United States
           Environmental Protection
           Agency
              Office of
              Emergency and
              Remedial Response
EPA/ROO/R02-88/073
September 1988
&EPA
Superfund
Record of Decision
            Ewan Property, NJ

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   30272-IQI
    REPORT DOCUMENTATION
           PAGE
                         REPORT NO.

                               EPA/ROD/RQ2-88/073
3. Recipient's Accession No.
4. Title and Subtitle
 SUPERFUND RECORD OF  DECISION
  wan Property, NJ
    ofr
                                                                            5. Report Oat*
                                                                                          09/29/88
    '. Authord)
                                                                            8. Performing Organization Rept. No.
   9. Parformini Organization Nam* and Address
                                                                            10. Project/Task/Work Unit No.
                                                                            11. Contract(C) or Grant(G) No.
                                                                            (C)

                                                                            (G)
   12. Sponsoring Organization Nam* and Addrass
     U.S.  Environmental protection Agency
     401  M Street,  S.W.
     Washington, D.C.  20460
                                                                         13. Typ* of Report & Period Covered

                                                                          800/000
                                                                         14.
   IS. Supplementary Note*
   18. Abstract (Limit: 200 words)
       The 43-acre Ewan Property  site is located in a predominantly  agricultural  and
     residential  area of Shamong  Township,  Burlington County, New Jersey.  Private residences
     are provided domestic water  from wells as close as  one mile downgradient  from the site,
     drawing from an aquifer that extends from beneath the site.  The  site is  broken into two
     study areas, Area A and Area B.  Area  A,  consisting of nine acres,  is the area of
     concern.  Site investigations revealed that during  the early to mid-1970s, at least
     500 to 8,000  55-gallon drums containing  hazardous  industrial wastes were disposed of  in
     trenches in  Area A, and the  trenches were subsequently backfilled with soil.
     Investigations also revealed that many of the drums are ruptured, corroded or leaking.
     Soil and ground water samples indicate the presence of VOCS and metals.   It  is estimated
     that Area A  has 4,500 yd3  of highly contaminated soil and waste material, and
     29,500 yd3 of moderately contaminated  soil.  Primary contaminants of concern affecting
     soil and ground water are  VOCs such as benzene, TCE, PCE, and xylenes, and metals
     including chromium and lead.

       The selected remedial action for this site includes: construction of decontamination,
     staging and  waste characterization areas; excavation, staging and characterization of
     (See Attached Sheet)
   17. Document Analysis  a. Descriptors
     Record of Decision
     Ewan Property,  NJ
     First Remedial  Action
     Contaminated  Media:  gw,  soil
     Key Contaminants:  metals (chromium,  lead), VOCs  (benzene, PCE,  TCE, xylenes)
     b. Identifiers/Open-ended Terms
^^B~Avi
     e. COSATI Field/Group
  Availability Statement
                                                         19. Security Class (This Report)
                                                             None	
                                                            20. Security Class (This Page)
                                                                None
           21. No. of Pages

              107
                                                                                   22. Price
  (See ANSI-Z39.18)
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                                                                                     Department of Commerce

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                 DO  NOT  PRINT THESE  INSTRUCTIONS  AS A  PAGE  IN  A REPORT


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    that identify the major concept of the research and are sufficiently specific and precise to be used as index entries for cataloging.
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SPA/ROD/R02-88/073
 ban Property, HJ
 irst Remedial Action

16.  ABSTRACT (continued)

waste materials with offsite incineration of all appropriate wastes (approximately 4,500
yd^ of buried drums and heavily contaminated soil);  temporary onsite storage and
assessment of non-incinerable wastes to determine proper disposal method; and monitoring
of air and ground water during remedial activities.   The estimated present worth cost of
the selected remedy i-s $21,153,000 with estimated annual O&M costs of $22,000.

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                      DECLARATION STATEMENT

                        RECORD OF DECISION

                           Ewan Property


SITE NAME AND LOCATION

Ewan Property, Shamong Township, Burlington County, New Jersey

STATEMENT OF PURPOSE

This decision document presents the selected remedial action for
addressing the source of contamination at the Ewan Property site,
developed in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980, as amended by
the Superfund Amendments and Reauthorization Act of 1986, and to
the extent applicable, the National Oil and Hazardous Substances
Pollution Contingency Plan.

The State of New Jersey concurs with the selected remedy.

STATEMENT OF BASIS

I am basing my decision primarily on the following documents,
which are contained in the administrative record, and which
characterize the nature and extent of contamination and evaluate
long-term remedial alternatives for the Ewan Property site:
                                        •
- Final Remedial Investigation Report, Ewan Property, prepared
  by Ebasco Services and NUS Corporation, June 1988;

- Final Feasibility Study Report, Ewan Property, Operable Unit
  One, prepared by Ebasco Services and NUS Corporation, July 1988;

- Proposed Remedial Action Plan, Ewan Property, Operable Unit One,
  August 1988;

- The attached Decision Summary for the Ewan Property site;

- The attached Responsiveness Summary for the Ewan Property site,
  which incorporates public comments received; and

- Staff summaries and recommendations.

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                               -2-
DESCRIPTION OF SELECTED REMEDY

The remedial alternative presented in this document represents
the first operable unit of a final remedial solution for the Ewan
Property site.  It addresses the contaminant source materials at
the site and includes the excavation and disposal, primarily via
incineration, of approximately 4500 cubic yards of buried drums
and heavily contaminated soil.  The ground water contamination
in the underlying aquifer and the lesser contaminated soils will
be addressed as part of a second operable unit following the
completion of additional studies and a second ROD.  The specific
components of the remedial action are as follows:

- Clearing of the waste disposal area and upgrading of site
  roadways;

- Construction of decontamination, staging and characterization
  areas;

- Excavation, staging and characterization of source materials;

- Transportation of wastes which are appropriate for thermal
  destruction to a permitted off-site thermal destruction facility;

- Additional assessment of wastes which are not appropriate for
  thermal destruction to determine the appropriate methods of
  waste management; and

- Monitoring of air and groundwater during remedial activities.

DECLARATIONS

Consistent with the Comprehensive Environmental Response, Com-
pensation, and Liability Act of 1980 as amended by the Superfund
Amendments and Reauthorization Act of 1986, and the National Oil
and Hazardous Substances Pollution Contingency Plan, 40 CFR Part
300, I have determined that the selected remedy is protective of
human health and the environment, attains federal and state
requirements that are applicable or relevant and appropriate for
this remedial action, and is cost-effective.  Furthermore, this
remedy satisfies the preference for treatment that reduces
mobility, toxicity, or volume as a principal element.  Finally, I
have determined that this remedy utilizes permanent solutions and
alternate treatment technologies to the maximum extent practicable.
    Date                             William J^/MuszynsJot,  P.E.
                                   Acting Regional Adi&nistrator

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              Decision Summary for Operable Unit One
                        Evan Property Site
                   Shamong Township, New Jersey
SITE DESCRIPTION

The Ewan Property site is located in Shamong Township, Burlington
County, New Jersey, approximately 5,000 feet east-northeast of
Indian Mills Lake and an estimated 4,000 feet south of Tuckerton
Road.  Figure 1 illustrates the location of Ewan Property rela-
tive to Indian Mills Lake and Tuckerton Road.. Wharton State
Forest is approximately two miles south of the site.  The Ewan
Property is situated in the northwest corner of the New Jersey
Pinelands and appears to border both the Pinelands Agricultural
and Protection Areas.

The Ewan Property is an approximate 43 acre tract of land iden-
tified on Shamong Township tax maps as block 23, lots 32 and
32A.  Currently, the property is privately owned by Mrs. Verna
Dale Donnelly (formerly Mrs. Verna Dale Ewan) of Willingboro,
New Jersey.  Figure 2 identifies both the Ewan Property and
adjacent tax parcels.

Land use within 1.25 miles of the site is generally agricultural
and single family residential developments.  Figure 3 displays
the land uses and classifications surrounding the Ewan Property
in June 1983.  Areas immediately northeast of the site are
being developed to accommodate middle to upper-middle income
single family residential units.

Domestic water within one mile of the site is obtained from
individual private wells developed within the Cohansey Sand
hydrogeologic unit, a water table aquifer.  Domestic sewerage
is disposed of via individual private septic systems.  Area
agricultural water usage is dependent upon the water table
aquifer.  Ground water within the Cohansey Sand has been deter-
mined to flow in a southerly direction.  The nearest identified
domestic ground water user down-gradient of the site is located
approximately one mile away.

Two aquifers were investigated beneath the site.  The upper or
water table aquifer is the Cohansey Sand hydrogeologic formation.
The ground water velocity within the Cohansey Sand aquifer was
estimated to be 50 to 124 feet per year.  The Cohansey Sand
aquifer demonstrated a slight downward vertical gradient into
the underlying Kirkwood Formation, the lower aquifer.  Both
aquifers demonstrated hydraulic linkage and a southerly flow.
No aquitards were identified within the investigated area.

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                             -2-


A small unnamed, intermittent tributary of Springers Brook is
identified as proceeding in a general northeast to southwest
direction across the Ewan Property.

The nearest surface water body is located on the Ewan Property
itself.  It is a small farm pond south of tax block 23, lot 32A
(see Figure 2).

SITE HISTORY

For purposes of the Remedial Investigation (RI), two study
areas were originally identified on the Ewan Property.  They
are known as Areas A and B (see Figure 2).

Area A is a nine acre parcel located in the southern portion of
tax block 23, lot 32.  The RI studies revealed that hundreds of
drums containing hazardous substances and other industrial con-
taminants were disposed of in trenches in Area A.  EPA believes
that the disposal of these drums occurred during the early and
mid-1970's.  After such disposal, the trenches were apparently
backfilled, thereby burying the drums containing hazardous
substances, and the surface soils were later recontoured.

The RI investigations also revealed the following information,
among others, concerning the conditions which presently exist at
Area A:

1.  At least 500 to 8000 55-gallon drums containing hazardous
    substances (HSs) and/or industrial contaminants are buried
    in the soil at Area A;"                             .

2.  Many of the drums buried at Area A are ruptured, corroded
    and/or are otherwise in a state of disintegration;

3.  HSs have been released into the soil and ground water at
    Area A from many of the buried drums which were found at
    this location;

4.  HSs have migrated from the drums at Area A into the Cohansey
    Sand aquifer which exists under the Ewan Property;

5.  A contaminant plume containing HSs exists in the Cohansey Sand
    aquifer under Area A and this plume has and will continue to
    migrate in a southerly direction away from Area A (see Figure
    5);

6.  Approximately 4500 cubic yards of soils and drums and
    contents which are heavily contaminated with HSs and other
    industrial contaminants exist at Area A;

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                              -3-
7.  Approximately 29,500 cubic yards of soils which are moderately
    contaminated with HSs and other industrial contaminants
    exists at Area A; and

8.  HSs contained in the buried drums and in the contaminated
    soils discovered at Area A have and will probably continue
    to migrate into the Cohansey Sand aquifer under the Ewar.
    Property.

The RI has concluded that Area B is not of concern.  Each magnetic
anomaly or soil gas detection within Area B was investigated.
Buried domestic trash was encountered at most of these locations.
Also, no ground water contamination was detected within Area B.
Therefore, Area B will not be considered for either operable unit
one or operable unit two remedial actions.  Figure 4 outlines the
approximate extent of contamination in Area A.

The Ewan Property site was originally proposed for inclusion on
the National Priorities List (NPL) in March 1985.  The site was
formally added to the NPL in June 1986.

REMEDIAL ACTIONS BY EPA

The Environmental Protection Agency (EPA) performs Remedial
Actions at toxic waste sites in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(P.L. 96-510: CERCLA), as amended by the Superfund Amendments
and Reauthorization Act of 1986 (P.L. 99-499: SARA).  These
Remedial Actions are pr.imarily planned and conducted in the
following sequence:

The first phase consists of performing a site-specific remedial
investigation and feasibility study (RI/FS).  The RI is imple-
mented to define the nature and extent of contamination.  The
FS evaluates technologies and alternatives which will be devel-
oped and implemented to remediate the contamination identified
in the RI.

Following the completion of the RI/FS, a Record of Decision
(ROD) is signed by the EPA.  This is the Agency's offical
document which selects a remedy for the site and provides the
rationale for the selected remedy.

Following the signing of a ROD, the Remedial Design (RD) is
initiated.  During the RD, plans and specifications are developed
to be utilized during the remediation phase, also referred to
as the Remedial Action (RA).  The RA is the actual implementa-
tion of the site cleanup.

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                              -4-
Pre-Remedial Investigation Activities*

In 1983, the New Jersey Department of Environmental Protection
(NJDEP) conducted an electromagnetic conductivity survey and
installed five monitoring wells in the Cohansey Sand aquifer
within Area A.  Figure 6 illustrates the location of these wells
(see EP-1 through EP-5).  Sample results from these wells in-
dicated the presence of the following organic and inorganic
contaminants': methylene chloride,  toluene, chloroform, 2,4-
dichlorophenol, n-butylbenzene, o-dichlorobenzene, p-dichloro-
benzene, 1,2,4-trichlorobenzene, arsenic, chromium, and lead.

NJDEP further characterized the site by conducting bulk samp-
ling of one drum and an investigation of waste spillage onto
soil at three other locations*  Table 2 illustrates the consti-
tuents of these four samples which includes chemical species
found in the ground water sampling as well as the following:
tetrachloroethane, benzene, xylenes, 1,2-dichloroethane, 1,1-
dichloroethane, napthalene, phenanthrene/anthracene, pyrene,
acenaphthylene, benzo(a)anthracene/chrysene, hexachlorobuta-
diene, styrene, 1,2,4 trimethylbenzene, 1,3,5-trimethylbenzene,
phenol, 4-nitrophenol, sec-butylbenezene, 4-chlorophenyl phenyl
ether, o-chlorotoluene, n-propylbenzene, bis(2-ethylhexyl)
phthalate, di-n-butylphthalate, diethylphthalate, antimony,
cadmium, copper, mercury, nickel,  selenium, silver, and zinc.

The subsequent -RI activities confirmed the presence of these and
other contaminants.

EPA Remedial Investigation'Activities

Pursuant to the National Oil and Hazardous Substances Pollution
Contingency Plan, EPA commenced field activities at Areas A and
B of the Ewan Property site in 1985.

The RI activities conducted to evaluate the nature and extent
of contamination on or near the site included: visual observa-
tion, direction by confidential sources familiar with the Ewan
disposal operation, geophysical surveys, soil gas screening,
test pits, soil borings, surface and sediment sampling and
analysis, health and safety monitoring, domestic well sampling
and analysis, and monitoring well installation, sampling and
analysis.

Figure 6 displays all of the sampling locations (except domestic
well, surface water and sediment sampling locations) that were
* Specific Target Compound List  (TCL) analysis is available in
  the RI report.  A brief summary of the TCL detections are
  listed on Table 1.

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                              -5-
utilized during the RI.  Provided below is a chronology of remedial
investigation activities for the Ewan Property.

    NJDEP pre-RI activities      9/83 - 10/83
    EPA pre-RI activities        4/84 - 9/84
    EPA RI activities (NUS)      10/85 - 10/86
    EPA RI activities (EBASCO)   10/86 - present

Preliminary Surveys

EPA conducted a series of preliminary field surveys to refine
the areas of the Ewan Property which would be scrutinized during
the RI.  These surveys included soil gas screening and geophys-
ical surveys (total magnetic field intensity surveys, magnetic
gradient surveys, and electromagnetic surveys).  The soil gas
surveys were implemented to identify areas of organic compound
volatilization.  The geophysical surveys were utilized to isolate
areas containing buried ferromagnetic objects or magnetic
anomalies.

The summary of these preliminary surveys provided the basis by
which the subsequent investigative activities, including the
sampling and analysis of the soil and ground water, were performed.

Test Pits*

Following the preliminary surveys, the locations of sixteen te-st
pits were identified.  The test 'pits were used to confirm the
accuracy of waste location estimates produced from the preliminary
surveys and a party familiar with the disposal operation.,  The
primary goals of the test pitting operation were to: determine
if industrial waste was present in Area B; examine the condition
of the buried drums; estimate the depth of waste burial; obtain
subsurface soil, ground water, and drum samples; and determine
if bulk uncontainerized disposal occurred in Area A.  Figure 6
illustrates test pits 1 through 7 which were excavated in Area
B, and displays test pits 8 through 16 which were dug in Area A.

The test pit field logs indicated that either nothing noteable,
or bog iron, or domestic trash was discovered in the Area B test
pits.  The TCL (Target Compound List) analysis of Area B test
pits did not indicate industrial waste disposal.

Conversely, test pits 10, 11, 13, 15, and 16 revealed drums in
various physical conditions or contained gases at explosive
limits.  The predominant chemical species detected during Area
A test pit sampling were xylenes and 2-methylnapthalene.  Drums
* Specific TCL analysis is available in the RI report.A brief
  summary of the TCL detections are listed on Table 1.

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                              -6-


were encountered from the ground surface to approximately 11
feet below grade.  Most often, drums were encountered at about
1.5 feet below grade..

In addition to the Area A test pit soil and ground water sampling,
NUS collected two samples of liquids which apparently spilled
from drums.  These two bulk samples differed slightly from the
July 1983 NJDEP samples in that the only TCL chemicals detected
were methylene chloride, tetrachloroethene, xylenes, and ethyl-
benzene.

Soil Sampling*

The Ewan Property soil sampling program was designed to define
the nature as well as the vertical and horizontal extent of
contamination.  Both field screening and laboratory analysis
were performed on the soil samples.  Twenty percent of the soil
samples that detected TCL constituents in the field screening
were analyzed in a certified laboratory.  A total of 56 soil
samples were collected and field screened for volatile organics;
47 soil samples were sent to a certified laboratory for TCL
analysis.

Figure 6 illustrates the soil sampling locations in Area B and
background areas.  Two soil borings, EP-SO-001 and EP-SO-002,
demonstrated low concentrations of 1,1,1-trichloiroethane at 6.1
micrograms per kilogram (ug/kg), 14.0 ug/kg, 55.0 ug/kg, and 72
ug/kg.   These detections were determined not to be indicative of
the industrial waste disposal evident in Area A.

Figure 6 illustrates the Area A soil boring locations.  Inorganic
compounds detected in Area A included lead, cyanide, tin, barium
and chromium.  The organic chemical species detected in area
soil borings were acetone, methylethyl ketone, methyl isobutyl
ketone, toluene,  ethylbenzene, xylenes, tetrachloroethene, tri-
chloroethene, methylene chloride, acenphthene, 2-methylnapthalene,
phenanthrene, bis(2-ethylhexyl)phthalate,  di-n-butylphthalate,
butyl benzyl phthalate, anthracene, fluorene,  fluoranthene, and
dibenzofuran.

Ground Water; Domestic Wells*

Figure 7 illustrates the approximate locations of the domestic
wells sampled during the RI.   Of the eleven domestic wells sam-
pled, two wells demonstrated estimated benzene concentrations
of 1 ug/1 (microgram per liter).  These wells  were located
south and west of the site.  The RI indicated  that no direct
correlation can be made between the site and these two wells.
Under the Federal Safe Drinking Water Act,  a Maximum Contaminant
Level for benzene was established at 5 ug/1.  Copper was esti-
* Specific TCL analysis is available in the RI report.  A brief
  summary of the TCL detections are listed on Table 1.

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                              -7-
mated to be 1.17 milligrams per liter (mg/1) in one domestic
well south of the site.  This value exceeds the National Drinking
Water Secondary Standard of 1 mg/1.  The RI does not attribute
this copper concentration to the site but does indicate that
the acidic ground water may be leaching the metallic plumbing at
this domestic well.  No domestic wells have demonstrated contami-
nation that is associated with the Ewan Property site.

Ground Water; Monitoring Wells*

Figure 5 illustrates the approximate extent of the contaminated
ground water plume.  The contaminated ground water plume has been
estimated to be approximately 500 feet long, 600 feet wide and
30 feet below grade.  This indicates that the upper portion of
the Cohansey Sand aquifer is contaminated.  However, the results
indicate that the contaminated ground water has not migrated into
the underlying Kirkwood Formation aquifer.  Major contaminants
of concern identified in the ground water are xylenes, toluene,
benzene, methylethyl ketone, 1,2-dichloroethane, acetone, 4-
methylphenol, ethylbenzene, bis(2-ethylhexyl)phthalate, butyl
benzyl phthalate, acenaphthene, napthalene, 2-methylnapthalene,
lead, and cyanide.  EPA will collect several monitoring and
domestic well samples for analysis to further define the ground
water contamination for Operable Unit Two.

Ground water within the study areas demonstrated a southerly
flow.  The horizontal hydraulic gradient of the Cohansey aquifer
across the study areas was determined to be a 2.foot vertical
water table decline over a.1000 foot distance (0.002 vertical
feet/horizontal foot).  Applying this and other hydrogeologic
data to actual site conditions, it was determined that the
actual ground water flow in the Cohansey Sand aquifer below the
site to be from 50 to 124 feet/year.

Surface Water*

Three surface water samples were taken outside of Area A as
part of the surface water sampling program.  Figure 8 displays
the surface water sampling locations.  All three surface water
samples were taken up-gradient of Area A in standing water.
Hone of the surface water samples demonstrated contaminant
concentrations that were indicative of industrial waste disposal.

Sediment*

Seven sediment samples were taken in the unnamed tributary of
Springers Brook.  These samples were up-gradient and sid«>-
gradient to Area A.  Figure 8 displays the sediment sampling
locations used for this program.  None of the sediment samples
demonstrated contaminant concentrations that were indicative
of industrial waste disposal.
* Specific TCL analysis is available in the RI report.  A brief
  summary of the TCL detections are listed on Table 1.

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                              -8-


Ambient Air

At present/ the site is in an undisturbed state.  EBASCO deter-
mined that, in the present condition of the site, no detectable
concentrations of volatilizing chemicals were encountered.

Radiation

During the RI activities, no detectable ionizing radiation was
encountered.

Public Health and Environmental Concerns

Due to local environmental conditions, including geography,
geology and hydrology, EPA has concluded that few contaminant
pathways exist for contamination associated with the Ewan site.
The primary pathways of concern are surface and subsurface soils,
and ground water.  As described in the previous section, local
site features are conducive to the leaching of contaminants from
the disposal area into the nearby ground water.  The major poten-
tial route of exposure is through domestic use (drinking, shower-
ing) of ground water.

As described in the RI report, 21 indicator chemicals were se-
lected in accordance with the Superfund Public Health Evaluation
Manual on the basis of toxicity, persistence, mobility, and
concentration.  The list of indicator chemicals includes:-

                      Volatile Organics

2-butanone, 1,2-dichloroethane, 4-methyl-2-pentanone, 1,1,1-tri-
chlorethane, benzene, trichloroethene, ethylbenzene tetrachloro-
ethene, toluene, carbon tetrachloride, total xylenes, 1,1-dichloro-
ethene, methylene chloride, and chloroform.

                   Semi-volatile Organics

bis(2-ethylhexyl)phthalate, naphthalene, and 2-methylnaphthalene

                       Inorganics

lead, chromium, barium, and copper


For risk assessment purposes, individual contaminants were sep-
arated into two categories of chemical toxicity depending upon
whether they cause carcinogenic or non-carcinogenic effects.
In the case of chemicals exhibiting carcinogenic effects,
exposures and associated risks are expressed in exponential
terms: lxlO~4 (one in ten thousand), IxlO"7 (one in ten million),
etc.  EPA has used a range of lxlO~4 to 1x10""^ in evaluating


* Specific TCL analysis is available in the RI report.A brief
  summary of the TCL detections are listed on Table 1.

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                             -9-


risk assessment decisions.  The level of 1x10-6 '(one in a mil-
lion) has often been used by regulatory agencies as a bench
mark.  In the case of chemicals exhibiting non-carcinogenic
effects, exposures and associated risks are expressed as a
ratio.  This ratio, which is referred to as the Hazard Index,
is calculated by dividing a potential predicted quantity of a
chemical that a person could be exposed to, divided by the
amount of that chemical that an individual can be exposed to
without being subject to any adverse health effects.  A hazard.
index less than one indicates that no adverse health affects
are expected.

Table 3 shows risks and hazard indices associated with organic
contaminants and Table 4 shows risks associated with inorganic
contaminants detected in the ground water at the Ewan site.  These
values represent potential future risks that would be associated
with the migration of contaminated ground water to the site boundary
(92 meters) and the nearest off-site presently existing drinking
water well (920 meters).  Currently, the EPA has not identified
any residents who are using the contaminated ground water.

The public health and environmental assessment for the Evan site
indicates that there are no current threats to the public health
or local wildlife populations.  Table 5 summarizes potential
future inpacts to potable ground water supplies.  The second
operable unit for this.site will .incorporate these findings in
order to fully address future ground water remediation.
           •
EPA ENFORCEMENT ACTIVITIES .

EPA conducted an investigation to identify potentially respon-
sible parties for the Ewan Property site.  Under Section 107 of
CERCLA, as amended, responsible parties may include owners; or
operators of sites as well as parties who generated the hazardous
substance at the site or were involved in the transport, treat-
ment or disposal of them.  As a result of EPA's investigation,
six potentially responsible parties were notified of their
potential liability under Section 107 of CERCLA, as amended by
SARA.  One of the six parties has expressed a willingness to
participate in the corrective action for the site and may enter
negotiations with EPA in the near future to perform the first
operable unit for remediation of the site.

EPA also intends to notify other potentially responsible parties
of their potential liability with respect to the selected remedy
described in the ROD.  In the event that potentially responsible
parties do not voluntarily agree to perform or finance the clean-
up, EPA is prepared to perform the first operable unit remedial
action using CERCLA funds and may use its enforcement authority
to recover its response costs from any or all of the potentially
responsible parties which have been identified to date.

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                             -10-


COMMUNITY RELATIONS

A Community Relations Plan for the Ewan Property was finalized
in April 1985.  This document lists contacts and interested
parties throughout the government and local community.  It also
establishes communication pathways to ensure timely dissemination
of pertinent information.

EBASCO finalized the work plan for the RI/FS in December 1987
and placed this document at one local information repository
established for the site.  A public meeting was held in May
1986 to discuss the work plan and to inform the public about
the Superfund program and the history and status of the site.

Upon completion of the RI, and the FS and Proposed Remedial
Action Plan (PRAP) for the first operable unit, EPA disseminated
these documents to the local repository.  Public notices were
mailed out to local residents and officals on July 31, 1988 in-
dicating the initiation of the public comment period.  The public
comment period extended until September 12, 1988.  During this
period, a public meeting was held on August 18, 1988 to discuss
the RI, Operable Unit One FS, and the Operable Unit One PRAP.

SCOPE AND ROLE OF OPERABLE UNIT ONE

The scope of the first operable unit remedial action at the Ewan
Property will address the buried drums and heavily contaminated
materials (source materials).  EBASCO has estimated the volume
of the source materials to be a maximum of 4,500 CY.  This oper-
able unit is an interim remedy designed to control a majority
of the source materials.  it is not the intention of this first
operable unit to remediate the site to chemical specific con-
centrations which would allow the site to be deleted from the
NPL.  Although the source material will be mitigated during the
initial phase of the remediation, the remaining site contaminants
would-continue to pose a threat to the underlying aquifer which
is classified as GW-1.  EBASCO has further estimated that an
additional 29,500 CY of lesser contaminated soils exist at the
site.  These lesser contaminated soils and the contaminated ground
water plume will be remediated during a subsequent operable unit.

FEASIBILITY STUDY

This FS was developed for the first operable unit of remediation
at the Ewan Property site.  The subsequent FS will address the
remediation of the lesser contaminated soils and ground water.

This section of the ROD describes the remedial alternatives that
were developed utilizing suitable remedial technologies which
are required by SARA.  The candidate remedial technologies
(thermal destruction, solidification/fixation, excavation and

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                              -11-


removal, and encapsulation) were screened based upon their
applicability to site-specific circumstances, ability to reduce
contaminant mobility, toxicity or volume, general effectiveness,
and technical and administrative feasibility.  The containment
option was shown not to be effective due to the site geology.

The remedial alternatives developed were created from those
remedial technologies which survived the preliminary screening.
SARA mandates that, to the fullest extent practicable, EPA choose
remedial alternatives that utilize permanent solutions and treat-
ment as the principal element.  The contaminants detected in
the bulk, soil and ground water media indicate that the source
materials are largely organic which are appropriate for thermal
destruction.  Therefore, the three formulated remedial altern-
atives are:

        Remedial Alternative 1: No Action

        Remedial Alternative 2: Excavation and Off-Site Thermal
                                Destruction of the Waste and/or
                                Treatment of the Waste

        Remedial Alternative 3: Excavation and On-Site Thermal
                                Destruction of the Waste and/or
                                Treatment of the Waste

Description of Remedial Alternatives

Three remedial alternatives were evaluated for the first oper-
able unit of the Ewan Property site remedial action.  These
remedial alternatives are described below:

Remedial Alternative 1; No Action

The No Action remedial alternative would require the coordination
of the EPA, NJDEP, and local authorities to reduce public and
environmental impacts posed by the site contamination.

Specific site related activities would include quarterly ground
water sampling and analysis of site monitoring wells for the
first year of implementation.  In the following years, ground
water sampling frequency would be reduced to semi-annual events.
For each successive five year period, new monitoring wells would
be installed down-gradient of the contaminated ground water
plume.  Each five year period after commencement would allow EPA
the opportunity to re-evaluate the No Action alternative.,  After
approximately fifteen years of initiation,"domestic wells south
of Area A will be included in the sampling program.  This samp-
ling would continue indefinitely.  The program would be designed
to predict and quantify the ground water contaminant plume.  As
domestic wells become contaminated, further studies would be
•conducted to determine programs by which the residents could be
supplied with alternate potable water.

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                              -12-
Area A would be permanently isolated via security fences and
alarms.  This area would definitely be "off limits" to unauth-
orized personnel for an indefinite period.  Regular security
patrols would inspect the area to protect it from damage or
trespassers.

Area A and the properties south of Area A would have deed and
ground water usage restrictions placed upon them.  As the contami-
nated ground water plume approached domestic wells, ground water
usage would be stopped.  Development over the existing or pre-
dicted ground water plume may need to be restricted.

Remedial Alternative 2; Excavation and Off-Site Thermal
Destruction of Waste and/or Treatment of Waste

Based upon chemical data illustrated in the RI, thermal destruc-
tion of the source material appears to provide adequate remedial
results.  EBASCO has determined that the organic contaminants
detected at the Ewan Property are appropriate for thermal des-
truction.  The overall EPA approach to remediating the Ewan
Property is to remove the source of contamination during
Operable Unit One, then mitigate the lesser contaminated soils
and ground water during Operable Unit Two.  As previously stated,
the source materials are the 4,500 CY of drummed, bulk waste
and heavily contaminated materials within Area A.

The initial phase of Remedial Alternative 2 is to provide se-
curity for Area A.  This would be created by the installation
of a standard security fence around Area A.  A portion of land
would be prepared for decontamination, and temporary waste stor-
age and characterization.  The unpaved roadway between Tuckerton
Road and Area A would be upgraded to accommodate heavy vehicle
traffic.  Area A would be cleared of vegetation.

Once the storage/characterization area, security fence, decontam-
ination area, and roadways are completed, the excavation of the
buried waste in Area A will commence.  Various excavation equip-
ment will be used to extract the randomly oriented drums and
waste.  Continuous air monitoring will be conducted within the
excavation area and at the perimeter of the Area A security
fence.  If the air monitoring program indicates concern, a con-
tingency plan will be enacted to protect the public and environ-
ment.  The air monitoring program will also be used to determine
the most effective protection for the remedial workers.  A con-
tingency plan would also be enacted if spillage from excavated
waste were to occur.  Heavily contaminated materials surrounding
the waste will also be excavated and stored on-site prior to
potential off-site disposal.

The waste would then be transported to the finished storage/
characterization area.  At this point, the waste would be sam-
pled for characterization parameters.  Waste which is determined
to be appropriate for thermal destruction will be segregated
from waste which is not appropriate for thermal destruction.

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                              -13-
The waste which is appropriate for thermal destruction will be
loaded onto trucks and transported to a licensed off-site thermal
destruction facility.  Waste which is not appropriate for thermal
destruction will be analyzed and stored on-site until the most
appropriate disposal or treatment method is identified and
enacted.

The capacity of off-site thermal destruction units remains a
limiting factor for implementation of this remedial altern-
ative.  Delays may be encountered in transporting the material
to an off-site thermal destruction facility if sufficient
capacity does not exist.

Those materials which do not demonstrate heavy contamination
and contaminated ground water will not be remediated under this
phase of cleanup.  EBASCO-has determined that the contaminants
detected in the bulk materials, soil and ground water will be
appropriate for thermal destruction.  However, it is possible
that a small fraction of the source material would not be appro-
priate for thermal destruction.  Those materials will be addressed
via the most appropriate treatment or disposal method identified.

Remedial Alternative 3; Excavation and On-Site Thermal Destruction
of Waste and/or Treatment of Waste
                                               »
This alternative is similar to Remedial Alternative 2, in that.
the buried waste and heavily contaminated materials will be ex-  •
cavated and stored on-site for characterization.  .The conceptual
plans are further explained in the description of Remedial
Alternative 2.

The exception to Remedial Alternative 2 is that a separate area
must be developed for the on-site thermal destruction unit.
The on-site thermal destruction unit itself would be installed
on-site in a secured area of the site.  This thermal destruction
unit will be fitted with "state-of-the-art" air pollution and
combustion control equipment.  The emissions from the thermal
destruction unit will be constantly monitored.  Waste which is
characterized as not appropriate for thermal destruction will
be further analyzed to determine the most appropriate disposal
or treatment method (see Remedial Alternative 2).

Limitations for this remedial alternative include mobile thermal
destruction unit availability, EPA/NJDEP approval/ and community
acceptance.

Those materials which do not demonstrate heavy contamination
and contaminated ground water will not be mitigated until the
conclusion of the remedial action for Operable Unit Two.  Ground
water monitoring will continue until the conclusion of Operable
Unit Two.

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                              -14-
First Operable Unit Remedial Alternative Evaluation

Nine criteria were utilized to evaluate the three remedial al-
ternatives for the first operable unit.  Listed below are the
nine criteria and a brief explanation of each:

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

   Remedial Alternative 1; No action provides limited protection
   of the public and the environment by indicating the movement
   of the ground water contaminant plume.  This remedial altern-
   ative does not address mitigation of the source or the
   ground water.

   Remedial Alternatives 2 and 3; Both Excavation and Off-Site
   and On-Site Thermal Destruction of Waste and/or Treatment of
   Waste address the ultimate treatment of the source materials.
   During the operation of either remedial alternative, site
   perimeter air monitoring and ground water monitoring would.
   be performed.  If volatilization, spillage,  or emissions
   indicates concern, contingency plans would be implemented.
   Alternative 3 will incorporate extensive thermal destruction
   unit emissions monitoring.

   Compliance with Applicable or Relevant and Appropriate
   Requirements of Federal and State of New Jersey Regulations;
   This criterion addresses whether or not a remedy will meet
   all of the applicable or relevant and appropriate require-
   ments of other environmental statutes and/or provide grounds
   for invoking a waiver.

   Both Excavation and Off-Site and On-Site Thermal Destruction
   of Waste and/or Treatment of Waste do not address the final
   site concentrations which will be required to delete the site
   from the National Priorities List.  Therefore, all contaminant
   specific ARARs would not be attained until the second phase
   of the remedial action is completed.  This second operable
   unit will remediate the site to specific ARAR concentrations.
   ARARs specific to enactment of the source control action
   will be complied with during all phases.

   Long-term Effectiveness and Permanence;  This criterion refers
   to the ability of the remedy to maintain reliable protection
   of human health and the environment over time once cleanup
   goals have been met.

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                           -15-


Remedial Alternative 1; No Action does not remediate the site
to a condition where the source is effectively removed or
treated.

Remedial Alternatives 2 and 3; Both Excavation and Off-Site
arid On-Site Thermal Destruction and/or Treatment of Waste
would contribute significantly to the long-term effectiveness
and permanence that will ultimately be achieved by the final
remedy for the Ewan Property, in that the potential hazard
to be managed is dramatically reduced.

Reduction of Mobility, Toxicity and/or Volume (MTV); This
criterion addresses the anticipated performance of the
treatment technologies that a remedy may employ.

Remedial Alternative 1; No Action does not address the reduc-
tion of MTV.

Remedial Alternatives 2 and 3; Both Excavation and Off-Site
and On-Site Thermal Destruction of Waste and/or Treatment of
Waste reduce MTV via thermal destruction of the organic
content of the source.

Short-term Effectiveness; This criterion involves the period
of time needed to achieve protection and any adverse impacts
on human health and the environment that may be posed during
the construction and implementation period until cleanup goals
are achieved.

Remedial Alternative 1; No Action achieves short-term protect-
ion only through monitoring of the contaminated ground water
and enactment of local administrative controls.

Remedial Alternatives 2 and 3; Both Excavation and Off-Site
and On-Site Thermal Destruction of Waste and/or Treatment of
Waste provide for site perimeter air monitoring and ground
water monitoring.  If either program indicates concern, con-
tingency plans will be implemented to protect both the public
and the environment.  Remedial Alternative 2 will attempt to
minimize impacts caused by off-site transport of waste and
does not present the potential impacts associated with the
on-site thermal destruction unit of Remedial Alternative 3.
Also, Remedial Alternative 2 can be employed more expeditious-
ly than Remedial Alternative 3.  As a result, the potential
impacts of Remedial Alternative 2 will be present for a
shorter period of time.  Remedial Alternative 3 will incorp-
orate -thermal destruction unit emissions monitoring.

Implementability; This criterion examines the technical and
administrative feasibility of a remedy, including the avail-
ability of materials and services needed to implement the
chosen solution.

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                           -16-
Remedial Alternative 1; No Action is technically feasible
through the use of present analytical monitoring procedures  .
and the development of local administrative jurisdictions
implementing deed and water well restrictions.

Remedial Alternatives 2 and 3; Both Excavation and Off-Site
and On-Site Thermal Destruction of Waste and/or Treatment of
Waste are implementable based upon tried and proven examples
at other hazardous waste sites.

Cost; This criterion includes capital and operation and
maintenance costs.  Table 6 provides a summary of the three
remedial alternatives.

Remedial Alternative 1; No Action is the least expensive of
the three remedial alternatives evaluated.  Costs for this
alternative are related to monitoring of the ground water
contamination.  The annual monitoring costs are $22,000 per
year for an indefinite period, creating a present worth cost
of $353,000.

Remedial Alternative 2; Excavation and Off-Site Thermal
Destruction of Waste and/or Treatment of Waste involves a
capital cost of $20,800,000.   The ground water monitoring
costs which are expected until completion Gf the final phase
of remedial action are $22,000 per year, creating a present
worth cost of $2-1,153,000.

Remedial Alternative 3; .Excavation and On-Site Thermal
Destruction of Waste.and/or Treatment of Waste involves a
capital cost of $18,964,000.   As with the previous two
remedial alternatives, the ground water monitoring will
continue until the completion of the final phase of remedial
action for $22,000 per year,  creating a present worth cost
of $19,317,000.

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

Remedial Alternative 1; Based upon EPA and NJDEP discussions,
No Action is the least favored remedial alternative.

Remedial Alternatives 2 and 3; Excavation and Off-Site and
On-Site Thermal Destruction of Waste and/or Treatment of
Waste were considered by EPA and NJDEP as the most favorable
alternatives for the destruction of the organic materials
anticipated at the Ewan Property.

Community Acceptance;  This criterion indicates whether, based
upon its review of the RI/FS and the Proposed Plan, the commun-
ity concurs with,  opposes, or has no comment on the selected
remedy.

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                              -17-
   Remedial Alternative 1; The community demonstrated opposition
   to the No Action alternative.

   Remedial Alternative 2; Excavation and Off-Site Thermal Des-
   truction of Waste and/or Treatment of Waste was widely accep-
   ted by the community.

   Remedial Alternative 3; The community demonstrated opposition
   to the Excavation and On-Site Thermal Destruction of Waste
   and/or Treatment of Waste.

EPA considered the No Action alternative as the least favored
alternative.  It is EPA's judgement that No Action does not
provide adequate protection of public health or the environment
and, therefore, does not fulfill the requirements set forth in
SARA.-

Remedial Alternatives 2 and 3 were considered to be equally
protective of the public and the environment.  These two altern-
atives differed somewhat in remedial implementation costs.  An
approximate $1.5 million difference exists when comparing
incineration of the estimated maximum source volume of 4,500
cubic yards.  The Shamong Township community presented verbal
endorsement of the selection of off-site thermal destruction.

The following section pertains to the specific evaluation of
the selected remedial alternative.

THE SELECTED REMEDY FOR OPERABLE UNIT ONE

After careful review and evaluation of the remedial alternatives
presented in the feasibility study, EPA presented Remedial
Alternative 2, Excavation and Off-Site Thermal Destruction of
Waste and/or Treatment of Waste, to the public as the preferred
remedy for the first phase of remedial action at the Ewan Prop-
erty site.

EPA has determined that mitigation of the source is necessary
prior to attempting to remediate the contaminated ground water.
The data in the RI suggests that the majority of the source
materials and heavily contaminated materials are appropriate for
thermal destruction.  SARA prefers the utilization of permanent
remedies wherever possible.  Thermal destruction is a proven
remedial treatment which is considered a permanent remedy.

The input received during the public comment period, consisting
primarily of questions and statements transmitted at the public
meeting held August 18, 1988, and Chrysler Corporation comments
of September 12, 1988, are presented in the attached Responsive-
ness Summary.  The public and Chrysler Corporation comments were
generally in agreement with EPA's preferred remedial approach.
Accordingly, the preferred alternative was selected by EPA as
the selected remedy for Operable Unit One.

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                             -18-


The costs associated with the implementation of the selected
remedy are summarized on Table 7.  The specific cost itemization
is located in the Final FS report, Appendix A.   The four major
components of the selected remedy are listed as follows:

 - Site Preparation

   Costs associated with the site preparation include:  upgrading
   of roadways within the Ewan Property to allow for heavy vehicle
   access; clearing of vegetation within Area A; construction
   of the staging/characterization/storage and decontamination
   areas; and security fence installation.  The cost for this
   item of the selected remedy is $875,187.

 - Waste Area

   Activities conducted in association with the waste area are:
   excavation of the buried drums and heavily contaminated ma-
   terials; hauling'waste from Area A to the staging/character-
   ization/storage area; ground water level controls; waste
   material/drum handling; and decontamination of the staging/
   characterization/storage area.  The total cost for this item
   of the remedy is $1,678,278.

 - Off-Site Thermal Destruction

   The activities associated with off-site thermal destruction
   are:  waste characterization;, waste hauling;  and off-site
   thermal destruction costs.   This portion of the remedy is
   estimated to be $7,910,520.

 - Operational Costs

   These operational costs associated with the first operable
   unit are subdivided into ten classifications (see Table 7).
   Increased health and safety working levels include upgrade
   from standard field clothing to respiratory and dermal
   protection.  Burden refers to the remedial contractors'
   field labor costs (i.e., Workman's Compensation Insurance,
   workers benefits, etc.) as well as various insurance cover-
   ages (e.g., builders insurance).  Labor costs include admin-
   istrative and overhead costs.   Materials refer to remedial
   action related purchases.   Subcontracting costs are  self-
   explanatory.  Indirect costs are associated with remedial
   action support activities (i.e., security costs, first aid,
   communications, utilities,  travel, field office use, etc.).
   Profit costs as well as health and safety monitoring are
   self-explanatory.  Contingency costs allow for a 15  percent
   cost contingency.  The engineering cost pertains to  the RD.
   The total cost estimate associated with operational  costs is
   $10,336,139.

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                              -19-


The cost of $20,800,124 is the summation of the annual or im-
mediate implementation costs.  The total present worth cost for
this alternative is $21,153,000.

Statutory Determinations

Pursuant to CERCLA, as amended by SARA, EPA must select remedies
that: are protective of human health and the environment; attain
ARARs; are cost-effective; utilize permanent solutions and alternate
treatment technologies or resource recovery technologies to the
maximum extent practicable; and provide preference for treatment
as a principal element.

The following sections describe how the selected remedy applies
to each of the aforementioned statutory determinations.

Protectiveness

The selected site remedy provides significant protection of
human health and the environment by effectively mitigating the
source of contamination at the Ewan Property site.  The principal
threat involves the ingestion of contaminated ground water.  The
selected remedy will include the removal of the waste and heav-
ily contaminated materials appropriate for thermal destruction
from the site.  Waste and heavily contaminated materials which
are not appropriate for this technology will be further tested
to determine their most appropriate disposal or treatment.  These
materials are the "source" contributing to the ground water con-
tamination underlying the site.  The remediation of the source
will greatly reduce the potential for the expansion of the ground
water plume.  The remedial alternatives which address the ground
water contamination and lesser contaminated soils will be
detailed in a separate feasibility study.

A component of the selected remedy includes the off-site thermal
destruction of the source materials.  Thermal destruction is
considered an alternative technology which can effectively reduce
the mobility, toxicity, or volume of the site source material
contaminants.

Additional protection is provided from the remedial action air
and ground water monitoring programs.  Contingency plans will be
enacted if either program indicates concern.

Compliance with Applicable or Relevant and Appropriate Requirements

Applicable or relevant and appropriate requirements (ARARs) relate
to those Federal and State laws, regulations and policies which
must be considered in evaluating remedial alternatives.  ARARs
can be classified as: action specific, chemical specific and
location specific.

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                              -20-


The first operable unit for the Ewan Property is only part of a
total remedial action which when completed, will attain a level
or standard of control at least equivalent to the legally
binding ARARs for the site.  Chemical specific ARARs for soils
and ground water will, therefore, not be achieved by this
first operable unit since it is not intended to mitigate the
site to final cleanup standards.  This first operable unit
addresses source remediation; final cleanup criteria will be •
•addressed in Operable Unit Two.  The second operable unit
involves the remediation of the contaminated ground water and
if needed, lesser contaminated soils.

Action specific ARARs pertain to meeting the requirements for the
enactment of the remedial action.  The appropriate requirements
of the Resource Conservation and Recovery Act (RCRA) and New
Jersey hazardous waste regulations will be followed during the
remedial action.  All staging and testing areas constructed
on-site will comply with the current RCRA (40 CFR Part 264.14,
40 CFR Part 264.17, 40 CFR Part 264.31, 40 CFR Part 264.33,
40 CFR Part 264.114, 40 CFR Part 264.193, et al.) and New
Jersey hazardous waste standards.  Furthermore, the remedy will
contain provisions for adequately storing all wastes, prior to
transport off-site, so as to minimize the potential release of
hazardous waste or its constituents into the environment.

Based upon the Land Disposal Restriction (LDR) provisions, RCRA
hazardous waste in accordance with-40 CFR Part 261 (i.e., hazardous
waste is defined as listed or characteristic) which is excavated,
treated and then disposed of constitutes placement and, therefore,
the LDR requirements are potentially ARARs.

To determine whether a waste is a listed RCRA hazardous waste,
it is necessary to know the source or the use of the waste.
When it is not possible to make an affirmative determination
that the wastes are listed RCRA hazardous wastes, RCRA require-
ments are not applicable to CERCLA actions, but may be relevant
and appropriate if the CERCLA action involves treatment, storage
or disposal and if the wastes are similar or identical to RCRA
hazardous wastes.  Because it has not been determined with
certainty that the wastes at the Ewan Property site are RCRA
listed hazardous wastes, EPA has determined that the RCRA LDR
requirements are not applicable.

Although the LDR requirements are not applicable in terms of a
listed hazardous waste, they may be applicable if the waste is
identified as RCRA characteristic hazardous waste.  A RCRA
characteristic hazardous waste is identified as a waste which
exhibits the characteristics of either ignitability, corrosivity,
reactivity or toxicity (using the extraction procedure (EP)).

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                              -21-
The waste at the Ewan Property site did not appear to exhibit
RCRA hazardous waste characteristics.  Furthermore/ virtually
all of the contaminants would be destroyed after treatment.  As
a result, the LDR requirements are also not applicable.

EPA has undertaken an LDR rulemaking that appies to soil and
debris which extends the time period for disposing of these
materials in landfill facilities.  Therefore, LDR is not
considered relevant and appropriate at this time.

Finally, all wastes' removed from the site, including the decon-
tamination fluids, must be taken to a permitted RCRA facility
which must be in compliance with EPA's Off-Site Policy.  The
transportation of these wastes will comply with Department of
Transportation hazardous waste regulations.

Location specific ARARs pertain to the potential impacts of the
remedial actions on specific land classifications.  The selected
remedy may have an impact on wetlands located within the vicinity
of the site.  Additional information will be collected during
and/or prior to the remedial design to evaluate this potential
impact.  If this additional information indicates that the
selected remedy may, in fact, have an impact on a wetland, a
wetlands assessment will then be conducted to ensure compliance
with Executive Order 11990 before the remedial action is
initiated.  Other potential impacts upon other nearby land
classifications will also be .evaluated during and/or prior to
the remedial design.  If these potential impacts are identified,
additional potential ARAR sources will be complied with.  The
ARAR sources are Executive Order 11998 (Floodplain Management),
the Endangered Species Act, the Farmland Protection Act, and
the Wild and Scenic Rivers Act.

The first operable unit for the Ewan Property is not designed
to remediate the contaminant concentrations to final site
conditions, but is intended to mitigate the source of contami-
nation.  This operable unit will not clean up the site to a
degree that will allow its deletion from the National Priorities
List.  The final site cleanup will be achieved at the conclusion
of Operable Unit Two.  This first operable unit will remove the
source in order to reduce contaminant leachate migrating into
the ground water.

Cost-Effectiveness

As previously stated, the selected remedy is cost-effective
based upon the assumption that the 4,500 CY estimate is a.
maximum value.

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                               -22-
Cost separation between Remedial Alternatives 2 and 3 is $1.5
million.  As previously stated/ these values were generated
utilizing the estimated "worst case" scenerio of 4,500 CY.  It
is EPA's judgement that the costs for this remedy are proportion-
ate to the level of protection provided and that this level is
afforded via thermal destruction of the majority of the source
materials.

Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Practicable

The selected remedy is a permanent solution for the source mate-
rials present at the Ewan Property.  A majority of the source
has been determined to be appropriate for thermal destruction.
Thermal destruction is a proven permanent solution for the reme-
diation of many organic substances.  Source materials which are
not appropriate for thermal destruction will be further analyzed
to determine permanent disposal or treatment methods.  Implemen-
tation of this remedy is the utilization of a permanent solution
to the maximum extent practicable for this site.

Preference for Treatment as a Principal Element

Thermal destruction of the source materials is the principal
element of the selected remedy.  EPA has been assured that the
majority of the source materials are appropriate for thermal
destruction.  Source materials which are not appropriate for
thermal destruction will be further analyzed to determine the
most appropriate disposal or treatment remedy.  Emphasis for
treatment of waste which is not appropriate for .thermal destruc-
tion will be applied after sufficient analysis has been performed.

-------
FIGURES

-------
                   APPROXIMATE EWAN
                   PROPERTY BOUNDARY
                                                   AREA

                                                 AREA'A
                                                                    RESIDENTIAL
                                                                    DEVELOPMENT
                                    SCALE IN FEET
iASE UAP IS A PORTION OF THE U.S.C.S. SOUTHWEST INDIAN MILLS, NJ QUADRANGLE (7.3 MINUTE SERIES, 1957,
'HOTOINSPECTED 1972, CONTOUR INTERVAL 10 FEET). EWAN PROPERTY LOCATION IS APPROXIMATE.
                 SITE LOCATION  MAP
      EWAN  PROPERTY  SITE. SHAMONG TWR. NJ
(3ORFORATXDN

-------
NOTE: LOT NUMBERS AND PROPERTY LINES TAKEN FROM SHAMONG TWP TAX MAP NO. 5, BLOCKS 23 AND 23F.


                   APPROXIMATE TRACT ARRANGEMENT
                 EWAN PROPERTY SITE. SHAMONG TWR. NJ
 FIGURE   2
IMUS

-------
                                                                  2KM.
                                                                  RADIUS
                                                                  (1.24 Ml.)
          LAND USE CATEGORIES
11  Residential
12  Commercial
21  Cropland and Pasture
24  Farmsteads  and Farm-Related Buildings
32  Shrub-Brush Rangeland
41  Deciduous Forest
S3  Han-Hade Reservoirs and Impoundments
61  Forested Wetlands
62  Non-Forested Wetlands
75  Extraction
768 Unidentifiable
SOURCE' EPIC, 1964  TS-PIC-84IS5
                                                                FIGURE  3
               LAND USE  CATEGORIES
      EWAN PROPERTY SITE, SHAMONG TWP.. NJ     IH-
                  IMUS
                  CORPORATION

-------
_^  -
O
                   LEGEND
     AREA Of MAGNETIC ANOMALT
     TEST PIT

     SOIL BORMG

     VISUAL OBSERVATION
     TEST PIT

     SOIL BOHINO
                      HMH LCVf LS V TO. COUfOUNM «T(C •
                     " no on CVBCMCC or DRUMS oejtuvto
_ COMFOUNM ocncit o «r \am icvti.it
'no VIHM.C CVIMNCC or onuut
     NJDCP MOMTQRMO WELL

     ESTIMATED EXTENT or CONTAMINATED AREA
                                                              \
                                                                                                                                              FIGURE
                               APPROXIMATE  EXTENT OF CONTAMINATED AREA
                                   EWAN PROPERTY SITE. SHAMONG TWR. NJ
                                                                                                                                             CORPORATION

-------
       LEGEND
    CSTMuno IONC or CONTAMINATION
   i e*sto ON nx ORCAMC* ocucuo
    M CnOlMMlTtN SAMPLf S
AH *4v

*• o*9»A<
                ! *"fA| Ippm]
                   TCL ORGANIC CONSTITUENTS DETECTED IN MONITORING WELLS
                            EWAN PROPERTY  SITE.SHAMON6 TWP.. NJ
lUtlMIIII
                                                                                                                                  FIGURE 5
                        IMUS
                                                                                                                                 CORPORATOR

-------
                                    TUOY AREA  'B*
                                                                                               STUDY  AREA "A
                                                IP-IS
                                             ip-to-oot •
••sot SAMPLES fp-so-ooa
AMDCP-SO-OIIUXATCD ISO
MOUTH (we ncuftc <-«)
                                                                                                                           	EP-SO-014
                                                                                                                             EP-SO-004
          LEGEND
           STAFF 6AUGC
           EIlSTwe MJOEP MOMTOMMG WLL
  SBC II    EllSIMC MOMTORWa WELL-
               ICtTEm mOCAT'E
           SCMEENEO MTENVA4.:
            TC i TOP Of OQHAMSCT FOMUTION
            •c • tor TOM or COHANST* roRMATiON
            TK> TOP Or IMWWOOO roMUATON
                   PCX SAMPLES SENT TO
                   f M CLP IAOOUTCWT
          SOR. SAMPLE I «* TCL AMALTSCS
                                                     M0tt> SAMPLI LOCATIONS A«C APPKOlMATf
                                       SUMMARY OF Rl SAMPLE LOCATIONS
                                         (EXCLUDING DOMESTIC  WELLS)
                                    EWAN PROPERTY SITE. SHAMONG TWP., NJ
tCAUMMIt
                            FIGURE  6
                           IMUS
                                                                                                                                                     CORPORATOR

-------
                                                      MAP 8 » ran an of rtf usos MOKNMLLS.NJ
                                                    OUWMMCU (»» HINUIf StRHl. Ittf, PMOIt»NS«C?tO
                                                    I9»l COHIOUH WTCHVAL UN FKI
L ^x-tE
                                .'.•:-•-41  It:
                              MUMjfTUL KVOOPMtNT
TCL INORGANIC AND ORGANIC CONSTITUENTS DETECTED
            IN  DOMESTIC WELLS
     EWAN PROPERTY SITE. SHAMONG TWR. NJ
                                                 icon mini
                                                                     FIGURE  7
                                                                    IMUS
                                                                        CORPORATOR

-------
SURFACE WATER 6 SEDIMENT SAMPLE LOCATIONS

    EWAN PROPERTY SITE. SHAMONG TWP..NJ
                                                         (Oil M Mil
 FIGURE 8



IMUS
CX3PPGRAPOK

-------
TABLES

-------
TABLE 1
   TYPE: EUAN PROPERT* - IEST PITS

                        I  OF POSITIVE
COMPOUND                 DETECTIONS
                                               MINIMUM
                                           DETECTED CONC.
    MAXIMUM
DETECTED CONC.
                                                                                AVERAGE
2-BUTANONE
4-METHYL-2-PENTANONE
ETHYLBENZENE
TOTAL XYLENES
1,1-DICHLUROETHANE
TETKACHLOROETHENE
TRANS- 1 ,2-DICHLOROETHENE
BIS(2-ETHYLHEXYL)PHTHALATE
DI-N-OCTYL PHTHALATE
DI-N-BUTYL PHTHALATE
BUTYL BENZYL PHTHALATE
NAPHTHALENE
2-METHYLNAPHTHALENE
PHENANTHRENE
4, 4 '-DDT
4, 4 '-DDE
ALUMINUM
ARSENIC
BARIUM
BERYLLIUM
TALCIUM
CHROMIUM
f.OBALT
IJOPPER
IRON
LEAH
MAGNESIUM
MANGANESt
MERCURY
N1CKLL
POTASSIUM
SILVER
SOUIUH
THALLIUM
VANADIUM
7i^-;
:iH
1
4
3
4
3
I
2
I
• •
15
1
%*
2
1
w
•I
29
15
15
5
22
29
4
15
30
29
29
26
21
0
21
•
16
1
24
26
o
580.00
3.00
2.00
8.00
2.00
4.00
13.00
65.00
10.00
3.00
82.00
3.00
3700.00
77.00
8.50
5.60
1650.00
1.10
13.00
1.20
72.00
3.90
22.00
4.50
19.00
0.70
51.00
2.30
0,14
4.40
115.00
1.10
228.00
1.80
4.50
2.90
4.2U
580.00
21.00
6.00
30,00
2.00
4.00
14.00
65.00
1400.00
170.00
82.00
87.00
11000.00
77.00
36.00
10.00
373000.00
83.00
760.00
9,00
13000.00
512.00
55.00
4920.00
246000.00
58.00
24100.00
484.00
2,00
165.00
13120.00
1.10
6210.00
l.SO
458.00
187.00
5.95
580.00
9.25
4.33
19.25
2.00
4.00
13.50
65.00
473.33
74.13
82.00
31.00
7350.00
77.00
22.25
?.BO
:i02B8.2B
17.29
177.40
4.04
726.05
48.67
14.00
365.54
39236.53
14.56
1986.38
79.75
0,42
43.86
209V. 38
1.10
2427.56
1. 80
90.22
85.51
5.02

-------
          TABLE  1
                 TYPE:  EUAN PROPERTY  -  SURFACE  WATERS
             COHPOUND
I OF POSITIVE
 [•ETECTIONS
    MINIMUM
DETECTED CONC.
    MAXIHUH
DETECTED CONC.
AVERAGE
DI-N-6UTYL PHTHALATE
D1ETHYL PHTHALATE
ALUMINUM
KAR1UH
CALCIUM
COPPER
IRON
LEnD
MAGNESIUM
MANGANESE
MERCURY
POTASSIUM
SILVER
SODIUM
ZINC
pH
                     6.00
                     7.00
                   650.00
                    52.00
                  1440.00
                    25.00
                  3510.00
                     3.00
                   583.00
                    21.00
                     0.40
                   508.00
                     5.00
                  1030.00
                    «2.00
                     3.60
19.00
7.00
5680.00
52.00
3650.00
25.00
3640.00
13.80
2080.00
63.00
0.40
905.00
5.00
4360.00
117.00
5.60
9.50
7.00
3000.00
52.00
2162.50
25.00
3577.50
8.6b
1008.50
34.00
0.40
659.33
5.00
2705.00
66.00
4.73

-------
          TABLE 1

          '.AMPLE TfPE: EUAN PROPERTY - SEDIMENTS
              COHPOUNli
I OF POSITIVE
 DETECTIONS
    MINIMUM
HETECTEH LONG.
    MAXIMUM
DETECTED CONC.
                                                                                           AVERAGE
ACETONE
TOLUENE
Mr1-TRICHLOROETHANE
M-DICHLOROETHENE
CARBON TETRACHLORIDE
LHLOROFORh
METHYLENE CHLORIDE
BENZOIC ACID
DE1A-KHC
4,4'-DDT
4,4'-DDD
4,4'-DDE
DIELDRIN
ALUMINUM
BARIUM
CALCIUH
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
SODIUM
VANADIUM
ZINC
2
2
4
1
1
1
3
1
I
1
4
4
1
9
9
8
1
9
7
8
9
7
9
3
7
6
9
91.00
13.00
6.00
5.00
15.00
1.90
33.00
3400.00
11. 60
104.00
4.80
12.60
3.60
273.00
1.00
19.00
7.00
4.00
2.00
148.00
3.90
111.00
1.00
0.30
24.00
2.70
3.00
105.00
43.00
100.00
5.00
15.00
1.90
150.00
3400.00
11.60
104.80
85.70
29.50
3.60
6175.00
118.00
2449.00
7.00
27.00
33.00
6385.00
91.00
554.00
13.00
2.10
581.00
13.10
63.00
93.00
28.00
69.00
5.00
15.00
1.90
104.33
3400.00
11.60
104.80
33.30
17.67
3.60
3302.63
38.63
751.88
7.00
12.13
14.29
2256.00
44.88
292.00
7.00
1.47
237.86
7.68
29.75

-------
iABLK 1
SAMPLE TYPE: EUAN PROPERTY - MONITORING UELLS
    COMPOUND
I OF F'OSITIVE      MINIMUM
 DETECTIONS    DETECTED CONC.
    MAXIMUM
DETECTED CONC.
                                                                                 AVERAGE
ACETONE
2-BUTANONE
4-METHYL-2-PENTANONE
BENZENE
TOLUENE
ETHYLBENZENE
TOTAL XYLENES
1,1-DICHLOROETHANE
1,2-DICHLOROETHANE
TETRACHLOROETHENE
TRICHLOROETHENE
TRANS- 1 ,2-DICHLOROETHENE
CHLOROFORM
METHYLENE CHLORIDE
DIS ( 2-ETHYLHEXYL )PHTHALATE
DI-N-BUTYL PHTHALATE
BUTYL BENZYL PHTHALATE
ACENAPHTHENE
NAPHTHALENE
2-HETHYLNAPHTHALENE
PHENOL
4-METHYLPHENOL
2,4-DIMETHYLPHENOL
ALUMINUM
ARSENIC
BARIUM
CADMIUM
CALCIUM
CHROMIUM
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SILVER
.SODIUM
H f A JJ A Ti T r •' U
v* nrifli.ii u-n
w
ZINC
1
1
1
6
9
7
6
2
2
1
3
4
2










47
4
24
1
•JO
15
14
50
25
49
37
4
ft
27
2
50
9
*0
190.00
600.00
52.00
1.00
14.00
4.00
130.00
2.00
690.00
2.00
0.30
2.00
1.00
230.00
2.00
6.00
240.00
150.00
2.00
5300.00
47.00
950.00 '
15.00
57.00
11.00
54.00
9.50
277.00
8.00
22.00
37.00
3.00
222.00
11.00
0.20
20.00
497.00
5.10
1150.00
?4.00
il.oo
190.00
600.00
52.00
50.00
680.00
450.00
2800.00
2.00
1300.00
2.00
15.00
21.00
31.00
230.00
300.00
8.30
240.00
150.00
110.00
5300.00
47.00
950.00
15.00
98100.00
29.00
1800.00
8.50
26180.00
208.00
94.00
365000.00
292.00
3420.00
431.00
1.00
40.00
9790.00
8.00
20600.00
257.00
1100.00
190.00
600.00
52.00
V.67
245.22
135.14
595.00
2.00
995.00
2.00
7.10
11.50
16.00
230.00
87.50
7.15
240.00
150.00
38.00
5300.00
47.00
950.00
15.00
10484.57
20.25
183.38
S.50
2460.66
64.40
37.57
28284.22
10.29
935.00
66.94
0.55
27.00
2139.33
4.55
3698.12
12Q.33
1A4.44

-------
          TABLE 1

          SAHPLE TYFC:  EUAN PROPERTY - MONITORING UELLS
              rimc-mmr.                * °F F
-------
         TAfLE 1
         SAMPLE TYPE: EUAN PROPERTY - DOMESTIC UELLS
             COMPOUND
t OF POSITIVE
 DETECTIONS
    MINIMUM
DETECTED CONL.
    MAXIMUM
DETECTED CONC.
AVERAGE
BENZENE
BARIUM
CALCIUM
COPPER
IRON
HAGNESIUH
MANGANESE
NICKEL
POTASSIUM
SELENIUM
SODIUM
        2
        2
        9
       11
        1
        8
       11

       12
        t
1.00
64.00
440.00
6.70
560.00
970.00
3.10
25.00
378.00
3.30
050.00
1.00
78.00
43200.00
1170.00
560.00
14700.00
27.00
27.00
7290.00
4.00
31300.00
1.00
71.00
11097.50
155.45
560.00
4406.25
14.83
26.00
2301.42
3.65
18437.50

-------
         TABLE  1
         SAMPLE TYPE: EUAN PROPERTY - SOILF
             COMPOUND
I OF POSITIVE
 DETECTIONS
    MINIMUM
HETECTED CONC.
    MAXIMUM
DETECTED CONC.
AVERAGE
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SILVER
SODIUM
VAN A [i IUH
ZINC
CYANIDE
       47
       42
       35
       44
        1
        9
       21
        4
402.00
2.00
4.10
1.60
0.20
2.10
71.00
3.30
3.50
3.20
2.00
0.80
26797.00
56600.00
1420.00
72.00
0.20
17.00
1680.00
4.50
1270.00
31.00
450.00
3.40
5600.28
1366.36
222.20
11.24
0.20
5.74
362.05
3.87
239. 57
10.98
28.32
2.10

-------
SAMPLE TYPE: EUAN PROPERTY - SOILIJ
    COMPOUND
I OF POSIT IMP
 DETECTIONS
    MINIMUM
DETECTED CONC.
    MAXIMUM
DETECTED CONC.
AVERAGE

•KETONE
2-PUTANONt
2 HEXANONE
•l-riETHYL-2-FErlTANUNE
TOLUENE
ETHYLPENZENE
TOTAL XVLENES
1,1,1-TRICHLOROETKANE
TETKACHLOROETHENE
TRICHLUROETHENE
flEIHYLENE CHLOHIDE
KIS(2-ETHYLHEXYL)PHTHALATE
HI-W-OtTYL PHTHALATE
HI N- BUTYL PHTHALATE
HIETHYL PHTHALATE
HUTYL BENZYL PHTHALAFE
ACENAPHTHENE
ANTHRACENE
*ENZO< A) ANTHRACENE
PENZO
-------
                          TABLE 2
NJDEP AND REMEDIAL INVESTIGATION WASTE SAMPLE DATA  (pg/kq)
     EWAN PROPERTY SITE, SHAMONG TOWNSHIP, NEW JERSEY
Parameter
Orqanics
Methylene Chloride
Tetrachloroethene
Toluene
Benzene
o-Xylene
m-Xylene
p-Xylene
1 , 2-Dichloroethene
1 , 2-Dichloroethane
o-Dichlorobenzene
Ethylbenzene
Naphthalene
Phenanthrene/anthracene
Pyrene
Chrysene
Acenaphthylene
Benzo(a)anthracene/chrysene
Hexachlorobutadiene
Styrene
ES-1»

-
-
-
-
225
115
-
-
250
415
-
-
800
200
-
-
-
-
-
ES-21

825
100
295
11,800
408
5,763
2,685
145
-
-
2,630
1,585
-
-
-
-
14.000
-
-
ES-31

-
145
-
-
-
185
-
-
-
-
-
-
-
-
-
-
-
-
-
ES-41

-
-
285,000
30,600
26,300
43,100
17,100
-
-
415
-
400.000
227,000
-
-
385,000
-
980
6,800
WA-001*
(Test Pit 10)

8
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
WA-0022
(Test Pit 15)

22,000
270
-
-
980*
-
-
-
-
-
700
-
• -
-
-
-
-
-
-

-------
TABLE 2
NJDEP AND REMEDIAL INVESTIGATION
WASTE SAMPLE DATA
EWAN PROPERTY SITE, SHAMONG TOWNSHIP,  NSW JERSEY
PAGE TWO
Parameter
Orqanics - Continued
I, 2, 4 -Tri methyl benzene
1,3, 5-Tri methyl benzene
Phenol
4-Ni trophenol
sec-Butylbenzene
4-Chlorophenyl phenyl ether
o-Chlorotoluene
N-propyl benzene
bis( 2-ethylhexyl Jphthalate
Di-n-butylphthalate
Diethylphthalate
Inorganics
Antimony
Arsenic
Cadmium
Chromium (Total)
ES-ll

-
-
11,200
-
-
-
-
-
-
-
- •

-
-
1,990
29,400
ES-21

-
-
-
-
-
25,000
-
-
-
-
-

IBB
468
-
2,190
ES-3»

-
-
-
61,000
-
-
-
-
-
-
-

126
4,933
-
1,320
ES-41

20,100
8,300
-
-
385
-
3,300
3,200
300,000
190,000
205,080

-
50
1,920
-
WA-0012
(Test Pit 10)

-
-
-
-
-
-
-
-
-
-
-

-
-
-
-
WA-0022
(Test Pit 15)

-
-
-
-
-
-
-
-
-
-
-

-
-
-
-

-------
TABLE 2
NJDEP AND REMEDIAL INVESTIGATION
WASTE SAMPLE DATA
EWAN PROPERTY SITE,SIIAMONG TOWNSHIP, NEW JERSEY
PAGE THREE
Parameter
Inorganics - Continued
Copper
Lead
Mercury
Nickel
Selenium
Silver
Zinc
ES-ll

2,460
8,810
-
8,230
-
1,650
3,120
ES-21

-
-
46
993
-
-
9,360
ES-31

1,050
-
68
2,080
-
-
55,600
ES-41

10,6-00
3,490
-
7,100
134
1,220
135,000
WA-001*
(Test Pit 10)

-
-
-
-
-
-
-
WA-0022
(Test Pit 15)

-
-
-
- .
-
-
-
1 NJDEP samples,  July 6,  1983
2 Samples  collected during RI
* Total Xylenes

-------
                                                 TABLE 3
                              FUTURE HAZARD  INDICES AND CARCINOGENIC  RISKS
                        FOR  RECEPTOR EXPOSURE TO ORGANIC  GROUNDWATER CONTAMINATION
                             EWAN PROPERTY SITE', SHAMONG  TOWNSHIP, NEW JERSEY
Compound
Hethylethylkelone
Methyl isobutyl
lie tone
Benzene
Toluene
Ethy Ibenzene
Xylenes
1.2-Dichloroe thane
Tc ichloroethene
Tetrachloroethene
Chloroform
Hethylene Chloride
Bis(2-ethylhexyl)
phthalata
Total HI or Rich:
Ingestion Route
Hazard Index
92m
0.017
0.014

0.018
0.02S
1.8


7.5 x 10-«

0.052
1.7 • 10-3
1 .9
920m
7. 2 x 10-4
5. 2 x 10-4

4.0 x 10-4
4.0 x ID'4
0.031


1.6 x ID'5

2.0 x 10'N3
1.5 x 10-5
0.03
Carcinogenic Risk
92m


3.0 x 10-5



1.5 x 10-3
1 .8 x 10-6
7.7 x 10-'
4.1 x 10-5
2.3 x 10-5-
2.3 x 10-8
1.6 x 10-3
920m


1.0 » ID"6



4.8 x 10'5
5.4 x 10'a
1.6 x 10-8
l.S*x 10'6
9.0 x ID'7
2.0 • 10-10
5.1 x 10-5
Inhalation Route
Hazard Index
92in
0.059


5.7 x 10-3
0.039
0.07






0.17
920m
2.5 x 10-3


1.3 x 10-4
6.3 x 10-4
1.2 x 10-3






4.4 x 10-3
Carcinogenic Risk
92n


2.4 x 10-5



9.5 K 10-4
1.2 x 10-6
4.1 x 10-'
6.6 x 10-5*
7.0 x 10-5

1.1 x 10-3
920*


8.1 x 10-'



3.5 x 10-5
3.5 x 10-H
8.3 x 10-10
2.4 x 10-6*
2.6 x 10-6

4.1 x 10-5
•  Oral CPF used

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                           TABLE A
                 FUTURE HAZARD  INDICES FOR
            INGESTION OF INORGANIC CONTAMINANTS
      EWAN PROPERTY SITE,  SHAMONG TOWNSHIP,  NEW JERSEY
Element
Barium
Chromium
Copper
Lead
Total HI
Hazard Index
(Dose/RfD) (92 m)
0.49
0.58*
0.81
2.93
4.81
Hazard Index
(Dose/RfD) (920 m)
0.15
0.18
0.12
0.86
1.31
*Calculated using RfD for Chromium VI.

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                                             TABLE 5
        CONTAMINANTS EXCEEDING OR PREDICTED TO EXCEED RELEVANT STANDARDS AND GUIDELINES
                                        EWAN PROPERTY SITE
                                   SHAMONG  TOWNSHIP, NEW JERSEY
Compound
Benzene
Tr ichloroethene
Tetrachloroelhene
1, 2-Dichloroe thane
Hethylene Chloride
Chloroform •
Total xylenes
Bar turn
Chromium (VI)
Lead
Maximum Concentration
(wg/i)
Actual
On Site
50
15
2
1,300
230
40
2,800
l.BOO
208
292
Predicted
92m
20.3
5.7
0.54
592
109
18.0
615



Predicted
920m
0.70
0.17
0.01
22.3
4.1
0.66
10.9



MCL
ivg/i}
5
5

5



1.000
50
50
MCI.G
(ng/l)
0
0
0
0


440*
1.500*
120*
20*
AWQC
(pg/l)
Drinking
Water Only
0.67
2.8
0.88
0.94
0. 19**
0.19
•

50
50
Drinking Water Health Advisories
(P9/1)
1-day
(10kg)
235


740
13.300

12.000

1,400
40*«*
10-day
(10kg)
235


740
1.500

7. BOO

1,400
40***
Li fetime
(70kg)
NA


NA
NA

2,200
1.800
170
40*«*
*  Proposed
** Value is  for  total  trihalomethanes
***20 pg/day at  2  liters/day.

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                             TABLE 6
        COST COMPARISION OF THE REMEDIAL ALTERNATIVES  FOR
                     OPERABLE UNIT ONE OF THE
               EWAN PROPERTY IN SHAMONG, NEW JERSEY

                                                  APPROXIMATE
                              APPROXIMATE          PRESENT
REMEDIAL ALTERNATIVE          CAPITAL COST        WORTH COST

No Action                         $0               $353,000

Excavation and Off-Site       $20,800,000         $21,153,000
Thermal Destruction of
Waste and/or Treatment
of Waste

Excavation and On-Site        $18,964,000          $19,317,000
Thermal Destruction of
Waste and/or Treatment
of Waste

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                             TABLE 7
         COST ITEMIZATION OF THE SELECTED REMEDY FOR THE
              FIRST OPERABLE UNIT REMEDIATION OF THE
               EWAN PROPERTY IN SHAMONG, NEW JERSEY*
ITEM

   Site Preparation
Upgrading of site roadways
Clearing of Area A
Staging area construction
Decontamination area construction
Security fence installation	
    COST
    $73,212
   $480,375
   $250,000
    $50,000
    $21,600
Site Preparation subtotal

   Waste Area
Source excavation
Waste hauling
Groundwater controls
Waste/Drun handling
Decontamination of Staging Area
   $875,187
   $808,960
   $167,848
   $269,640
   $420,000
    $11,830
Waste Area subtotal

   Off-site Incineration
Waste characterization
Waste hauling
Off-site incineration
 $1,678,278
   $240,000
   $652,600
 $7,017,920
Off-site incineration subtotal

   Operational costs
Increased health and safety working levels
Burden
Labor   !
Material
Subcontractor
Indirect costs
Profit
Health and safety monitoring
Contingency
Engineering	
 $7,910,520
   $945
   $253
   $292
    $12
   $871
 $1,874
 $1,284
    640
 $3,328
   $832
,845
,874
,932
,656
,919
,763
,121
,004
,020
,005
Operational costs subtotal
$10,336,139
Costs
Site Preparation
Waste Area
Off-site Incineration
Operating Costs
   $875,187
 $1,1578,278
 $7,910,520
$10,336,139
Total
$20,800,124
  Approximated costs from the Ewan Property Final Feasibility
  Study of July 1988, Appendix A.

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RESPONSIVENESS SUMMARY

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               EPA WORK ASSIGNMENT NO. 130-2LA5
                  EPA CONTRACT NO.  68-01-7250
                             FINAL
                     RESPONSIVENESS SUMMARY
                             FOR THE
                       EWAN PROPERTY SITE
                  SHAMONG TOWNSHIP, NEW JERSEY
                         SEPTEMBER 1988
                             NOTICE

  The preparation of this document has been funded by the United
States Environmental Protection Agency (U.S.EPA) under REM III
Contract No.68-01-7250 to Ebasco Services, Inc. (EBASCO).

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                       EWAN PROPERTY SITE
                   SHAMONG TOWNSHIP, NEW JERSEY

                   FINAL RESPONSIVENESS SUMMARY


The U.S. Environmental Protection Agency (EPA)  held a public
comment period from July 31,  1988 through September 12, 1988 for
interested parties to comment on EPA's final Remedial
Investigation/Feasibility Study (RI/FS)  and Proposed Remedial
Action Plan (PRAP) for the Evan Property site.

EPA held a public meeting on August 18,  1988 at the Indian Mills
Public School in Indian Mills, New Jersey to describe the remedial
alternatives and present EPA's proposed remedial alternatives for
the Evan Property site.

A responsiveness summary is required by Superfund policy for the
purpose of providing EPA and the public vith a summary of
citizens' comments and concerns about the site, as raised during
the public comment period, and EPA's responses to those concerns.
All comments summarized in this document vill be factored into
EPA's final decision for selection of the remedial alternatives
for cleanup of the Evan Property site.

     I.     RESPONSIVENESS SUMMARY OVERVIEW.  This section briefly
     describes the background of the Evan Property site and
     outlines the proposed remedial alternatives for the Evan
     Property site.

     II.    BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS.
     This section provides a brief history of community interest
     and concerns regarding the Evan Property site.

     III.   SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED
     DURING THE PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THESE
     COMMENTS.  This section summarizes both oral and vritten
     comments submitted to EPA at the public meeting and the
     public comment period, and provides EPA's responses to these
     comments.

     IV.    REMAINING CONCERNS.  This section discusses community
     concerns that EPA should be avare of as they prepare to
     undertake the remedial designs and remedial actions at the
     Evan Property site.

I.   RESPONSIVENESS SUMMARY OVERVIEW.

The Evan Property  site, consists of forty-three acres located in a
heavily vooded area of the Pinelands, the site is located
approximately three quarters of a mile south of Tuckerton Road in
Shamong Township,  Nev Jersey.  The property is surrounded by
forests and agricultural land vith several residential
developments  located north and east of the site.  The nearest

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residence is located approximately 2000 feet avay.

There were two areas on the site where waste disposal was
suspected.  The remedial investigation focused on these areas
noted as Area A (approximately nine acres) and Area B
(approximately five acres).  No indication of any dumping activity
was observed on the remaining portions of the forty-three acre
property.  The areas are identified in the Ewan Property RI/FS.

The results of the remedial investigation activities indicate that
disposal and burial of an estimated 500 to 8000 drums of
industrial waste occurred within approximately four acres of Area
A during 1974 and 1975.  The primary method of disposal involved
the excavation of trenches, the burial of the drums in these
trenches, and subsequent re-contouring of the trenched areas.

During the EPA investigation, domestic refuse was encountered in
Area B, however, there was no evidence of any hazardous waste
disposal nor was industrial type contamination detected in the
soils or groundwater underlying Area B.  Therefore, Area B will
not be addressed under the Superfund program.

The significant findings of the remedial investigation are noted
below:

     • Approximately 4500 cubic yards  (cy) of source material
       waste are  estimated to be buried within Area A.  An
       additional 29,500 .cy of material contaminated to varying
       degrees is'estimated to be in close proximity to the
       'source.

     • Source area subsurface samples  indicate that the principal
       contaminants of the source materials are largely
       chlorinated aliphatics organic  compounds (i.e.
       tetrachloroethene, methylene chloride, etc.) and aromatic
       hydrocarbons (i.e. xylenes, toluene, etc.), as well as
       lead, barium, and chromium.

     • A groundwater contaminant plume originating from Area A has
       been estimated to be approximately 500 feet long, 600 feet
       wide, and 30 feet deep.  Groundwater within the study areas
       flows in a southerly direction.

Based upon the projected overall remedial effectiveness and
efficiency, EPA has decided to address the remediation of the site
in two operable units.  The first action, which is the subject of
this PRAP, will address the source and heavily contaminated source
materials. The second operable unit will address lesser
contaminated soils and the contaminated groundwater.  Options to
remediate these soils and groundwater  will be evaluated by EPA,
the State of New Jersey and the public after completion of
additional studies.  Based on preliminary information, it is

                               -2-

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believed that the contaminated soils and groundvater will be
addressed via an on-site treatment process.

The first operable unit will address remediation of the estimated
500 to 8000 buried drums of waste and heavily contaminated
materials near the drums.  The source volume has been estimated to
be approximately 4500 cy.  EPA and the New Jersey Department of
Environmental Protection (NJDEP) recognize the need to take an
action to mitigate the source material at the site.  Based upon
available knowledge of the source material,  it is believed that
excavation followed by thermal destruction are the primary
alternatives for source remediation.

It is EPA's proposed intent to remove the source of contamination
prior to addressing the groundwater contamination and lesser
contaminated soils.  In this way further additions of contaminants
to the groundwater can be prevented, after which the existing
groundwater plume can be addressed.  As previously mentioned, the
contaminated groundwater plume is estimated to be approximately
500 feet long, 600 feet wide and 30 feet deep.  The volume of the
lesser contaminated materials has been estimated to be
approximately 29,500 cy.

Additional public comment will be sought by EPA in evaluating
remedial alternatives related to the groundwater contamination and
lesser contaminated soil.

The alternatives presented in this section correspond to the
remedial alternatives evaluated in the Feasibility Study report.
Numerous remedial technologies were initially screened on the
basis of reduction of mobility, toxicity or volume  (MTV) of the
hazardous substance present; treatment effectiveness; and
technical implementability.  A subsequent screening of
alternatives was performed evaluating each remedial alternatives'
performance in relation to short-term and long-term impacts,
permanent solutions; compliance with applicable or relevant and
appropriate requirements (ARARs); overall protection of public
health and the environment; and State and community acceptance.

The three remedial alternatives considered after screening
numerous possible alternatives are described below.  The three
alternatives evaluated for the first operable unit in the FS are
as follows:
                               -3-

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Remedial Alternative 1;  No Action

Capital Cost:  $0 (Assuming site security fence was installed)
Annual Cost:   $22,000 (Monitoring costs and other "institutional
  contract" costs)
Implementation Time:  Indefinite

As required by federal regulations, the "No Action" remedial
alternative must be considered by EPA as a potential remedy at
each Superfund site.  No Action would mean that the source
material leachate would continue to migrate off-site and pose
potential health and/or environmental threats in the future.  This
alternative would require local authorities to enact land and
water usage restrictions in the area.  Residential development in
and south of Area A would most likely be prohibited.  Monitoring
of groundwater would continue to quantify and predict contaminated
groundwater movement.

Remedial Alternative 2:  Excavation and Off-Site Thermal
Destruction of Waste and/or Treatment of Waste

Capital Cost:  $20,800,000
Annual Cost:   $22,000
Implementation Time:  20 months after remedial design is completed

Excavation and Off-Site Thermal Destruction of Waste and/or
Treatment of Waste  would involve the identification, excavation,
transport and thermal destruction of incinerable source materials.
After identification is completed, source materials which are non-
incinerable would be treated with the most appropriate remedial
technology.  Such appropriate technologies may include on-site
treatment during the second operable unit of remediation, off-site
treatment at a licensed hazardous waste treatment facility, pilot
studies of potential treatment methods, etc.  This alternative
requires that a site access road be constructed and that Area A be
cleared of vegetation.  Staging and testing areas would be
constructed to separate and test the source materials which would
be excavated.  Site perimeter air monitoring would be conducted
during the excavation.  Contingencies for excess volatilization or
spillage will be enacted upon detection.  After materials have
been tested for incineration parameters, they will be loaded onto
vehicles and transported from the site to an off-site facility
legally permitted to incinerate hazardous wastes.  Materials which
are not incinerable will be treated appropriately.  Groundwater
will be monitored until completion of the second operable unit of
the remedial action.  Following completion of this subsequent
operable unit, the excavated area will be filled with clean
material.
                               -4-

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Remedial Alternative 3s  Excavation and On—Site Source Thermal
pestruction of Waste and/or Treatment of Waste

Capital Cost:  $18,964,000
Annual Cost:   $22,000
Implementation Time:  26 months after completion of the remedial
design

Excavation and On-Site Thermal Destruction of Waste and/or
Treatment of Waste involves the thermal destruction of incinerable
source materials in an on-site transportable incinerator.  This
remedial alternative requires that a site access road, eirid areas
for staging and testing of source materials be constructed.  In
addition, an area for an on-site mobile incinerator would be
developed.  As with Remedial Alternative 2, Area A will be cleared
of vegetation.  The on-site incinerator would be fitted with
state-of-the-art combustion and air pollution control equipment.
During all phases of this remedy, site air and incinerator
emissions monitoring would be conducted.  Contingencies for excess
volatilization, spillage, or malfunction of the thermal
destruction unit would be enacted upon detection.  Ash generated
from this unit will be tested to determine its ultimate disposal.
Also, as with Remedial Alternative 2, material which is not
incinerable would be appropriately treated.  Groundwater would be
monitored until completion of the second operable unit.  Following
completion of this subsequent action, the excavated area would be
filled with clean material.

Selection of an Alternative

EPA's selection for remediation at the Ewan Property site will be
based on the requirements of the CERCLA and SARA regulations.
These regulations require that a selected site remedy be
protective of human health and the environment, cost-effective,
and in accordance with other statutory requirements.  Current EPA
policy also emphasizes permanent solutions incorporating on-site
remediation of hazardous waste contamination whenever possible.
Final selection of a remedial alternative will be documented in
the Record of Decision (ROD) only after consideration of all
comments received by EPA during the public comment period and
addressed in this responsiveness summary.


II.  BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

Local residents reported buried drums at the Ewan Property site in
1982 to the Burlington County Health Department and NJDEP.
Subsequently, residents have held numerous meetings, signed
petitions, and written letters to federal, state and local
officials requesting cleanup of the site.
                               -5-

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In February 1983, more then 100 residents participated in a
meeting to discuss the site and how to get a government agency to
cleanup the site.  A petition with 92 signatures was circulated by
the Coalition Against Toxics to the federal congressional
delegation to request the Evan Property site be cleaned up.  The
Shamong Township Board of Education also requested help in
developing an educational campaign for area school children about
the Ewan Property site.

The primary concerns citizens have raised about the site include:

     •   Alleged decreases in property values of 10-15% that
         residents feel occurred as a result of the Ewan Property
         site.

     •   Potential contamination of potable wells if the
         contaminated groundwater spread to the residential areas.

     •   Potential health risks associated with exposure to
         contaminants leaking from the buried drums.

III.  SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE
PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THESE COMMENTS

Comments raised during the public comment period for Ewan Property
site are summarized below.  The public comment period was held
from July 31, 1988 to September 12, 1988 to receive' comments on
the draft supplemental RI/FS report and the Proposed Remedial
Action Plan.  Comments received during the public comment period
are summarized below and organized into three categories:
liability for cleanup costs, remedial investigation results, and
future activities.

A.   Liability for Cleanup Costs

     Comment:

     A resident inquired whether potential responsible parties
     (PRPs) had been identified and if the cleanup of the Ewan
     Property site might be delayed by the PRP's?

     EPA Response:

     EPA has notified several PRP's of their potential liability
     with respect to the site and is currently negotiating with
     one of these PRPs.  As with any cleanup action of this type,
     EPA will offer the PRPs the option of undertaking the cleanup
     action.  EPA prefers the PRPs to directly fund and conduct
     the cleanup, so that Superfund resources can be used for
     abandoned sites where PRPs cannot be identified.  However,
     EPA will not delay the cleanup process pending an agreement
     with the PRPs.

                               -6-

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     Comment:
     Several residents were interested in determining if EPA
     considered Shamong Township to have any liability for site
     cleanup.
     EPA Response:
     EPA is not aware of any potential liability by Shamong
     Township.
B.   Remedial Investigation Results
     Comment:
     A resident inquired as to the depth of test borings conducted
     as part of the remedial investigation.
     EPA's Contractor Response:
     The deep wells (approximately 60-80 feet deep) were
     constructed to the bottom of the Cohansey and the top of the
     Kirkwood Aquifers.  Contamination was not detected in this
     portion of the aquifer.  However, contamination was detected
     in the shallow wells installed at the top of the Cohansey
     Aquifer  (approximately 30 feet deep).
     Comment:
     One citizen inquired how deep the drums that were found
     during the remedial investigation were buried?
     EPA Response:
     The drums are buried near the surface and to a maximum depth
     of 10 feet.
     Comment:
     A resident wanted to know the nature of the waste found in
     Area B during the remedial investigation.
     EPA's Contractor Response:
     The waste identified in Area B during the remedial
     investigation consisted of  domestic trash, plastic
     containers, and garbage bags.
                               -7-

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Comment:

A resident asked about a pit that was alleged to be on site.

EPA Response:

A pit identified by a confidential source was located in Area
A.  Excavations were made in the pit and soil borings was
conducted during the remedial investigation.  The analytical
results of the samples collected during the pit excavation
and soil boring program indicate that contamination is not
present in the pit.

Comment:

A resident inquired about the potential impact of an
archeological study to be conducted as part of the
supplemental investigation.

EPA Response:

An archeological investigation is planned to be conducted
during the supplemental investigation but the archeological
investigation should not hinder the cleanup effort.

Comment:

A resident asked if there were specific cleanup standards for
groundwater quality in the Pinelands which were applicable to
the Ewan Property site.

EPA Response:

The State of New Jersey has recently proposed drinking water
standards under A-280 legislation that are more restrictive
then federal standards.  EPA intends to use the New Jersey
standards unless the Pinelands Commission imposes something
more restrictive.
                          -8-

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C.   Future Activities

     Comment:

     A resident expressed concern that funds might not be
     available to complete the cleanup action at the site.

     EPA Response:

     The funding for each phase (investigation,  design, and
     cleanup) of the Evan Property site is appropriated
     independently prior to initiation of each phase.  Independent
     appropriation of funding by phase prevents a project from
     running out of funding prior to completion of each phase.
     While this process prevents a project from running out of
     funding midway through a phase, it does not guarantee funding
     will be available for each phase of the cleanup.  At this
     time, however, EPA does not expect funding of any phase of
     the project to be a problem.  Additionally, the New Jersey
     Congressional delegation has consistently ensured adequate
     funding to complete remedial actions at Superfund sites in
     New Jersey.

     Comment:

     One citizen who resides adjacent to the Evan Property site
     expressed concern about potential traffic disruption and
     safety problems that might arise from the installation of the
     proposed fence and increased truck traffic during the
     remedial action.

     EPA Response:

     Plans for the fence and transportation impacts will be
     considered during the design phase.  Interested citizens were
     welcomed and encouraged to share their ideas on the most
     efficient, safest, and least disruptive way to implement the
     proposed remedial action.

     Comment:

     One resident wanted to know if EPA would provide continued
     updates on site activities once the ROD was signed.

     EPA Response:

     EPA expressed its continued support for active public
     involvement at the site and stated that it would provide
     formal updates on the design plans and the results of the
     supplemental studies as information becomes available.  EPA
     also, restated their willingness to meet formally or
     informally with any interested citizen.

                               -9-

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     Comment:

     Several residents expressed an interest in the schedule for
     the cleanup.

     EPA Response:

     Once a ROD is signed a design contractor will be hired.
     Concurrently, the supplemental groundvater investigations
     will be conducted.  The design phase and supplemental
     investigations could take approximately one year.  EPA will
     then hire a contractor to actually remove the drums and
     contaminated soil and another contractor to design the
     selected groundvater remedial action.  Subsequently, a
     cleanup contractor for the groundwater contamination design
     phase will be hired.  A very rough ballpark figure of four or
     five years was estimated for the entire cleanup action.

Written comments submitted to EPA during the public comment period
are attached as Appendix A.


IV.  REMAINING CONCERNS

Concerns raised by the community about remedial activities at the
Evan Property site vill continue to be important issues.  The
primary reason for continued concern is that the site is broken up
into tvo distinct operable units and identical issues may
resurface during the RI/FS process for the second operable unit.

In addition, a number of concerns that are directly related to the
groundvater contamination to be addressed in the RI/FS of second
operable unit vere expressed.  The issues vhich should be
considered during the supplemental investigations of the second
operable unit are summarized belov:

Phase II Groundvater Investigations

     Comment:

     A number of residents vere interested in the schedule for
     sampling of residential veils.

     EPA Response:

     The veils vill be resampled as part of the Phase II remedial
     investigation during the next fev months.  Results of
     individual veil sampling vill be forwarded to the affected
     residents as soon as the results are validated.  This process
     takes several months.
                               -10-

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Comment:

A realtor expressed interest in the potential for the
groundwater flow direction to be changed by increased pumping
of the groundwater.

EPA Response:

Massive pumping of a large municipal-size vellfield at other
sites has been known to trigger some changes in groundwater
flow patterns, the volume and flowrate of private wells near
the Ewan Property site should not cause any change in
groundwater flow patterns.  Additionally, groundwater studies
at the Ewan Property are expected to be completed sometime
next year which will likely result in a decision to pump and
treat the contaminated groundwater thus permanently removing
the contaminants.
                          -11-

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        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                             REGION I i
                          if, FEDERAL PLAZA
                      MEvV YORK NEW YOHK  iC278
Mr. H. John Phelps, III
Superfund Administration Executive
Chrysler Corporation
Plant Engineering and Environmental Planning
12000 Chrysler Drive
CIMS 416-15-14
Highland Park, MI 48288-1919

Dear Mr. Phelps:

This is in response to your letter of September 12, 1988,,  in
which you provided comments to me related to the Ewan Property
Remedial Investigation, Feasibility Study and Proposed Remedial
Action Plan for the first operable unit remediation.  Also,
attached with your letter were comments raised by your consultant
Roy F. Weston Incorporated.  I have enclosed a copy of the EPA
response to your concerns, which has been prepared with assistance
from our contractor NUS Corporation.  I have further addressed
one specific concern below.

Roy F. Weston, Incorporation has indicated that six bulk samples
of the 'potentially 8000 drums buried at the Ewan Property  is  •
not a significant sample quantity.  The remedial investigation
indicates that in several of the test pits, drums of poor
structural integrity were encountered.  This would indicate
that some of the previously drummed waste has leaked into  the
surrouding environment.  It is our judgement that Target Compound
List analytes detected in the nearby soil and groundwatei:
provide an indication of the general type of waste buried  at
the Ewan Property.

I hope that this clarification and the enclosed response will
address your concerns.

Sincerely yours,
Crai,q/De 3iase, Project Manager
Soutnern New Jersey Remedial Action Section

Enclosure

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                                       a
*jr»i - It
'
    • a
""V^

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                      nn     *       by   ** Qf






                                             ""







 ^      la      c
•




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15, 16) metal  shards  in  one  (11)  bog iron in one (8),  one
test pit  (9) was  excavated as  a . background checfc, and  one
was  excavated to  investigate the  reported presence of
buried fiberglass resins  (12).   Only one test pit (14)  was
excavated based  upon the magnitude of a magnetic anomaly
without encountering drums or  visible  signs of bog iron
(See Appendix B of  the RI Report).

Bullet Three:   Subsurface  Investigation -  The soil
contamination will be addressed in the  Operable Unit  Two
FS.   Weston is  referring to Figure  3-6;  this figure is a
composite of information  obtained  during the  RI.   Although
the analytical data  indicates that several soil samples
within the "estimated contaminated  area"  do not exhibit
contamination/  the fact remains  that these locations  are
adjacent to either visual surface evidence of drums or near
test  pits  which exhibited  contamination or  contained
drums.  Estimates included in  the RI and  FS  are  typically
conservative; therefore,  we cannot eliminate  these areas.

Sample  EP-SO-013-M does  contain high levels  of lead;  this
location  was above  a drum.   Weston's  reference to  a
provision for addressing  such heavy metals refers to the FS
and not the Site  Investigation.  Costs have been allocated
in the FS for handling ash which may contain metals.

Bullet  Four:  Soil Gas Survey - The soil gas survey was
conducted as part  of the interim activities  prior to
preparing the Site Operations  Plan  (SOP)  for planning the
RI field  activities.  The detailed procedure was  included
in the SOP, as stated on  page 25 of the  RI.   As part of the
evolution of this RI Report,  it was determined that  the
description included on pages 24 and  25  were  sufficient for
the inclusion in the RI Report.

A visual representation of the  results  of the soil gas  are
included  in the  text on Figures  3-1 and 3-2.   The visual
representation  of data in the  text has  been supported by
the details provided  in  the Appendix.   Also/ pH  and
conductivity were  conducted  as part of the  soil  gas
screening.

5.0  Endangerment Assessment

Bullet One:  Vapor Suppression  - This statement is true and
has been  considered in the remedial  alternatives presented
in the FS Report.

Bullet  Two:  The closest downgradient residential veil is
located approximately one mile  from the site; however/  the
closest downgradient potable well  is  located  at the Shamong
Field House.  The 920 meters  refers to the field house  and
not the nearest downgradient  residence.
                           -2-

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The flow  in the  Cohansey sand aquifer ranges from 50 to
124 feet per year.   In order  to  provide  a  conservative
estimate  the  value  of 124 feet  per year was  used for
calculations.

Bullet  Three:   There  is  "no  immediate and substantial
hazard presented by the soils and  buried waste  materials".
This was a similar conclusion stated by Weston in  a 1984
report  prepared as the TAT contractor for the EPA.  If
there were an immediate and substantial  hazard,  a removal
action  would have been undertaken,  not  the formal  RI/FS
proceedings.   Inactivity with regard to  expeditious source
mitigation  will allow  the  potential  for  further soil and
groundwater  degradation.

6.0  Feasibility Study

Validity/Integration of Operable Units

An immediate removal  action,  based  upon  protection  of the
public  health  and the  environment,  is not warranted, as
stated by  Weston.   This is the  reason remedial  activities
evaluations  were performed.   The Operable Unit  approach was
established  to  expedite  the  remediation  of  the  site.   The
longer  the  drums  remain  in  the ground  the more  difficult
and costly soil and groundwater remediation will become.
It will also become more difficult to excavate the drums, as
they continue to  rust and become  more fragile.   Weston
suggests  that drum  removal may  exacerbate  contaminant
levels and migration  potential  in  the groundwater.   It is
REM Ill's judgment that expeditious source mitigation will
prevent continued degradation of the soil  and groundwater.
Precautions  will be taken during  excavation activities to
limit the  potential  for  source  material  to further
contaminate  the  soils  and groundwater.

Apparently a further  clarification is required.   The FS for
Operable Unit Two is  presently being conducted  and  will be
issued once  treatability studies on  the  soils are
completed.   The Operable Unit Two  FS  will  concentrate on
the lesser  contaminated  soil and  groundwater  remediation
activities.   These remedial  activities will provide for  a
protective,  expeditious,  and cost effective  overall  site
mitigation.

Technology/Alternative Screening Process

A  statement on page 49  indicates that the alternatives for
remediation  of Operable  Unit One  are  interim  measures.
This was written to indicate  that the entire site will not
be remediated as part  of Operable  Unit One  and that
contamination would remain at  the  site to be  remediated
under Operable Unit Two.
                           -3-

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The  alternatives evaluated  do  include temporary storage
(following over-packing,  stockpiling,  and testing).
REM III realizes that some portion  of  the material may not
be suitable for incineration  or  may better be treated by
other  means.   However,  until all  source  material is
excavated  and  characterized this  issue cannot be  truly
evaluated.  The RZM  III  RI indicates  that the majority of
the source material disposed of at the  site is  suitable for
incineration.

Weston also  states  that  "technologies  which might be
equally protective,  particularly  in  the context of  a
comprehensive site remedial alternative, were  not selected
for  evaluation."   Weston  provides a list of  these
technologies  at the end  of  the  package.  Incineration of
the source material  may be more  universally applied  than
in-situ volatilization, stabilization,  etc.

Volume  Estimation  •

REM  III  agrees that  assumptions have been made; however,
firm estimates  cannot  be  obtained until  all of the .source
material  is  excavated.   What was  suggested was to'obtain
information on exact  numbers  of  drums  which contain
liquids,  how  many have leaked, etc., by conducting a large
scale, test pit operation.   The information obtained  from
this operation  would  be limited  to  the exact drums sampled
and the trenches investigated.   However,  costs and  time
incurred  for  additional  RI  activities could be  better
utilized  in  beginning the site remediation.

Validity of Incineration

Based upon information that REM III  has obtained during the
RI,  incineration is appropriate for the majority of the
source  material.   It is conceivable that portions  of  the
material  would not be  suitable for  incineration or that
other treatment  options would be  more effective.   This
potential  issue will  be addressed if  it occurs.

Other Potentially Viable Technologies

Weston  lists  several  technologies which  may prove to be
appropriate for a portion of the  source  materials.   As
noted by Weston, incineration  was selected as  a technology
which may be appropriate for the majority of the  source
materials.
                           -4-

-------
                   Nomogrim for Ettirfuting Anom*ii« from Typical Objects (mumino, dipoia
                   moiwu M • 5 X 10* cyt/ton. i.r. k  • 8 cfft. Estimates »«lid onlv within
                   ort* of magnitude)
        CCMTIMCTCM
                      100
                              200        400    WO MO 1000

                                OltTANCI FHOM MAGNETOMETER •
iMrrnuenoMt «o* uu:
To 10* tna ••nuojam. Mian • ft«*n woiant or rypa of obiact from amona KM rtlaaonal
                 (
                                                                     Urm. Tboii «Moo» • ai«in«
                         l of «M fnprt Mid follow t vortical HIM yp»»ordl from m« dinane* until ll inuncca ttM
                            At tftoi point, mow rtoricomaUy w ««• i«h to • M*«M on tfx wtieoJ 411* (ordVwBil o( •*•
     rtt«
diot»nol U«« o» 0M
•/•9M ond rdd 014 MttMlty MI
At i tivon  dtaanca. tfw intomitv • »ro0oio! to th« «Hnt of tn« oeioet. T)Mr«for«. tor on eb*ct ««•»• «rw««ii • not
       ui of tn« l»a>loa Una. Brnpry multiolv UM mi«n«ny In (Mnma by in* ratio of UM d«ir«« tMioM to t«Mi lottotad
      on ttw roan, if UM dinanca da^rad doai not atiaii on tna anpft. rannmaor mat for t ryy
       roxnional M tha ouoa of ft* dlaiama and for a to«a oia«Una MM Intanaity • invartatv >i
of UiadMtanca tin ioan maanatomaiar tanotr and ooiact. Owa to tna many wncartamiiai doaeribad harain, tha aatimaaai< <
horn mil nomoaram may ba lar«or or 01101107 by a factor of 3 to S or pomao* more
                                                                                M Ml
                                                                                   fMGURE  3-6
NOMOGRAM  USED  FOR  DRUM  ESTIMATE  CALC
     EWAN PROPERTY SITE, SHAMONG TWR, NJ
                                           40
                                                                                  CORPORATION
                                                                               A HaJliburton Company

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                                      I
                                 PAGE 2
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500,650,56269.8
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                                 PAGE 3
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500,625,54610.3
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450,625,54527.7
425,625,54616.5
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200,600,54720.2
225,600,54723.7
250,600,54726.5
275,600,54724.5
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325,600,54728.6
350,600,54757.6
375,600,54752.1
400,600,54711.9
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500,600,54533.7
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750,600,54723.5
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                                 PAGE 4
 575,575,55213.7
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                                 PAGE 5
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                                  PAGE 6
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                                  PAGE 7
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                                      I
                                PAGE 8
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                                PAGE 9
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275,325,53952.7
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400,300,54682.5
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                                PAGE 10
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225,225,54010.9
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100,225,54976.5
75,225,54687.3
50,200,54429.7
75,200,54470.5
100,200,55113.7
125,200,54132.5
150,200,54463.4
175,200,54462.9
200,200,53917.4
225,200,54777.6
250,200,54038.9
275,200,54369.4
300,200,54598.8
325,200,54280.5
350,200,54696.4
375,200,54553.5
375,175,54720.9
350,175,54288.0
325,175,54443.5
300,175,53953.1
275,175,54425.6
250,175,53632.1
225,175,54724.5
200,175,57737.2
175,175,54589.0
150,175,54801.1
125,175,54974.7
100,175,55404.2
75,175,54539.2
50,175,54199.2
75,150,54724.3

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                                PAGE 11
100,150,54641.2
125,150,54260.5
150,150,54580.0
175,150,53885.4
200,150,54657.7
225,150,53931.4
250,150,54652.2
275,150,59594.8
300,150,53940.1
275,125,54638.3
250,125,55439.4
225,125,55545.3
200,125,54864.1
175,125,54597.7
150,125,54520.7
125,125,54529.2
100,125,54273.4
75,125,54708.5
50,125,54575.8
25,100,54301.8
50,100,54124.6
75,100,54691.4
100,100,53945.2
125,100,54659.3
150,100,54480.5
175,100,54740.0
200,100,60627.0
225,100,55123.1
250,100,54641.3
275,100,54336.7
275,75,54454.2
250,75,54284.9
225,75,54545.8
200,75,55154.2
175,75,53986.3
150,75,53851.9
125,75,54689.2
100,75,54665.9
75,75,54466.6
50,75,54867.2
25,75,61451.0
75,50,54177.9
100,50,54407.3
125,50,53964.3
150,50,54722.0
175,50,54289.8
200,50,54365.2
225,50,54706.0
250,50,54260.9
275,50,54713.9
275,25,54491.3
250,25,54600.5
225,25,56835.9
200,25,54780.6

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                                PAGE 12
175,25,54534.8
150,25,54621.3
125,25,54186.5
100,25,54043.3
75,25,54548.9
50,0,54722.8
75,0,54378.4
100,0,54207.8
125,0,54326.1
150,0,54474.3
175,0,54421.9
200,0,54244.1
225,0,59871.2
250,0,54301.6
275,0,54558.7

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  APPENDIX A




PUBLIC COMMRMTC

-------
                   TOWNSHIP OF SHAMONO-C^ITAL rnprsv:.:
                      BURLINGTON COUNTY, N.J.     AwNCY, RiLiwI II
                        Office of the Township Clerk  in-"* «p _g  •(.'  7; 30
                          60 Willow Grove Road
                          Vincentown, NJ 08088     fRM-HJ REMEDIAL AC7C.V
                             (609) 268-2377



                                   August 31, 1988
Craig DeBiase
Project Manager
U.S. Environmental  Protection Agency
26 Federal Plaza
Room 711
New York, New York  10278

Dear Mr. DeBiase:

     The Shamong Township Committee recommends Remedial  Alternative 2
for the Ewan Property  Site, Shamong Township, New Jersey.

     Of the three remedial alternatives discussed at your  public
meeting of August 18,  1988, and a review of the material filed at
the Municipal Building, Remedial Alternative 2 will correct the
hazardous waste site with the least negative effect on the environment.
Alternative 1 is not acceptable because the environment will continue
to be.damaged by the hazardous waste.  On site burning as  described
in Alternative 3 raises servious health and safety concerns for our
residents .as well as environmental concerns.

     Thank you for  arranging the public meeting and we look
forward to our continued cooperation.
                                     L. E. Heinold '
                                     Township Clerk
LEHrbv

cc:  Township Committee

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                    TOWNSHIP OF SHAMONpy,3&l;,7il?-.3,K;: ;.
                        BURLINGTON COUNTY, NJ.      AGENCT. REGION !i
                         Office of the Township Clerk
                            60 Willow Grove Road      CSS S£P "6  An  7= 33
                            Vincentown. NJ 08088
                               (609) 268-2377



                                        August  30,  1968
Craig DeBiase
Project Manager
U.S. Environmental Protection Agency
26 Federal Plaza
Room 711
New York, New York 10278

Dear Mr. DeBiase:

     As Mayor of Shamong Township I want to go on record  as  supporting
Remedial Alternative 2 for the Ewan Property Site, Shamong Township,

New Jersey.

     Remedial Alternatives 1 and 3 raise serious environmental,  as
well as, health and safety concerns.

    • If .there is anything I can do to help expedite Remedial  Alternative
       »
2, please do not hesitate to contact me.

                                        Yours truly,
                                     '  Richard 0.  Erisman
                                             Mayor
ROE:bv

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Bunker Hill Rd. • R.D. *5 • VIncentown. NJ • 08088 • 609-654-2549.711 •--—--
                                               fci * i i*«*»i i* .•».»i r*L * r«v iLvi^»«f.
                                                  AGEKSY. KI;;GN u
                                               I3SS SEP -7  AK 8 0?
                                                  -KJ REKE3,'!AL JL'TS:;
   Shamong
   MANUFACTURINGCOMPANY, INC.
                                                      lo»»^|
   PRECISION SHEET METAL
                                                   1  SEPTEMBER 1988
   CRAIG DE BIASE
   PROJECT MANAGER
   _U.S. ENVIRONMENTAL PROTECTION AGENCY
   26 FEDERAL PLAZA
   ROOM 711
   "NEW YORK, N.  Y.   10278
   SUBJECT;  EVAN PROPERTY
             SHAMONG TOWNSHIP NEW JERSEY
             LOT 32.01, 32.02   BLOCK 5
   I WOULD LIKE TO COMMEND MR. JOHN FRISCO AND THE AGENCY ON THE
   DECISION .TO REMOVE ALL HAZARDOUS WASTE AND CONTAMINATED SOILS
   AT THE PROPERTY SITE.
    DONALD AUTIO
    SHAMONG TOWNSHIP PLANNING BOARD

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                                                            CHRYSLER
 ChryiUi Motors Corporation
September^, 1988
Mr. Craig DeBiase
Project Manager
U. S. Environmental Protection Agency
26 Federal Plaza, Room 711
New York, New York 10278

Dear Mr. DeBiase:

Subject: Ewan Property Site, Shamong Township, Burlington County, New Jersey

This letter, together with the attached technical analysis by Weston Engineering,
constitutes Chrysler Motors' comments on the Remedial Investigation and Feasi-
bility Study ("RI/FS") report for the Ewan Property Super-fund site in Shamong
Township, New Jersey. Chrysler's specific comments and concerns about technical
aspects of the RI/FS, on which the Proposed Remedial Action Plan ("PRAP") is based
are  set forth in the attachment. The purpose of this letter is to provide an overview
of Chrysler's position on the PRAP and underlying documents.

In general, Chrysler concurs with the Agency's proposal to utilize a combination of
off-site incineration and waste treatment as a remedy for the first operable unit at
the site. Indeed, as Chrysler representatives have discussed with EPA, Chrysler may
be interested in undertaking remedial action at the site, under EPA's oversight.
Chrysler's active involvement in implementing the remedy will facilitate timely and
efficient remediation of the site.

Although Chrysler agrees with the fundamental remedial approach set forth in the
PRAP, Chrysler is concerned because the final remedy set forth in the PRAP does not
provide for on-site technical judgments regarding which materials will require
incineration, and which may be more appropriately handled by other methods. As
is explained in more detail in the attached technical comments, a flexible approach
is necessary due to the lack of reliable waste characterization data, and because the
data that is available for the site is suspect in many crucial respects. Waste charac-
terization activities conducted as part of the remedial effort, for example, may
reveal that some of the materials potentially located at the Ewan property are not
hazardous because they had been treated prior to disposal.

-------
 Mr. Craig DeBiase                                        September 12, 1988
 Project Manager                                                  Page Two
 U. S. Environmental Protection Agency


 In view of the foregoing uncertainties, it is important that the Record of Decision
 ("ROD") describe the selected remedy in general terms and that it provide for
 flexibility in the implementation of the remedy. In particular, the ROD should pro-
 vide for an on-site waste characterization process followed by an on-site deter-
 mination as to which of the materials should be incinerated and which may be
 handled by other appropriate methods.  These on-site activities should be con-
 ducted by the remediation contractor with the assistance of the on-scene EPA
 coordinator.

 This approach is consistent with the PRAP and should require only minor changes in
 the ROD. To assist in implementing the approach described above, Chrysler
 suggests that language along the following lines be used to describe the selected
 remedial alternative:

     Excavation and off-site thermal destruction of waste and/or treatment of
     waste would involve a three-step process.  First, waste materials (i.e.,
     drummed waste and materials in contact with drums) shall be identified
     and sampled. Second, all drummed waste and  materials in contact with
     drums shall be evaluated on-site to determine the level of hazardous
     substances present and to select the appropriate remedial method to be
     used for those materials. Third,  hazardous wastes identified as appro-
     priate for incineration will then  be transported off-site to a designated
     thermal destruction facility, while materials identified as inappropriate
     for incineration will be treated with the most appropriate remedial
     technology. Such appropriate technologies may include on-site treatment
     during the second operable unit of remediation, off-site treatment at a
     licensed hazardous waste treatment facility, pilot studies of potential
     treatment methods, or equivalent measures. Materials identified as non-
   .  hazardous during the on-site characterization process will be handled as
     appropriate in light of their non-hazardous nature.

The matters discussed above are analyzed in greater technical detail in the attached
comments by Weston Engineering. In particular, the Weston  analysis identifies why
the investigations of the volume of drums potentially present at the site and of the
contents of those drums have been inadequate. The Weston  comments also discuss
deficiencies in the technology screening and alternatives analysis, which arbitrarily
excluded any in depth consideration of non-thermal treatment approaches. Those
comments further explain why the RI/FS' lack of reliable data  means that exclusive
reliance on thermal destruction as a remedial approach for the first operable  unit is
 not justified, and why allowance for alternative treatment approaches following
 more definitive waste characterization is required.

 Chrysler appreciates the opportunity to comment on the PRAP and RI/FS, and looks
 forward to continuing to work with the Agency to resolve all  the issues at the Ewan
 property site.

 Sincerely,
Enclosure
PW/PE&EP/08

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       REVIEW ON RI/FS




             FOR




     EWAN PROPERTY SITE




SHAMONG TOWNSHIP, NEW JERSEY
         Prepared by



     ROY F. WESTON, INC.



       September 1988

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1.0    EXECUTIVE SUMMARY

2.0    INTRODUCTION

3.0    OVERVIEW

       Remedial Investigation Objectives
       Feasibility Study Objectives

4.0    SITE INVESTIGATION

5.0    ENDANGERMENT ASSESSMENT

6.0    FEASIBILITY STUDY
                          •
       Validity/Integration of Operable Units
       Technology/Alternative Screening Process
       Volume Estimation
       Validity of Incineration
       Waste Characteristics
       Other Potentially Viable Technologies

7.0    CONCLUSIONS AND RECOMMENDATIONS

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1.0  EXECUTIVE SUMMARY

Roy  F.   Weston,   Inc.   (WESTON)   has  reviewed   the  Remedial
Investigation (RI) and Feasibility Study (FS) Reports prepared by
U.S.  EPA  Contractors  on  the  Evan  property  Site  in  Shamong
Township,  Burlington  County, New  Jersey.   WESTON  has completed
the review of the RI/FS reports and concentrated on the following
items:

     o  Validity of the technical approach.

     o  Consistency with applicable regulations and guidance.

     o  Sufficiency  of  the RI  data  base  to  develop  remedial
        alternatives.

     o  Technical  consistency  of  the  evaluation/selection  of
        remedial alternatives with the findings of the RI.

WESTON's key  findings from the review of the RI  are enumerated
below:

     o  The geophysical survey was not performed using techniques
        that are more applicable to the site conditions.

    . o  There is  insufficient information  pn the  contents of the
        drums since  only two drum samples  were  collected during
        the  RI,  and  only  six  have  been  sampled  during  all
        investigations.

     o  Insufficient  information  was  collected  on  the physical
        condition and spatial distribution of the drums.

     o  No  attempt   was   made   to  collect  verifiable  field
        information on the  volume  of  "highly contaminated" soils
        adjacent to the drums.

     o  The Remedial  Investigation, therefore,  did  not  achieve
        the objective of developing a sufficient data base for
        evaluation of all remedial alternatives in the FS.

The  Feasibility  Study  divides  the   Remedial  Action  into  two
Operable Units.  Operable Unit No. 1 addresses the remediation of
the buried drums and the adjacent "highly contaminated" soils and
Operable  Unit No.  2 address  the remediation  of  the  remaining
contaminated  soils  and  on-site  groundwater.   The  Feasibility
Study,  reviewed by WESTON,  addresses  Operable  Unit  No.  1.   The
following  key findings were developed from WESTON's   review of
the FS:
                               -1-

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     o  There is insufficient waste characteristic information to
        facilitate a  comprehensive development and evaluation of
        technical alternatives.

     p  An expedited  response of drum  removal  on the basis of an
        imminent and  substantial hazard  to the public health and
        the environment is not justified based on the information
        presented in the RI.

     o  Additional   remedial   alternatives   should  have   been
        considered and evaluated.

     o  No  attempt was  made  in the  FS  to  integrate the  two
        operable  units  to  evaluate  benefits  which  could  be
        derived based on a combined approach.

     o  Cost information is not reliable due to insufficient data
        in the RI.

Based on  our  review of  the  RI  and  FS,  WESTON recommends  the
following:

     o  Additional field  investigations  involving  geophysics to
        locate and estimate quantities of drums.   Soil and drum
        sampling should be conducted, in order to more accurately
        characterize  and  quantify  the   waste   prior  to  drum
        removal.

     o  If  an  interim  remedial  action  for Operable  Unit 1 is
        performed, intermediate handling and ultimate disposition
        of the  waste material should  be flexible,  based  on  the
        waste characteristics.

     o  Any  interim  remedial action  should  allow  for  future
        integration  of  the  operable  units,   especially  with
        respect to contaminated soils disposition.
                               -2-

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2.0  INTRODUCTION

The Evan Property Site is located in Shamong Township, Burlington
County,  New Jersey.   The  site was  used  for disposal  of drums
containing  a  variety  of substances  including  solvents,  resins
etc.  The  site  was the  subject  of investigation  from  the early
1980's  by  New   Jersey  Department  of  Environmental  Protection
(NJDEP), U.S.  EPA's Field  Investigation Team  (FIT Contractor),
U.S. EPA's  Technical Assistance Team  (TAT Contractor)  and U.S.
EPA's  REM-FI.T  Contractor-NUS  Corporation.   The  site is  on  the
National Priorities  List (NPL) and a  remedial  investigation was
conducted   by   NUS   Corp.   in  1985-1986.     Subsequently,  the
Feasibility Study for Operable Unit No.  1  at  the site was issued
by EBASCO in 1988.  WESTON  reviewed the  RI/FS reports to achieve
the following objectives:

     o  Evaluate  the  technical   approach  of   the   RI/FS  for
        completeness   and   application   of  sound  scientific/
        engineering principles.

     o  Evaluate  the  regulatory  compliance  of  the  RI/FS  with
        CERCLA,  SARA and related guidance documents.

     o  Evaluate  if  the data  base generated  during  the  RI  was
        'sufficient to perform a feasibility study.

     o  Evaluate if the  selection  and  evaluation of alternatives
        is  consistent  with  the  findings   of  the  RI  and sound
        engineering principles.

     o  Evaluate if the findings of the RI provide valid evidence
        for requiring remedial action as proposed in the RI/FS.

     o  Evaluate  if   other  remedial   technologies/alternatives
        merit  a  detailed   evaluation  to   address  the  remedial
        action at the site.

WESTON has  completed the review of the reports  and has addressed
each of  the above mentioned objectives. The  ensuing  sections of
the report summarize the results of WESTON's review.
                               -3-

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3.0  OVERVIEW

Remedial Investigation Objectives

The  stated   objectives   of  the   Remedial   Investigation   (RI)
performed by EBASCO are to:   (1)  define the  nature and extent of
contamination which  presents a threat  to the  public health and
the  environment,  and  (2)  obtain the  information  necessary to
develop  and  evaluate remedial  alternatives.   The  Ewan Property
Site Remedial  Investigation Report  does not  adequately fulfill
these   objectives.    First,   the  RI   does   not  sufficiently
characterize the  contents  of  the drums.  Since only  six total
samples  were  taken  from   an  estimated 500  to  8000  drums.
Moreover, the estimate of the total number of drums  (500 to 8000)
is not supported by any factual data.  The only identified source
of this  estimate  is  given as unknown "parties  familiar with the
site".

With respect  to  the gathering  of information in  support  of the
development of remedial alternatives in the Feasibility Study the
RI likewise fails to provide the  necessary critical data.   Again
the lack of information on  the  wastes contained in the drums and
total number of drums is  critical.   The selection of appropriate
disposition methods  for the  drum contents may  vary drastically
depending  on  their nature   (organic or' inorganic)  and physical
state  (solid  or  liquid).   The location  and condition  of drums
will 'also effect  the remedial  alternatives development and these
are as yet not  adequately defined.   The water  table is within 6
to 10 feet of the ground  surface  and the possibility exists that
a number of the  drums  may be in  the saturated  zone.  This would
greatly  effect  the progress of  excavations  necessary  for drum
removal.

feasibility Study Objectives

The overall objective of  the CERCLA Feasibility Study process is
the  identification  of  the  most  appropriate,  cost  effective
alternative(s) for remediation of a site.  The Ewan Property site
FS is focused on  only  the buried drums  on-site  and the adjacent
"highly  contaminated"  soils.    This   does   not  appear  to  be
appropriate,- because adjacent  soils may  contain  non-visible yet
significant concentrations  of the constituents  of concern.  More
importantly the  risk  assessment  identified the  potential  future
use  of  groundwater as  the  only  significant  risk posed  by the
site.  Based  on  the rate of groundwater movement  in  this area,
the risk assessment indicates  that  groundwater  impacts may occur
24 or more years  in the future.  Therefore, the immediate removal
of drums does not appear to be justified based on potential short
term  threats  to  public  health.   The  FS does  not  address  the
groundwater pathway  at all.   In  fact,   it is possible  that the


                               -4-

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drum excavation, prior to the  appropriate  waste characterization
program, could  exacerbate the  potential  groundwater  problem  by
causing corroded drums to spill during removal operations.
                               -5-

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4.0  SITE INVESTIGATION

The  site investigation  activities  included  a soil  gas survey,
geophysics  surveys,  test  pit  installation,  and  environmental
media  sampling (soil, groundvater,  sediment, surface  water and
air) .  The results  of the investigation is a characterization of
the  present  site  contamination.  There  are several inadequacies
regarding the activities conducted during the investigation.

     o  Geophysical  Surveys:    Electromagnetic conductivity  (EM
        34)  and magnetic  surveys were conducted  of  the  site.
        Because the drums are  reported to be near the surface,
        additional  information  could  be obtained using an  EM 31
        model.  The EM  31 has  an  effective  depth of  15  feet.
        This data may be used to confirm the magnetometer survey.
        Another geophysical method which has proven effective for
        locating  trenches  or  disturbed  soil  areas   is  Ground
        Penetrating  Radar  (GPR) .  Both  the EM 31  and  GPR  might
        have been  more effective in  developing a  more accurate
        estimate of the  exact  location and  resultant  volume of
        drums to be removed.

     o  Test Pit Operations:  The location of test pits based on
        soil gas,  geophysical and visual information was
        ineffective  since  only 4  of  9  test  pits in Area  A
        uncovered drums.    Data  correlating the location of  drums
        with   respect .to  the  water   table,  the  amount  of
        contaminated   soils  surrounding'  the  drums   and  the
        condition of  the  drums  was not  collected during the test
        pit operations.  These  were identified as  the objectives
        of the test pit operation on page 29 of the RI report and
        they  were  apparently  not  addressed during  the  field
        investigation.

     o  Subsurface  Investigation:   The study  was deficient  in
        several respects.   Several soil sampling locations  which
        did not  show evidence  of  contamination are  included in
        the  estimated contaminated  area.   Another soil  boring
        sample  (EP-SO-013-M)  contained   levels  of  lead  (6%)  and
        organic  compounds;  however,   there  appears  to  be  no
        provision for addressing such heavy metals.

     o  Soil  Gas   Survey:    The  report   does  not  provide  a
        discussion  of  the  analytical  instruments used,  the
        analytical methods or the field sampling procedures.  The
        NUS  procedure cited  in the  text  is not provided  in
        Appendix E.   The results are  normally presented in  the
        text of the report not in an appendix.  The usefulness of
        the  survey  is dependent on the procedures used,  since
        these  are  not given  no meaningful  evaluation can  be


                               -6-

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performed.   Additionally,   the  information  for  pH  and
conductivity screening  should be separated  into  another
section.   Presenting this  information in  the soil  gas
section confuses the issue.
                       -7-

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5.0  ENDANGERMENT ASSESSMENT

In the Level  3  risk assessment that was performed for this site,
there is insufficient detail regarding selection of the indicator
chemicals.  The following statements provide more  detail of the
major issues  in the assessment:

     o  Air quality was  not of concern during the field  studies,
        as indicated in Section 6.0 of the RI.  Hence, no ambient
        air sampling program  was conducted as  part of  the RI.
        However, there was evidence of VOC's in  the  air in some
        of the  test pits  and  monitor wells as measured  by both
        OVA and PID.   As  a  preponderance  of indicator chemicals
        being volatile  in  nature,  it may  be expected  that air
        quality  could  be  affected  during drum  excavations.   If
        large numbers of drums  (e.g. in the thousands) are found,
        there may  be  a  need  for  vapor  suppression technology
        during  active  excavation  remedial actions  depending  on
        the actual condition  of  the drums,  type  of  materials
        found, and amount  of liquid remaining in the  drums.

     o  The risk  assessment  summary  concludes  that "the  only
        significant  risk posed is  to potential  future  users  of
        site  groundwater."  On page  131 of the  RI  it  is noted
        that  the  closest resident to  the  south of the  site (in
        the  direction  of  groundwater  flow)  is  1  mile  (920
        meters)  .   The  value  920  meters  was  used  in the  risk
        assessment;  however,  one  mile is  1,609  meters  not 920
        meters.   In addition,  at an estimated flow velocity of 99
        feet  per  year   for  water  at the  top  of the   Cohansey
        Formation  (p. 86)  it would  take 30.5 years to travel 920
        meters  or 53.3  years to  travel 1  mile.   Based  on the
        information presented  in  the RI, there appears  to be  no
        immediate threat to the public health.

     o  Finally,  in the  risk  assessment discussion  of   exposure
        pathways  (p.  133  of  the  RI)  the  following  statement  is
        made:

           "Presently there  is no basis for assessing exposure or
           risk  to  on-site surface  soils  or  waste materials.
           Although   these    materials   are   the   source   of
           environmental   contamination,  direct  exposure  under
           present  site  conditions  is unlikely.  A significant
           degree of soil  disturbance  at some  time in the future
           may  increase   the  potential  for  human  health  and
           environmental exposure."
                               -8-

-------
This  statement  directly  contradicts  the  focus  of  the
Feasibility  Study.   There  no  immediate  and  substantial
hazard presented by the soils and buried waste materials.
                       -9-

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6.0  FEASIBILITY STUDY

The  comments were  limited to  substantial  issues  which  have  a
bearing on the selection of a remedy as follows.

Validity/Integration of Operable Units

The  Feasibility  Study was specifically designed  to address only
the  buried drums and the adjacent visibly stained  soils.   These
media were designated as  an operable  unit for the purpose  of the
FS  and  associated  remedial  actions.    The designation  of  an
operable  unit is typically  made to  segregate and  simplify the
analysis  of  alternatives  for discrete site  areas/media  in order
to accelerate cleanup.   The  solution for one  discrete  operable
unit should  have little  impact on the  selection/performance  of
any  other.   If this  is  not true,  the  alternative analysis  should
then encompass the  more comprehensive coupled  areas/media in  an
integrated manner.

The  identification of  buried  drums and visibly stained  soils  as
an operable  unit - (Operable Unit  No.  1)  for this  site  does not
appear  to be appropriate,  as  the   alternatives  developed  for
Operable  Unit No. 1  will impact  the media  to be  addressed  as
Operable  Unit  No.  2  (i.e.   residual  soil  contamination  and
groundwater  contamination may  increase  due to  waste  handling).
The  distinction  between visibly  stained soils  and contaminated
soils  is  an  artificial  one   relative   to  both   the   cleanup
objectives and the appropriateness of technologies  which will  be
considered for the different operable units as currently defined.
In particular,  technologies  which may  be employed  for  Operable
Unit No.  2 remediation  may be applicable  to Operable Unit No.  1
remediation.    This  includes  technologies  not  selected  in  the
current FS.

The drum excavation alternatives developed and analyzed in  the  FS
raises the  concern that  drum damage  common to  such  activities
will result  in waste  losses during the excavation to surrounding
soil and  groundwater.   Due to the length  of time the drums have
been buried,   acidic soils  and high water  table, the condition  of
the drums is highly suspect and waste' losses must be anticipated.
Such waste losses  may not be visible or  recoverable.  Without  a
comprehensive approach to soil and groundwater cleanup concurrent
with  drum removal,  .these activities  may  actually  exacerbate
contaminant  levels and migration potential in the groundwater.

Perhaps more importantly,  the Endangerment Assessment identified
groundwater  transport  to  off-site  groundwater users  as the
principal threat  to  public health.   It  conservatively  estimated
that such potential public health impacts would occur 24  (page  6,
FS)  or more  years from the present.  These results do not support


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an  immediate  removal  or interim  remediation  focused  upon drum
removal  based  on  protection  of  the  public  health  and  the
environment.  Groundwater, which was  identified  as the principal
pathway, is not addressed in the FS.

Rather than enhancing  protection of public health, the immediate
removal of  drums  would more likely have value in minimizing the
volume of contaminated soil which  might occur if an intact drum
were to  leak  prior to initiation  of the  comprehensive remedial
action.  This  benefit may  be  outweighed by the  inefficiency of
deactivating the site and, potentially, subsequently 'returning to
identify and  remediate  soils and groundwater with non-visible
residual concentrations.

Based on these considerations, the FS should have been conducted
on the basis of an  integrated analysis of the previously defined
Operable Units 1 and 2.

Further comments  on the FS  are  oriented toward  the existing FS
basis focused on Operable Unit No.  1.

Technology/Alternative Screening Process

The technology screening and alternative  analysis criteria used
in the FS are  generally consistent with current  RI/FS guidelines
with.some exceptions.

In  the FS  at P.  49,  it  is  stated that  the  alternatives for
remediation of Operable Unit No. 1 are interim/expedited measures
which do not have to meet all site cleanup requirements.  Yet the
screening and  selection  of  technologies apparently did not allow
for the  selection of technologies  or evaluation of alternatives
that did not  meet goals  of reduction of  mobility,  tpxicity and
volume  or  did not  represent  a  "final"  solution.   Since  the
characteristics  of waste  materials  is,  as  yet,  lacking,  such
"technologies"  or  approaches  should  have  included1  temporary
storage  (following over-packing,  stockpiling,  and  testing)  and
land  disposal (for  solid  wastes  which  are more appropriately
landfilled  than thermally treated).   The current FS alternatives
only  provide   for thermal-  treatment  or  no action.   Successful
implementation of thermal treatment may be thwarted by the  waste
properties  that are as yet  uncharacterized.   The selection of an
alternative  which   provides  for  proper   evaluation  and  for
flexibility   in   routing  waste   materials  to   their  ultimate
treatment/disposition would enhance the probability of successful
implementation.

Current  guidance also allows  for evaluation  and  selection  of
alternatives which do  not meet ARARs  if equivalent performance in
protecting public health and the environment can  be achieved.  In


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this  regard,  technologies which  might  be equally  protective,
particularly  in  the  context  of a  comprehensive  site  remedial
alternative, were not selected for evaluation.

For all  these  reasons,  the number of  alternatives developed for
analysis in the FS was insufficient.

Volume Estimation

The volume  estimate of  the material  to  be remediated  for both
Operable Units  1  and  2  is  currently imprecise.   Operable  Unit 1
is estimated to contain 8000  drums,  each one-half full,  plus a
volume  of  soil  equal  to  8000  drums.   Essentially,  these  are
assumptions based on  personal recollections and  a  best  guess of
leakage upon removal  of drums.  As noted in Section  3.0 of this
review,  there   is   no   reliable  basis  for   these  estimates.
Therefore,  evaluations  of  remedial  actions  in  the  FS are  not
based on  reliable data.  The  quantity of liquids  could vary by
several  orders  of magnitude,  depending on  how many  drums were
buried, how many  contained  liquids,  and how many have previously
leaked.  The  soils  in  immediate contact with  the waste  can be
expected to vary in a similar manner.

Generally,  the  cost   of   any  on-site  remediation  effort  is
sensitive    to    quantities,    due     to    capital    costs,
mobilization/demobilization,  start-up,  transportation  charges,
and '(if  applicable)  permitting  costs.  No  sensitivity  analysis
was conducted to show the variation in total alternative costs as
a  function  of  volume/number  of  waste/drums.   In  regard  to
operable Unit  2, there is again  no  reliable  data showing  the
quantities  involved.    Without  this   information,   it   is  not
possible to  accurately  evaluate alternate technologies.   In  the
case  of  this  FS,  only  on-site and  off-site  incineration  were
evaluated.  However,  as noted herein, other technologies may also
aPPly» and should be considered.

Validity of Incineration

The FS  only evaluates  two options  in addition  to  no  action:
on-site  and   off-site   incineration.    While   incineration   is
generally applicable to destruction  of concentrated organics,  it
is not necessarily the most appropriate option  for all the waste
material and stained soil at the site.  Neither the soil nor  the
drums  are  characterized  to  the  degree  necessary  to  assure
acceptance  by   an off-site incinerator,  or utilization  of  an
on-site incinerator.   The BTU  values,  moisture  content,  chloride
concentrations,  and  volatile  metals  concentrations are largely
undefined.   These parameters  will greatly  affect  the  economics
and technical feasibility of incineration.
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The  FS  attempts  to  address  this  issue  by  requiring  interim
storage while the wastes are being characterized.  However, there
is  no   allowance   other   appropriate   treatment  technology  or
disposition   other   than   by   incineration   based   on   the
characterization results.

Waste Characteristics

The FS attempts to identify a technology (incineration) that will
be  applicable  to direct  treatment  of  all wastes  on  site.   As
noted   in   the  .previous  section,   there   is   insufficient
characterization  data  available  on  source  material.   It  is
reported that the wastes were  generally brought  on-site in drums
by truck over at  least a two year period.  The  number,  type,  an
identity of  generators contributing  to the  site have  not  been
established.   It  should be  expected  that  wastes bought on-site
over  this  long a  time  frame,  and very  possibly  from multiple
sources, will vary  in  content.   Therefore,  neither  the drums nor
the  contaminated  soil  can be expected to be  suitable  for any
single type  of  remedial technology.  The  lack  of data  makes  it
necessary either to  conduct  additional  characterization efforts,
or   to   design   a   remedial  action  program   with   sufficient
flexibility to deal with varying waste types and quantities.

Other Potentially Viable Technologies

Although numerous technologies were  screened in  the  FS,  not all
potential  alternatives were considered.    For   example,  in-situ
volatilization  can  be used  for  removal of volatile  organics  as
can low temperature thermal treatment.  Also of potential use are
extraction and  stabilization.   Stabilization was screened as  an
on-site process.  However,  this  process can also be  carried out
at  the  point of disposal  and  eliminate potential  fugitive  dust
problems at the site.
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7.0  CONCLUSIONS AND RECOMMENDATIONS

Based on  a review  of the  Evan Property Site  RI/FS report  the
following conclusions were reached:

     o  An expedited response of drum removal on  the basis of an
        imminent and substantial hazard to the  public health  and
        environment is  not  justified  based  on the  information
        presented in the RI.

     o  The data base developed in the RI is not  sufficient  for
        the development  and evaluation of remedial  alternatives
        required in the FS.

     o  The   alternatives   which   were  developed   cannot   be
        adequately   evaluated   for  selection  of   the   most
        appropriate,  cost  effective,  land  protective  remedial
        action for the site.

In order to address the issues outlined above the following steps
should be taken:

     o  Further geophysics surveys using EM  31  and GPR  should be
        conducted for definition and location of the  trenches  and
        associated buried drums.   Also, test trenches uncovering
        larger areas  of  drums  should be  installed to  allow  for
        drum  sampling,   assessment  of  drum  conditions,   and
        determination of the  amount  of  contaminated  soils  in
        relation  to  the  number  of  drums   and  evaluation   of
        dewatering  techniques  which   may   be  required   in  a
        full-scale drum removal operation.

     o  If an interim remedial  action  of  Operable Unit No. 1 is
        pursued  there should  be  sufficient flexibility  during
        remedial  activities  to   allow  for  on-site  decisions
        concerning the disposal of soil and  waste material based
        on their  chemical characteristics,   physical  properties,
        and quantities.

     o  An interim  remedial  action should  also allow for  future
        integration  of   the operable  units,   especially with
        respect to the disposition of other contaminated soils.

tlb
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