PB97-963815
                                 EPA/541/R-97/107
                                 January 1998
EPA  Superfund
       Record of Decision:
       Curcio Scrap Metal Inc., OU 2
       Saddle Brook, NJ
       9/30/1997

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                            DECISION DECLARATION

                             RECORD OF DECISION

                       CURCIO SCRAP  METAL, INC. SITE

SITE NAME AND LOCATION

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

STATEMENT OF BASIS AND PURPOSE

This Record of Decision presents the selected No Further Action remedy for the Curcio Scrap
Metal Site, in Saddle Brook, Bergen County, New Jersey. The remedy was developed in
accordance with the requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended, 42 U.S.C. §9601, et seq., and
to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), as amended, 40 CFR Part 300.

The New Jersey Department of Environmental Protection (NJDEP) concurs with the selected
remedy.  A copy of the concurrence letter can be found in Attachment 1. The information
supporting this remedial action decision is contained in the Administrative Record for this Site,
the index of which is Attachment 2 to this document.

DESCRIPTION OF THE SELECTED REMEDY

The U.S. Environmental Protection Agency (EPA), in conjunction with NJDEP, has determined
that no further remedial action is necessary at the Curcio Scrap Metal Site. The removal of
contaminated materials by the Potentially Responsible Parties (PRPs) in 1994 was successful in
remediating the principal threats associated with the Site.

The major components of the No Further Action remedy are:

•     Implementation of a groundwater monitoring program to monitor contaminants in the
      groundwater. Groundwater samples will be collected and analyzed for Target Compound
      List (TCL) volatile organic compounds (VOCs) and Target Analyte List (TAL) inorganic
      compounds for the first yearon approximately a quarterly basis. Special analytical
      services will be used, where appropriate, in the analytical procedures to minimize any
      variability of data. The monitoring program may be modified based upon sampling
      results collected during the first year.  Currently, EPA and NJDEP do not believe that
      additional  groundwater monitoring wells will be required for the purpose of the sampling
      program. However, if the results of the initial rounds of sampling indicate that additional
      wells are necessary, then they will be  installed.

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•     A Classification Exception Area (CEA) will be established by NJDEP to provide
       information on contamination in the groundwater resulting from Site operations. The
       CEA will remain in effect until contaminant levels are below New Jersey Groundwater
       Quality Standards. NJDEP may establish a Well Restriction Area (WRA) if groundwater
       contamination associated with the Site should be determined to impact potential users.
       By establishing a WRA, NJDEP can assure that contaminants in the groundwater will not
       pose a threat to human health as a result of well installation and operations;

•     After five years, or less, if the sampling and analyses indicate the need for action, the
       potential risks to human health and the environment will be reassessed.  The groundwater
       monitoring would then either continue for another five-year period, or some other action
       will be considered.  If monitoring reveals that contamination at the Site increases so that
       an unacceptable risk to human health or the environment develops, an appropriate action
       can be initiated at any time during the five-year period to address the risks. The CEA will
       remain in effect until constituents in the groundwater do not exceed established drinking
       water standards.

DECLARATION

In accordance with CERCLA and the NCP, EPA and NJDEP have determined that all remedial
actions for the Curcio Scrap Metal Site have been successfully implemented and no further
response actions are necessary to ensure the protection of human health and the environment.

In lieu of a Final Close Out Report, this Record of Decision also documents that the PRPs  have
completed all construction activities for the Site in accordance with Close Out Procedures for
National Priorities List Sites (OSWER Directive 9320.2-09). Therefore, the  response at the
Curcio Scrap Metal Site is complete and  it now qualifies for inclusion on the Construction
Completion List. However, a five year review will be performed since contaminants remain on
the Site above health protective levels.
Jeanne M. Fox, Rearona
U.S. Environmental Prote
   istrator
n Agency - figion 2
                                                            Date

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                              TABLE OF CONTENTS
                                                                             Page
1. Introduction.	  1
2. Site Location and Description.	  1
3. Site History and Enforcement Activities.	  2
4. Community Relations History	  3
5. Site Characteristics Summary	  3
      5.1 OU-1 RI Findings: Soil	  4
      5.2 OU-1 Remediation of Soils.	  4
      5.3 Hydrology	  5
      5.4 OU-1 Rl Findings: Groundwater	  6
      5.5 OU-2 Groundwater Investigatioa	  6
             5.5.1  Bedrock Monitoring Well Investigation Findings	  8
             5.5.2  Overburden Monitoring Well Investigation Findings	  9
             5.5.3  Residential Well Investigation Findings	  10
      5.6 Surface Water and Sediments.	.".	  11
6. Site Risk Summary	  11
      6.1 Human Health Risk Assessment	  13
      6.2 Ecological Risk Assessment	  16
      6.3 Uncertainties	  16
7. Evaluation and Summary of the 'No Further Action' Remedy	  17
8. NJDEP Acceptance.	  19
9. Community Acceptance.	  19
10. Explanation of Significant Differences	  19
11. Site Close Out	  19
            ATTACHMENTS   T     NJDEP Letter of Concurrence
                               2.     Administrative Record Index
                               3     Figures
                               4.     Responsiveness Summary
                               5.     Tables

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                               DECISION SUMMARY

                              RECORD OF DECISION

                        CURCIO SCRAP METAL, INC. SITE
1.      INTRODUCTION

This Decision Document presents the No Further Action remedy for the Curcio Scrap Metal, Inc.
Site (the Site) located in Saddle Brook, Bergen County, New Jersey.  The selected remedy for the
Site was chosen in accordance with the requirements of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as amended, 42 U.S.C. §9601,
et seq., and to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), as amended, 40 CFR Part 300.  This decision document serves to
explain the factual and legal basis for selecting the No Further Action remedy for this Site.

The information supporting the No Further Action remedy is contained in the administrative
record for this Site. This Decision Document includes a Decision Declaration, Decision
Summary and a Responsiveness Summary.

2.      SITE LOCATION AND DESCRIPTION

The Curcio Scrap Metal, Inc. Site is located at 416 Lanza Avenue in Saddle Brook, New Jersey.
The Site includes, but is not limited to, the real property where two active scrap metal recycling
businesses operate; Curcio Scrap Metal, Inc., (CSMI) and Cirello Iron and Steel Company
(CISC) (see Figure 1 in Attachment 3). The Site is approximately one acre in size and contains
two single story buildings which are used primarily as warehouses.  It is bordered by Lanza
Avenue on the north, Walther Avenue on the south, a light industrial site on the east and
Midland Avenue on the west.  The area surrounding the Site is comprised of residential homes
and industrial properties.

The Site is subdivided into the East, West and South Lots. CSMI and CISC conduct their
business from the buildings located on the West and South Lots (see Figure 1).  With the
exception of two narrow passageways, all the areas of the West and South Lots are paved. A ten-
inch thick reinforced concrete slab currently covers the entire area of the East Lot; however, the
East Lot had been unpaved until the'completion of the EPA selected remediation of its soils in
1994. The East Lot measures approximately 90 by 100 feet.
Curcio Scrap Metal, Inc. Site - ROD                                                    Page - I •

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3.     SITE HISTORY AND ENFORCEMENT ACTIVITIES

Salvaging operations began at the Site in the early 1950's, by Mr. Curcio's father.  Prior to this
time, the land was used for dairy farming. In 1952, Mr. Curcio purchased the East and West
Lots; in 1981, he purchased the South Lot.  Initially, only rags and paper were recycled. Later,
aluminum and copper were stored and recycled at the Site.  Today, CSMI and CISC deal with the
collection and compaction of scrap iron, aluminum, and other ferrous and non-ferrous metals. In
1977, the original structures on the Site were demolished, the present main building was erected
and sections of the West Lot were paved. In 1978, the truck scale and scale control shed were
constructed on the northern edge of the East Lot. The structures at the Site have remained
essentially unchanged since 1985.

The New Jersey Department of Environmental Protection (N JDEP) conducted an initial
investigation of the Site in October  1982. During this investigation, several disassembled
transformers were observed on the Site.  Puddles of oil also were observed on the ground beneath
and adjacent to the transformers. Samples of the puddles were collected, analyzed and elevated
concentrations of polychlorinated biphenyls (PCBs) were detected.  Further investigation
revealed that transformers containing PCBs were purchased by SECO Corporation from
Consolidated Edison Company of New York, Inc. (Con Ed) and subsequently sold to and
transported to CSMI by SECO. At least three documented PCB spills have occurred on the Site.

At NJDEP's request, EPA conducted a preliminary assessment of the Site in April 1984. In
September 1984, EPA performed a subsequent Site inspection which revealed the  presence of
hazardous substances such as PCBs, trichloroethylene, copper, lead and nickel, among other
substances, in Site soils.

The Site was placed on the National  Priorities List (NPL) in July 1987.  On May 27, 1988, EPA
entered into an Administrative Order on Consent (AGO) with CSMI, SECO Corporation and
Con Ed (collectively referred to as 'Respondents').  The ACO required the performance of a
Remedial Investigation and Feasibility Study (RJ/FS) at the Site in order to determine the nature
and extent of contamination along with alternatives to address that contamination.

The RI was conducted from July 1989 through October  1990 and addressed soil and shallow
groundwater contamination.  Based on the results of the investigation and the elevated risk posed
by the contaminated soil, EPA determined that the cleanup of contaminated soil would be
addressed on an expedited basis.  Consequently, the Site was divided into two operable units
(OUs), or phases. Operable Unit One (OU-1) addressed soil and shallow groundwater
contamination. The cleanup of the soils was completed in January 1994. A detailed description
of the OU-1 remedial action activities is included in the March 1994 Remedial Action Report for
Operable Unit One: East Lot Soils, which is included in the Administrative Record. A summary
of the soil remediation is presented in Sections 5.1 and 5.2 of this document.
Curcio Scrap Metal, Inc. Site - ROD                                                     Page - 2 •

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EPA determined that additional groundwater investigation was required in order to fully assess
the nature and extent of groundwater contamination, therefore, the groundwater was designated
as Operable Unit Two (OU-2). The OU-2 RI for groundwater was conducted from January' 1996
to January 1997. A detailed description of the OU-2 groundwater investigation activities is
included in the March 1997 Final Groundwater Investigation Report - Operable Unit 2, which
is included in the Administrative Record and is summarized later in this document. A summary
of these findings is presented in sections 5.1 through 5.6 of this document.

4.     COMMUNITY RELATIONS HISTORY

Throughout the RI/FS process for both operable units, representatives from EPA and NJDEP
have attended meetings with the public concerning the Site. In February 1991, EPA presented its
preferred remedial approach for Site soils which outlined the excavation of contaminated soils
with off-site disposal. The first public meeting was held on February 21,1991  to brief interested
parties, discuss the RI/FS process for contaminated soils and present EPA and NJDEP's
preferred remedial approach of excavation of soils with off-site disposal. A public comment
period was established  from February 8, 1991 to March 11, 1991, during which time EPA and
NJDEP welcomed any  verbal and/or written comments or questions on the proposed remedy.

The Administrative Record is a comprehensive collection of all records relating to the selection
of the No Further Action remedy for the Site. An information repository has been established for
both OUs at the Saddle Brook Memorial Library, as well as EPA offices in New York City. The
Index for the OU-2 Administrative Record is Attachment 2 to this Decision Document.

The Proposed Plan, which presented the preferred No Further Action remedy for groundwater,
was released to the public for comment in July 1997.  The notice of availability of this document
was announced by means of a newspaper advertisement in the Bergen Record on July 30, 1997.
Notices were also mailed to the area residents and other concerned parties identified for this Site.
A public comment period was established from July 30, 1997 to August 28,1997, during which
time EPA and NJDEP welcomed any verbal and/or written comments or questions on the
proposed No Further Action remedy.

In addition, a public meeting was held during the public comment period, on August 6,1997 at
the Saddle Brook Memorial Library. At this meeting, representatives from EPA and NJDEP
presented Site background information and the rationale for the proposed No Further Action
remedy and answered questions about the Site. Responses to significant comments and concerns
received during the public comment period are included in the Responsiveness Summary, which
is Attachment 4 to this  document.  '

5.     SITE CHARACTERISTICS SUMMARY

An RI was conducted from July 1989 through October 1990 and addressed soil and shallow
groundwater contamination. Based on the results of the investigation and the elevated risk posed

Curcio Scrap Metal, Inc. Site • ROD                                                     Page • 3 -

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by the contaminated soil, EPA determined that the cleanup of contaminated soil would be
addressed on an expedited basis. Consequently, the Site was divided into two OUs.  Operable
Unit One (OU-1) RI addressed soil and shallow groundwater contamination. The cleanup of the
soils was completed in January 1994.

EPA determined that additional groundwater investigation was required in order to fully assess
the nature and extent of groundwater contamination, therefore, the groundwater was designated
as OU-2. This is the last planned OU for this Site. This ROD addresses the groundwater
investigation conducted as part of OU-2 for the Site. During the OU-2 RI for groundwater, EPA
and NJDEP evaluated contamination detected in Site groundwater. The OU-2 RI for
groundwater was conducted from January 1996 through January 1997.

The findings of the RI's for both OUs are summarized as follows:

       5.1    OU-1 RI Findings: SOIL [July 1989 - October 1990]

       The soil investigation portion of the OU-1 RI characterized the extent of the soil
       contamination through the collection and analyses of soil samples from 47 soil borings
       obtained at two-foot vertical intervals.  Of this total, 36 samples were collected from the
       East Lot. All borings extended to the water table, which is approximately six feet below
       grade. Each sample was analyzed for volatile organic compounds (VOCs), semi-VOCs,
       PCBs and inorganic compounds.  The results revealed the presence of organic and
       inorganic substances, with a wide range of concentrations, in Site soils in and around the
       East Lot. Tetrachloroethylene was detected at a level of 28 parts per million (ppm),
       trichloroethylene was detected at 6 ppm, and arsenic was detected at 55.6 ppm.  The
       maximum lead concentration detected was 39,300 ppm. PCB levels in the soil ranged
       from  levels of non-detectable to 6,200 ppm.

       5.2    OU-1:  Remediation of Soils [September 1993 - January 1994]

       In June 1991, EPA issued a ROD for OU-1. The ROD called for excavation and off-Site
       incineration of the contaminated soil. The cleanup level was established to be 1 ppm for
       PCBs. In September 1991, EPA issued an Administrative Order (Index No. II-CERCLA-
       10113) requiring the Respondents to remediate the soil in accordance with the ROD.

       Because of a nationwide shortfall in incineration capacity for PCB-contaminated
       materials that occurred  after the issuance of the ROD, EPA determined in an Explanation
       of Significant Difference, dated August 1992, that it was necessary to allow disposal of
       soils containing less than 1,000 ppm of PCB at a landfill permitted under both the
       Resource Conservation and Recovery Act (RCRA) and the Toxic Substances Control Act
       (TSCA) in order to proceed with the remedial action in a timely fashion. This revised
       remedial approach differed from the ROD only with regard to the off-Site
       disposition/treatment of the contaminated soil.  The on-Site soil cleanup level of 1 ppm

Curcio Scrap Metal, Inc. Site - ROD                                                      Page - 4 -

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       for PCBs, selected in the ROD, remained unchanged.

       The OU-1 cleanup was performed during the period from September 1993 through
       January 1994. The Respondents selected CH2M HILL to perform the remedial design
       and Westinghouse Remediation Services to conduct the remedial action activities. EPA's
       contractor, Camp Dresser & McKee (CDM), and the Respondents contractor, CH2M
       HILL, provided full time oversight of field activities during implementation of the
       remedial action. Approximately 3,000 tons of contaminated soil were excavated and
       removed from the Site. Approximately 500 tons of contaminated soil was transported
       off-Site for disposal at the Aptus Incinerator in Coffeyville, Kansas.  Approximately
       2,500 tons of contaminated soil was transported off-Site for disposal at the Chemical
       Waste Management Landfill facility in Model City, New York.  When confirmatory
       sampling indicated that the cleanup level was achieved, the area was backfilled with clean
       soil and a ten-inch thick reinforced concrete slab was installed over the East Lot. EPA
       conducted a final inspection on January 19, 1994 and determined that all remedial actions
       were successfully implemented by the PRPs. A detailed description of the OU-1
       remedial action activities is included in the EPA approved March 1994 Remedial Action
       Report for Operable Unit One: East Lot Soils, which is included in the Administrative
       Record.

       5.3     Hydrology

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

       A conceptual model of the aquifer depicts a leaky, multi-unit aquifer system consisting of
       thin water-bearing units and much thicker intervening aquitards. An aquitard, or
       confining unit, is characterized by low permeability and does not readily permit water to
       pass through it, see Figure 2.  Confining units generally store large quantities  of water.
       Groundwater flow within the water-bearing units is primarily along fractures.  Fractures
       are commonly of two types: horizontal bedding planes or vertical fractures that cross
       bedding planes.

       Geophysical logging of all boreholes was performed to define the lithology and fractures
       and to help determine bedrock stratigraphy and structure. Three hydrogeologic zones
       characterize groundwater conditions within and between the overburden and bedrock at
       the Site. The three hydrogeologic zones are: the Overburden Water Bearing zone;
       transition zone; and the Upper Bedrock Aquifer zone.
Curcio Scrap Metal. Inc. Site - ROD                                                     Page - 5 -

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       Based on water level measurements, the direction of groundwater flow was determined to
       be northeasterly in both the Overburden Water Bearing zone and the Upper Bedrock
       Aquifer zone. Shallow groundwater, located at a depth ranging between approximately 5
       feet to 15 feet below ground surface, is considered to be the Overburden Water Bearing
       zone.  Groundwater in the Overburden Water Bearing zone generally flows in a
       northeasterly direction. However, changes in the stratigraphy in the easternmost portion
       of the Site cause a general upgradient flow from the Upper Bedrock Aquifer zone to the
       Overburden Water Bearing portion of the aquifer. This may limit the vertical migration
       of contaminants to the deeper bedrock zone. Because of the upward hydraulic head in the
       Upper Bedrock Aquifer zone in relation to the Overburden Water Bearing zone, there is
       limited potential for downward flow of water into the Upper Bedrock Aquifer zone
       within the eastern portion of the East Lot.

       5.4    OU-1 RI  Findings: Groundwater  [July 1989 - October 1990]

       The groundwater investigation portion of the OU-1 Rl characterized the extent of the
       contamination in the Overburden Water Bearing zone. As part of the OU-1 RI, in July
       1989, six groundwater monitoring wells were installed on the Site.  Groundwater samples
       were  collected in August 1989, November 1989, and July  1990.  In addition, five
       temporary well points were installed during the July 1990 sampling event.

       Elevated concentrations of VOCs, inorganic compounds and PCBs were detected in the
       groundwater monitoring wells and temporary well points installed on the East Lot.  Vinyl
       chloride was detected at a level of 160 parts per billion (ppb), tetrachloroethylene was
       detected at 35 ppb, and methylene chloride was detected at 15 ppb. Lead was detected at
       a level of 610 ppb and cadmium was detected at 18.6 ppb. PCBs were found at
       concentrations ranging from non-detect to 10 ppb.

       An additional round of groundwater sampling was conducted in September 1993, prior to
       commencement of the OU-1 soil cleanup activities. PCBs, VOCs and inorganic
       contaminants were detected at elevated levels.  It was necessary to remove the existing
       monitoring wells installed for the RI because they were located in the East Lot, which
       was the area to be excavated for the selected soil remedy.  Therefore, all of the wells
       except monitoring well MW-2, which was located in the South Lot, were removed in
       1993.

       5.5    OU-2: Groundwater Investigation [January 1996-January 1997]

       Subsequent  to the remediation of the contaminated soils and the mitigation of the risks
       associated with the contaminated soils, the Respondents conducted the OU-2 RI, pursuant
       to the May 1988 AGO, in order to determine the nature and extent of the groundwater
       contamination.
Curcio Scrap Metal, Inc. Site - ROD                                                     Page -6-

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       The Respondents began the groundwater investigation field work in January 1996 and
       concluded in January 1997. The purpose of the groundwater investigation was to
       determine the extent of groundwater contamination in the Overburden Water Bearing
       zone; identify the stratigraphy of deeper portions of the aquifer underlying the Site; and to
       determine the overall quality of the groundwater at the Site.

       The groundwater investigation consisted of the following: installation of six additional
       monitoring wells; collection of four rounds of groundwater samples from all wells;
       analyses of all samples for Target Compound List (TCL) VOCs, Target Analyte List
       (TAL) metals and PCBs; comprehensive analysis of all the data gathered; and assessment
       of the groundwater quality underlying the Site.

       The six monitoring wells were installed at the Site in January 1996. Three overburden
       monitoring wells were installed in the Overburden  Water Bearing zone at depths ranging
       from ten to fifteen feet below ground surface. The overburden monitoring wells are
       denoted as MW-1R, MW-3R,  and MW-4R. The letter "R " indicates that the new wells
       were replaced in the location of the previous wells which were removed during the OU-1
       soil cleanup. MW-2 remained in place from the 1989 RI. Three bedrock monitoring
       wells were installed at depths ranging from 51 to 68 feet in the Upper Bedrock  Aquifer
       zone. The bedrock wells are denoted as BR-1, BR-2 and BR-3.  See Figure 3 for
       monitoring well locations.

       Groundwater in all seven monitoring wells was sampled on a quarterly basis for one year.
       The four groundwater sampling events occurred in March 1996 (round one), June 1996
       (round two), October 1996 (round three), and January 1997 (round 4). All on-Site
       activities (i.e., installation of wells, collection of samples) were performed by the
       Respondents, under EPA oversight.  EPA collected split samples throughout all four
       rounds of sampling.

       Analytical results from all groundwater samples were compared to federal Maximum
       Contaminant Levels (MCLs), which are regulatory levels EPA uses to determine if
       potable drinking water is of acceptable quality, and NJDEP specific Class II-A
       Groundwater Quality Standards (GWQS) (N.J.A.C. 7:9-6 et seqt. which NJDEP
       promulgated for groundwater in New Jersey.  The sampling and analytical work was
       conducted in accordance with  approved quality assurance/quality control (QA/QC) plans.

       At the conclusion of the groundwater investigation in January 1997, over 200
       groundwater samples had been collected and analyzed.  In addition to the data analyses,
       Site geological investigation and characterization was performed in order to fully assess
       groundwater conditions at the  Site.
Curcio Scrap Metal, Inc. Site • ROD                                                     Page -7 -

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       The findings of the OU-2 Groundwater Investigation are discussed below in the following
       sections:

              5.5.1: Upper Bedrock Aquifer zone - monitoring well investigation findings;
              5.5.2: Overburden Water Bearing zone - monitoring well investigation findings;
              5.5.3: Residential well findings.

       The analytical results of all groundwater sampling is presented in the March 1997 Final
       Groundwater Investigation Report - Operable Unit 2. The information provided in the
       following subsections is a brief summary of the elevated concentrations of the
       contaminants detected in the groundwater during the OU-2 Rl.

                    5.5.1   Upper Bedrock Aquifer zone - Monitoring Well Investigation
                           Findings

                    Groundwater samples were collected from the three monitoringiWells
                    installed in the Upper Bedrock Aquifer zone, BR-1, BR-2 and  BR-3, on a
                    quarterly basis beginning in March 1996 and concluding in January 1997
                    (see Figure 3 for monitoring well locations). These wells  range in depth
                    from 51-68 feet below the ground surface, see Figure 2.  Table 1 contains
                    a list of those chemicals which were detected at elevated concentrations in
                    the monitoring wells located in the Upper Bedrock Aquifer zone.

                    In two of the three Upper Bedrock Aquifer zone wells, no VOCs were
                    detected at levels exceeding the NJDEP GWQS and/or federal MCLs. In
                    BR-1, only trichloroethylene (TCE) was detected at 1.1  ppb and 1.9 ppb.
                    The GWQS for TCE is 1 ppb and the MCL is 5 ppb.

                    The following inorganic compounds were detected at concentrations
                    exceeding the NJDEP GWQS and/or federal MCLs: aluminum, arsenic,
                    lead and thallium.

                    In BR-3, Aluminum concentrations ranged from 296 ppb to 416;ppb.  The
                    state GWQS and federal MCL for aluminum is 200 ppb.

                    Arsenic concentrations, in all three bedrock wells, ranged from 1.6B ppb
                    to 12.2 ppb.  The GWQS for arsenic is 8 ppb and the MCL is 50 ppb. The
                    data indicate that six of the twenty-four samples analyzed  had a "B"
                    qualifier. This "B" qualifier indicates that the integrity of the sample is
                    suspect and the presence of arsenic may be considered a false positive.

                    During the last sampling event, lead was detected in two of the three wells
                    at concentrations ranging from 5.7 ppb to 29.8 ppb. For lead, the GWQS
                    is 5 ppb and the federal action level is 15 ppb.
Curc/o Scrap Metal, Inc. Site - ROD                                                     Page - 8 -

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                    Thallium was not detected during the March and June 1996 sampling
                    events. During the October 1996 sampling event, thallium was detected in
                    two wells at concentrations of 3.2B ppb and 3.6B ppb. During the January
                    1997 groundwater sampling event, 3.2B ppb thallium was detected in BR-
                    3. EPA's split sample result indicated thallium at 10.6 ppb during the
                    January 1997 round of sampling. The G WQS for thallium is 10 ppb and
                    the MCL is 2 ppb. The data indicate that three of the twenty-four samples
                    analyzed  had a "B" qualifier.  This "B" qualifier indicates that the integrity
                    of the sample is suspect and the presence of thallium may be considered a
                    false positive.

                    Due to some variability in the analytical results for arsenic and thallium
                    during the groundwater investigation, special analytical procedures will be
                    performed during future sampling events which are expected to yield less
                    variable results.

                    5.5.2   Overburden Water Bearing zone - Monitoring Well Investigation
                           Findings

                    Groundwater samples were collected from the four monitoring wells
                    installed in the Overburden Water Bearing zone, MW-1R, MW-2, MW-3R
                    and MW-4R, on a quarterly basis beginning in March 1996 and
                    concluding in January 1997 (see Figure 3 for monitoring well locations).
                    The depths of these wells range in depth from ten to fifteen feet below the
                    ground surface (see Figure 2).  The results indicate that the northeast
                    comer of the Site (MW-3R and MW-4R) is impacted the most by Site
                    contaminants.  Table 2 contains a list of those chemicals which  were
                    detected at elevated concentrations in the monitoring wells located in the
                    Overburden Water Bearing zone.

                    The results of the sampling indicate that three VOCs, vinyl chloride,
                    benzene and trichloroethylene, were detected at concentrations exceeding
                    state GWQS and/or federal MCLs. Vinyl chloride was detected in MW-
                    3R at concentrations ranging up to 7.3 ppb. Benzene was detected at
                    concentrations of 2.9 ppb to 16 ppb. Trichloroethylene was detected at
                    concentrations ranging from 2.7 ppb to 19 ppb.  For a comparison of these
                    numbers to the health based levels, please see Table 2.
                                *

                    In addition, the sampling results indicate that the following inorganic
                    compounds were detected at concentrations exceeding the GWQS and/or
                    MCLs: aluminum, arsenic, iron, lead, manganese, sodium, and thallium.
                    Aluminum was detected at concentrations ranging from 147 ppb to 12,700
                    ppb.  Arsenic was detected at concentrations ranging from 95 ppb to 226

Curcio Scrap Metal, Inc. Site - ROD                                                     Page - 9 -

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                    ppb.  Iron was detected at concentrations ranging from 158 ppb to 38,700
                    ppb.  Lead was detected at concentrations ranging from 11 ppb to 47 ppb.
                    Manganese was detected at concentrations ranging from 51 ppb to 8,530
                    ppb.  Thallium was detected at concentrations ranging from 3B ppb to 15
                    ppb.  This "B" qualifier indicates that the integrity of the sample is suspect
                    and the presence of thallium may be considered a false positive. For a
                    comparison of these numbers to the health based levels, please see Table
                    2.

                    It should be noted that the water in the Overburden Water Bearing zone is
                    not currently being used as a potable water source. In the Overburden
                    Water Bearing zone, the soil is characterized as unstratified with low
                    permeability and low yields (less than 2 gallons per minute (gpm)).
                    Aquifer yields of greater than 2 gpm are required for residential,
                    agricultural or commercial use.  Therefore, the Overburden Water Bearing
                    zone portion of the aquifer does not produce sufficient quantities of water
                    to readily serve as a reliable long term potable source.

                    5.5.3  Residential Well Findings

                    As part of the groundwater investigation, the Respondents conducted an
                    updated well record search. The updated well record search indicated that
                    there  are no private wells in a downgradient direction within one mile of
                    the Site and within the Overburden Water Bearing zone or the Upper
                    Bedrock Aquifer zone.  There is one private well, located twenty-five feet
                    upgradient from the Site, which was sampled in February 1997.  No
                    organic or inorganic contaminants were found to be present in this well at
                    levels above established drinking water standards.

                    Residents in the vicinity of the Site receive their water from public water
                    supply wells which are  operated by the municipalities of Garfield, Lodi
                    and Fair Lawn. The township of Garfield operates two municipal wells,
                    which are approximately one mile upgradient of the Site. The townships
                    of Lodi and Fair Lawn operate municipal wells within two to three miles
                    in the area of the Site. In addition, the water drawn from the public water
                    supply wells that are operated by the municipalities of Garfield; Lodi and
                    Fair Lawn, is currently  being treated, prior to distribution, for the presence
                    of VOCs which are not suspected to be related to the Site. The. average
                    depth of all of these municipal supply wells is approximately 400 feet
                    below ground  surface.
Curcio Scrap Metal, Inc. Site • ROD                                                      Page -10-

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       5 6    SURFACE WATER AND SEDIMENTS

       In June 1995, as part of the OU-1 soil remediation Site activities, the Respondents
       remediated a small body of standing surface water (Area 1) and associated sediments
       (Area 2) of Schroeder's Brook, located nearby the Site (please see Figure 4).  These areas
       are located along the NJ Transit railroad tracks, just south of the Route 46 overpass
       bridge, approximately 300 feet to the east of the Site. Sampling indicated that No. 2 fuel
       oil was present on the top layer of the small body of standing surface water. The oil was
       absorbed onto absorbent pads designed for cleaning up oil spills. Stones, along the edges
       of the small surface water body, which were suspected to be contaminated were washed
       with high pressure water or steam. The wash water was collected, the recovered oily
       material and absorbent pads were all collected, containerized and disposed off-site in a
       permitted facility.

       In addition, contaminated stream sediments in Area 2 were excavated to an approximate
       depth of four feet. Excavation began at the western (upstream) end of Area 2 and
       progressed to the eastern (downstream) end. Confirmatory sampling indicated that the
       cleanup level was achieved.  The sediments were then solidified and shipped off-site for
       disposal.

       These two areas were then restored to form a rock lined channel that meets the State of
       New Jersey's erosion and sediment control standards. A stabilizing mesh fencing was
       placed over the stone backfill. A total of 88.5 tons of stone backfill was used for the
       restoration.

       A detailed description of the Area 1 and Area 2 cleanup activities is included in the
       August 1995 Remedial Action Report - Sediment Area, which is included in the
       Administrative Record.

6.     SITE RISK SUMMARY

The RI for OU-1 was conducted from July 1989 through October 1990 and addressed soil and
shallow groundwater contamination. In December 1990, EPA performed a risk assessment to
characterize potential risks to public health from exposure to soils at the Site. Risks were
estimated to be high primarily due to the high levels of metals and polychlorinated biphenyls
(PCBs) detected in soils on and around the East Lot. Based on the high concentrations of these
contaminants in the Site soils, and the correspondingly high risks associated with potential
exposure to the soils, EPA determined that soil remediation should be addressed on an expedited
basis. Consequently, the Site was divided into two OUs or phases.  OU-1 addressed soil
contamination. The cleanup of the soils was completed in January 1994.
Curcio Scrap Metal, Inc. Site - ROD                                                     Page -11 -

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EPA determined that additional groundwater investigation was required in order to fully assess
the nature and extent of groundwater contamination, therefore, the groundwater was designated
as OU-2.  The OU-2 RI for groundwater was performed from January 1996 to January 1997.

In June 1997, EPA completed a document titled Baseline Risk Assessment for the Cur do Scrap
Metal, Inc. Site - Operable Unit Two (Risk Assessment).  This baseline Risk Assessment
presents an evaluation of the potential risks and hazards to human health that may exist at the
Site, currently and in the future, were there to be no further remedial actions taken. Although the
vicinity of the Site is currently zoned as residential, amongst the residences there is a mix of light
industries, which have been operating in the area for many years. Risks were evaluated based on
potential human exposure to contaminants currently present in Site groundwater. To be most
protective of human health, the baseline risk assessment assumed that the Site would be
developed for residential use in the future.  The aquifer underlying the Site is designated by
NJDEP as a Class - II-A drinking water aquifer.

The data used in the Risk Assessment includes the samples collected by the Respondents'
contractor during the four rounds of the groundwater investigation (March 1996  to January 1997)
and the split samples obtained by EPA during technical oversight of the investigation.

The OU-2 groundwater risk assessment investigated the nature and extent of contamination in
the Upper Bedrock Aquifer zone and the Overburden Water Bearing zone portions of the aquifer
underlying the Site.  The groundwater risk assessment  addresses the potential human health
impacts associated with exposure to groundwater contamination in the absence of remediation.
The risk assessment included an evaluation of the four rounds of groundwater samples collected
by the PRPs' contractor during the  groundwater investigation (March, June, October of 1996
and January  1997) and the split samples obtained by EPA during technical oversight of the
investigation. The results from EPA's sampling of a single residential well are also included.
All data were validated in accordance with  EPA Region II protocols. The data qualifiers have
been included in the data summary tables for completeness.

EPA conducted a baseline risk assessment to evaluate the  potential risks to human health from
groundwater exposure. The risk assessment evaluated  contaminants in groundwater based on
seven on-Site monitoring wells.  The Overburden Water Bearing zone samples were collected
from four shallow Overburden Water Bearing zone wells (MW-1R, MW-2, MW-3R and MW-
4R) and three Upper Bedrock Aquifer zone wells (BR-1, BR-2, and BR-3). All samples were
analyzed for low detection VOCs, target compound list pesticides/PCBs, and target analyte list
inorganics. A summary of the potential contaminants of concern for the Upper Bedrock Aquifer
zone, Overburden Water Bearing zone, and off-Site well is provided in Attachment 5 - Tables 3,
4, and 5, respectively. Table 6 summarizes the background levels from the on-Site upgradient
well.  Table 7 lists the selected contaminants of concern for each of the zones within the aquifer.
The chemicals listed in Table 7 were selected using the screening procedures identified in the
Risk Assessment Guidance for Superfund document (USEPA  1989).
Curcio Scrap Metal. Inc. Site - ROD                                                     Page -12 -

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       6.1 Human  Health Risk Assessment

       EPA guidelines require the separate analysis of carcinogenic (cancer causing) and non-
       carcinogenic effects due to chemicals at the Site.  It is assumed that the toxic effects of
       chemicals at the Site would be additive. Therefore, carcinogenic and non-carcinogenic
       risks associated with exposures to individual contaminants of concern were added to
       determine the potential risks associated with mixtures of potential carcinogens and non-
       carcinogens, respectively.

       For carcinogens, the individual chemical specific risks are added together for each
       pathway to develop a total cancer risk.  For non-carcinogens, the total non-cancer risks
       for each chemical in each pathway are added together to determine the total hazard.  A
       Hazard Index greater than 1.0 indicates that potential exists for non-carcinogenic health
       effects to occur as a result of Site-related exposures.  The HI provides a useful reference
       point for gauging the potential significance of multiple contaminant exposures within a
       single medium or across media.

       Exposure Assessment. The EPA human health risk assessment identified several
       exposure  pathways at the Site under current and potential, future land-use scenarios.
       Health effects were then evaluated for each of these exposure scenarios and respective
       chemicals of concern.  Based on the present land-use, since residents currently live in the
       vicinity of the Site, numerous potential exposure scenarios were selected for quantitative
       evaluation in the risk assessment.  Residents, including adults and children, were assumed
       to ingest the groundwater and also be exposed dermally during showering and through
       inhalation of VOCs while showering.  This evaluation is based on the current use of the
       single off-Site residential well.  For the future scenario, potential residents (children and
       adults), both on-Site and off-Site, were evaluated for ingestion of water from the Upper
       Bedrock Aquifer zone, Overburden Water Bearing zone and residential well. In addition,
       potential exposure through dermal contact while showering and inhalation of VOCs while
       showering were evaluated. This was based on the current use near the Site of a private
       drinking water well and the potential for the Site to be developed as residential property
       in the future.  It is important to note that the although groundwater data suggest that the
       Overburden Water Bearing zone aquifer yield is inadequate to support residential use,
       residential exposure to Overburden Water Bearing zone groundwater is quantitatively
       addressed in the risk assessment for protectiveness.

       Carcinogen Analysis. EPA evaluates the potential for a chemical to cause cancer using a
       Weight of Evidence approach and a Cancer Potency Factor.  The Weight of Evidence
       approach uses data from human epidemiological studies and animal studies to determine
       the potential for a chemical to cause cancer. Based on this information, chemicals are
       classified as Known Human Carcinogens (Group A); Probable Human Carcinogens
       (Group Bl or B2 based on the available human evidence); Possible Human Carcinogens
       (Group C) and Not Classifiable (Group D). Non-human carcinogens are classified as

Curcio Scrap Metal. Inc. Site - ROD                                                      Page -13-

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       Group E.

       Potential carcinogenic risks were evaluated using the cancer potency factors developed by
       EPA for the contaminants of concern. Cancer slope factors (CSFs) have been developed
       by EPA's Carcinogenic Risk Assessment Verification Endeavor for estimating excess
       lifetime cancer risks associated with exposure to potentially carcinogenic chemicals.
       Separate CSFs are developed for inhalation and oral exposure. CSFs, which are
       expressed in units of (mg/kg-day)~ , are multiplied by the estimated intake of a potential
       carcinogen, in mg/kg-day, to generate an upper-bound estimate of the excess lifetime
       cancer risk associated with exposure to the compound at that intake  level. The term
       "upper-bound" reflects the conservative estimate of the risks calculated from the CSFs.
       Use of this approach makes the underestimation of the risk highly unlikely.

       The Weight of Evidence and CSFs for the chemicals of concern are  presented in Table 8.
       The data was obtained from the Integrated Risk Information System (IRIS), the Health
       Effects Assessment Summary Tables, and EPA's National Center for Environmental
       Assessment.

       For known or suspected carcinogens, EPA considers an excess upper bound individual
       lifetime cancer risk of between  10"" to 10~6 to be acceptable.  This level indicates that an
       individual has no greater than a one in ten thousand to one in one million chance of
       developing cancer as a result of site-related  exposure to a carcinogen over a 70 year
       period under specific exposure conditions at the Site. NJDEP's acceptable upper bound
       risk is 10"6.  A summary of the carcinogenic risk estimates is presented in Table 9.

       Under the current Site conditions, the off-Site residential well groundwater does not pose
       any significant carcinogenic risk to human health.  The risks were calculated at 7.1x10'7
       (7 in ten million) for adults and 5.4xlO"7 (5 in ten million) for children.

       Risks were also calculated for potential future conditions, as if residents lived on-Site and
       used potable wells in the shallow groundwater aquifer.  For potential future on-Site
       residents using water from the Overburden Water Bearing zone, the  adult risks were
       3.6xlO~3 (approximately 4 in one thousand)  and the risk for children was 2.1x10° (2 in
       one thousand) with arsenic as the major risk contributor.

       For the on-Site wells in the Upper Bedrock  Aquifer zone, the risks are 1.9X10"4
       (approximately 2 in ten thousand) for adults and 1 .IxlO"4 (approximately 1 in ten
       thousand) for children. No chemicals individually exceed the target risk range.

       These carcinogenic risk numbers, which are considered a conservative upper-bound
       estimate, indicate the number of people in a population that would be at risk of
       developing cancer if the Site is not remediated. As indicated in Table 9, carcinogenic risk
       associated with each of the pathways falls within or below EPA's acceptable risk range of

Curcio Scrap Metal. Inc. Site - ROD                                                      Page -14-

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       10"4 to 10'6 with the exception of the results from the Overburden Water Bearing zone
       wells. Carcinogenic risks associated with potential on-Site residents' ingestion of water
       from the Overburden Water Bearing zone posed an unacceptable risk. The hypothetical
       residential carcinogenic risk for the Site of 5.0x10"3 (approximately 5 in one thousand) is
       attributed to arsenic. Although the risks from the Overburden Water Bearing zone were
       calculated, it is important to note that it is not anticipated that the overburden will be able
       to support potable uses based on the low yield.

       Non-Carcinogen Analysis. Non-carcinogenic hazards were assessed using a Hazard
       Index (HI), which is the ratio  of the expected contaminant  intakes to the safe levels of
       intake (reference doses). Reference doses (RfDs) have been developed by EPA for
       indicating the potential for adverse human health effects per kilogram bodyweight per
       day (mg/kg/day).  Reference Doses are an estimate of the daily exposure levels for
       humans which are thought to  be safe over a lifetime (including sensitive individuals).
       Estimated intakes  of chemicals from environmental media (e.g., the amount of a chemical
       ingested from contaminated drinking water) are compared  with the RfD to derive  a
       hazard quotient (HQ) for the contaminant in the particular  media. The HQs are then
       added to develop an HI.  The reference doses for the chemicals of potential concern at
       the Site are presented in Table 10.

       Similar to the carcinogens, separate oral and inhalation Reference Doses are developed.
       The data was obtained from the Integrated Risk Information System, the Health Effects
       Assessment Summary Tables and the EPA National Center for Environmental
       Assessment.

       Table 11 shows that the Site media currently do not pose any significant risk to human
       health with the exception of the hazards associated with the Overburden Water Bearing
       zone wells. Results of the quantitative risk assessment using the Hazard Index approach
       are summarized in Table 11.  Under hypothetical, future conditions where on-Site
       residents would rely on the shallow Overburden Water Bearing zone groundwater for
       drinking, a Hazard Index of 30 for adults and 71 for children was calculated.  Under this
       scenario, the chronic Hazard Index was exceeded and the primary chemicals contributing
       to the hazard were arsenic, manganese and thallium.  Evaluation of the individual
       chemical Hazard Index by toxicity endpoint/target organ resulted in a Hazard Index for
       arsenic of 22 for adults and 52 for children based on effects on the skin, a Hazard  Index
       for manganese of 5.5 for adults and 13 for children based on effects on the Central
       Nervous System, and a Hazard Index for thallium of 2.5 for adults and 5.8 for children
       based on effects on the liver, blood and hair.  Again it is important to note that the
       Overburden Water Bearing zone cannot support potable purposes so that these risks are
       not likely.

       The Hazard Indices for the off-Site resident which are more representative of current risk
       were well below the level of 1.  The Hazard Indices for the potential future on-Site

Curcio Scrap Metal, Inc. Site - ROD                                                      Page -IS-

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       consumption of groundwater from the bedrock well were 2.2 for adults and 5.1 for
       children. However, no chemicals individually exceeded the target level of 1, for the
       adults. The Hazard Index for arsenic is 1.4 based on effects on the skin and 2.4 for
       thallium based on effects on the liver, blood and hair, for the children.

       6.2 ECOLOGICAL RISK ASSESSMENT

       In April 1997, EPA performed an evaluation of the need to perform an ecological
       assessment at the Site.  The objective of the evaluation was to determine, through a Site
       inspection and review of Site information, if ecological pathways of exposure exist, to
       compile a Site inventory of plants and animals, and to identify any rare and endangered
       species or their habitat. Details regarding this survey are presented in the Evaluation of
       the Potential Need to Perform an Ecological Assessment Report, dated April 1997. The
       area of concern identified in the ecological evaluation is a ponded  area which is believed
       to receive groundwater discharge from the Site. This ponded area discharges  into a
       drainage ditch known as Schroeder's Brook and subsequently into Dahnert's Lake,
       located approximately *A mile southeast of the Site.  Due to the fact that the Site is located
       in an industrial  area, and the ponded area and drainage ditch are small and intermittent,
       the area in the vicinity of the Site is not expected to significantly support or attract
       wildlife. Further, groundwater contaminant levels are expected to decline since the
       source of the contamination (soil at the Site) has been removed. In addition,  the area of
       standing surface water also receives possible surface runoff the nearby Route 46 roadway,
       nearby local roads/catch basins,  other local light industrial businesses and nearby active
       railroad tracks.  No rare or endangered species were identified near the Site.  Therefore,
       as no suitable habitat exists, and the potential for groundwater contaminants to impact
       surface water is minimal, EPA has determined that no additional ecological investigation
       is necessary.

       Based on the evaluation of data collected at the Site, the actual or threatened  releases of
       hazardous substances from this Site are not considered to present a current threat to
       public health or the environment.

       6.3 UNCERTAINTIES

       The procedures and inputs used to assess risks in this evaluation, as in all such assessments,
       are subject to a wide variety of uncertainties.  In general, the main sources of uncertainty
       include the following:
                                 \

                    environmental chemistry sampling and analysis;
                    environmental parameter measurement;
                     fate and transport modeling;
                    exposure parameter estimation; and
                    toxicological data.

Curcio Scrap Metal, Inc. Site - ROD                                                      Page -16-

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       Uncertainty in environmental sampling arises in part from the potentially uneven distribution
       of chemicals in the media sampled. Consequently, there is significant uncertainty as to the
       actual levels present. Environmental chemistry analysis error can stem from several sources
       including the errors inherent in the analytical methods and characteristics of the matrix being
       sampled.

       Uncertainties in the exposure assessment are related to estimates of how often an individual
       would actually come in contact with the chemicals of concern, the period of time over which
       such exposure would occur, and in the models used to estimate the concentrations of the
       chemicals of concern at the point of exposure. Uncertainties in toxicological data occur in
       extrapolating both from animals to humans and from high to low doses of exposure, as well
       as from  the difficulties in assessing the toxicity of a mixture of chemicals.   These
       uncertainties are  addressed by making conservative  assumptions concerning risk and
       exposure parameters throughout the assessment. As a result, the risk assessment provides
       upper-bound estimates of the risks to populations near the  Site, and is highly unlikely to
       underestimate actual risks related to the Site.

       More specific information concerning public health and ecological risks,  including
       quantitative evaluation of the degree of risk associated with various exposure pathways, can
       be found in the June 1997 Final Risk Assessment Report - OU-2.

7.     EVALUATION AND SUMMARY OF THE 'NO FURTHER ACTION' REMEDY

After careful consideration of Site-specific details and analysis of all data collected, EPA has
determined that the No Further Action remedy, with long-term monitoring, remedial approach is
protective of human health and the environment based on the following:

• Currently, potable water is provided to the  residents in the vicinity of the Site via the local
municipalities and/or local water company. There is presently no elevated risk  posed  by Site
groundwater since  no  potable wells downgradient from  the Site are  impacted  or considered
threatened by Site-related contamination;

• Although there is an elevated risk associated with any potential future use of the Overburden Water
Bearing zone for potable water in the vicinity of the Site, this zone is not capable of supporting
residential use due to its low water yield. Furthermore, the presence of the upward gradient within
the Upper  Bedrock Aquifer  zone creates a hydraulic barrier which  limits the migration  of
contaminants from the Overburden Water Bearing zone;
                                i
• Although there is a slightly elevated risk (but still within EPA's acceptable risk range) associated
with the potential future use of the Upper Bedrock Aquifer zone of the aquifer for potable water, a
Classification Exception  Area (CEA) will be established by NJDEP  to provide information on
contamination in the groundwater resulting from Site operations. The CEA will remain in effect
until contaminant levels  are below New Jersey Groundwater Quality Standards.  NJDEP may

Curcio Scrap Metal. Inc. Site - ROD                      .                               Page -1~-

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establish a Well Restriction Area (WRA) if groundwater contamination associated with the Site
should be determined to impact potential users. By establishing a WRA, NJDEP can assure that
contaminants in the groundwater will not pose a threat to human health as a result of well installation
and operations;

• Although slightly elevated human health risks (but still within EPA's acceptable risk range) would
occur if the Upper Bedrock Aquifer zone of the aquifer were used as a potable water supply, the
extent of contamination is considered limited, and is not indicative of a plume of contamination.
Only one organic compound was detected in one well in this zone at a slightly elevated level. Four
inorganic compounds were detected in all, and the levels did not significantly exceed the established
drinking water standards. Of these four contaminants, only one, arsenic, was detected in all three
Upper Bedrock Aquifer zone wells at levels slightly above drinking water standards;

• As part of the No Further Action remedy, throughout the course of the monitoring program, a
decrease in Site-related groundwater contamination is expected,  since the source of groundwater
contamination (contaminated soils) has been  effectively removed. Natural attenuation of some
contaminants is expected to be observed and will be monitored during the long-term monitoring
program; and

• The stratigraphy of the aquifer formation beneath the Site includes an aquitard between the
Overburden Water Bearing zone and the Upper Bedrock Aquifer  zone. This aquitard acts to limit
the migration of contaminants from the Overburden Water Bearing zone downward toward portions
of the aquifer which could potentially be used for potable purposes.

As part of the No Further Action remedial approach, a groundwater monitoring program will be
required for a minimum of five years. Samples will  be collected and analyzed for TCL VOCs and
TAL inorganic compounds for the first year on approximately a quarterly basis. Special analytical
services will be used, where appropriate, in the  analytical procedures to minimize any variability of
data. The monitoring program may be modified based upon sampling results collected during the
first year.  Currently, EPA and NJDEP do not believe that additional groundwater monitoring wells
will be required for the purpose of the sampling program. However, if the results of the initial
rounds of sampling indicate that additional wells are necessary, then they will be installed.

After five years, or less, if the sampling and analyses indicate the need for action, the potential risks
to human health and the environment will be reassessed.  The groundwater monitoring would then
either continue for another five-year period, or some other action will be considered. If monitoring
reveals that contamination at the Site increases so that an unacceptable risk to human health or the
environment develops, an appropriate action can be initiated at any time during the five-year period
to  address the risks.  The CEA will remain in effect until constituents in the groundwater do not
exceed established drinking water standards.

The present worth cost of the initial five-year monitoring program is estimated to be approximately
$200,000.

Curcio Scrap Metal. Inc. Site - ROD                                                      Page -18-

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The preferred No Further Action remedial approach for the Site has been developed based on the
findings of the Groundwater Investigation Report, the baseline Risk Assessment Report and data
collected during the groundwater investigation.  As described in this document,  the remedial
approach includes long-term groundwater monitoring and the establishment of a CEA to ensure that
the public is not exposed to the relatively low levels of groundwater contamination that exist at the
Site.  EPA and NJDEP believe the remedial approach is protective  of human health and the
environment and is cost-effective.

8.    NJDEP ACCEPTANCE

NJDEP concurs with the No Further Action with long-term monitoring remedial approach. NJDEP's
Letter of Concurrence is Attachment 1 to this Record of Decision.

9.    COMMUNITY ACCEPTANCE

A summary  of the comments received during the public comment period is provided in the
Responsiveness Summary which is Attachment 3 to this Decision Document.

10.   EXPLANATION OF SIGNIFICANT DIFFERENCES

There are no significant changes from the recommended No Further Action remedy presented in the
Proposed Plan.

11.   SITE CLOSE OUT

In lieu of a Final Close Out Report, this No Further Action ROD documents that the Respondents
have completed all construction activities for the Curcio  Scrap Metal Site in accordance with Close
Out Procedures for National Priorities List Sites (OSWER Directive 9320.2-09).  This decision
documents that EPA and NJDEP have determined that remedial actions for this Site have been
successfully  implemented and no further response actions are necessary. Therefore, the Site now
qualifies for inclusion on the Construction Completion List. A five year review will be performed
since contaminants remain on the Site above health-protective levels.
Curcio Scrap Metal, Inc. Site - ROD                                                   Page -19-

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               ATTACHMENT 1
        NJDEP CONCURRENCE  LETTER
Curcio Scrap Metal, Inc. Site - ROD

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                                          of
Chri»tinp TtiOJ Whitman             Department of EnvironmunUl Protection                Robert C. Sh.nn. Jr.
Governor                                                                            ^'tm


       Ms. Jeanne Fox                                          $£P 3 Q 1997
       USEPA - Region II                                             	
       290 Broadway
       New York. NY 10007

       Dear Ms. Fox,

       Re:   Concurrence Letter • Record of Decision Operable Unit II
             Curcio Scrap Metal, Inc. Supcifund Site
             Saddle Brook, Bergen County

       The NJDEP has reviewed the final No Further Action Record of Decision for Operable
       Unit 11 of ihe Curcio Scrap Metal, Inc. Superfund Site in Saddle Brook, Bergen County and
       we concur with the document as submitted.

       This Record of  Decision describes  the  No  Further Action with long-term monitoring
       remedial approach for Operable Unit II of the Curcio Scrap Metal, Inc. Superfund Site.
       This remedial activity in combination with the establishment  of a Classification Exception
       Area satisfies all substantive requirements pursuant to New Jersey law,  and all To Be
       Considered criteria applicable to the remediation of this facility.

       It has therefore been determined by the NJDEP this No Further Action remedial decisirm
       will serve to ensure the protection of human health and the environment.

       New Jersey appreciates the importance of the Record of Decision ia the cleanup process
       and will continue to take all reasonable steps to ensure that the State's commitments in this
       area are met.
                                                   Sincerely,
                                                   Richard* I/Gimello
                                                   Assistant Commissioner
       c.     Carole Petersen, Chief - USEPA/Region II
                                   Newjeney if an fqial Opportunity Rnylnyrr

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                ATTACHMENT 2




       ADMINISTRATIVE RECORD INDEX
Curcio Scrap Metal Inc. Site - ROD

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           CURCIO SCRAP METAL, INC. SITE -OPERABLE UNIT TWO
                        ADMINISTRATIVE FILE RECORD
                            INDEX OF DOCUMENTS

1.0   SITE IDENTIFICATION
1.5   Previous Operable Unit Information
P.    100001-      Report:Remedial Action Report. Operable Unit
      100646       One: East Lot Soil. Curcio Scrap Metal. Inc. Site. Saddle Brook. New
                   Jersey, prepared by CH2M Hill, prepared for Consolidated Edison
                   Company of New York, Inc., Curcio Scrap Metal, Inc., Cirello Iron &
                   Steel Co., Inc., and SECO Corporation, March 1994.

P.    100647-    .  Letter to Ms. Mary Anne Rosa, U.S. EPA, Region
      100647       II, from Mr. Ian  R. Curtis, Case Manager, Bureau of Federal Case
                   Management, New Jersey Department of Environmental Protection and
                   Energy (NJDEPE), re: Remedial Action Report - OU I, Curcio Scrap
                   Metals Superfund Site, Saddle Brook Township, Union County, May 18,
                   1994.

P.    100648-      Letter to Mr. Edward R. Underwood, CH2M Hill,
      100648       from Mr. Raymond Basso, Chief, New Jersey Superfund Branch II, U.S.
                   EPA, Region II, re: Curcio Scrap Metal, Inc. Superfund Site, Operable
                   Unit One - Remedial Action Report, September 28, 1994.

P.    100649-      Report: Remedial Action Report. Sediment Area 2.
      100760       Curcio Scrap Metal. Inc. Site. Saddle Brook. New Jersey, prepared by
                   CH2M Hill, prepared for Consolidated Edison Company of New York,
                   Inc., Curcio Scrap Metal, Inc., Cirello Iron & Steel Co., Inc., and SECO
                   Corporation, August 1995.

3.0   REMEDIAL INVESTIGATION
3.3   Work Plans
P.    300001-      Plan:  Groundwater Investigation. Volume I.
      300046       Work Plan. Curcio Scrap Metal Inc. Site. Saddle Brook Township. Bergen
                   County. New Jersey, prepared by CH2M Hill, prepared for Consolidated
                   Edison Company of New York, Inc., Curcio Scrap Metal, Inc., Cirello Iron
                   & Steel Co., Inc., and SECO Corporation, October 1994.
                              «
P.    300047-      Plan:  Groundwater Investigation. Volume II -
      300376       Appendices. Curcio Scrap Metal. Inc.  Site. Saddle Brook Township.
                   Bergen County.  New Jersey, prepared by CH2M Hill prepared for
                   Consolidated Edison Company of New York, Inc., Curcio Scrap Metal,
                   Inc., Cirello Iron & Steel Co., Inc., and SECO Corporation, October 1994.
Curcio Scrap Metal, Inc. Site - ROD

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3.4    Remedial Investigation Reports
P.     300377-      Report: Final Groundwater Investigation Report.
       301525       Operable Unit 2. Curcio Scrap Metal. Inc. Site. Saddle Brook Township.
                    Bergen County. New Jersey, prepared by CH2M Hill, prepared for
                    Consolidated Edison Company of New York, Inc., Curcio Scrap Metal,
                    Inc., Cirello Iron & Steel Co., Inc., and SECO Corporation, March 1997.

P.     301526-      Report: Evaluation of the Potential Need to
       301543       Perform an Ecological Assessment Curcio Scrap Metal. Inc.. OU II Site.
                    Saddle Brook. New Jersey, prepared by CDM Federal Program
                    Corporation, prepared for U.S. EPA, Region II, April 15,1997.

P.     301544-      Report: Final Human Health Risk Assessment.
       301774       Curcio Scrap Metal. Inc.. Operable Unit Two Site. Saddle Brook N.J..
                    prepared by CDM Federal  Programs Corporation, prepared  for U.S. EPA,
                    Region II, June 26,  1997.

3.5    Correspondence
P.     301775-      Letter to Ms. Theresa Gerrish, CH2M Hill, from Mr.
       301775       Raymond Basso, Chief, New Jersey Superfund Branch II, U.S. EPA,
                    Region II, re: Curcio Scrap Metal, Inc. Superfund Site. - Operable Unit
                    Two, Groundwater Investigation Work Plan Approval, April 21, 1995.

P.     301776-      Letter to Mr. Edward R. Underwood, CH2M Hill, from
       301776       Mr. Raymond Basso, Chief, N.J. Superfund Branch II, U.S. EPA, Region
                    II, re: Curcio Scrap Metal,  Inc. Superfund Site, Sediment Area 2 Remedial
                    Action Report Approval, September 14,1995.

P.     301777-      Letter to. Ms. Mary Anne Rosa, U.S. EPA,
       301777       Region II, from Mr. Ian R. Curtis, Case Manager, Bureau of Federal Case
                    Management, New Jersey Department of Environmental Protection and
                    Energy, (NJDEPE), re: March 1997 Remedial Investigation OU II, Curcio
                    Scrap Metals Superfund Site, Saddle Brook Township, Bergen County,
                    May 15,1997.

P.     301778-      Letter to Mr. Scott Vozza,  CH2M Hill, from Ms.
       301779       Carole Petersen, Chief, New Jersey Remediation Branch, U.S. EPA,
                    Region II, re:'Curcio Scrap Metal, Inc. Site, Final Groundwater
                    Investigation Report (GIR) Approval, June 27,1997.
Curcio Scrap Metal, Inc. Site - ROD

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                   ATTACHMENT 3




                      FIGURES
Curcio Scrap Metal, inc. Site - ROD

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VEHICLE
ACCESS TO
AREA 1
                                                           ACCESS TO
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                                                           WORK
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                                     GENERAL PROJECT LOCATION   e
                                       (INCLUDING ACCESS ROUTE)
                          CURClO SC3A? METAL.  INC.. SADDLE' 3ROOK. NJ


                         —  FIGURE 4	'	"•—

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                 ATTACHMENT 4




          RESPONSIVENESS SUMMARY
Curcio Scrap Metal. Inc. Site - ROD

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                          RESPONSIVENESS SUMMARY

                             DECISION DOCUMENT

              CURCIO SCRAP METAL. INC. SITE - Operable Unit Two


OVERVIEW

This is a summary of the public's comments and concerns regarding the Proposed Plan and
related documents for the Curcio Scrap Metal, Inc. Site and U.S. Environmental Protection
Agency (EPA) and new Jersey Department of Environmental Protection (NJDEP) response to
those comments.

In accordance with the public participation requirements of the Comprehensive Environmental
Response, Compensation and Liability Act, as amended (CERCLA), EPA, in conjunction with
NJDEP, held a public comment period from July 30, 1997 to August 28, 1997 to provide
interested parties the opportunity to comment on the Proposed Plan  and documents contained in
the Administrative Record for the Curcio Scrap Metal, Inc. Site.

During the public comment period, EPA and NJDEP held a public meeting on August 6, 1997 at
7:00 pm at the Saddle Brook Memorial Library to discuss the results of the Groundwater
Investigation and to present the preferred No Further Action remedy. No objections to the No
Further Action remedy presented in the Proposed Plan were raised at the public meeting. Public
comments received during the public meeting are documented in this Responsiveness Summary.

This Responsiveness Summary is divided into the following sections:

      I.     BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS: This section
            provides the history of community concerns and interests regarding the Site.

      II.    SUMMARY OF  COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND
            AGENCY RESPONSES: This section summarizes the oral comments, as well as
            written comments, received by EPA and NJDEP at the public meeting and during
            the public comment period.

      III.    COMMUNITY RELATIONS ACTIVITIES AT THE CURCIO SCRAP METAL, INC. SITE:
            This section provides information regarding the location of the Administrative
            Record repositories.
Curcio Scrap Metal, Inc. Site • ROD

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I.      Background on Community Involvement and Concerns

Over the course of the Site investigations and subsequent remedial action, discussions and
exchanges of correspondence have taken place between EPA, NJDEP, Township officials and
residents regarding Site operations and activities. The Township officials were notified of all
activities throughout the implementation of the first remedial phase, or OU-1, at the Site.  In
addition, EPA was informed by the local Planning Board of the change in zoning laws for the
area surrounding the Site.

II.     SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
       PERIOD AND AGENCY RESPONSES

Comments raised during the Curcio Scrap Metal, Inc. Site Public Meeting held on August 6,
1997, as well as written comments received during the public comment period, and EPA's and
NJDEP's responses are summarized below:

       HA.   Summary of Verbal Questions and Responses:

       Comment: A resident expressed concern  about the possibility of contaminated surface
       water at the ponding areas along the railroad tracks.

       Response: In June 1995, as part of the OU-1 soil remediation Site activities,  the areas of
       standing surface water and associated sediments of Schroeder's Brook were remediated.
       Confirmatory sampling indicated that the cleanup level was achieved. The contaminated
       materials were solidified and shipped off-Site for disposal. The areas were then restored
       to form a rock-lined channel that meets the State of New Jersey's erosion and sediment
       control standards. In addition to the standing surface  water cleanup in June 1995, all of
       the contaminated soil which was on the Site was removed and transported off the Site for
       disposal. The Site was then backfilled with clean soil and a reinforced concrete pad was
       placed over the area where the soil was backfilled. EPA and NJDEP do not believe there
       are any negative impacts to the standing surface water from the Site. In addition, the area
       of standing surface water also receives surface runoff from the nearby Route 46 roadway,
       nearby local roads/catch basins, and other local light industrial businesses.

       The resident also expressed concern over the appearance of the standing surface water,
       which he described as "green and slimy". In response to the resident's comment, EPA
       conducted a Site visit on August 27,1997, to inspect the standing surface water areas,
       Schroeder's Brook and Dahnert's Pond (approximately Vi mile from the Site).  EPA
       believes the greenish coloration of the standing surface water is due to the growth of
       algae and other natural plantlike material. The greenish colored material which was
       floating near the surface was inspected and is  believed to be elongated pieces of grass.
       Another form of green algae was observed growing on the rocks in the stream channel.
       The algae growth observed in the standing surface water area is not believed to be

Curcio Scrap Metal. Inc. Site - ROD

-------
       affected by surface runoff from the Site since all contaminated soil from the Site has been
       removed. The area surrounding the standing surface water was abundant with lush
       plantlife.  Furthermore, the inspection of Dahnert's Pond revealed that there is abundant
       algae growth present along the perimeter of the Pond as well as the presence of numerous
       geese, duck and other wildlife.

       Comment: A resident asked if the Site was still active and  how it was regulated.

       Response: The Site is an active facility. The soil contamination was in the East Lot
       portion of the facility and the monitoring wells are located at various points throughout
       the property of the facility. The facility is currently regulated by local and state
       regulations and requirements.

       Comment: A resident asked how much money has been spent on the Site activities to
       date.

       Response: EPA requires that the proper actions are taken by the PRPs to ensure the
       protection of human health and the environment. All the work performed at the Site was
       funded by the PRPs.  The PRPs have indicated that they have expended in excess of four
       million dollars on all Site-related work to date.

       IIB.   Summary of Written Comments and Responses:

       During the public comment period, one party, the Consolidated Edison Company of New
       York, Inc. (Con Ed), submitted a comment letter, dated August 28, 1997, to EPA
       regarding the Curcio Scrap Metal,  Inc.  Site Proposed Plan. Con Ed's comment letter is
       attached to the end of this Responsiveness Summary. These comments are summarized
       and responded to as follows:

       Comment: The commenter questioned the need for collecting groundwater samples on a
       quarterly  basis for the first year. The commenter suggested the frequency of groundwater
       sampling during the first year should be decreased from quarterly to  semi-annually.

       Response: The long-term monitoring plan currently being  considered by EPA is quarterly
       sampling of the groundwater for the first year and evaluation of that  data.  Based upon the
       review of the first year's data, the frequency of sampling may be modified by EPA. EPA
       believes that quarterly groundwater sampling for the first year is appropriate in order to
       further evaluate the quality o'f the groundwater underlying the Site. Another year of
       quarterly  groundwater monitoring, in addition to the data collected during the quarterly
       groundwater sampling conducted from January 1996 through January 1997, will provide
       comprehensive information relative to groundwater quality throughout seasonal
       fluctuations.  If monitoring indicates that contamination at the Site is decreasing, it is
       likely that the sampling frequency  would be reduced. If monitoring  reveals that

Curcio Scrap Metal. Inc. Site - ROD

-------
       contamination at the Site increases so that an unacceptable risk to human health or the
       environment develops, an appropriate action can be initiated at any time during the
       monitoring period to address the risks.

       Comment: The commenter questioned the analysis of groundwater samples for Target
       Compound List (TCL) volatile organic compounds (VOCs), semi-VOCs and Target
       Analyte List (TAL) inorganic compounds; and that future groundwater monitoring only
       include analysis for arsenic, manganese, thallium and possibly lead.

       Response: The long-term monitoring plan currently being considered by EPA includes
       the collection of groundwater samples on a quarterly basis for the first year and the
       analysis of the samples for all TCL VOCs and TAL inorganic compounds. At the
       conclusion of the first year and after careful review of all Site-related data, modifications
       to the sampling frequency, analysis for specific compounds and individual well sampling
       locations will be revisited accordingly.  EPA agrees that semi-VOCs need not be part of
       the groundwater analyses since semi-VOCs have not historically been chemicals of
       potential concern at the Site.

III.    COMMUNITY RELATIONS ACTIVITIES AT THE CURCIO SCRAP METAL,
       INC. SUPERFUND SITE

       •      EPA prepared an updated Community Relations Plan in July 1997.

       •      EPA has established information repositories at the following locations:

                   Saddle Brook Memorial Library
                   340 Mayhill Street
                   Saddle Brook, New Jersey 07662
             and
                   U.S. Environmental Protection Agency
                   Record Center
                   290 Broadway -18th Floor
                   New York, N.Y. 10007-1866

       The repositories contain a comprehensive collection of records relating to the Site which
       comprise the Administrative Record. The index to the Administrative Record is
       Attachment 2 of the Record of Decision.
                               *

       •      Throughout the RI/FS process, representatives from EPA and NJDEP attended
             meetings concerning the Site. The first public meeting was held in February 1991
             to brief interested parties and discuss the RI/FS process.
Curcio Scrap Metal. Inc. Site - ROD

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             EPA and NJDEP have participated in subsequent meetings to update the
             community on the progress at the Site over the course of the RI/FS and remedial
             activities.

             On August 6,1997, EPA and NJDEP held a public meeting at the Saddle Brook
             Memorial Library to discuss the Site investigations and present the Proposed Plan
             for the No Further Action remedy. Approximately 12 people attended. A
             transcript of the meeting can be found in the record repositories listed above.

             A public comment period was held from July 30,1997 to August 28,  1997.
Curcio Scrap Metal. Inc. Site - ROD

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         Consolidated Edison Company of New York, Inc.
         4 Irving Place, New York, N.Y. 10003
                                                             August 28,1997
BY FACSIMILE AND CERTIFIED MAIL
Ms. Mary Anne Rosa, Project Manager
U.S. Environmental Protection Agency
Emergency and Remedial Response Division
New Jersey Remediation Branch
290 Broadway -19* Flooi
New York, New York 10007-1866
Subject   Comments on
          Proposed Plan for the Curcio Scrap Metal, Inc. Site - Operable Unit Two
Dear Ms. Rosa:


In response to the EPA July 30,1997 letter, Consolidated Edison Company of New
York, Inc. (Co.; Edison) is herein submitting comments on the EPA Proposed Plan
(Plan) for the Curcio Scrap Metal, Inc. (CSMI) Site - Operable Unit Two, Ground
Water.

In general. Con Edison agrees with EPA's Plan of a No Further Action Remedy fot
the CSMI Site. The groundwater well search performed by CH2M Hill, Con
Edison's consultant for this site, has indicated that there are no potable water wells
located downgradient of the Site which could be impacted or potentially threatened
by Site-related contamination. Currently, potable water is provided to the residents
in the vicinity of the site from public sources.  In addition, there is little, if any,
probability that the overburden and upper bedrock water zones in the vicinity of
the site would be used for potable water supply purposes in the foreseeable future.
The overburden water bearing zone cannot be expected to support residential use
due to its ' jw wa ter yield. Any future potable well, if installed in the bedrock
formation,  would with all likelihood draw water from significantly deeper water-
bearing zones rather than the upper bedrock zone, in which limited contamination
was detected beneath the Site during the Groundwater Investigation program.
Furthermore, only four inorganic compounds were detected in the upper bedrock

-------
Ms. Mary Anne Rosa

Page 2
August 28,1997
zone at concentrations slightly exceeding drinking water standards. Since
contaminated soil, the suspected source of groundwater contamination, was
removed from the site, the natural attenuation process should be expected to result
in a gradual improvement in the groundwater quality in the vicinity of the site.
Con Edison also concurs with EPA that on the basis of available groundwater
quality data and the results of the EPA Baseline Risk Assessment; some future
groundwater monitoring at the site is appropriate. However, Con Edison believes
that certain requirements of the long-term groundwater monitoring program should
be revised before the Plan is finalized, and the Record of Decision (ROD) for the
CSMI Site Operable Unit 2 is issued. These requirement and our concerns are
summarized below.

 •  The Proposed Plan states that, as part of the No Further Action  Remedy, a
    groundwater monitoring program will be required for a minimum of five years
    and that groundwater samples will be collected on a quarterly basis during the
    first year. We believe that the frequency of the groundwater sampling during
    the first year should be decreased from quarterly to semi-armually.  CH2M Hill
    conducted quarterly groundwater sampling during the 1996-1997 Groundwater
    Investigation program at the Site.  Our review of the groundwater data
    collected during this program indicates slow changes in groundvater quality
    at the CSMI site. Thus, a frequent data collection (such as every quarter) does
    not provide any significant additional information to or  benefit the monitoring
    program.

•  The Proposed Plan states that groundwater samples collected at  die site during
   the five year groundwater monitoring program will be analyzed for TCL VOCs,
   semi-VOCs, and TAL inorganic compounds. Semi-VOCs have not been
   chemicals of potential concern at the CSMI site. In fact, groundwater samples
   collected at the site during the 19% -1997 Groundwater Investigation were not
   required to be analyzed for semi-VOCs. Thus, we suggest that these compounds
   not be included in the Final Plan or, if included, only be analyzed forone time
   per year.

•  With respect to the TAL inorganic compounds in the overburden water-bearing
   zone, we conclude that monitoring for all TAL inorganic compounds is not
   ne:essary. The future groundwater monitoring should only include arsenic,
   manganese, thallium, and (possibly) lead. With the exception of lead, these were
   the inorganic compounds that EPA selected as chemicals of potential concern in

-------
Ms. Mary Anne Rosa

Page 3
August 28,1997
   its baseline risk assessment of the overburden aquifer.  We similarly conclude
   that future monitoring of the upper bedrock water zone for all TAL inorganic
   compounds is not appropriate or necessary. The future monitoring program for
   this water zone should include arsenic, lead, aluminum, and thallium, i.e., the
   inorganic compounds that were detected in this aquifer at concentrations that
   exceeded the New Jersey State groundwater quality standards and/or the
   federal MCLs during the 19% • 1997 Groundwater Investigation. An alternative
   could provide for sampling at the end of the first year and/ if any compound is
   detected in excess of the groundwater quality standards, continuing to monitor,
   if not detected above sv.ch levels discontinuing any further analysis.

Con Edison would like to have an opportunity to discuss these comments with you
before the Plan for the CSMI site is finalized. Please contact Con Edison's Project
Manager, Karel Konrad (212-460-4700), at your convenience.
Very truly yours,
      (7
Troy J. Meyer
Director, Remediation Section
Environment Health & Safety
       Garret Austin
       Karel Konrad
       Michael Wilcken
       Scott Vozza-CH2M Hill

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                  ATTACHMENT 5




                      TABLES
Curcio Scrap Metal, Inc. Site - ROD

-------
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-------
                                                     TABLE 2
                                             Circle
                                                  fcrw ••«••. "•• *'«• ' OUZ
                                                                                                      1B.OO 0     II*.** •
                                                                                                       n.oo o     rr.M *
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Data Qualifier  '                       —	
J indicates for all chemicals mat the reported concentnoion is estimated.
B indicates tharthe repotted value is less than the contract required
   detection limit but greater **"" the fa«*"""ft* detection ifa"ftj the

   integrity of tie sample is suspect
                                                                                            "5=.*
    1181111
           ,
NOTE: The CDM nomenclature next to the Sample Name
indicates EPA's split sampling results; the Sample Name
without any nomenclature is the Respondent J sampling results.
                                                      TABLE 2

-------
                                                        TABLE 2
                                                   Cure I • tcr*> Mml, Ine. fin • alt-
                                                                ptlm Iwdu
                                                             I Mil* (Ovllt*)
MVlJ MM
IMCLf MH
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                        The CDMnomenclaturt next to the Sample Name
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                without any nomenclature is the Respondent's sampling rest

-------
                                                         TABLE 2
                                                     brel* ten* •«•!. inc. sit* • OUZ.
                                                                 toptln* tauln
                                                                i Mill (On-lltt)
  SMPU MTI
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 DaU Qualifier      .                               '	
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MTUl
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                                          NOTE: The CDM nomenclature next to the Sample home
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                                           without any nomenclature is the Respondent's samplmg res

-------
                                                        TABLE 2
                          CurcU lcn» weal.
                                                                    lit* - OB
                                                                   l«Mlu
                                                             Wilt (On-llu>
t^tJtlYtf tjMtf
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                                      without any nomenclature is the Respondent's sampling result.

-------
                                                          TABLE 2
                 Cure)* ten* Mtil
                                                                    Inc. »!«« - OU2
                                                                    lnt tawtu
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(MTU MM
IMTU MTI
MTM
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AU1IIUI
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(2) »M»tt «•!« I
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                                 NOTE: The CDM nomenclature nag to the Sample Name
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                                 without any nomenclature is the Respondent's sampling resi

-------
                                                          TABLE2


(Mm «M1
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rw.oo
 44.00
                                                                       (J)
   Data Qualifier
   J indicates for all chemicals tbn the repotted conceaoitic

B  indicates that the reported value is less than the contract required
   detection limit but greater than the instrument detection limit; the
   integrity of the sample is suspect
                                                                                                                           :*f
OOTUl  (1) !•*(• <•!<• I
      (Z) 0>*U wtui <
      (I)
                      	  IM IMl '
                     I SOU MM IWl «•
                     i kMk IttHtl mi tOt» MM tMt wliM.
                           The CDMnotoaidatirt no* to «*r Sample Name
                   indicates EPA's split sampling rquby the Sample Name
                   withovJ any nomenclature is the Respondent's sampling ro

-------
                                                            TABLE2
                                                           tcnp Mt«l. Im. (It* • OU2
                                                                  MM In* t«*utu
                                                                  Mil* (On-IIK)
  IMTU MMi
  tMTU MTI
                        •a-tTAtc

                    MM Mrwr «MI
                 mt-ai-t-au
                 •   U/Q1/W
                                    10/01 m
                                                    W/W/97
                                                                                                                        oi/ot/fr
  k«M MIKttvi v»l«tll«
  vim onMiOf
  OUOHCTMJOI
  MIITLII*] CHAIN
                          (•SI
                          NO/I
       2.00

       1.00


       7.0»

       70.00
      100.00
      100.00
       1.00 ,

      200,00
      100.00
       t.oo
      100.00
       1.00

    1,OH.«
       0.10
      700.00
    10.000.00
  2.09

  2.00


.  2.00

 10.00
 to.oo

  2.H

 24.00

  1.00

  1.0*
                                                      4.N
                                                    700.00
                                                     44.00
1.10
2.00
                                                                     11.00
                                                                      4.40
                                                                      11.00

                                                                      olio i
                                                                      O.JO J
                                                                              (II
               11.00
                4.10
                                                                                      ».»•
   10.00
    1.00
                                                                                              (»»
                    0.42 i
                    0.41 I
    0.27 i
    t.oo
    t.U
    0.24 J
                                                                                                                      O.U J
                                                                                                                      O.tf J
 wnu
       MTI
                                                        -IMH
                                                                     •M-M-l-CM
                                                                       ItrtVO*
                                                         10/01/W
                                                                          01/W/T7
        utt
                                     I.SO
                                                     O.JO
 2MB
                                     t.oo
                                    M.OO

                                  .«••«
                                     s.oo
                                    1N.OO
                         «•/«
                         «/t
                                    n.oo
                       4.00
                      M.OO
                    2.000.00
                       4.M
                       S.OO
 n.00


100.N

 tt.M

 2.00
                                   UJ.ON.N
                                                                  ».l
                                                                   • #•

                                                                  «.
                                                                                    MT.OOO
               M.MO
                2JOO

           IU.OOO'N"
                1.40 U
                2.0*0

              ur.oo*
                **•*«
            II,400.•
             1.JJO.N
                7JOI
            U.TQO.O*
                                                 W^OO
                                                  S.100

                                                . *1.40 0
                                                  1.MO
                                                                                                      1400
                                                                                      7.NO

                                                                                     H!«* I
                                                                                              O»
   pi:.!*
    0.70
-•"•iS
    1JO*
    1.H I
                                                                                                              0)
    44.70*
    O.M*
 J   •••••
1I2.000.Ot

    I.4C*

    27.70 0

 20.100.N
 1.J20.M
    2.100
 I.400.N

 M,tOO.N
    1.NO

 !   IJ» I
                                                                                                                              i .^
                                                                                                (1)
                                                                                                •
 Data Qmlifier        '                                       ~
 J indicaw for all cbemicalsthit the repotted conctntratiraiiestinute^
 B indicates that the reported value is less *•" the contract required
    detection limit but greater than die instrument detection limit; me
    integrity of the sample is suspect
OOTMI. (1) lao** itlm.
      (2) «••«• Ml»
      lit tap** mlut
      IMt
«IM ttalt «•(<•.
      «n« OUtt MM IMIt
                        : The CDM nomenclature next to the Sample Name
                  indicates EPA's split sampling results; the Sample Name
                  without any nomenclature is the Respondent's sampling n

-------
                                        Table 3
                     Summary of Potential Contaminants of Concern
                              Upper Bedrock Aquifer zone

Chemicals

Frequency of
Detection
Range of Detected Concentrations (ppb)
Minimum
Maximum
Volatile Organic Compounds
Chloromethane
Vinyl Chloride
Methylene Chloride
Chloroform
1,1,1 -Trichloroethane
Carbon Tetrachloride
Trichloroethene
Benzene
4-Methyl-2- Pentanone
Toluene
2/24
1/24
1/24
5/24
4/24
7/24
10/24
2/24
1/24
1/24
0.30 J
0.32 J
0.20 J
0.10J
0.20 J
0.30 J
0.20 J
0.55 J
0.70 J
0.30 J
l.OOJ
0.32 J
0.20 J
0.30 J
0.40 J
0.50 J
1.90
0.70 J
0.70 J
0.30 J
PCBs
Arochlor 1248
1/24
3:20
3.20
 Data Qualifiers
  J     indicates for all chemicals that the reported concentration is estimated.
  B    indicates for inorganics that the reported value is less than the contract required
        detection limit but greater than the instrument detection limit.
Curcio Scrap Metal. Inc. Site - ROD

-------
Table 3 — continued
Inorganics
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Selenium
Sodium
Thallium
Vanadium
Zinc
13/24
2/24
9/24
24/24
12/24
2/24
24/24
8/24
7/24
3/24
9/24
12/24
24/24
13/24
9/24
16/24
2/24
24/24
4/24
15/24
15/24
41.7B
0.90 B
1.60B
214
0.16 B
0.75 J
30,800
0.71
0.35 B
8.90 B
21.9B
l.OOBJ
13,000
0.83B
0.79 B
1,840B
5.30
8,765
2.25 B
1.70 B
2.45 B
439
11.5B
12i2
562
2.30 B
1.20B
91,700
23.0
1.70B
47.5
270
27.7
38,400
13.2B
7.55 B
13,500
9.20
33,150
10.6
13. IB
24'.8
Data Qualifiers                                                                  ,
 J     indicates for all chemicals that the reported concentration is estimated.
 B    indicates for inorganics that the reported value is less than the contract required detection
       limit but greater than the instrument detection limit.
Curcio Scrap Metal. Inc. Site - ROD

-------
Table 4 - continued
Inorganics
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Selenium
Sodium
Thallium
Vanadium
Zinc
19/24
3/24
9/24
18/24
12/24
1/24
24/24
11/24
15/24
9/24
21/24
11/24
24/24
24/24
16/24
21/24
4/24
24/24
11/24
12/24
15/24
48.4 B
5.10B
2.10 B
61.6 B
0.36 B
5.00
150
2.30 BJ
1.40B
1.40 B
27.7 B
1.80 B
24.0
1,270
2.10 B
4,1 90 B
3.20 J
26.0
2.70 B
0.53 B
2.10B
12,700
11.8B
243
583
2.30 B
5.00
163,000
176
ll.OB
85.0
38,700
47.0
34,000
8,620
124 B
114,000
8.70
83,800
15.1
17.2B
106
Data Qualifiers  J   indicates for all chemicals that the reported concentration is estimated.
 B    indicates for inorganics that the reported value is less than the contract required detection
       limit but greater than the instrument detection limit.
 N    indicates for organics that there is only presumptive evidence for their presence.
 U    indicates for chemicals that the chemical was not detected at the reported detection limit.
Curcio Scrap Metal. Inc. Site - ROD

-------
Table 4 - Continued
VOCs Continued
Trichloroethene
Dibromochloromethane
Benzene
4-Methyl-2-pentanone
Toluene
Chlorobenzene
Ethylbenzene
Xylenes (Total)
P + M Xylenes
O-Xylene
Isopropylbenzene
n-Propylbenzene
1 ,3,5-Trimethylbenzene
1 ,2,4-Trimethylbenzene
Naphthalene
11/24,
1/23
8/24
3/24
7/24
5/24
6/24
4/16
2/9
2/9
2/9
1/9
2/9
1/9
1/9
0.30 J
0.30 J
0.30 J
0.50 J
0.30 J
1.00 ,
1.20
0.42 J
0.70 J
0.90 J
0.30 J
0.50 J
0.20 J
3.50
2.50
21.0
0.30 J
13.0
!1.00J
2.30
2.50
4.00
;4.60
3.00
1.80
'0.40 J
,0.50 J
1.80
3.50
;2.50
PCBs
Arochlor 1248
1/23
0.1 1JN
6.1 1JN
i
Data Qualifier
J indicates for all chemicals that the reported concentration is estimated.
N indicates for organics that there is only presumptive evidence for their presence
Curcio Scrap Metal, Inc. Site - ROD

-------
                                      Table 4.
                    Summary of Potential Contaminants of Concern
                          Overburden Water Bearing zone

Chemicals

Frequency of
Detection
Range of Detected Concentrations (ppb)
Minimum
Maximum
Volatile Organic Compounds
Vinyl Chloride
Chloroethane
Methylene Chloride
Acetone
Carbon Disulfide
1 , 1 -Dichloroethene
1,1-Dichloroethane
Cis 1,2-Dichloroethene
Trans 1,2-Dichloroethene
Chloroform
1 ,2-Dichloroethane
2-Butanone
1,1,1 -Trichloroethane
Bromodichloromethane
12/24
6/24
4/22
1/7
1/24
4/24
8/24
12/24
9/24
1/24
3/24
1/12
4/24
1/21
0.42 J
0.61 J
0.20 J
7.50
0.60 J
0.27 J
9.00
3.50 J
0.26 J
51.0
0.30 J
2.0
0.30 J
3.0
7.30
4.90
0.30 J
7.50
0.60 J
0.80 J
29.0
8.00
l.OOJ
51.0
0.50 J
2.0
0.44 J
3.0
Data Qualifier
J indicates for all chemicals that the reported concentration is estimated
Curcio Scrap Metal, Inc. Site - ROD

-------
                                         Table 5
           Summary of Potential Chemicals of Concern (Off-Site- Residential Well)

Chemicals
Frequency of
Detection
Range of Detected Concentrations (ppb)
Minimum
Maximum
VOCs
Carbon Tetrachloride
1/1
0.40 J
0.40 J
SVOCs
None Detected
None Detected


Pesticides/PCBs
None Detected
None Detected


Inorganics
Barium
Calcium
Magnesium
Sodium
1/1
1/1
1/1
1/1
212
54,000
18,000
11,000
212
54,000
18,000
11,000
Data Qualifier
 J     indicates for all chemicals that the reported concentration is estimated.
Curcio Scrap Metal. Inc. Site - ROD

-------
                                      Table 6
                    Summary of Potential Contaminants of Concern
               Overburden Water Bearing zone - (upgradient on-Site well)

Chemicals

Frequency of
Detection
Range of Detected Concentrations (ug/1)
Minimum
Maximum
Volatile Organic Compounds
Vinyl Chloride
Chloroform
Trichloroethene
Benzene
Toluene
1/8
1/8
3/8
1/8
1/8
0.30 J
0.24 J
0.40 J
0.40 J
0.20 J
0.30 J
0.24 J
2.70
0.40 J
0.20 J
PCBs
None Detected
None Detected


Data Qualifiers
J indicates for all chemicals that the reported concentration is estimated.
Curcio Scrap Metal, Inc. Site - ROD

-------
Table 6 - Continued
Inorganics
Aluminum
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Selenium
Sodium
Thallium
Vanadium
Zinc
6/8
5/8
4/8
8/8
4/8
3/8
2/8
5/8
3/8
8/8
8/8
6/8
4/8
4/8
8/8
1/8
1/8
7/8
85.0 B
75.0 B
0.52 B
46,300
2.00 B
0.39 B
2.00 B
26.3 B
2.50 BJ
7,000
30.0
19.1 B
2,740 B
3.00 B
34,500
2.33 B
2.70 B
14.3 B
1,110
114B
2.20 B
I
56,200
;124
9,.80B
3.50 B
1,930
3.30
8,550
166
111
4,340 BJ
7.40
40,400
2.33 B
2.70 B
129 EJ
Data Qualifiers
 J     indicates for all chemicals that the reported concentration is estimated.
 B    indicates for inorganics that the reported value is less than the contract required detection
       limit but greater than the instrument detection limit.
 E    indicates for inorganics that the value is estimated due to matrix interferences.
 U    indicates for all chemicals that the chemical was not detected at the reported detection
       limit.
Curcio Scrap Metal. Inc. Site • ROD

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                                        Table 7
                         Chemicals of Concern in Aquifer zones

VOCs
PCBs/Pesticides
Inorganics
BEDROCK
WELLS
Vinyl Chloride
Aroclor 1248
Antimony
Arsenic
Barium
Beryllium
Thallium
OVERBURDEN
WELLS
Vinyl Chloride
None Selected
Antimony
Arsenic
Beryllium
Manganese
Thallium
RESIDENTIAL
WELL
Carbon Tetrachloride
None Detected
Barium




Curcio Scrap Metal, Inc. Site - ROD

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                                         Table 8
                     Summary of Weight of Evidence Classification and
                       Cancer Slope Factors for Chemicals of Concern.
Chemical
Weight of
Evidence
Cancer Slope
Factor Inhalation
(mg/kg-day)-' -
Cancer Slope
Factor Oral
(mg/kg-day)-1
Source of Data
VOCs
Vinyl Chloride
Carbon
Tetrachloride
A
B2
0.3
0.053
1.9
0.13
HEAST Annual FY'95
IRIS 3/97
PCBs
Aroclor 1248
B2
0.4
0.4
IRIS 3/97
Inorganics
Antimony
Arsenic
Barium
Beryllium
Manganese
Thallium
chloride
-
A
-
B2
D
D

15

8.4
-
-

1.5

4.3
-
-

IRIS 3/97

IRIS 3/97
IRIS 3/97
IRIS 3/97
1
Cvrcio Scrap Metal, Inc. Site • ROD

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                     Table 9 — Potential Cancer Risks Across Pathways
Media
Gronndwater


Upper Bedrock
Aquifer zone
(On-Site)



Overburden
Water Bearing
zone
(Oo-Site)
Note: the voter in
this zone is not
currently being
used for potable
purposes nor is it
expected to be used
for potable
nurnntfs in thf
fumre.


Orr-Site Well





Receptors


Residents •
Adults


Children
(0-6 years old)


Residents -
Adults

X*V "U
Children
(0-6 years old)


Area Residents:
Adults


Children (0-6
years old)


Exposure Route Pathway

Ingest lot.
Dermal (shower)
Inhalation of VOCs in Shower
TOTAL
Ingestion
Dennal(Shower)
Inhalation of VOCs in Shower
• TOTAL
Ingestion
Dermal (shower)
Inhalation of VOCs in Shower
TOTAL
Ingestion
Derntal(Shower)
Inhalation of VOCs in Shower
T~- ! T_
Ingestion
Derroal(Shower)
Inhalation of VOCs in Shower
TOTAL
Ingestion
Dermal(Shower)
Inhalation cf VOCs hi Shower
TOTAL
Potential
Cancer Risk

1.9x10*
8.4x10-'
1.0x10*
I.9XIO-1
l.lxlO-4
2.9x10-'
1.2x10*
1 >10"
3.6xlO-J
1.6x10-'
l.lxlO-5
3.6x10^
. 2.1x10°
5.5x1 0*
IJxlO-'
2 1x10-'
4.9x1 0-7
NA
2.2x10-'
7.1x10-'
2.8x1 fr7
NA
2.6x10-'
5.4x10-'
Chemicals Contributing to
Cancer Risks


No chemicals individually
exceed the target risk range.


No chemicals individually
exceed the target risk -ange.


Arsenic



.Arsenic
•


*»— »•••••—•



_


Curcio Scrap Metal. Inc. Sue - ROD

-------
                                        Table 10
                      Summary of Inhalation and Oral Reference Doses
                                for Chemicals of Concern.
Chemical
Inhalation
Reference Dose
(mg/kg-day)
Oral Reference Dose
(mg/kg-day)
Source of Data
VOCs
Vinyl Chloride
Carbon Tetrachloride
-
0.00057
-
0.0007

NCEA for inhalation
IRIS 3^97 for oral
PCBs
Aroclor 1248
0.00002

IRIS 3/97
Inorganics
Antimony
Arsenic
Barium
Beryllium
Manganese
Thallium chloride


0.00014

0.000014
-
0.0004
0.0003
0.07
0.005
0.024
0.00008
IRIS 3/97
IRIS 3/97
HEAST FY'95 inh.
IRIS 3/97 for oral
IRIS 3/97
IRIS 3/97
IRIS 3/97
Curcio Scrap Metal. Inc. Site - ROD

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                                        Table 11
                      Combined Hazard Index Values Across Pathways
Media
Groundwater
Upper Bedrock
Aquifer zone
(On-Site)
Overburden
Water Bearing
zone (On-Site)
Note: the water in
this zone is not
currently being
used for potable
purposes nor is it
expected to be used
for potable
purposes in the
future.
Off-Site Well
Receptors

Residents -
Adults
Children
(0-6 years old)
Residents -
Adults
Children
(0-6 years old)
Area Residents:
Adults
Children (0-6
years old)
Exposure Route Pathway

Ingestion
Dermal (shower)
Inhalation of VOCs in Shower
TOTAL
Ingestion
Dermal(Shower)
Inhalation of VOCs in Shower
TOTAL
Ingestion
Dermal (shower)
Inhalation of VOCs in Shower
TOTAL
Ingestion
Dermal(Shower)
Inhalation of VOCs in Shower
TOTAL
Ingestion
Dermal(Shower)
Inhalation of VOCs in Shower
TOTAL
' Ingestion
Dermal(Shower)
Inhalation of VOCs in Shower
TOTAL
Non-
Cancer
Hazard
Index
Chemicals Contributing Most
to non-Cancer Hazard Index

2.2
0.01
NA
2.2
5.1
0.014
NA
5.1
30
0.14
NA
30
71
0.19
NA
71
0.099
0.00038
NA
0.099
0.23
0.00052
NA
0.23
No chemicals individually
exceed the target level of 1 .
Arsenic and Thallium
Arsenic, Manganese and
Thallium
Arsenic, Manganese and
Thallium
	
	
Curcio Scrap Metal. Inc. Site - ROD

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                          ROD FACT SHEET

SITE	
Name           : Curcio Scrap Metal, Inc. Site
Location/State : 416 Lanza Avenue, Saddle Brook, New Jersey
EPA Region     : 2
HRS Scpre  (date): 34.54 (July 1987)
EPA Site ID #  :NJD011717584

ROD	
Date Signed:   September 30, 1997
Remedy:         No Further Action, with long term groundwater
            monitoring
Operating Unit Number: OU-2
Capital cost: 0
Construction Completion: N/A
O & M in 1997: $45,586   (in 1997 dollars)
Present worth: $200,000  (7% discount rate and 5 years 0 & M)

LEAD	
Remdial/Enforcement: Remedial
EPA/State/PRP:       PRP
Primary contact:     Mary Anne Rosa 212-637-4407
Secondary contact:   Kimberly O'Connell 212-637-4399
Main PRP :            Consolidated Edison Company of NY
PRP Contact:         Karel Konrad 212-460-4700
WASTE
Type:        VOCs, metals
Medium:      Groundwater
Origin:      Scrap metal recycling
Est.  quantity: N/A

-------