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
-------
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)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-3S)
Department of Commerce
-------
DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT
INSTRUCTIONS
Optional Form 272, Report Documentation Page is based on Guidelines for Format and Production of Scientific and Technical Repo
ANSI Z39.18-1974 available from American National Standards Institute. 1430 Broadway. New York, New York 10018. Each separately
bound report—for example, each volume in a multivoJume set—shall have its unique Report Documentation Page.
1. Report Number. Each individually bound report shall carry a unique alphanumeric designation assigned by the performing orga-
nization or provided by the sponsoring organization in accordance with American National Standard ANSI Z39.23-1974, Technical
Report Number (STRN). For registration of report code, contact NTIS Report Number Clearinghouse, Springfield, VA 22161. Use
uppercase letters. Arabic numerals, slashes, and hyphens only, as in the following examples: FASEB/NS-75/87 and FAA/
RD-75/09.
2. Leave blank.
3. Recipient's Accession Number. Reserved for use by each report recipient.
4. Title and Subtitle. Title should indicate clearly and briefly the subject coverage of the report, subordinate subtitle to the main
title. When a report is prepared in more than one volume, repeat the primary title, add volume number and include subtitle for
the specific volume.
5. Report Date. Each report shall carry a date indicating at least month and year. Indicate the basis on which it was selected (e.g.,
rlate of issue, date of approval, date of preparation, date published).
6. Sponsoring Agency Code. Leave blank.
7. Author(s). Give name(s) in conventional order (e.g., John R. Doe. or J. Robert Doe). List author's affiliation if it differs from
the performing organization.
8. Performing Organization Report Number. Insert if performing organization wishes to assign this number.
9. Performing Organization Name and Mailing Address. Give name, street, city, state, and ZIP code. List no more than two levels of
an organizational hierarchy. Display the name of the organization exactly as it should appear in Government indexes such as
Government Reports Announcements & Index (GRA & I).
10. Project/Task/Work Unit Number. Use the project, task and work unit numbers under which the report was prepared.
11. Contract/Grant Number. Insert contract or grant number under which report was prepared.
12. Sponsoring Agency Name and Mailing Address. Include ZIP code. Cite mam sponsors.
13. Type of Report and Period Covered. State interim, final, etc.. and. if applicable, inclusive dates.
14. Performing Organization Code. Leave blank.
15. Supplementary Notes. Enter information not included elsewhere but useful, such as: Prepared in cooperation with . . . Translation
of... Presented at conference of ... To be published in ... When a report is revised, include a statement whether the new
report supersedes or supplements the older report.
16. Abstract. Include a brief (200 words or less) factual summary of the most significant information contained in the report. If the
report contains a significant bibliography or literature survey, mention it here.
17. Document Analysis, (a). Descriptors. Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms
that identify the major concept of the research and are sufficiently specific and precise to be used as index entries for cataloging.
(b). Identifiers and Open-Ended Terms. Use identifiers for project names, code names, equipment designators, etc. Use open-
ended terms written in descriptor form for those subjects for which no descriptor exists.
(c). COSATI Reid/Group. Reid and Group assignments are to be taken from the 1964 COSATI Subject Category List. Since the
majority of documents are multidisciplinary in nature, the primary Field/Group assignment(s) will be the specific discipline,
area of human endeavor, or type of physical object. The application(s) will be cross-referenced with secondary Reid/Group
assignments that will follow the primary posting(s).
18. Distribution Statement. Denote public reusability, for example "Release unlimited", or limitation for reasons other than
security. Cite any availability to the public, with address, order number and price, if known.
19. & 20. Security Classification. Enter U.S. Security Classification in accordance with U.S. Security Regulations (i.e., UNCLASSIFIED).
21. Number of pages. Insert the total number of pages, including introductory pages, but excluding distribution list, if any.
22. Price. Enter price in paper copy (PC) and/or microfiche (MF) if known.
: -H3 : - 331-525 (3393) OPTIONAL FORM 272 BACK (4-77)
-------
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.
-------
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.
-------
-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
-------
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.
-------
-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;
-------
-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.
-------
-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.
-------
-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.
-------
-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.
-------
-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.
-------
-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.
-------
-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.
-------
-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
-------
-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.
-------
-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.
-------
-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.
-------
-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.
-------
-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.
-------
-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.
-------
-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.
-------
-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.
-------
-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.
-------
-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)).
-------
-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.
-------
-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
-------
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.
-------
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.
-------
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
-------
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.
-------
RESPONSIVENESS SUMMARY
-------
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).
-------
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
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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
-------
a
*jr»i - It
'
• a
""V^
-------
nn * by ** Qf
""
^ la c
•
-------
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-
-------
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-
-------
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
-------
NUS CORPORA TION AND
CUENT; - .
^!jECT P Au
suasioiMues STANDARD CALCULATM
FILE
Drofx (
NOYffq
U^m<
IV
^•€.
LJ^T^
CHECKED BY:
f AGE / OF ^
DA TE *
^^ / ^ *
U»sr-. -vr.-
_^_ JJL.
So
i r i
£00
S^Soo
(
«- V-.,,
/.i
7.03
-------
NUS CORPORA TION AND SUBSIDIARIES STANDARD CALCULATION^
CUINT:USiP^
SUtJECT-
£-UJ
*t'r
FILEN0^,V
<-
8vrl 'oo
;oo
to JOo
600
te ^co
.50
^00 i7S
JO
3co
100
100 ^oo
A
C .
5.*?
0
*. - .
b ,-
5 J5
o- >-
$1,12Q
-------
^ ^-4
^ ^
*» i*
j.-
f.
/•^
c >
Fc*?o
•7"
'CO ,.- C>?s
>i£ ** 5t£
/o0 ^ << Co ^'
•* /f^ - ^03
."•*c ^ ^''L--?
te'i '*3 ij'.'?*
JK 'i* *,Xf
:: ' : - |i ="0o /«l£ Oc^T'/
- = r ... " '-^ ,- - ' <- 9
' ,' ' /- -> &C',-
'• ' ' t£ y - °>^
-.;.:.u_. / /.c^ yo0 r/;^*/ •
I ••" •/ ^ /e^ -'*°x
¥•-••'• '*< .^ -^9^
«; c^o^ °o ^r;/
•ij..' . • . k . /*^ • t*^* ^ ^
^>5 /°° cV^/
^n /0o ''^-° ^
/--0 /00 -7^/ ^Vr
w c V ^ "^
Hwf O-> ' C ^"*/ ^ '^t '••
•OO O ^- 7/L 0 « '^
-• ^ * *«&.
£o * ^,8^ "^
ff^ £° tf/vc, •(>(.
I* •% ^v'y^ %;
^0 -0 ^3 ^U;
<^- ?£ f^ ^:
*to pi -^0« ^;''-
^o ^ ^6>,4° j3"'
JJA- ^S vSvC4 /^
>-.«6 /*?/ -:^
° /,'5?/ #
^>flJ 5y?/
•^U
^^ ,
> ^C /^:.t
^4 ?
4f f i*
''Vr /?7^>3
^^ ^'
<0* ^^l
^ ? -«?/
^/ r .^
• --o^ «
,' • '•-
' ''•-•:'
.-• »C
/^to.i/
/AJr
*<*
X 5 '
••*?
, '• r«i 5-
x/3^
£•*{."
-• ?j ??:•
^j- ."0
r-J^ • -.-^
?"
6^ii '. -
(V>¥
9j-^ >^'
r ,. . •"•'./
w» * X /• . '
-'•>o
U
£s
^
A
^
#•
s» .-
^-'.
^•r
^'•F-
^ ^
r^1'
• >
« *
>J
•%
•
»
Q
i
-------
-<
*so.
-c
MliMJ'
IjjjjP
-------
I
PAGE 2
550,700,54734.1
575,700,54147.9
600,700,54616.4
625,700,54337.8
650,700,54725.5
675,700,54602.4
700,700,54301.6
725,700,54595.8
750,700,54075.1
775,700,54726.8
800,700,54541.0
825,700,54212.6
825,675,54727.0
800,675,54727.3
775,675,54725.7
750,675,54734.6
725,675,54731.7
700,675,54711.6
675,675,54722.2
650,675,54717.4
625,675,54719.6
600,675,54712.9
575,675,54707.6
550,675,54738.5
525,675,54657.0
500,675,54574.3
475,675,54672.6
450,675,54696.1
425,675,54724.6
400,675,54732.7
325,650,54722.6
350,650,54724.1
375,650,54717.2
400,650,54712.6
425,650,54695.8
450,650,54670.2
475,650,54604.7
500,650,56269.8
525,650,54638.1
550,650,54720.7
575,650,54748.4
600,650,54798.2
625,650,54732.9
650,650,54730.3
675,650,54693.3
700,650,54730.6
725,650,54722.9
750,650,54715.9
775,650,54725.3
800,650,54723.7
775,625,54724.4
750,625,54725.8
725,625,54715.3
700,625,54724.0
-------
PAGE 3
675,625,54716.3
650,625,54720.8
625,625,54720.2
600,625,54712.6
575,625,54694.3
550,625,54665.9
525,625,54668.7
500,625,54610.3
475,625,54642.1
450,625,54527.7
425,625,54616.5
400,625,54683.0
375,625,54703.6
350,625,54716.8
325,625,54720.2
300,625,54802.4
275,625,54720,?
175,600,54722.1
200,600,54720.2
225,600,54723.7
250,600,54726.5
275,600,54724.5
300,600,54719.0
325,600,54728.6
350,600,54757.6
375,600,54752.1
400,600,54711.9
425,600,54655.8
450,600,54529.1
475,600,54134.0
500,600,54533.7
525,600,54500.8
550,600,54151.2
575,600,54503.8
600,600,54644.5
625,600,54690.0
650,600,54718.6
675,600,54768.2
700,600,54752.6
725,600,54717.7
750,600,54723.5
775,600,54725.1
800,600,54721.6
825,600,54723.5
825,575,54724.5
800,575,54732.6
775,575,54720.2
750,575,54742.2
725,575,54717.2
700,575,54715.7
675,575,54709.9
650,575,54683.2
625,575,54641.0
600,575,54587.8
-------
PAGE 4
575,575,55213.7
550,575,56629.8
525,575,54499.6
500,575,54673.6
475,575,57131.5
450,575,54618.7
425,575,54726.8
400,575,54694.3
375,575,54701.6
350,575,54737.0
325,575,54704.9
300,575,54711.1
275,575,54720.3
250,575,54725.4
225,575,54721.3
200,575,54741.6
125,550,54722.^
150,550,54721.3
175,550,54724.1
200,550,54717.7
225,550,54714.7
250,550,54719.1
275,550,54732.7
300,550,54739.6
325,550,54729.6
350,550,54709.3
375,550,54683.6
400,550,54674.6
425,550,54657.0
450,550,54671.3
475,550,54875.9
500,550,54692.7
525,550,54601.6
550,550,54597.8
575,550,55134.5
600,550,54570.6
625,550,54666.6
650,550,54688.6
675,550,54708.9
700,550,54697.2
725,550,54714.9
750,550,54732.7
775,550,54720.6
800,550,54742.1
825,550,54729.8
825,525,54738.9
800,525,54718.2
775,525,54736.3
750,525,54711.2
725,525,54760.5
700,525,54727.6
675,525,54714.4
650,525,54705.1
625,525,54685.7
-------
PAGE 5
600,525,54652.1
575,525,54583.9
550,525,55712.4
525,525,54869.5
500,525,54021.7
475,525,54378.8
450,525,54553.4
425,525,54573.1
400,525,54589.7
375,525,54610.5
350,525,54629.8
325,525,54630.2
300,525,54655.4
275,525,54678.7
250,525,54671.8
225,525,54714.8
200,525,54710.5
175,525,54717.1
150,525,54717.6
125,525,54716.4
100,525,54740.7
75,525,54723.2
50,525,54721.5
25,500,54747.6
50,500,54770.9
75,500,54729.3
100,500,54717.4
125,500,54735.8
150,500,54751.2
175/500,54715.9
200,500,54707.0
225,500,54695.8
250,500,54656.2
275,500,54641.4
300,500,54607.0
325,500,54638.0
350,500,54549.3
375,500,54123.9
400,500,54560.7
425,500,54564.6
450,500,54386.9
475,500,54316.0
500,500,54092.8
525,500,55577.4
550,500,55766.6
575,500,54621.4
600,500,54683.3
625,500,54694.9
650,500,54710.0
675,500,54683.6
700,500,54709.6
725,500,54717.1
750,500,54718.1
600,475,54663.8
-------
PAGE 6
575,475,54625.8
550,475,54553.9
525,475,54727.9
500,475,55234.9
475,475,55517.4
450,475,55241.0
425,475,54744.6
400,475,54366.4
375,475,54537.2
350,475,55855.4
325,475,54645.2
300,475,54573.8
275,475,54486.8
250,475,54430.0
225,475,54593.0
200,475,54672.8
175,475,54701.7
150,475,54702.5
125,475,54712.0
100,475,54723.1
75,475,54726.5
50,475,54721.6
25,475,54726.7
75,450,54740.4
100,450,54729.3
125,450,54715.6
150,450,54716.4
175,450,54708.0
200,450,54696.5
225,450,54657.8
250,450,54491.3
275,450,55024.2
300,450,53925.2
325,450,54356.3
350,450,54579.5
375,450,54670.7
400,450,54585.8
425,450,54810.0
450,450,54681.8
475,450,54654.1
500,450,54664.7
525,450,56505.4
550,450,54878.8
575,450,55055.8
600,450,54628.2
625,450,54691.2
650,450,54703.1
675,450,54707.3
700,450,54715.1
725,450,54714.2
725,425,54716.9
700,425,54713.9
675,425,54708.6
650,425,54699.5
-------
PAGE 7
625,425,54678.3
600,425,54593.2
575,425,54324.1
550,425,54222.7
525,425,54591.3
500,425,54607.1
475,425,54531.7
450,425,54449.7
425,425,53870.5
400,425,53926.3
375,425,54486.0
350,425,54443.8
325,425,54267.6
300,425,57351.7
275,425,55597.2
250,425,54575.7
225,425,54672.0
200,425,54696.3
175,425,54701.7
150,425,54708.7
125,425,54717.7
100,425,54711.7
75,425,54718.1
25,400,54768.4
50,400,54649.9
75,400,54705.9
100,400,54705.3
125,400,54712.6
150,400,54706.3
175,400,54633.6
200,400,54686.6
225,400,54665.2
250,400,54646.2
275,400,54588.3
300,400,54691.0
325,400,55230.4
350,400,54429.8
375,400,54273.7
400,400,54497.4
425,400,54515.6
450,400,53771.2
475,400,54205.0
500,400,54243.6
525,400,53987.8
550,400,57167.5
575,400,59909.0
600,400,54544.6
625,400,54676.1
650,400,54641.3
675,400,54617.2
700,400,54523.0
725,400,54698.7
725,375,54726.8
700,375,54715.8
-------
I
PAGE 8
675,375,54485.0
650,375,54702.0
€25,375,54693.6
600,375,54642.3
575,375,54664.0
550,375,54527.0
525,375,54379.7
500,375,54616.8
475,375,54379.3
450,375,56746.7
425,375,55982.1
400,375,54332.9
375,375,54384.6
350,375,53797.9
325,375,54280.4
300,375,54665.9
275,375,54667.3
250,375,54659.0
225,375,54657.2
200,375,54707.8
175,375,54686.1
150,375,54661.5
125,375,54666.1
100,375,54675.0
75,375,54687.2
50,375,54699.2
25,375,54700.1
75,350,54634.4
100,350,54610.4
125,350,54606.6
150,350,54521.9
175,350,54401.0
200,350,54509.7
225,350,54610.6
250,350,54625.2
275,350,54619.2
300,350,54543.7
325,350,54834.9
350,350,56416.3
375,350,54356.3
400,350,54501.5
425,350,54825.1
450,350,55701.3
475,350,54647.0
500,350,58978.3
525,350,55391.3
525,325,54795.7
500,325,54637.4
475,325,54527.6
450,325,55127.6
425,325,60087.5
400,325,54498.3
375,325,55079.1
350,325,56012.5
-------
PAGE 9
325,325,54754.8
300,325,54463.5
275,325,53952.7
250,325,54282.2
225,325,54464.9
200,325,59605.4
175,325,56026.5
150,325,54146.7
125,325,53829.4
100,325,54024.6
75,325,54511.1
50,325,54331.2
25,300,54206.8
50,300,54817.6
75,300,54613.6
100,300,55834.4
125,300,54511.2.
150,300,54963.3
175,300,55335.5
200,300,54235.5
225,300,54173.3
250,300,55269.2
275,300,54447.0
300,300,54060.0
325,300,54588.6
350,300,54676.0
375,300,55226.8
400,300,54682.5
425,300,54451.3
450,300,53829.1
475,300,54659.9
500,300,54167.9
525,275,54027.5
500,275,53912.6
475,275,54681.2
450,275,54889.7
425,275,55048.0
400,275,54631.2
375,275,54138.9
350,275,54418.6
323,275,54594.1
300,275,54626.7
275,275,54507.5
250,275,54927.5
225,275,54568.8
200,275,54363.3
175,275,54091.8
150,275,54580.8
125,275,54358.8
100,275,55021.2
75,275,54501.5
50,275,54665.2
75,250,54382.1
100,250,54223.1
-------
PAGE 10
125,250,54447.1
150,250,54238.0
175,250,55818.0
200,250,54140.2
225,250,54445.7
250,250,54440.4
275,250,54417.2
300,250,54480.9
325,250,54105.2
350,250,54142.0
375,250,54965.7
400,250,54232.1
375,225,55000.3
350,225,54256.7
325,225,53836.9
300,225,54613.9
275,225,54730.0
250,225,54857.9
225,225,54010.9
200,225,53591.9
175,225,54971.1
150,225,54503.3
125,225,54104.0
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
REVIEW ON RI/FS
FOR
EWAN PROPERTY SITE
SHAMONG TOWNSHIP, NEW JERSEY
Prepared by
ROY F. WESTON, INC.
September 1988
-------
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
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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
-10-
-------
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
-11-
-------
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.
-12-
-------
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.
-13-
-------
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
-14-
------- |