in approximately 90%  of the soil samples collected.

However,  based on the historical industrial use of the  site, non residential use scenarios
are more  appropriate for estimating potential risks and identifying soil areas requiring
remediation.  To ensure nonresidential use of the site in the future, an environmental use
restriction will be imposed. As  discussed below, not all contaminants on Table 8 need to
be addressed as part of the selected remedy herein.
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Compliance with the soil cleanup criteria is determined using the following policy: Data
generated within an area of concern, excluding any samples from a "clean" buffer zone, is
what is being utilized for compliance averaging.  An area of concern as first identified may
be reduced or expanded based on site investigation sampling events. Only those samples
which lie within the modified area of concern can be utilized for compliance averaging. The
sample collection shall be from discrete six inch (6") intervals, unless poor sample recovery
or other filed logistical problems occur.  Samples from different depth intervals are not
averaged together to determine compliance with applicable remediation criteria.

Once it has been determined which samples may be utilized for compliance averaging, the
following represents NJDEPE policy on determining compliance, which incorporates using
(1) arithmetic mean and 2) the multiplying factor. The arithmetic mean of the concentration
of contaminant in all soil samples from the same depth interval in an area of concern must
be less  than or equal  to the applicable soil cleanup  criteria for that contaminant.  The
multiplying factor is dependent on the soil cleanup criteria.  No single sample can exceed
the applicable soil cleanup criteria for that contaminant by more that the following factors:
1) if the applicable soil cleanup criteria is ten (10) ppm or less, then the individual  soil
samples cannot exceed the  soil  cleanup criteria  by more  than  a factor of ten (10) and
cannot exceed a total of fifty (50) ppm; 2) if the applicable soil cleanup criteria is greater
that ten  (10) ppm but less that or equal to one hundred (100) ppm, then the individual soil
samples cannot exceed the soil cleanup  criteria by  more than a factor of five  (5) and
cannot exceed  a total  of two hundred (200) ppm and;  3) if the applicable  soil cleanup
criteria is greater that one hundred (100) ppm, then the individual soil samples cannot
exceed the soil  cleanup criteria by more than a factor of two (2).

Methylene chloride may be attributable to some extent to laboratory contamination since
it was commonly detected in blank samples.  Methylene chloride was also detected in
samples of fill  material  collected from the disposal area.   The arithmetic average
concentration (15.9 mg/kg)  of methylene chloride in  soil samples is below the  NJ non
residential soil cleanup  criteria (210 mg/kg) and the maximum concentration  (310 mg/kg)
did not  exceed two times the standard.  Therefore, remediation of methylene chloride
contaminated soils is not required.

Benzene was detected in 6 of the 97 soil samples. The arithmetic average concentration
of benzene (2.85 mg/kg) is below the NJ nonresidential soil cleanup criteria (13  mg/kg)
and the maximum concentration (34 mg/kg) does not exceed the cleanup criteria by a
factor of five.  Therefore, remediation of benzene in site soils is not required.

For each of the five PAHs (benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthrene/
benzo(k)fluoranthrene,  chrysene,  and indeno(1,2,3,c,d)pyrene)  the arithmetic average
concentration did not exceed the NJ soil cleanup criteria, and the maximum concentration
did not exceed the cleanup criteria by a factor of  10.

Toxicity  values are not  available to calculate risks due to lead, which was found in every
soil sample  collected, including background samples.  Several hot spots  of lead were
detected. Excavation of lead hot spots which exceed the NJ non residential soil cleanup

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criteria of 600 ppm will be conducted.

ECOLOGICAL RISK ASSESSMENT

The  purpose of the ecological assessment  is to identify and  estimate the potential
ecological impacts from the release of contaminants on the aquatic resources in the
Rockaway River, which is adjacent to the site.

The technical guidance for the performance of this risk assessment comes from several
sources, including the Endangerments Assessment Handbook (EPA, 1986a); Ecological
Risk Assessment (Urban and Cook, 1986a);  and the  Interim  Final Risk Assessment
Guidance for Superfund: Volume II Environmental Evaluation Manual (EPA, 1989b).

The  ecological  risk assessment focused on the potential impacts  that site related
contamination may have on the aquatic resources of the Rockaway River. The ecological
assessment evaluated whether aquatic organisms were adversely exposed to contaminants
at concentrations in the sediments based  on the National Oceanic and Atmospheric
Administration (NOAA) sediment-sorbed contaminant data. Comparison of surface water
contaminant concentrations in the Rockaway to the Ambient Water Quality Criteria (AWQC),
which are  developed  to be protective of  95%  of  all  aquatic species,  indicated the
contaminant levels  may  potentially  pose  a  threat to aquatic  life.   Comparison  of
contaminant concentration in the Rockaway River to the Surface Water Quality Criteria
indicated that levels are below the daily  maximum level for each contaminant.  In order to
supplement the findings of the  Baseline Ecological Risk Assessment, LE.  Carpenter
conducted a community level biological  assessment of the species in the Rockaway River
sediments.   The objective  of the  biological assessment was to  evaluate whether
contaminants detected  in river sediments  have  adversely  impacted the  benthic
macroinvertebrate community of the  Rockaway River. The assessment concluded that
historical operations on-site  and current conditions of the site  do not appear to be
impacting the biological community in the sediment or aquatic species of the Rockaway
River.

The results of a site-wide habitat survey and direct field observations were compared to the
National Heritage Program  data base. The comparison indicates that the on-site habitat
does not support threatened or endangered species.

Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected  in  this ROD, may present an imminent and
substantial endangerment to public health, welfare, or the environment.

7.    SUMMARY OF REMEDIAL AL TERNA TIVES

CERGLA 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, alternative treatment technologies, and resource recovery alternatives to the
maximum extent practicable.  In addition, the statute includes a preference for the use of

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treatment as a principal element for the reduction of toxicity, mobility,  or volume of the
hazardous substances. N.J.P.L 1993 c139 requires that the development, selection, and
implementation  of any remediation standard or remedial  action shall  ensure that it is
protective of public health, safety, and the environment. Permanent and nonpermanent
remedies are allowed, however, permanent remedies are preferred over nonpermanent
remedies.  The  NJDEPE shall  not require a person performing a remedial  action to
implement a permanent remedy, unless the cost of implementing a nonpermanent remedy
is 50 percent or more than the cost of implementing a permanent remedy.

The L E. Carpenter Final Feasibility Study Report (FS) includes a preliminary screening of
all  potentially applicable technologies, followed  by  the elimination of  inappropriate or
infeasible technologies.  The resulting number of technologies are then developed into
remedial alternatives.  The  FS summarizes  the preliminary  identification of remedial
technologies and process options for each of the environmental media which needs to be
addressed.  However, the number of potentially applicable technology types and process
options are  reduced  by evaluating the option with respect to technical implementability,
effectiveness and  cost.  The following are those  remedial alternatives which were
considered  to be the most  effective and technically implementable to  address  the
contaminated media at the site.

Table 4 and  Table 5 summarize the preliminary remedial alternatives and the summary for
technology screening of soil and ground water.

These alternatives are:

1.     No Action
2.     Institutional Controls
3.     Ground Water Treatment/Containment
4.     Treated Ground Water with Reinfiltration/Soil Biodegradation
5.     Excavation/On-site Soil Washing/Bioslurry Treatment/Treatment  of Ground Water
6.     Soil Excavation/Thermal Treatment/Treatment of Ground Water

A brief description of each of the remedial alternatives is provided below:

Alternative 1:     No Action

The Superfund  program  requires that the "no action" alternative be  considered as a
baseline for comparison of other alternatives. Under the no action alternative, no additional
remedial actions would be initiated  beyond passive recovery of the floating product as
specified in the 1986 Amended AGO. The no action alternative would be  appropriate if the
potential endangerment is negligible or if implementation of a remedial action would result
in a greater potential risk.  Because this alternative would result in contaminants remaining
on-site in excess of health based levels, CERCLA requires that the site be reviewed every
five years. If justified by the review, remedial  actions may be implemented to remove or
treat the waste.
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 (Alternative #1  continued)

 Capital Cost: $ 0.00
 O&M Cost: $ 79,000/year
 Present Worth Cost: $ 1,215,000
Time to Implement: Immediate

Alternative #2:    Institutional Controls

The alternative involves a filing of Declaration of an Environmental Restriction with the
county recording officer pursuant to N.J.P.L 1993 c139, Section 36(2); ground water use
restriction; an expanded ground water monitoring program; maintenance of existing site
fencing  and;  continuation of passive recovery of floating product.  The deed  notations
would be written to restrict future use of the property  to non-residential use due to the
presence of contaminants above NJDEPE's residential standards. Ground water restriction
involves  designation of  local ground water sources as nonpotable with delineation of a
corresponding well restriction area. The expanded monitoring program requires installation
and quarterly sampling  of a sentinel well on  the Air Products property.  Because this
alternative would result in contaminants remaining on-site in excess of health-based levels,
CERCLA requires that the site be  reviewed every five years.  If justified by the review,
remedial actions may be implemented to remove or treat the waste.

Capital Cost: $ 50,000
O&M Cost: $ 90,000/year
Present Worth Cost: $ 1,434,000
Time to Implement: Four months

Alternative #3:    Ground Water Treatment/Containment

This alternative involves  the following remedial  actions; soil cover for DEHP contaminated
soil; spot excavation and offsite disposal of isolated metal and PCB contaminated surficial
soil; active immiscible product recovery; above ground biological treatment and carbon
polishing of ground water; recirculation of a portion of extracted ground water within the
capture zone; discharge of remaining extracted ground water to a deep aquifer.  A soil
cover would be designed to allow natural precipitation to infiltrate into the vadose zone soils
to allow natural attenuation of soil contaminants to continue.  The cover would mitigate the
threat of direct contact,  ingestion, inhalation or erosion of soil contaminants.  Hot spot
excavation and off-site disposal of metal and PCB contaminated soils, which exceed the
soil cleanup criteria, would be performed. Contaminated soil which do not  meet the land
disposal requirements (LDRs) designated for off-site disposal would  need to be treated
prior to disposal.  Phase I of the ground water remedial strategy requires active recovery
of floating product prior  to startup of the aerobic biological treatment system.  Extracted
ground water will be treated through an oil/water/solids separator. Ground water will be
extracted then treated by an above ground biological treatment system with a portion of

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 it recirculated within a capture zone.  The levels of contaminants in the ground water will
 be expected to meet a performance standard to indicate that contamination in the ground
 water is being reduced.  Remaining treated ground water will be discharged via reinjection
 into a deeper aquifer at levels in compliance with the site specific discharge criteria which
 can be found in Appendix A. The water being discharged to the deep aquifer will be
 polished by granular activated carbon after biological treatment to assure compliance with
 site specific discharge criteria.  The biological treatment system would include equaliza-
 tion/nutrient mix tank, bioreactor vessel, effluent  polishing treatment, and vapor phase
 granular activated carbon (GAG) treatment for volatile organics. Institutional controls would
 be required because this alternative may result in contaminants remaining on-site in excess
 of the NJ residential soil cleanup criteria. A site review every 5 years is required pursuant
 to CERCLA until health based levels are met.  If justified by the review, remedial actions
 may be implemented to remove or treat the waste.

 Capital Cost: $ 5,716,562
 O&M Cost: $210,000/year
 Present Worth Cost: $ 8,944,000
 Time to Implement: 33 months

 Alternative #4:    Treated Ground Water with Reinfiltration/Soil Biodegradation

 Alternative  4 consists of the  following components; extraction of contaminated ground
 water, above ground enhanced biological treatment  and  the addition  of oxygen and
 nutrients and  possibly a surfactant prior to reinfiltration of ground water to the  shallow
 aquifer zone within the treatment basin. Biological treatment will occur after all immiscible
 product has been removed through an active removal system (Phase  I).  Phase II would
 incorporate extraction of ground water, treatment and discharge  to three distinct areas.
 Reinfiltration of some treated ground water (to maximum amount possible)  with added
 oxygen and nutrients and possible surfactants will percolate through the unsaturated zone
 soils through an infiltration system to aid in soil in situ biological activity. A larger portion
 of the treated water will be recirculated within the capture zone. The levels of contaminants
 in the recycled treated ground water will be expected to meet a performance standard to
 ensure that contamination  in the ground water is being reduced. The remaining water
 would be treated and discharged into a deeper aquifer at the discharge criteria found in
 Appendix A.  The ground water treatment system may also include GAC treatment which
 can be converted to carbon adsorption (or other polishing technology) as contaminant
 concentrations diminish.  The infiltration system will be covered by a soil cover to limit
 contaminant migration; limit direct contact with contaminated soil, and protect the system.
 In-situ biological activity  is designed to clean up soils,  to the remediation levels found in
 Appendix B, with microbes which would degrade  organic contaminants adhering to soil
 particles. Laboratory scale treatability studies were conducted to assess the feasibility of
 bioremediation of soils at the site.  Results indicated that a combination of bioremediation
 and soil flushing  is technically feasible  and  can  achieve  remediation  goals for site
 contaminants.   Hotspot excavation and disposal of isolated soils located outside the
treatment zone would be performed.  Next, excavate and  dispose of "disposal area" fill
 which may  prove inhibitory to in situ treatment. Soils to be disposed of  off-site would meet

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all applicable RCRA treatment and disposal criteria. Institutional controls would be required
because this alternative may result in contaminants remaining on-site in excess of the NJ
residential soil cleanup criteria. A site review every 5 years is required pursuant to CERCLA
until health  based levels are met.  If justified by the review, remedial actions may be
implemented to remove or treat the waste.

Figure 4 shows a schematic of the ground water treatment with reinfiltration.

Capital Cost: $ 8,452,000
O&M Cost: $ 210,000/year
Present Worth Cost: $ 11,020,000
Time to Implement: 36 months
Alternatives:      Soil   Excavation/On-site   Soil   Washing/Bioslurry
                   Treatment/Treatment of Ground Water

Alternative 5 consists of the following components: excavation of contaminated soil, on-site
soil washing of excavated organic contaminated soils; and placement of the cleaned soil
back on-site; off-site disposal of some metal and PCB contaminated soil and  excavation
and  disposal of "disposal area"  sludge/fill; treatment of ground  water through  above
ground biological treatment after immiscible product has been removed through active
recovery system as explained in Alternative 3. The soil will be treated by soil washing which
would separate coarse fraction soils from fine fraction soils. Soil washing would provide
scrubbing action to the coarse  soils.  The fine fraction soils  would then  be  treated
biologically in a bioslurry treatment by destroying the organic contaminants. The scrubbing
action of the soil washing technology would remove any  leachable organics and metals
contained in  the soils. Process wash water will be treated prior to recycling in the soil
washer. All ground water process treatments described in Alternative 3 are included in this
alternative.  On site treated waste would be subject to land disposal  restrictions (LDRs)
because soil cleanup criteria is higher than the  LDRs for some relevant contaminants.
Institutional controls would be required because this alternative may result in contaminants
remaining on-site in excess of the NJ residential soil cleanup criteria. A site review every
5 years is required pursuant to CERCLA until health based levels are  met.  If  justified by
the review, remedial actions may be implemented to remove or treat the waste.

Capital Cost: $19,872,000 to $32,191,000
O&M Cost: $205,000/year
Present Worth Cost: $34,000,000
Time to Implement:  39 months

Alternative #6: Soil Excavation/Thermal Treatment/Treatment of Ground water

Alternative 6  consists of excavation of contaminated soils greater than the soil cleanup
criteria and destruction of the constituents via thermal treatment by incineration.  Under this
alternative,  two options (A and B) are considered.  Option A provides for  an on-site

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incinerator, for example a rotary kiln incinerator, to thermally treat the contaminated soils.
In Option B, all soils are transported off-site to a commercial RCRA permitted incinerator
for treatment.  Option A allows for potential backfilling of the excavation with stabilized
incinerator ash. Option B allows the excavated area to be backfilled with clean fill.  Under
either option, treatment  of soils must meet LDR for off or on site disposal.  Option A
requires various state permits for water, air, and wetlands disturbance.  Option B would
require meeting Federal  DOT transportation and RCRA requirements.  All ground water
process treatments described in Alternative 3 are included in this Alternative. Institutional
controls would be required because this alternative may result in contaminants remaining
on-site in excess of the NJ residential soil cleanup criteria. A site review every 5 years is
required pursuant to CERCLA until health based levels are met.  If justified by the review,
remedial actions may be implemented to remove or treat the waste.

OPTION A
On site incineration via Rotary Kiln

Capital Cost: $ 43,991,000
O&M Cost: 205,000/year
Present Worth Cost: $46,000,000
Time to Implement:  45 months

OPTION B
Off site incineration

Capital Cost: $ 85,140,000
O&M Cost: $ 205,000/year
Present Worth Cost: $88,000,000
Time to Implement: 30 months

8.    SUMMARY OF COMPARA TIVE ANAL YSIS OF AL TERNA TIVES

During the  detailed  evaluation of remedial alternatives,  each alternative was assessed
against the nine CERCLA evaluation criteria, as described below:

•     Overall Protection of Human Health and the Environment

      Overall Protection of Human Health and the Environment addresses whether or not
      a remedy provides adequate  protection  and describes how risks posed through
      each pathway are eliminated, reduced or controlled through treatment, engineering
      controls, or institutional controls.

      Alternative  #1, no action, would not be protective of  human health  and the
      environment.  Current levels of DEHP and PCBs in the soil and DEHP, xylene and
      ethylbenzene in ground water pose an unacceptable risk. By restricting access and
      ground water usage, Alternative #2 provides greater protection, but not to the future
      on-site worker and potential contact with contaminated soil. In addition, the potential

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for off-site migration of contaminated ground water is likely. Therefore, Alternative
#2 is not  considered to be protective of human health  and the environment.
Alternative  #3 through #6 involve ground water treatment and reduction of soils
contamination and reduce the potential for further off-site migration of contaminated
ground water. Alternative #4 provides the potential for in situ treatment through the
infiltration of oxygen  and nutrients into the subsurface.  Therefore, Alternative #4
would be more protective with respect to ground water contamination than the other
alternatives.  Alternatives #3 and #4 preclude direct contact with surface soils
through the installation of a soil cover and are considered protective nonpermanent
remedies.  In Alternatives #5 and #6,  contaminated soil is  excavated  and treated
either on-site  or off-site to  residential standards and are therefore permanent
remedies. The flushing of soil via ground water extraction will aid in the removal of
soil contaminants in  the unsaturated zone. Should institutional and  engineering
controls  be implemented, then Alternative 3 through 6 are equally protective of
human health  and the environment.

Compliance with ARARs

Compliance with applicable or relevant and  appropriate requirements (ARARs)
addresses whether or not a remedy will  meet  all of the applicable or relevant and
appropriate requirements of federal and state environmental  statutes and other
requirements or  provides grounds for invoking a waiver.

Alternatives #1 and #2 would not meet the 1 x 10"6 NJ remediation standard at the
L E.  Carpenter site nor the NJ Ground Water Quality standards.  Alternatives #3
through #6 employ bioremediation for ground water treatment.  Bioremediation of
target organic compounds will attain ARARs. Under Alternative #3, soils containing
DEHP in excess of the remediation goals would remain for  a period subject to
natural  attenuation.    In  situ  bioremediation is  effective for  treating  organic
contaminated  soils under Alternative #4 and  therefore is expected to meet soil
remediation goals which are protective  based on  a  cancer  risk level of  1x10"6.
Alternatives #5 and #6 are also expected to meet remediation goals but would be
required to meet Land Disposal Restrictions (LDRs). Alternatives #3 through #6 will
need  to meet LDRs for some hot spot removal actions, where applicable. Wetlands
mitigation for Alternatives #5 and #6 would be required to limit the negative impacts
of excavation  (and associated disruptions including  increased  siltation  to the
Rockaway  River  and  possible disturbance of  downstream  wetlands) of large
volumes  of soil. All alternatives would meet the air requirements.  Each alternative
is anticipated to meet  action and location specific ARARs at the site except for
Alternatives #1, #2 and possibly #3 since soils containing DEHP in excess  of the
cleanup criteria would remain on site for a period subject to natural attenuation.

Table 6 summarizes how each alternative meets each identified ARAR.
Appendix B summarizes the soil remediation goals
Appendix A summarizes the NJ Class II-A Ground Water Quality Standards
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Long-term Effectiveness and Permanence

Long-term effectiveness and permanence refers to the ability  of  a remedy to
maintain reliable protection of human health and the environment over time, once
cleanup criteria have been met.

Alternatives #1  and #2 offer limited long-term effectiveness and permanence since
contaminated media will remain untreated, with the exception of immiscible product
collection.   The  potential of  migration of contaminated  ground  water exists.
Alternatives #3 through #6 offer long-term effectiveness through the  ground water
treatment component, although long-term maintenance and ground water monitoring
are required. Alternative #3 will not  be as  effective in reducing vadose zone soil
contamination as a potential long-term contaminant source, thus extending the time
required for  ground water treatment.   Alternative #3  can provide long  term
effectiveness as long as the soil cover was properly maintained and institutional
controls  are in  place. Alternative #4 minimizes  site soil contaminants remaining
through in situ  treatment of  the soil, Alternative #5 by excavation,  removal and
treatment of soil containing contaminants, and Alternative #6 through excavation
and thermal treatment of contaminated soils at the site.  Long-term maintenance of
the soil cover will be required for Alternatives #3  and #4.  Alternatives #4 through
#6 permanently remove contaminants from the soil, however,  all would require a
use restriction on the property.

Reduction of Toxicity. Mobility, or Volume through Treatment

Reduction of toxicity, mobility, or volume through treatment is the anticipated
performance of the treatment technologies  a remedy may employ.

Alternatives #1  and #2 do not meet this criteria because no active treatment, other
than product recovery is implemented.  Alternative #3 offers contaminant reduction
through the active recovery of floating product and treatment of ground water and
remediation of isolated hot spot surface soils. Some contaminants would leach from
saturated soils into the ground water  and also be  extracted.  However, much of the
soil contamination would not easily  leach into ground water, and would rely on
natural remediation and attenuation processes.

Alternative #4 would offer additional contaminant reduction by employing in situ
treatment. Alternative #5 offers similar contaminant reduction via soil washing and
subsequent  biological  treatment of  the soil  slurry.  The soil washing step on
Alternative #5 reduces the volume of soil to be treated by removing the relatively
clean, coarse soils prior to treatment. Alternative #6 reduces the toxicity of the soil,
with minimal volume reduction. Metals in the ash  may need to be fixated to reduce
mobility.  The ground water  recovery and  extraction system will be designed to
control the migration of immiscible product  and ground water contaminants.
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Short-Term Effectiveness

Short-term effectiveness addresses the period of time needed to achieve protection
from any adverse impacts on human health and the environment that may be posed
during the construction and implementation period until cleanup  criteria are
achieved.

Alternative #1 will not have any short-term adverse affect because no construction
or treatment is  required.   Alternative #2 achieves a degree  of protection  in a
relatively short period of time and would result in minimal short-term impacts with
its implementation.  Alternatives  #3 and #4 are  anticipated to have the greatest
short-term effectiveness.  Some paniculate emissions during the cover installation
is anticipated, however, dust control methods should reduce this risk. Furthermore,
most of the soil contamination is in the subsurface.  Alternatives #5 and #6 offer a
lower degree of short-term effectiveness due to the  intrusive soil removal activities.
During excavation activities, wetlands disturbances are expected due to disruption
of the existing  topography,  and increased siltation  and  sediment loading.
Alternative #6 would also require that the ground  water  collection  system be
temporally dismantled during the excavation due to  well destruction  as their
supporting soils  are removed.

Implementabilitv

Implementability  is the technical and administrative feasibility of a remedy, including
the availability of materials and services needed to implement a particular option.

Alternatives #1 and #2 are the simplest alternatives to implement from  a technical
standpoint since the passive recovery system is already in place. The ground water
remediation set forth  in Alternatives #3 and #4  offer a relatively high degree  of
implementability.  Both alternatives offer a  combination of well established, readily
available  construction methods  and innovative  technology which  may  require
additional design coordination. Alternative #4 involves several additional design
considerations because of the in situ soil treatment.  Such consideration would
include the infiltration  system,  rate of treated ground water recycling allowable for
site hydraulics, and the reactivity  (both desorption  and biological degradation)  of
contaminants adsorbed to the site soils.

Major limitations  are associated with the implementation of Alternatives #5 and #6
due to the combination of immiscible product recovery, ground water extraction and
soil removal.  Any  soil (not  including  hot spot) removal conducted  during the
product recovery and  ground water extraction would be severely hampered by the
collection piping  between the  wells and the central collection points, as well as the
wells themselves. The implementation of Alternatives #5 and #6 cannot begin until
all immiscible product is removed, which may be several years. On site incinerators
are usually not well received by the community and the approval process may delay
the implementation of Alternative # 6A.

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      Alternative #1 's present worth cost is approximately $1.2 M. The primary component
      would be to maintain the passive recovery system until all immiscible product had
      been removed. Alternative #2's present worth cost is approximately $1.4 M.  The
      primary component would be to maintain institutional controls, passive recovery
      system and ground water monitoring program. Alternative #3's present worth cost
      is $8.9 M. The primary components are hotspot removal, maintenance of soil cover,
      institutional controls and ground water remediation using bioremediation. Alternative
      #4's present worth cost is $11.0 M. The primary components are hotspot removal,
      bioremediation of ground water and soil. Alternative #5 present worth cost is $34
      M. The primary components are hotspot removal, soil washing, and bioremediation
      of ground water.  Alternative #6A's present worth  cost is  $46 M.   The primary
      components are hotspot removal on-site soil incineration and  bioremediation of
      ground  water.   Alternative #6B's present worth cost is $88  M.   The primary
      components are off-site soil incineration and bioremediation  of ground water.

      Table 7 summarizes Preliminary cost estimates estimated for each alternative.

•     EPA Acceptance

      EPA concurrence indicates whether the federal  regulatory  agency  concurs,
      opposes, or has no comment on the selected remedy.

      Pursuant to the EPA/State Pilot Agreement dated December 1992, EPA concurrence
      on this  ROD is not a prerequisite to NJDEPE selecting a remedy.  However, EPA's
      comments on the Proposed  Plan and the ROD do not raise  any objections to the
      selected remedy.

•     Community Acceptance

      Community acceptance assesses  the public comments  received on the RI/FS
      report,  Baseline risk assessment, Final FS report, and Proposed Plan.

      Community concerns/comments received during the public  comment period and
      the public meeting on December  8, 1993, are  included in the  responsiveness
      summary,  together with  NJDEPE  responses, which is a part of this ROD.
      Community concerns/comments received indicate that the community accepts the
      preferred alternatives  identified  in the Proposed Plan and  selected in the ROD
      herein.

9.     SELECTED REMEDY

Based on an evaluation of  the  various alternatives and  after consideration of public
comments, NJDEPE  has selected Alternative  #4  (treatment  of ground water  with
reinfiltration and soil bioremediation) as the remedy for the L. E.  Carpenter site because

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 it best satisfies the requirements of N.J.P.L  1993 c139, CERCLA and the NCR's nine
 evaluation criteria for the remedial alternatives.

 Alternative #4 consists of two Phases which include the following components: extraction
 of contaminated ground water,  above ground enhanced biological treatment and the
 addition of oxygen and nutrients and possibly a surfactant prior to reinfiltration of ground
 water to the shallow aquifer zone within a treatment basin.  Phase I includes biological
 treatment which will occur after all immiscible product has been removed through an active
 removal system.   Phase II would incorporate extraction  of ground water, treatment and
 disposition to three distinct areas. Reinfiltration of some treated ground water (to maximum
 amount possible) with added oxygen and nutrients and possible surfactants will percolate
 through the unsaturated zone soils through  an infiltration system to  aid in  soil in situ
 biological activity.  A larger portion of the treated water will be recirculated within the
 capture zone.   The  levels of  contaminants in  the  treated ground water  will  meet
 performance standards.  The performance criteria  shall  be the  least  stringent  of  95%
 removal for each parameter or an effluent limit equal to  the  higher of the ground water
 quality standard or PQL for the parameter.  Should site specific conditions prove that such
 removal is  not reasonably  attainable, the  effluent level for the discharged water to be
 recycled will be based on the Best Available Technology (BAT) for the  treatment system
 discussed herein. The remaining water would be treated, monitored and discharged into
 a deeper aquifer at the following site specific discharge criteria for the major contaminants
 found: ethylbenzene at 350 ppb; toluene at 500 ppb; xylenes (total) at 20 ppb; bis (2-ethyl-
 hexyl) phthalate at 30 ppb; n-decane at 50 ppb; di-n-octylphthalate at 50 ppb; 1-ethyl-3-
 methylbenzene at 50 ppb; n-nonane at 50 ppb; 1,2,3-trimethylbenzene at 50 ppb; 1,2,4-
 trimethylbenzene at 50 ppb; 1,3,5-trimethylbenzene at 50 ppb; Antimony at 20 ppb;  Arsenic
 at 8 ppb; all  discharge criteria which apply to this site, including the above  referenced
 contaminants can be found in Appendix A of this ROD. Upon determination that the ground
 water discharge has met the criteria for compounds which are not to be site related (i.e.,
 the chlorinated solvents  detected in the off site wells such  as 1,1-dichloroethane, 1,1-
 dichloroethene, tetrachloroethene, and trichloroethene) and for those compounds which
 repeatedly  indicate non-detect in the  sampling rounds, monitoring will no longer be
 necessary.   Such a change in the  monitoring requirements  must be requested of and
 approved by NJDEPE. The major contaminants listed above may not be deleted from the
 monitoring  parameter list.  The ground water treatment  system may also  include  GAC
treatment which can be converted to carbon adsorption (or other polishing technology) as
 contaminant concentrations diminish.  The infiltration  system will be covered by a soil
 cover to limit contaminant migration;  limit direct contact with contaminated soil; and protect
the infiltration system.

 In-situ biological activity is designed  to clean up soils with microbes which would degrade
 organic contaminants adhering to soil particles. Laboratory scale treatability studies were
 conducted to assess the feasibility of bioremediation of soils at the site.  Results indicated
that a  combination of bioremediation and soil flushing  is technically  feasible and can
achieve remediation goals for site  contaminants.  The addition  and specific  amount of
oxygen, nutrients and surfactant will be determined during design.  Hotspot excavation and
disposal of isolated soils located outside the treatment zone would be performed.  Soils to

                                       -23-

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be disposed of off-site would meet all applicable RCRA treatment and disposal criteria.

Institutional controls would be required because this alternative may result in contaminants
remaining on-site in excess of the NJ residential soil cleanup criteria. A site review every
5 years is required pursuant to CERCLA until health based levels are met. If justified  by
the review, remedial actions may be implemented to remove or treat the waste.
10.   STA TUTORY DETERMINA TIONS

Under their legal authorities, NJDEPE's and EPA's primary responsibility at Superfund sites
is to undertake remedial actions that achieve adequate protection of human health and the
environment.  In  addition, section  121  of CERCLA  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  State and Federal environmental laws unless  a statutory
waiver is justified.  The selected remedy also must be cost effective and utilize permanent
solutions and alternative treatment technologies to the maximum extent practicable. Finally,
the statute includes a preference for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of hazardous wastes as their principal
element.

The selected remedy is protective of human health and the environment, complies with
State  and Federal requirements that are  legally applicable or relevant  and appropriate
requirements for the remedial action (see Table 2 which lists ARARs and TBCs), and is cost
effective. This remedy utilizes  permanent solutions and alternative treatment technologies
to  the maximum extent practicable for this site.  This  remedy will require a Declaration of
Environmental Use Restriction be placed on the property. The soil remediation goals are
protective of ground water. Ground water will be remediated to meet the NJ Ground Water
Quality Standards which are protective of human health. Because this remedy will result
in  hazardous substances  remaining on the site until the health based cleanup criteria are
met, a review will be conducted every five  (5) years after commencement of the remedial
action to ensure that the remedy continues to provide adequate protection of human health
and the environment.

Phase I of the ground water treatment system will be to actively remove the immiscible
product from the  ground water.  After the floating product is removed, Phase II of  the
system will extract and treat ground water and reinfiltrate treated ground water back into
the soils to allow for in situ biodegradation.  This alternative will degrade some waste
completely, and most residuals remaining from incomplete degradation will be at or below
the cleanup criteria.  Surfactant addition, microbial activity and the increased rate of ground
water flow through the  treatment  zone  may  mobilize  sorbed contaminants.   The
mobilization of sorbed contaminants is a significant step in the biodegradative process.
The other treatment options (soil washing or incineration) are projected to provide a shorter
remediation time  period  when compared to  in situ biological soil treatment, but  are
significantly more costly and more difficult to implement.  The total cost for Alternatives #4,

                                       -24- .

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#5 and #6a and #6b are $11,020,000.00, $34,000,000.00, $46,000,000.00, $88,000,000.00
respectively.  Pursuant to  N.J.P.L 1993 c139, the NJDEPE shall not require a person
performing a remedial action to implement a permanent  remedy, unless  the  cost of
implementing a nonpermanent remedy is 50 percent or more than the cost of implementing
a  permanent remedy.  The least costly of the non  permanent remedial alternatives
evaluated is $8,944,000, the  least costly of the permanent  remedies is $34,000,000.  It
would  cost more  than 50% to implement a permaent remedy.   Alternative  #4,  a
nonpermanent remedy which provides additional contaminant reduction that Alternative #3,
meets the selection requirements pursuant to N.J.P.L. 1993 c139.
The selected alternative will contribute to achieving the ARABS, at a significantly lower cost
with  minimal disturbance to the surrounding neighbors and community than the  other
options. The selected alternative will provide the best balance of trade-offs among all the
alternatives with respect to the CERCLA nine evaluation criteria.  NJDEPE has selected
treated ground water with reinfiltration/soil biodegradation  as the remedial alternative
because it will be protective of human health and the environment, will comply with ARARs,
will utilize  permanent solutions and alternative treatment technologies to the  maximum
extent practicable, will be cost effective, and will create the least amount of disturbance to
the surrounding community during the remediation process. The selected remedy will also
meet the  statutory preference  for the use of treatment as a principal  element to the
maximum  extent practicable.

11.   DOCUMENTA TION OF SIGNIFICANT CHANGES

There is no change from the Preferred Remedy described in the Proposed Plan and the
Selected Remedy described in this ROD.
                                      -25-

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                                  GLOSSARY

This glossary defines the technical terms used in this Record of Decision. The terms
and abbreviations  contained in this glossary  are often defined in the context of
hazardous waste management, and apply specifically to work performed under the
Superfund program.  Therefore, these terms may have other meanings when used
in a different context.

Administrative Consent Order: A legal and enforceable agreement between EPA or the
State and the potentially responsible parties (PRPs). Under the terms of the  Order, the
PRPs agree to perform or pay for site studies or cleanup work.  It also describes the
oversight rules, responsibilities and enforcement options that the government may exercise
in the event of non-compliance by the PRPs. This Order is signed by the PRPs and the
government; it does not require approval by a judge.

Ambient air: Any unconfined part of the atmosphere.  Refers to the  air that may  be
inhaled by workers or  residents in the vicinity of contaminated air sources.

Aquifer:  An underground  layer of rock, sand, or gravel capable of storing water within
cracks and pore spaces, or between grains. When water contained within an aquifer is of
sufficient quantity and  quality, it can be tapped and used for drinking or other purposes.
The water contained in the aquifer is called ground water.

Backfill:  To refill an excavated area with removed earth; or the material itself that  is used
to refill an excavated area.

Bioremediation:  A cleanup process using naturally occurring or  specially cultivated
microorganisms to digest contaminants naturally and/or break them  down (biodegrade)
into nonhazardous components.

Bioslurry: A form of bioremediation which occurs in an above  ground unit.

Carbon adsorption/carbon treatment: A treatment system in which contaminants are
removed from ground water and surface water by forcing water through tanks containing
activated  carbon,  a  specially  treated material  that  attracts  and  holds or  retains
contaminants.

Containment:  The process  of enclosing or containing hazardous substances  in a
structure, typically in ponds and lagoons, to prevent the migration of contaminants into the
environment.

EPA/State Pilot Agreement: An agreement entered into by the EPA and NJDEPE which
delineate the respective roles and responsibilities of each Party as they relate to the
conduct of the oversight of this site or project.

Effluent: Wastewater, treated or untreated, that flows out of a treatment plant, sewer, or

                                     -26-

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industrial outfall.  Generally refers to wastes discharged into surface waters.

Soil Washing: A cleanup process which removes contaminants and/or fine soil particles
to which they are adsorbed by contacting soil particles with reagents that consist of a
water/surfactant or water/solvent solution.

Thermal Treatment:  Cleanup technologies which rely upon relatively high temperatures
to  either  destroy  organic  contaminants or  separate them  from  natural  materials.
Incineration and Rotary Kiln Incineration are examples of "Thermal treatment".

Use Restriction: A form of institutional control in which a notice is filed with the office of
the county recording officer, in the county in which the property is located, to inform
prospective holders of an interest in the property that contamination exists on the property
at a level that may statutorily restrict certain uses of or access to all or part of that property,
a delineation of those restrictions, a description of all specific engineering  or institutional
controls at the property that exist and that shall be maintained in order to prevent exposure
to contaminants remaining on the property, and the written consent to the notice by the
owner of the property.  Use restrictions are filed as DECLARATION OF ENVIRONMENTAL
RESTRICTIONS.

Volatile Organic Compounds (VOCs): VOCs are made as secondary petrochemicals.
They include light alcohols, acetone, trichloroethylene, perchloroethylene, dichloroethylene,
benzene, vinyl chloride, toluene, and methylene chloride. These potentially toxic chemicals
are used as solvents, degreasers, paints, thinners, and fuels.  Because of their volatile
nature, they readily evaporate into the air, increasing the potential exposure to humans.
Due to their low water solubility, environmental persistence, and wide spread industrial use,
most are commonly found in soil and ground water.

Wetland:   An area that is  regularly saturated by surface or ground water and, under
normal circumstances, capable  of supporting  vegetation typically  adapted  for life in
saturated  soil  conditions.  Wetlands are critical to  sustaining many  species of fish and
wildlife. Wetlands generally include swamps, marshes, and bogs.  Wetlands may be either
coastal or inland.  Coastal wetlands have salt or brackish (a mixture of salt and fresh)
water, and most have tides, while inland wetlands are non-tidal and freshwater. Coastal
wetlands are an  integral component of estuaries.
                                       -27-

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                       RESPONSIVENESS SUMMARY
                          RECORD OF DECISION
              L. E. CARPENTER & COMPANY SUPERFUND SITE

OUTLINE:

This Responsiveness Summary is divided into the following sections:

A.   Overview
B.   Background on Community Involvement and Concerns
C.   Summary of Comments Received During the Public Meeting and Comment Period
           and Agency Responses
D.   Community Relations Activities at the L. E. Carpenter & Company Site
                                  -28-

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A.    OVERVIEW

This is a summary of the public's comments and concerns regarding the Proposed Plan
for Remediation at the L E. Carpenter & Company Superfund Site and the New Jersey
Department of Environmental Protection and Energy's (NJDEPE) responses to those
comments.

The public comment period extended from December 1,1993 through December 31,1993
and provided interested parties the opportunity to comment on the Proposed Plan and the
Remedial  Investigation/Feasibility Study (RI/FS)  Reports for  the  L.  E.  Carpenter  &
Company  Site.  On December  8, 1993 at 7:00  PM, during the comment period, the
NJDEPE held a public meeting at the Wharton Borough  Municipal Building to discuss the
results of the RI/FS and to present the preferred remedy.

On the basis of the information contained in the above  referenced documents, NJDEPE
has selected the following remedy for the L. E. Carpenter & Company Site: Biological
treatment of ground water with reinfiltration and soil bioremediation.
B.    BA CKGROUND ON COMMUNITY INVOL VEMENT AND CONCERNS

Community concerns were first expressed to NJDEPE representatives at the June 28,1989
public meeting and focused on alleged past dumping of materials by L. E. Carpenter at
other locations in and around Wharton.  In response to these concerns, NJDEPE held a
follow-up meeting and tour of the suspected "satellite" dumping locations on July 19, 1989.
Currently, NJDEPE is  continuing investigations at three of these sites.

The community has also raised issues regarding conditions and appearances of buildings
on the L. E. Carpenter property and future use of the site. Congressman Dean Gallo tours
the site annually and has expressed concerns related to the impact of past site activities
on the Rockaway River. L E. Carpenter has repaired or demolished some site buildings
and  the public seems satisfied  with current site conditions.  Sediment studies in the
Rockaway River adjacent to  the L. E. Carpenter site did  not indicate an impact on the
biological community from past or current site activities.
C.    SUMMARY OF COMMENTS  RECEIVED DURING THE PUBLIC COMMENT
      PERIOD AND AGENCY RESPONSES

Concerns raised during the L. E. Carpenter & Company Superfund Site Public Meeting held
on December 8, 1993 are summarized below. No written comments were received during
the comment period which extended from December 1, 1993 through December 31,1993.

Comment 1:        Mayor Harry Shupe  of Wharton Borough  stated that it was  the
                  Borough's position that anything less than the  preferred alternative
                  would not be acceptable, and asked if L. E. Carpenter has to proceed

                                     -29-

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                  with alternative number four (the number of the preferred alternative
                  in the proposed plan) or something more extensive.

NJDEPE Response:      L E. Carpenter will be given the opportunity to implement
                       remedy number four or something more extensive.  If they do
                       not,  NJDEPE and USEPA will use public money to implement
                       the  preferred alternative  and then  proceed  against L. E.
                       Carpenter for triple damages for the cost of that alternative.
                       Alternative number four is the minimum that would  occur at this
                       site.

Comment 2:            Mayor Shupe asked  how long it will take to implement the
                       remediation.

NJDEPE Response:      Alternative number four would take approximately 36 months to
                       implement.  We will sign a record of decision in about two
                       months.  We hope to proceed with hot spot removal by the
                       summer of 1994. The design for the removal and  treatment of
                       ground water should take about two years.
D.    COMMUNITY RELATIONS ACTIVITIES AT THE L. E. CARPENTER & CO. SITE

NJDEPE established information repositories at the following locations:

      Wharton Borough Municipal Building
      10 Robert Street
      Wharton, NJ 07885  Phone # (201) 361-8444

      Wharton Public Library
      1519 South Main Street
      Wharton, NJ 07885  Phone # (201) 361-1333

      New Jersey Department of Environmental  Protection And Energy
      Bureau of Community Relations
      401 East State Street, CN 413
      Trenton, NJ 08625       Phone # (609)  984-3081
      Contact: Doreen Gordon

NJDEPE prepared a Community Relations Plan (January 1989)

NJDEPE held a public meeting in Wharton to discuss the initiation of the RI/FS on June
28, 1989.

NJDEPE  held  a briefing  in Wharton to update local officials on  the progress of site
investigations on June 5,  1992.

                                     -30-

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NJDEPE held a public comment period from December 1,1993 to December 31,1993 and
a public meeting in Wharton on December 8, 1993 to discuss the Proposed Plan for Site
Remediation.
                                   -31-

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APPENDIX A

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          APPENDIX A
GROUND WATER DISCHARGE CRITIERIA
             AND
 GROUND WATER QUALITY STANDARD
       L E. CARPENTER SITE
COMPOUND
Organic Compounds
Ethylbenzene
Toluene
Xylenes (total)
Bis(2ethylhexyl)phthalate
n-Decane
Di-n-octylphthalate
1 -Ethyl-3-methylbenzene
n-Nonane
1 ,2,3-Trimethylbenzene
1 ,2,4-Trimethylbenzene
1 ,3,5-Trimethylbenzene
Chlorobenzene
Chloromethane
1,1-Dichloroethane
1,1-Dichloroethene
cis-1 ,2-Dichloroethene
trans-1 ,2-Dichloroethene
Heptane
Tetrachloroethene
1,1,1 -Trichloroethane
NEW JERSEY GROUND
WATER QUALITY
STANDARDS* (ppb)

700
1000
40
30
100"
100
100"
100"
100"
100"
100"
4
30
70
2
10
100
100"
100
30
DISCHARGE CRITERIA
(ppb)

350
500
20
30
50
50
50
50
50
50
50
2
15
35
2
5
50
50
1
15
              A-1

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Trichloroethene
1,1,2Trichloro-1,2,2-
trifluoroethane
Carbon Tetrachloride
Acetone
Methyl Ethyl Ketone
[2-Butanone]
Butylbenzylphthalate
n-Butylbenzene
1,2-Diethybenzene
Diethylphthalate
Di-n-buytlphthalate
Isopropylbenzene
[Cumene]
Naphthalene
N-Nitrosodiphenylamine
1 ,2,3,4-Tetramethylbenzene
Phenol
2-Nitrophenol
2,4 Dimethylphenol

Inorganic Compounds
Beryllium
Cadmium
Chromium (total)
Copper
Lead
Mercury
Nickel
1
20,000""
2
700
300
100
100"
100"
5000
900
300"'
30""
20
100
4000
100"
100


20
4
100
1000
10
2
100
1
10,000
2
350
150
50
50
50
2500
450
150
15
20
50
2000
50
50


20
2
50
500
10
1
50
A-2

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Selenium
Silver
Zinc
Antimony
Arsenic
50
40
5000
20
8
25
20
2720
20
8
Interim Generic Criteria pursuant to NJAC 7:9-6.7(c}6
Interim Specific Criteria pursuant to NJAC 7:9-6.7(c)
                                        A-3

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APPENDIX B

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                                   APPENDIX B
                 L. E. CARPENTER SOIL REMEDIATION GOALS
Contaminant
Organic Compounds
Arclor 1254 (PCB)
Bis(2-ethylhexyl)phthalate
Di-n-butyl phthalate
Ethylbenzene
Toluene
Xylene (total)

Inorganic Compounds
Antimony
Arsenic
Lead
Non Residential Direct
Contact Soil Cleanup
Criteria (mg/kg)

2.0'
210
10,000
1000
1000
1000


340
20
600
Impact to Ground Water
Soil Cleanup Criteria
(mg/kg)

100
100
100
100
500
10


340
*
*
Baeed upon the enactment of a Declaration of Environmental Restriction on the Wharton Enterprices property.
                                        A-4

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FIGURES

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                          FIGURE 1
    TO PENNSYLVANIA
                                   TO NEW YORK
           ROUTE 80
                        E. CARPENTE
                          SITE
WASHINGTON
  FORGE
  POND
LE.  CARPENTER  SITE
   WHARTON,  NJ.
   SITE  LOCATION

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                                          ^^•*,•:<>.' ,•ป \V::'?A "'-,,' 'A.;."';',''',',. ,'*
LE. Carpenter Site Map Showing
Contaminated Areas

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LEGEND

MM^B  INVESTIGATION AREA BOUNDARY

—	  PROPERTY LINE

	UNDERGROUND PIPING

	  	 FENCE

    *    FORMER PRODUCTION WEIL

         WEHRAN ENGINEERING MONITOR WELL INSTALLED
    A    1980. RETROFITTED WITH GCOMON CAS  DIS-
   ~T~    PLACEMENT  SAMPLERS BY GEOENCINEERING 1983
         (MW-t TO MW-5)

   .A.    GROUNDWATCR TECHNOLOGY MONITOR WELL
   "    INSTALLED  1983 (MW-6 TO MW-10)

    A    GEOENGINEERING MONITOR WELL INSTALLED 1989
    T    (MW-tl TO MW-I8)

         CEOENCINEERING PIEZOMETER  INSTALLED 1989
    •    (CEI-1 TO GEl-J)

         STORAGE TANKS
                                    NOTES:

                                    I. GENERAL SITE PLAN WAS BASED ON AND AOAPIEO FROM DRAWINGS
                                      REFERENCED IN FIGURE I.
                                    2. UNDERGROUND PIPING, STORAGE TANKS, FORMER STARCH DRYING BEDS.
                                      RAILROAD RIGHT OF WAY, AND  TRANSFORMER LOCATIONS ARE APPROXIMATE.

                                    1. REFER TO FIGURE I FOR TANK INVENTORY SUMMARY.
                                    4. SEE FIGURE  I FOR FULL BASE DRAWING DETAILS
AIR PRODUCTS  &  CHEMICALS,  INC.
                                               WHARTON  ENTERPRISES,  INC.
                                                                                                                                                 L.E.  CARPENTER  AND  CO.
                                                                                                                                                   WHARTON.  NEW  JERSEY
                                                                                                                                                  AREA  OF   CONCERN
                                                                                        0     60'   120'

                                                                                         t
                                                                                      Approximole   Scale
                                                                                                                                        From  Original  by  GEOENGINEERING

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                  OFF SITE  DISPOSAL
                    EXTRACTED
                    PRODUCT
                                               NITROGEN
                                               PHOSPHOROUS
                                               MICRONUTRIENT
  EXTRACTED
GROUNDWATER
PRODUCT
WATER
SEPERATOR
WATER
 FEED .
ABOVE GROUND
 BIOREACTOR
TREATED
 WATER
 CARBON
POLISHING
                                            TREAMENT
                                              ZONE
                                                           RECYCLED
                                       STEP
                                             CAPTURE
                                              ZONE
                                                            RECIRCULATED
                                                                                             EFFLUENT
                                                                                            DISCHARGE
                     ALTERNATIVE 4:  GROUNDWATER  TREATMENT WITH  REINFILTRATION

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TABLES

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                       TABLE 1




CHRONOLOGY OF INVESTIGATIVE AND REMEDIATION ACTIVITIES
DATE
1982
1982
1984
1989
August 1989
Sept. 1989
January -
March 1991
March 1991
June 1991
June 1991
ACTIVITY
Remediation of
surface impoundment
Remediation and
closure of starch
drying beds
Installation of
groundwater
monitoring system
and immiscible
product recovery
wells
Initiation of passive
recovery of floating
product
Completion of
remedial
investigation
Supplemental
remedial
investigation
Asbestos removal
Decommissioning
and tank closure
Additional sediment
sampling
Additional
groundwater
sampling
Installation of
recovery wells
DESCRIPTION
Excavation of 4,000 cubic yards of sludge and contaminated
soils from former surface impoundment.
Excavation and removal of starch drying beds.
Installation of a network of ten groundwater monitoring wells
used to monitor extent of groundwater contamination and free
product thickness. Five of the wells were equipped with
skimmer pumps to recover floating product.
Passive recovery system utilizing skimmer pumps in
monitoring/recovery wells began operation.
Completion of a soil gas survey, test pit and soil sampling,
monitoring well installation and sampling, air sampling, and
stream sediment and surface water sampling.
Additional sampling of soil, test pit installation, surface water
sediment, and background soils/sediment.
Building 12, 13, and 14
Decontamination and excavation of 16 storage tanks in
accordance with NJDEPE approved Closure Plan.
Collection of seven sediment samples from the Rockaway River
including two from upgradient locations.
Sample collection from MW-13s and MW-S3i to confirm
presence/absence of phthalate compounds. Also included
installation and monitoring of MW-21 on Wharton Enterprises.
Installation of three additional recovery wells as part of the
enhancement of the immiscible product recovery system.

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DATE
Sept. 1991
Dec. 1991 -
January 1992
January 1992
February
1992
Sept. 1992
January -
February
1993
March 1993
ACTIVITY
Decontamination and
decommissioning of
structures in
Buildings 13 and 9
Demolition of
Buildings 12, 13, 14
Disposal area
investigation
Installation and
sampling of
additional
groundwater wells
Ecological
Assessment of
Rockaway River
Well Point
Installation
Gamma Logging
Program
DESCRIPTION
Decontamination and dismantling of former process piping,
tanks, etc. in Building 13; decontamination of building 9
interior.
Buildings 12, 13, 14 razed.
Installation of nine test pits in order to investigate and delineate
the aerial extent of a former disposal area.
Installation and monitoring of four new shallow groundwater
wells; two on Air Products property and two on Wharton
Enterprises property.
Collection of sediment samples at six location to characterize
Rockaway River environments upstream, adjacent to and
downstream of L.E. Carpenter and evaluate potential biological
impairment.
Installation of twenty-three temporary well points to further
delineate extent of floating product at site.
Geophysical logging via down-hole natural-gamma ray logging
of thirty-four wells, well points and piezometers to develop a
better understanding of site stratigraphy.

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                                                      TABLE 2
                       POTENTIAL ACTION AND LOCATION-SPECIFIC ARARs
                               AND TBCs FOR THE L.E.  CARPENTER SITE
                    Relevant and Appropriate
                                                                                     To Be Considered
                                                     ACTION-SPECIFIC
RCRA-40 CFR 261, 263, 264

RVRSA policy prohibiting discharge from groundwater remediations

NJ. P.L. 1993 c!39

NJDEPE DWR Order No. 60-Groundwater Cleanup Criteria

NJAC 7:14A-6 - Additional Requirements for Discharges to Groundwater

NJAC 7:14A - New Jersey Pollutant Discharge Elimination System

NJAC 7:27 - Air Pollution Control

NJAC 7:26 - New Jersey Hazardous Waste Regulations

NJAC 7:14A-5 - Requirements for Wells Infiltrating Liquid Wastes

NJAC 7:14A-12 and 13 - Wastewaier Treatment Requirements

NJAC 7:9-9 - Sealing of Abandoned Wells

NJAC 7:9-7 - Well Installation

NJAC 7:26E - Technical Requirements for Site Remediation

NJAC 7:9-6 - Ground Water Quality Criteria
•       EPA document EPA/450/1-90-002

•       EPA document EPA/450/3-87-017

•       Required pretest protocol

•       Protocol - continuous emission monitors DEQ

•       Guidelines for review of application for toxic substances
        emissions

•       Equipment compliance with NJ Air Pollution Control
        Regulations

•       Technical Guidance Study EPA/450/4-90-014

•       Guidance on Ambient Air Monitoring. EPA/450/4-89-015 and
        EPA/450/4-90-005

•       Hazardous Waste Incineration Guidance Series EPA /62S/6-
        86/012, EPA/625/6-S9/OI9. and EPA/625/6-89/021

•       EPA Seminar Publication:  Requirements for Hazardous Waste
        Landfill Design. Construction, and Closure

•       Draft RCRA Guidance  Document:  Landfill Design, Liner
        Systems and Final Cover PB87-157657

•       Guidance on Delisting NPL sites, OSWER directive 9320.2 - 3A


•       OSWER Directive 9234.1-06:  Applicability of LDRs to RCRA
        and CERCLA Groundwater Treatment Reinjection

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                                          TABLE 2 (Continued)
                     POTENTIAL ACTION AND LOCATION-SPECIFIC ARARs
                            AND TBCs FOR THE L.E. CARPENTER SITE
                • Relevant and Appropriate
                    To Be Considered
                                              LOCATION-SPECIFIC
Treatment facility location:

•       In 100-year Flood Plain - 40 CFR 18

•       In Lowlands - Executive Order 11988

•       NJAC 7:13 - Flood Hazard Area Regulations

•       National Historic Preservation Act (16 USC 470)

Fish and Wildlife Coordination Act:

NJAC 7:7E-3 - Flood Plains, Wetlands, Endangered Species/Habitat

NJAC 7:2-11 - Description of Natural Areas of State

Wetlands:

•       Wetlands Act of 1970 (NJSA 13:9A-1)

•       Freshwater Wetlands Protection Act
New Jersey's threatened plant species list

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Risk Batimatei - Curreri Conditions
                                                                            TABLES
                                                                 L. B. CARPENTER A COMPANY
RECEPTOR
On-Site Worker
Trespasser
Wader/Swimmer
Child/ Adult
Toxrcmr
ASSESSMENT
HI
CA
HI
CA
HI
CA
HI
CA
SOIL
Insertion
Inhalation
Denial
11
sxia4
2.1
2.6xl05
NA
NA
NC
NC
SEDIMENTS
Iteration
Dermal
NC
NC
NC
NC
0.32
7.9X106
NC
NC
SURFACE WATER
Ingeatioo
Dermal
NC
NC
NC
NC
0.013
2.1xl07
NC
NC
FISH INQESTION <*)
NC
NC
NC
NC
NC
NC
1.6
6.3X104
 ' Calculations are based at the upper 95% confidence limit
HI = Hazard Index (Noncarcinogenic)
CA = Cancer Risk (Carcinogenic)
NC = Not Calculated

Risk Estimate! - Future Condition
Current Conditions are based on:
(a) no current groundwater use
         on-site
RECEPTOR
Hypothetical
Future
Resident
TOXICirY
ASSESSMENT
HI
CA
SHALLOW
GROUNDWATB
R
logcation
Inhalation
Dermal
413
l.SxlO2
INTERMEDIATE O
GROUNDWATER
Ingeation
Inhalation
Dermal
4.4
1.3X104
DEEpO
GROUNDWATB
Rlngestion
Ubalation
Dermal
6.2
4-OxlO4
SOIL
79
1.9xl03
SEDIMENTS
Ingeation
Dermal
.32
7.9X106
SURFACE
WATER
iQgCfltlOfl
Dcnnu
.013
2.1xl07
FISH
INOESnoN
1.6
6.3X104
Future Conditions are based on: assumptions of future groundwater use on-site at levels comparable to overall site groundwater quality
(*) Based in available information and the conservative risk evaluation, control of fish consumption and remediation of intermediate and deep ground water does not seem warranted.

-------
                                                              TABLE 4

                           REMEDIAL TECHNOLOGIES EVALUATED FOR THE L.E. CARPENTER SITE
 Environmental Media
    General Response
         Actions
  Remedial Technology Types
                   Process Options
Soil/Sediment
No Action

Institutional Controls

Containment



Removal

Treatment
                       Disposal
No Action

Restricted access

Surface runoff controls

Capping/covering/consolidation

Excavation

Physical treatment

Chemical treatment

Thermal treatment


Biological treatment

In-situ treatment


Landfill
Fencing deed restriction

Regrading, drainage ditches, and silt fencing

Soil, clay, asphalt, concrete, or multimedia liners

Excavation

Soil washing, stabilization, supercritical fluid extraction

Wet air oxidation, supercritical water oxidation

On-site incineration, off-site incineration, low-temperature
thermal treatment

Solid phase treatment/composting, slurry bioremediation

Bioreclamation, soil flushing, in situ volatilization,
electromagnetic heating, vitrification

On-site, off-site

-------
                                                              TABLE 4
                                                             (Continued)

                           REMEDIAL TECHNOLOGIES EVALUATED FOR THE L.E. CARPENTER SITE
 Environmental Media
    General Response
         Actions
  Remedial Technology Types
                   Process Options
Groundwater
No Action

Institutional Controls



Containment

Collection



Treatment
                       Disposal
No Action

Restricted use
Alternate water supply
Point-of-use treatment

Subsurface diversion

Floating product collection

Groundwater collection

Physical treatment


Chemical treatment

Biological treatment

In situ treatment

Groundwater discharge
Monitoring

Deed restriction
Public water hookup, bottled water
Carbon filters

Slurry walls, grout injection, sheet piling, electroosmosis

Product recovery wells, interceptor trenches

Extraction wells, interceptor trenches

Liquid phase separation, air stripping, steam stripping,
carbon adsorption, membrane separation, resin adsorption

UV/chemical oxidation, high-energy electron beam

Aerobic, anaerobic, spray irrigation, artificial wetland

Biodegradation, permeable treatment beds

To POTW, to surface water, to groundwater

-------
                                                                                         Table 5-1

                                                                        Summary of the Technology Screening for Soil
    Remedial Technology
       Process Option
                                                                                              Effectiveness
      Implementability
         Cost
No Action


No Action
                                                                              Will not significantly reduce the  risk to human
                                                                              health or the environment within the foreseeable
                                                                              future
                                                                                           No  further  implementation
                                                                                           required
                                  Minimal
                                        Deed & Permitting Restrictions
                                       Effectively limits future-use risk scenario and         Implementable
                                       prevents potential exposure pathways
                                                                                                                                                                     Low
Surface Runoff Controls
Regrading, Drainage Ditches,
and Silt Fencing
                                                                              Reduces soil migration via erosion
                                                                                           Readily implemented
                                  Low capital and O&M
                                        Clay, Soil, Asphalt, Concrete, 01
                                        Multimedia Liners
                                       Prevents  exposure  to and migration of  soil
                                       contaminants. Reduces leaching of contaminants
                                       to groundwater from percolated rainwater.
Readily implemented (pavement
currently  covers  42% of the
site)
Low to moderate capital
and O&M
Excavation


Excavation
                                                                              Removes contaminated soil
                                                                                           Readily implemented  although
                                                                                           structures and  activity at  the
                                                                                           site may hinder implementation
                                  Moderate to high capital

-------
                                                                                           Table 5-1
                                                                                           (continued)
    Remedial Technology
Process Option
Effectiveness
Implementability
Cost
Physical Treatment
                                Well-suited for  high-permeability  soils.    A
                                multistage  process  could extract organics and
                                inorganics.  Useful in  reducing soil volume for
                                subsequent treatment steps.

                                Applicable primarily to metals. Not well suited
                                for organic contamination unless proprietary
                                additives   are   used.      Some   leaching   of
                                contaminants   possible.    Does  not   reduce
                                contaminant volume.

                                Potentially effective for DEHP
                                                                                                                                      Laboratory testing required
                                      Land disposal restrictions may
                                      apply.   Would require  treata-
                                      bility and performance tests.
                                                                                                                                      Technology  in  developmental
                                                                                                                                      phase.      Would   require
                                                                                                                                      ireatability tests.
                                                                        Moderate   capital  and
                                                                        O&M
                            Moderate capital, low to
                            moderate O&M
                                                                         High capital and O&M
Chemical Treatment
Thermal Treatment
                                          Supercritical Water Oxidation
                                         Low-Temperature Thermal
                                         Treatment
                                                                                 Effective only for organics at high concentration
                                                                                 Effective only for organics at high concentration
                                                                                 Effective destruction of organics. Metals remain
                                                                                 in ash.
                                 Effective for volatile organics. Less effective for
                                 DEHP.
                                                                                      Applicability to  soil slurry  is
                                                                                      unproven.     Would   require
                                                                                      treatability tests.
                                                                                      Applicability to  soil slurry  is
                                                                                      unproven.     Would   require
                                                                                      treatability tests.
                                                                                      Mobile/transportable    units
                                                                                      available.  Local opposition  to
                                                                                      on-site treatment anticipated.
                                      Pilot tests required to confirm
                                      effectiveness.
                                                                         High capital and O&M
                                                                                                                                                                         High capital and O&M
                                                                         High capital and O&M
                            High  capital,  moderate
                            O&M

-------
                                                                                     Table 5-1
                                                                                    (continued)
Remedial Technology
Process Option
Effectiveness
                                            Implementability
Cost

Biological Treatment






Solid Flute
Treatment
Convorint

Slurry
Bioremediation
                                                                          Potentially effective for organics. Metals remain
                                                                          in soil.
                                                                          Removes readily degradable organics
                                                                                    Space  constraints and VOC
                                                                                    emissions make it infeasible
                                                                       Moderate   capital,  low
                                                                       O&M
                                                                                    Laboratory or pilot-scale tests      High  capital,  moderate
                                                                                    would be required for DEHP       O&M
                                                                          Effectiveness hinges  on  oxygen distribution.
                                                                          Native microbes effective in degrading organic
                                                                          contaminants of concern.

                                                                          Nonuniform permeability hinders solvent contact.
                                                                          Not effective for DEHP.  Effective for volaliles.
                                                                          Better semivolatile volatilization than  ISV, but
                                                                          not effective for DEHP
                                                                          Permeability and nonuniformity of soils impairs
                                                                          vitrification. Stabilizes metals.
                                                                                    Treatability testing performed.
                                                                                    No  excavation   or  delisting
                                                                                    required.

                                                                                    Contaminant migration needs to
                                                                                    be   controlled.      Can   be
                                                                                    implemented  in   combination
                                                                                    with insitu bioremediation.
                                                                                    Readily implementable
                                                                                    Readily   implementable.
                                                                                    Potential flammability hazard.
                                                                                    Implementable
                                                                       Moderate  capital  and
                                                                       O&M
                                                                       Moderate  capital  and
                                                                       O&M
                                                                       Moderate  capital  and
                                                                       O&M
                                                                       High capital and O&M
                                                                       High capital and O&M

-------
                                                                                       Table 5-1
                                                                                      (continued)
Remedial Technology
Process Option
Effectiveness
Implementability
                                                                                  Cost
                                                                            Isolates contaminants to  inhibit  leaching.   No
                                                                            contaminant reduction.
                                                                            Isolates contaminant to inhibit leaching.   No
                                                                            contaminant reduction.
                                                                                      Space limitations, and land use
                                                                                      prohibitions. Future liability.
                                                                                      Subject to RCRA  restrictions.
                                                                                      Future liability.
                                                                        High capital, low O&M
                                                                        Low capital, low O&M

-------
                                                                                        Table 5-2

                                                        Summary of (he Technology Screening for Groundwater and Immiscible Product
    Remedial Technology
       Process Option
                                                                                             Effectiveness
                                                           Implementability
Cost
No Punter Action


Monitoring
Institutional Controls
Deed Restriction, Public Water
Hookup, or Point of Use
Treatment	
                                                                              Would not reduce the extent of contamination
Prevents  use  of  contaminated water.    No
contaminant reduction.
                                                                                           No   further   implementation     Minimal
                                                                                           required
                                                                                                                                  Readily implemented               Low
                                                                              Effective  in  reducing  migration of  floating
                                                                              product. Bedrock is too deep to form a complete
                                                                              groundwater barrier.  Can reduce extraction of
                                                                              clean groundwater.

                                                                              This technology has proven to be ineffective in
                                                                              soils with varying permeability.
                                                                              Effective  in  reducing  migration  of  floating
                                                                              product. Bedrock is too deep to form a complete
                                                                              groundwater barrier.

                                                                              Unclear how floating product would be affected
                                                                                            Readily implemented
                                                                                            Readily implemented
                                                                                            Boulders in  the  overburden
                                                                                            make installation impractical
                                                                                            Unproven  technology.   Field
                                                                                            testing required.
                                                                                       Moderate   capital,  low
                                                                                       O&M
                                                                                       Moderate   capital,  low
                                                                                       O&M
                                                                                       Moderate   capital,  low
                                                                                       O&M
                                                                                       Low to moderate capital,
                                                                                       high O&M

-------
                                                                                     Table 5-2
                                                                                    (continued)
Remedial Technology
Process Option
Effectiveness
Imptementability
                                                                                Cost
                                                                          Effectiveness would be  increased  if  used  in
                                                                          combination with pump and treat technologies
                                                                          Effective in permeable soils for floating product
                                                                          and groundwater
                                                                          Also effective for floating product and shallow
                                                                          groundwater, but less flexible  than extraction
                                                                          wells.
                                                                                    In operation at the site since
                                                                                    May  1984.   E1PRS  currently
                                                                                    operating.
                                                                                    Extracted  groundwater would
                                                                                    require   treatment   and
                                                                                    permitting

                                                                                    Readily implemented
                                                                       Low incremental  capital
                                                                       and O&M
                                                                       Moderate   capital  and
                                                                       O&M
                                                                       Moderate   capital  and
                                                                       O&M

-------
                                                                                   Table 5-2
                                                                                   (continued)
Remedial Technology
Process Option
                                                                                        Effectiveness
Implementability
Cost
                                   Supercritical Fluid Extraction
                                                                         Effective  for  organics,  as long as suspended
                                                                         solids concentrations are not excessive
                                                                         Effective for VOCs and could be used to reduce
                                                                         total organics  mass loading prior to further
                                                                         treatment for DEHP.
                                                                         Effective for VOCs.  Unlikely to be effective for
                                                                         DEHP.
                                                                         Effective for higher molecular weight compounds
                                                                         and  metals.   Substantial  pretreatment  and
                                                                         maintenance  requirements.     Not  durable.
                                                                         Retained   only  if metals  removal  becomes
                                                                         necessary.
                                                                         May be effective for DEHP.
                                                                         Can be tailored to inorganics or organics.  Not
                                                                         effective  for  concentrated   contaminants.
                                                                         Retained  only if  metals  removal  becomes
                                                                         necessary.
                                                                         Effective on water/organic mixtures.  Separated
                                                                         products   would   require   further
                                                                         treatment/disposal.
                                                                                   Readily implemented
                                                                                   Readily implemented.  Would
                                                                                   require  treatment  and   per-
                                                                                   mitting of off gases.
                                                                                   Readily implemented
                           Moderate  capital,  high
                           O&M
                           Moderate   capital   and
                           O&M
                           High capital and O&M
                                                                                   Membranes subject to fouling      High capital and O&M
                                                                                   and degradation.
                                                                                   Technology  in  developmental      High capital and O&M
                                                                                   phase
                                                                                   Treatability test required
                                                                                   Readily implemented
                           High capital and O&M
                           Low capital and O&M

-------
                                                                                          Table 5-2
                                                                                         (continued)
    Remedial Technology
Process Option
Effectiveness
Implementability
                                                                                                                                                                                Cost
Chemical Treatment
                                                                               Effective for concentrated organics, some metals,
                                                                               and floating product.  Not effective for dilute
                                                                               contaminants.

                                                                               Effective for organics and some metals
                                Effective for concentrated organics. Not effective
                                for floating product or dilute contaminants.
                                                                               Effectiveness  similar to other  oxidation type
                                                                               treatment.    Works  for  both   dilute  and
                                                                               concentrated contaminants.
                                                                                     Treatability test required
                                                                                     Treatability test required
                                                                                                                                     Treatability test required
                                                                       Very high  capital, high
                                                                       O&M
                                                                        High capital and O&M
                                                                        High capital and O&M
                                                                                     Several  years   away  from     High capital and O&M
                                                                                     commercial availability
Biological Treatment
                                                                                Removes readily degradable organics.Treatabilily
                                                                                study indicated effective for DEHP, xylenes, and
                                                                                ethylbenzene

                                                                                Removes degradable organics.  Susceptible to
                                                                                upsets.  Reported to be unsuitable for DEHP.
                                                                                Removes  volatiles   and  readily  degradable
                                                                                organics.  No DEHP removal.
                                                                                Removes organics.  Not effective for metals or
                                                                                PCBs.
                                                                                     Treatability  study   indicated
                                                                                     favorable implementability.
                                                                                     Laboratory and pilot-scale tests
                                                                                     would be required
                                                                                     Problems with VOC emissions
                                                                                     and space constraints
                                                                        Moderate   capital,
                                                                        moderate O&M
                                                                        High  capital,  moderate
                                                                        O&M
                                                                        Low capital and O&M
                                                                                     Problems with VOC emissions      Low capital and O&M
                                                                                     and space constraints

-------
                                                                                         Table 5-2
                                                                                        (continued)
    Remedial Technology
Process Option
Effectiveness
Itnplementability
                                                                                Cost
In Situ Treatment
Groundwater Discharge
                                                                              Similar to aerobic degradation in an activated
                                                                              sludge  system.     Potentially  effective  on
                                                                              contaminants sorbed to soil.
                                                                              Effective   only  for   organics   in   shallow
                                                                              groundwater for short duration
                                                                               Effective. Could use existing outfall to drainage
                                                                               ditch.
                                                                               RVRSA not  accepting  discharge  from  GW
                                                                               remedialions
                                                                              Tile  fields,  injection  wells,  well  points,  or
                                                                              infiltration galleries would be effective.
                                                                                    Laboratory or pilot-scale tests
                                                                                    required.   Treatability  study
                                                                                    indicated   favorable
                                                                                    implementability.

                                                                                    Readily implemenlable
                                                                                    Would  require  pretreatment
                                                                                    and permitting procedure
                                                                                    Would  require  pretreatment
                                                                                    and permitting procedure
                                                                                    Would  require pretreatment,
                                                                                    and permitting procedure, and
                                                                                    demonstration of containment.
                                                                       Moderate  capital  and
                                                                       O&M
                                                                       Moderate  capital  and
                                                                       O&M
                                                                       Low
                                                                       Low
                                                                       Low

-------
             TABLE 6



  ARARs COMPLIANCE SUMMARY

1
No Action
2
Institutional Controls
3
Groundwater
Treatment
4
Groundwater
Treatment with
Reinfiltration
5
Excavation/On-Site
Soil
Washing/Bioslurry
Treatment
6
Excavation/
Thermal
Treatment
Chemical-Specific
Groundwater
Soil
RCRA Toxicity Characteristic
(Treated Soil, Used Carbon)
MCLs and NJ
Class II-A
cleanup
standards'
exceeded
New Jersey draft
cleanup criteria*
exceeded
NA
MCLs and NJ Class
II-A cleanup
standards exceeded
New Jersey draft
cleanup criteria
exceeded
NA
Expected to meet
New Jersey
proposed cleanup
standards
exceeded
NA
Expected to meet
Expected to meet
Expected to meet
Expected to meet
Expected to meet
Expected to meet
Coarse soil may
require additional
treatment
Expected to meet
Expected to meet
Expected to meet
Action-Specific
Clean Closure (40 CFR
264.111)
Closure with Waste in Place (40
CFR 264.228)
Solid Waste Disposal (40 CFR
241.200-212)
NA
Will not meet
NA
NA
Will not meet
NA
NA
Will not meet
Will meet
(disposal of used
activated carbon)
Will meet
NA
NA
Will meet
NA
See Alternative 3
Will meet
NA
Nonhazardous
residuals will be
disposed off
site/on site
dependent on
analyses.
' New Jersey draft cleanup criteria are not ARARs but are TBCs.

-------
          TABLE 6

ARARs COMPLIANCE SUMMARY
         (Continued)

NPDES (40 CFR 122-125) and
NJPDES NJAC 7:9-4.1 et seq.
and NJAC 7:15 A-5)
Ambient Water Quality
Standards (CWA 402 (a)(l))
Air Emissions (from
Excavations) (NJAC 7:27-16)
1
No Action
NA
NA
NA
2
Institutional Controls
NA
NA
NA
3
Groundwater
Treatment
Permit
requirements for
surface water
discharge will be
fulfilled.
Compliance will
occur by meeting
NPDES
limitations
NA
4
Groundwater
Treatment with
Reinfiltration
Permit requirements
for groundwater/
surface water
discharge will be
fulfilled.
See Alternative 3
NA
5
Excavation/On-Site
Soil
Washing/Bioslurry
Treatment
See Alternative 3
•
See Alternative 3
Will meet
6
Excavation/
Thermal
Treatment
See Alternative 3
See Alternative 3
Will meet
Location-Specific
RCRA Location of TSD Facility
in 100- Year Floodplain (40
CFR 264.18)
Floodplain Management -
Evaluate Potential Effects of
Actions, Avoid Adverse Impacts
(40 CFR 6, App. A)
State Siting Standard for New
Incineration
NA
NA
NA
NA
NA
NA
Will meet
Will meet
NA
Will meet
Will meet
NA
Will meet
May require
exemption for low-
lying area near
Wharton Enterprises.
NA
Will meet
See Alternative 5
Expected to meet
substantive
requirements

-------
                                  TABLE?

              PRELIMINARY COST ESTIMATE: ALTERNATIVE 1
                                NO ACTION
                                        Unit Price
                 Estimated               Material          Estimated
Description        Quantity       Unit      and Labor         Amount

No capital costs are associated with Alternative 1.
Note:

This cost estimate is considered an order of magnitude estimate with an accuracy of +50 percent
to -30 percent.

-------
                             TABLE 7 (continued)

              PRELIMINARY COST ESTIMATE: ALTERNATIVE 2
                         INSTITUTIONAL CONTROLS
Description

Deed Notation
Additional Monitoring Well
Fstirnated
Quantity
1
Unit
Lump sum
Well
Unit Price
Material and
Labor
$35,000
$5,000
Subtotal
Contingencies (25%)
Estimated
Amount
$35,000
$5.000
$40,000
$10.000
                                                    Total
$50,000
Note:

This cost estimate is considered an order of magnitude estimate with an accuracy of +50 percent to -30 percent.

-------
                                    TABLE 7 (continued)

                 PRELIMINARY COST ESTIMATE: ALTERNATIVE 3
                             GROUNDWATER TREATMENT
Description

Deed Notation
Phase I Wells: extraction/monitor well'0
Phase I Wells: recirculation well
Phase n Wells: extraction/monitor well0'
Phase II Wells: recharge well
Phase U Wells: discharge well
Treatability Testing
Permit Applications
Groundwater Treatment System
Soil Cover
Hot Spot Excavation
Hot Spot Transport & Disposal

Estimated
Quantity
.
tor well0' 4
ill 4
itorwell0' 6
5
1
-
-
u0)
3.5
1,100
10> 1,100

Unit Price
Material
Unit and Labor
lump sum $35,000
each $15,000
each $10,000
each $20,000
each $15,000
each $25,000
lump sum $100,000
lump sum $60,000
lump sum $443,000
acre $28,300
cu. yd. $23
cu. yd. $2,095
Subtotal
Engineering, Construction Management (25%)
Mobilization, Demobilization, Site Services(10%)




Subtotal
Contingencies (25%)
Total
Rounded to

Estimated
Amount
$35,000
$60,000
$40,000
$120,000
$75,000
$25,000
$100,000
$60,000
$443,000
$99,000
$25,000
$2.305.000
$3,387,000
$846,750
$338.700
$4,572,450
$1.143.112
$5,715,562
$5,716,000
Notes:

This cost estimate is considered an order of magnitude estimate with an accuracy of +50 percent to -30 percent.

(l)   -  Includes pumps and controllers.
ro   -  Includes treatment building, utility hookups, clarifier, equalization tank, fixed film submerged aerobic
      bioreactor, granular activated carbon (GAC) beds for effluent polishing, GAC vapor phase treatment, and
      associated pumping and piping.
O)   -  Includes post excavation sampling - assumes incineration as disposal method for costing purposes.

-------
                                   TABLE 7 (continued)

                 PRELIMINARY COST ESTIMATE:  ALTERNATIVE 4
              GROUNDWATER TREATMENT WITH REINFBLTRATION
                                    Estimated
Description                          Quantity

Deed Notation
Phase I Wells: extraction/monitor well01   4
Phase I Wells: recirculation well         4
Phase n Wells: extraction/monitor well'"  6
Phase n Wells: recharge well           5
Phase n Wells: discharge well           1
Phase n reinfiltration network           50,000
Treatability Testing
Permit Applications
Groundwater Treatment System0'
Nutrient/Hydrogen Peroxide
 Addition System
Soil Cover                           3.5
Hot Spot Excavation                   1100
Hot Spot Transport & Disposal0*         1,100
Hot Spot Excavation (Deep Soils)        1130
Hot Spot Disposal (Deep Soils)          300(4)
Unit
Unit Price
Material
and Labor
lump sum
each
each
each
each
each
sq. ft.
lump sum
lump sum
lump sum
$35,000
$15,000
$10,000
$20,000
$15,000
$25,000
$10
$100,000
$70,000
$443,000
lump sum
acre
cu. yd.
cu. yd.
cu. yd.
cu. yd.
$42,000
$28,300
$23
$2,100
$28.5
$3,470
                                                             Subtotal
                             Engineering, Construction Management (25%)
                           Mobilization, Demobilization, Site Services(10%)

                                                             Subtotal
                                                   Contingencies (25%)

                                                                Total
                                                          Rounded to
Notes:
 Estimated
 Amount

   $35,000
   $60,000
   $40,000
  $120,000
   $75,000
   $25,000
  $497,000
  $100,000
   $70,000
  $443,000

   $42,000
   $99,000
   $25,000
$2,305,000
   $32,000
$1.041.000

$5,009,000
$1,252,250
  $500.900

$6,762,150
$1.690.538

$8,425,688
$8,452,000
This cost estimate is considered an order of magnitude estimate with an accuracy of +50 percent to -30 percent.
(l)   -  Includes pumps and controllers.
c>   -  Includes treatment building, utility hookups, clarifier, equalization/nutrient mix tank, fixed film submerge
      aerobic bioreactor, granular activated carbon (G AC) beds for effluent polishing, GAC vapor phase treatment,
      and associated pumping and piping.
o)   -  Includes post excavation sampling - assumed incineration as disposal method for costing purposes.
<4)   -  Due to nature of waste, assume materials to be drummed for shipment. Remaining 830 cu. yd. consolidated
      within CAMU.

-------
                                       TABLE 7 (continued)

                     PRELIMINARY COST ESTIMATE: ALTERNATIVE 5
            EXCAVATION/ON-SITE SOIL WASHING/BIOSLURRY TREAIfMENT*
Description

Deed Notation
Phase I Wells: extraction/monitor well10
Phase I Wells: recirculation well
Site Preparation (Staging/Equip. Area)
Treatability Testing
Permit Applications
Groundwater/Washwater Treatment
 System
On-site Laboratoryฎ
Bulk Excavation
Bulk Treatment/Disposal

Hot Spot Transport & Disposal 0)
Site Restoration (Backfill/grading)'4'
Phase n Wells: extraction well(1)
Phase n Wells: recharge well
Phase II Wells: discharge well




litor well10
'ell
ip. Area)

fmAnt
UUCUv




JO)
ling)'4'
J<"

1



Estimated
Quantity
.
4
4
4,200
-
-
.
8
31,500
31,500

300
3,150
6
5
1


Unit Price
Material
Unit and Labor
lump sum $35,000
each $15,000
each $10,000
sq. ft. $24
lump sum $360,000
lump sum $70,000
lump sum $565,000
months $40,000
cu. yd. $15.40
cu. yd. $263.5 to
$495
cu. yd. $3,470
cu. yd. $5.70
each $20,000
each $15,000
each $25,000
Subtotal

Engineering, Construction Management (25%)



Mobilization, Demobilization, Site Services (10%)



















Subtotal

Contingencies (25%)

Total

Rounded to


Estimated
Amount
$35,000
$60,000
140,000
$100,000
$560,000
S;70,000
$565,000
$220,000
$485,000
$8,300,000 to
$15,600,000
$1,041,000
$180,000
$120,000
$75,000
$25.000
$ll,776,000to
$19,076,000
$2,944,000 to
$4,769,000
$1,177,600 to
$1.<>07.600
$15,897,600 to
$25,752,600
3,974,400 to
$6.438.150
$19,872,200 to
$32,390,750
$19,872,000to
$32,1.91,000
Notes:
   -  This cost estimate is considered an order of magnitude estimate with an accuracy of +50 percent to -30 percent.
<"  .  Includes pumps and controllers.
ฎ  -  Laboratory to provide post excavation analysis, post treatment analysis, and verification of suitability of material for
      backfill.
0)  -  Assumes material excavated from waste disposal area not suitable for soil washing process.
<4)  -  Assumes all soil except fines (assumed 20% by volume) are suitable for backfill after treatment.

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                                       TABLE 7 (continued)

                    PRELIMINARY COST ESTIMATE: ALTERNATIVE 6A
             EXCAVATION/THERMAL TREATMENT (ON-SITE INCINERATION
                                   Estimated
Description                          Quantity

Deed Notation
Phase I Wells: extraction/monitor well01  4
Phase I Wells: recirculation well        4
Site Preparation (Staging/Equip. Area)   9,170
Treatability Testing
Permit Applications
Groundwater Treatment System
On-site Laboratoryฎ                  20
Bulk Excavation                     31,500
Incinerator Permitting/Trial Burn
Thermal Treatment                   31,500
Site Restoration (Backfill/grading)0'      31,500
Phase n Wells: extraction well"        6
Phase n Wells: recharge well           5
Phase n Wells: discharge well          1


Unit
lump sum
each
each
sq. ft.
lump sum
lump sum
lump sum
months
cu. yd.
lump sum
cu. yd.
cu. yd.
each
each
each
Unit Price
Material
and Labor
$35,000
$15,000
$10,000
$24
$100,000
$20,000
$425,000
$50,000
$15.4
$2,000,000
$675
$6.4
$20,000
$15,000
$25,000
                                                            Subtotal
                             Engineering, Construction Management (25 %)
                          Mobilization, Demobilization, Site Services(10%)

                                                            Subtotal
                                                  Contingencies (25%)

                                                              Total
                                                         Rounded to
Notes:
  Estimated
  Amount

    $35,000
    $60,000
    $40,000
   $220,000
   $100,000
    $20,000
   $425,000
 $1,000,000
   $485,000
 $2,000,000
$21,263,000
   $201,000
   $120,000
    $75,000
    $25.000

$26,069,000
 $6,517,250
 $2.606.900

$35,193,150
 $8.798.288

$43,991,438
$43,991,000
This cost estimate is considered an order of magnitude estimate with an accuracy of +50 percent to -30 percent.

0)  -  Includes pumps and controllers.
ฐ*  -  Laboratory to provide bum characteristic analysis, post excavation analysis, post treatment analysis (including PCDD
      and PCDF analyses), and verification of suitability of material for backfill.
ฐ> -   Assumes incinerator ash and oversize material suitable for backfill.

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                                       TABLE 7 (continued)
                    PRELIMINARY COST ESTIMATE: ALTERNATIVE 6B
            EXCAVATION/THERMAL TREATMENT (ON-SITE INCINERATION)
                                   Estimated
Description                          Quantity

Deed Notation
Phase I Wells: extraction/monitor well"1  4
Phase I Wells: recalculation well        4
Site Preparation (Staging/Equip. Area)    4,600
Instability Testing
Permit Applications
Groundwater Treatment System
Bulk Excavation                      31,500
Waste Characterization Analysis         45
Transportation to Incineration           31,500
Off Site Thermal Treatment             31,500
Site Restoration (Backfilling/grading)     31,500
Phase n Wells: extraction well(l>         6
Phase n Wells: recharge well           5
Phase n Wells: discharge well          1
Unit
Unit Price
Material
and Labor
lump sum
each
each
sq. ft.
lump sum
lump sum
lump sum
cu. yd.
each
cu. yd.
cu. yd.
cu. yd.
each
each
each
$35,000
$15,000
$10,000
$24
$100,000
$20,000
$425,000
$15.4
$1,200
$125
$1,950
$15.45
$20,000
$15,000
$25,000
                                                            Subtotal
                           Engineering, Construction Management (25%)C)
                        Mobilization, Demobilization, Site Services(10%)ra

                                                            Subtotal
                                                 Contingencies (25%)

                                                              Total
                                                         Rounded to
Notes:
  Estimated
  Amount

   $35,000
   $60,000
   $40,000
   $110,000
   SIX), 000
   $20,000
   $4:25,000
   $455,000
   $54,000
 $3,938,000
$61,425,000
   $487,000
   $1:20,000
   $75,000
   125.000

$67,399,000
   $51)9,000
   $2D3.100

$68,111,600
$17.027.900

$85,1:59,500
$85,1.10,000
This cost estimate is considered an order of magnitude estimate with an accuracy of +50 percent to -30 percent.

(I)  -  Includes pumps and controllers.
C)  -  Cost factors applied to subtotal less transportation and thermal treatment costs since these factors are applicable to on-
      site services.

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                          ROD FACT SHEET
SITE
Name            :
Location/State  :
EPA Region      :
HRS Score (date):
Site ID #       :

ROD	
Date Signed:


Remedies:
    L. E. Carpenter/Dayco Corporation
    Wharton Borough,  Morris County, New Jersey
    II
    46.13 (April 1985)
    NJD002168748
  April 18,  1994 (signed by NJDEPE under
  USEPA/State Pilot Agreement)

  Ground water treatment with re-infiltration;
  soil off-site disposal and in situ
  bioremediation
Operating Unit Number: OU-1

Construction Completion:    36 months
Capital cost:
O & M:
Present worth:
LEAD
$ 8,452,000
$   210,000
$11,020,000
(in 1993  dollars)
(in 1993  dollars)
(7.1% discount rate,
 30 years O & M assumed)
Remedial: N.J. Department of Environmental Protection and Energy
Primary contact:   Christina H. Purcell  (609)-633-1455
Secondary contact: Sharon Jaffess  (212)-637-4396
Main PRP: L. E. Carpenter Co.
PRP Contact  (phone): Christopher R. Anderson (216)-589-4020
WASTE
Type: volatile organics, base neutral compounds, metals, PCB, PAH
Medium:  soil, groundwater
Origin:  manufacture of vinyl wall coverings from 1943 until 1987
Estimated quantity: 14.3 acre site includes 2230 cu.yds. soil to
         be excavated and disposed off-site; also 20 wells for
         extraction and 50,000 sq. ft. reinfiltration network

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           Note on Superfund  Record  of Decision  (ROD)
                       L. E. Carpenter Site
           Wharton Borough, Morris County/ New Jersey


The L.  E.  Carpenter site is part of the USEPA/State Pilot agreement
program wherein the State is  given  full authority to  produce a
CERCLA quality cleanup at the site.   The Record of Decision (ROD)
signed April  18,  1994,  is the  first  formal ROD  under  a  pilot
agreement with  USEPA to eliminate duplicative  government agency
review.    Pursuant to  the   Pilot  agreement   "Support  agency
concurrence on  lead agency  RODs is not required".    All  USEPA
comments regarding this ROD have been addressed and incorporated.
The USEPA decision not  to concur on the ROD should not be construed
to mean that USEPA disagrees with the remedy proposed j'.n  the ROD or
with the rationale described in the ROD.   The New Jersey Department
of Environmental  Protection has  selected Biological Treatment of
ground water  with reinfiltration and soil bioremediation as  the
remedy for the  L. E. Carpenter Site.  This  selected  remedy best
satisfies the requirements of the NCP's  nine evaluation criteria
for the  remedial alternatives.   A site  review  will be conducted
every five years of execution  of  the  ROD  until health based levels
are met.

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