Superfund Record of Decision: Ewan Property, NJ (September 1989)


           United States
           Environmental Protection
           Agency
              Office of
              Emergency and
              Remedial Response
EPA/ROD/R02-89/095
September 1989
&EPA
Superfund
Record of Decision
            Ewan Property, NJ

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16.  Abstract (Continued)

EPA/ROD/R02-89/095
Ewan Property, NJ

 The selected remedial action for this site includes excavating and treating 22,000
cubic yards of soil using solvent extraction and soil washing,  followed by redepositing
treated soil onsite as clean fill; treating and disposing of spent solvent offsite;
treating spent wash water onsite using the ground water treatment system; regrading and
revegetating disposal areas; pumping and treatment of ground water followed by
reinjecting treated ground water into.the underlying aquifer; and environmental
monitoring.  The estimated present worth cost for this remedial action is $35,152,447
which includes annual O&M costs of $1,903,980.

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50272-101
"REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-89/095
X Recipient:* Acoaaion No.
4. Tide and Subtitle
SUPERFUND RECORD OF DECISION
Ewan Property, NJ
Second Remedial Action - Final
5. Report Date
09/29/89
7. Author(s)
8. Performing Organization Rept No.
9. Peffoimlng Organization Nam and Addreu
10. ProjectfTaak/Work Unit No.
11. Contract(C) or Grant(G) No.

(C)

(G)
12. Sponaoring Organization Nam and Addrea*
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type ol Report ft Period Covered

800/000
14.
15. Supplementary Notea
16. Abatract (Limit: 200 word*)

The 43-acre Ewan Property site is in the New Jersey Pinelands in Shamong Township,
Burlington County, New Jersey. The site neighbors forests and forested wetlands,
farmland, and residences. An aquifer underlying the site contains a plume contaminated
by onsite disposal practices. Between 1974 and 1975 the site owner reportedly buried
ncontained and drummed hazardous wastes in an onsite disposal area. In 1982 the county
as informed of the possible hazardous waste dumping and initiated ground water
monitoring and soil sampling programs the following year. Both the ground water and
soil within the disposal area were found to be contaminated with VOCs and metals. This
remedial action represents the second of two operable units for the site. The 1988
Record of Decision addressed the treatment of 4,500 cubic yards of source waste
including buried drums and other heavily contaminated materials. This second operable
unit addresses the remediation of the residual soil which will remain after
implementation of the first operable unit and the treatment of the contaminated ground
water. The primary contaminants of concern affecting the soil and ground water are VOCs
including benzene, PCE, TCE, toluene, and xylenes; and metals including chromium and
lead. (Continued on next page).
NJ
17. Document Analyse a. Descriptor*
Record of Decision - Ewan Property,
Second Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, PCE, TCE, toluene, xylenes), metals (lead,
e. COSATI Held/Group
Availability Statement
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None
21. No.olPagea
114
22. Price
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SM Instruction* on fterarw
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DECLARATION STATEMENT

RECORD OF DECISION

BWAN PROPERTY (OPERABLE UNIT TWO)

Site Name and Location

Evan Property, Shamong Township, Burlington County, New Jersey

Statement of Basis
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• Collection and treatment of the contaminated ground water,
and reinjection of the treated ground water into the
underlying aquifer;

• Recontouring and restoration of the disposal areas; and

• Appropriate environmental monitoring to ensure the
effectiveness of the remedy.

Statutory Determinations

The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the remed-
ial action, and is cost-effective. The remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable and satisfies the statutory preference for
remedies that employ treatment that reduces toxicity, mobility,
and/or volume as a principal element. At the conclusion of this
remedy, there will be no hazardous substances remaining on the
site above health-based levels. However, because the remedial
goals will not be attained within five years, the five year
review will apply to this remedial action.
'w*' sts~*-^^,\.\- » j j^**~*fl~zrr~ y^—tf S ^K ' * *
William J. MHszYJfeJdrV/.E. I>ate
Acting Regional Administrator
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DECISION SUMMARY

RECORD OF DECISION

EWAN PROPERTY (OPERABLE UNIT TWO)

Site Location and Description

The Evan Property consists of forty-three heavily wooded acres in
Shamong Township, New Jersey. The New Jersey Department of
Environmental Protection (NJDEP) has concluded that the site,
which includes the contaminated groundwater plume, is located
within the Central Pine Barrens portion of the New Jersey
Pinelands. The site is approximately 4,000 feet south of
Tuckerton Road and 5,000 feet east-northeast of Indian Mills Lake
in Shamong Township, New Jersey. Land use within 1.25 miles of
the property is generally forests, forested wetlands, agri-
cultural land, and single family residential areas. Wharton
State Forest is approximately two miles south of the site.
Upper-middle income residential developments are located both to
the north and east. The nearest resident is located approx-
imately 1500 feet from the site.

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 sewage is
disposed of through individual private septic systems. Area
agricultural water usage is dependent upon the water table
aquifer. Ground water within the Cohansey Sand has been de-
termined to flow in a southerly direction. The nearest ground
water user downgradient from the site is located approximately
one mile away.

Two areas of industrial waste disposal were initially studied
during the preliminary site investigation, and were the focus of
the Remedial Investigation. The two areas were identified as
Area A (approximately nine acres) and Area B (approximately five
acres). Both Area A and Area B are identified on Figure 1. No
indication of industrial waste disposal was encountered in the
remaining portions of the property.

The significant findings of the Remedial Investigation and the
Operable Unit Two Feasibility Study are noted below:

• Area B was not identified as containing industrial-type
wastes. Therefore, Area B will not be addressed by the
Superfund program.

• Approximately 4500 cubic yards of source waste material
(i.e., drums and heavily contaminated materials) were buried
in the four acre tract of Area A (see Figure 2). These
materials will be addressed during the Operable Unit One
Remedial Action.
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APPROXIMATE EWAN
PROPERTY BOUNDARY
SCALf IN HIT
BASE MAP IS A PORTION cr THE US.O.S. SOUTHWEST INDIAN MILLS, NJOUOORAMOUEI 7.9 MINUTE SERIES, 1997.
PHOTOINSPECTEO 1972, CONTOUR INTEHVKL 10 FEET). EWAN PROPERTY LOCATION a APPROXIMATE.

FIGURE I
RESIDENTIAL
DEVELOPMENT
SITE LOCATION MAP
EWAN PROPERTY SITE. SHAMONG TWR. NJ
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STUDY AREA'A1
ESTIMATED EXTENT OF CONTAMINATED SOIL
REQUIRING REMEDIATION (OUI AND OU2)
_ (AS REFMD UJUNG ES CLC)
AREA OF MAGNETIC ANOMALY
TEST PIT

SOIL BORING

VISUAL OBSERVATION
MKJM LCVCLI v ret COMPOUNDS oertc
UO (M CVOCNCC Of (MUMS oaSCnvCO
A TEST PIT

O SOIL BORING
COMPOUNOS otrtcrco»r
NO VISIiLt f VIOCNCC OF OMUMS
NJOEP MONITORING WELL

ESTIMATED EXTENT OF AFFECTED AREA
FIGURE 2
APPROXIMATE EXTENT OF CONTAMINATED SOIL
EWAN PROPERTY SITE. SHAMONG TWR. NJ
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• The Remedial Investigation had estimated that 29,500 cubic
yards of contaminated soil exist within the burial trenches.
The Operable Unit Two Feasibility study further refined this
estimate to 22,000 cubic yards of soil which will require
treatment during implementation of the Operable Unit Two
Remedial Action.

• The principal source contaminants are largely chlorinated
aliphatic organic compounds (1,2-dichloroethane, tetra-
chloroethene, 1,1,1-trichloroethane, methylene chloride,
trichloroethene, carbon tetrachloride, 1,1-dichloroethane,
chloroform) and aromatic hydrocarbons (benzene, ethyl-
benzene, naphthalene, xylenes, toluene) as well as lead,
barium, copper and chromium.

• The ground water contaminant plume originating from Area A
continues to migrate. This plume is contained within the
Cohansey Sand aquifer. As presented in various geological
references and confirmed during the Remedial Investigation,
exposed portions of the Cohansey Sand geologic unit are
recharge areas for the aquifer. The sampling of ground
water in January, 1989 indicates that the contaminant plume
is approximately 760 feet long, 600 feet wide, and 30 feet
deep (see Figure 3).

Site History and Enforcement Activities

The United States Environmental Protection Agency (EPA) has
notified six potentially responsible parties of their possible
liability associated with the hazardous substances at the Ewan
Property. These potentially responsible parties are:

Chrysler Motors Corporation

A & B Drum Company

Lightman Drum Company

State Steel Drum Company

Ms. Verna Evan Donnelly

Mr. Francis Block

EPA has information to show that Mr. Herbert Evan conducted waste
disposal on his property within Area A in 1974 and 1975. His
general method of operation was to excavate one trench per truck-
load of drummed waste. The waste was deposited into the trench
and buried.
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HACHURES INDICATE HORIZONTAL EXTENT
OF PLUME (ONLY TOP OF COHANSEY FOR-
MATION IS AFFECTED)
omccTiOMOf ••. i;
GMOIMOWATEII FLOW II.
' s wioumiwm11» rmw ,1
' \\
\>
- -• - ^-
K-IO»0»COM»*mr

K • (OTTOM Of (OHAMM r

U. I O» O» UU1MOOO
FIGURE J
ESTIMATED CONTAMINATED GROUNDWATER PLUME (BASED ON 1989 DATA)

EWAN PROPERTY SITE. SHAMONG TWR. NJ
1011 Mill I
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Mr. Evan reportedly tried bulk uncontainerized disposal within
Area A. After incompatible wastes were mixed together, there was
a small fire on the site. Mr. Ewan did not attempt uncontain-
erized disposal after that incident. After Mr. Evan's death, his
wife, formerly Ms. Verna Dale Ewan, became the sole owner of the
Ewan Property.

In September, 1982 the Burlington County Health Department ob-
tained information that the dumping of possible hazardous waste
had occurred at the site.

In 1983, the NJDEP conducted a geophysical survey and installed
five monitoring wells in the Cohansey Sand aquifer within Area A.
The geophysical survey concluded that a significant magnetic an-
omaly existed within Area A. Sample results from these monitor-
ing wells indicated the presence of contaminants such as meth-
ylene chloride, toluene, chloroform, 2,4-dichlorophenol, n-butyl-
benzene, o-dichlorobenzene, p-dichlorobenzene, 1,2,4-trichloro-
benzene, arsenic, chromium, and lead.

NJDEP further attempted to characterize the site by bulk sampling
one drum and collecting soil samples from three areas of apparent
spillage. The contaminants detected in these four samples were
similar to the chemical compounds detected in the ground water.

EPA performed a Preliminary Assessment/Site Investigation in
1984. As part of this action, EPA conducted more geophysical
investigations within Area A including on-site and residential
well sampling. The geophysical investigation and on-site mon-
itoring veil results confirmed the earlier NJDEP ground water
findings. EPA determined that the nearby residential wells were
not impacted by on-site contamination.

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

EPA began the Remedial Investigation in September, 1986. During
these investigation activities, domestic refuse was found in Area
B. However, there was no evidence of industrial waste disposal.
Therefora, Area B was not addressed further by the Superfund
program.

EPA decided to divide the site remediation into two operable
units. Operable Unit One was developed to address the treatment
of the 4500 cubic yards of source waste. The Operable Unit One
Feasibility Study was completed concurrently with the overall
Remedial Investigation. Both documents were presented to the
public during August, 1988. The Operable Unit One Record of
Decision (ROD) was signed in September, 1988.
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In December, 1988, Chrysler Motors Corporation, a potentially
responsible party, completed the installation of a site security
fence around Area A. The action was conducted under the terms of
a Consent Order issued by EPA.

EPA is pursuing enforcement actions against potentially respons-
ible parties to conduct the Operable Unit One Remedial Design and
Remedial Action.

The Operable Unit Two Feasibility Study was designed to address
the remediation of the residually contaminated soils which will
remain after the Operable Unit One Remedial Action is implemented
and also the treatment of the contaminated ground water.

As part of the Operable Unit Two Feasibility Study, additional
ground water and soil samples were taken, and additional geo-
physical activities were conducted to better refine the contam-
inated soil volume. The soil samples were also used for a treat-
ability study to examine the potential use of two innovative
technologies: soil washing and solidification. The treatability
study determined the effectiveness and permanence of these tech-
nologies in reducing toxicity, mobility, or volume of contamin-
ants in the residual site soils. This additional study was con-
ducted from January, 1989 to July, 1989.

Highlights of Community Participation

The Operable Unit Two Feasibility Study and the Operable Unit Two
Proposed Plan for the Ewan Property were released to the public
on August 7, 1989. These documents were made available to the
public in both the administrative record of September 13, 1989
and an information repository maintained with Mr. Lynn Heinhold,
Shamong Township Clerk, Shamong Township Municipal Building,
Vincentown, New Jersey. The notice of availability for these
documents was published in the Burlington County Times on August
7, 1989. A public comment period was held from August 7, 1989
through September 11, 1989 (the public comment period was extend-
ed from September 6, 1989 to September 11, 1989 in response to a
public request). In addition, a public meeting was held on
August 17, 1989. At this meeting, representatives from the EPA
answered questions about problems at the site and the remedial
alternatives under consideration. A response to the comments
received during this period is included in the Responsiveness
Summary, which is a part of this ROD.
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8

This decision document presents the selected remedial action for
the Evan Property, in Shamong, New Jersey, chosen in accordance
with the Comprehensive Environmental Responsibility, Liability,
and Compensation Act of 1980 (CERCLA) as amended by the Superfund
Amendments and Re-Authorization Act of 1986 (SARA), and to the
extent applicable, the National Contingency Plan. The decision
for this site is based on the administrative record.

Scop* and Role of Operable Unit Two

The problems at the Evan Property site are complex. Therefore,
as noted previously, EPA separated the site remediation into tvo
phases or operable units. Operable Unit One vas designed to ad-
dress buried drums and heavily contaminated materials. Operable
Unit Two addresses residual contaminated soils and contaminated
ground vater.

EPA has already selected cleanup remedies for the buried drums
and heavily contaminated material. This "source material" is a
principal threat at the site because of the possibility of direct
contact and the impact of the material on the ground vater. The
remedies vere selected, after a public meeting and a 30-day pub-
lic comment period, in the Operable Unit One Record of Decision
signed on September 29, 1988. The 1988 Record of Decision called
for excavation and off-site thermal destruction and/or treatment
of approximately 4500 cubic yards of source material (i.e., bur-
ied drums and heavily contaminated materials). The source mat-
erial vill be separated into materials vhich are appropriate for
thermal destruction and materials vhich are not appropriate for
thermal destruction. Each source material classification vill be
treated accordingly.

Operable Unit Tvo vill address the remediation of the 22,000
cubic yards of less contaminated soils and the ground vater
contaminant plume remaining after the completion of the Operable
Unit One Remedial Action. The residual contaminated soil is a
principal threat at the site because of direct contact and the
impact of the soil corttaninants on ground vater. The contam-
inated ground vater vas also determined to be a principal threat
at this site because of the future potential for direct ingestion
of contamination through drinking vater veils.
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Summary of Site characteristic*

The Remedial Investigation established that approximately 4500
cubic yards of source waste material (i.e., drums and heavily
contaminated materials) were buried in the five acre tract of
Area A. These materials present a threat to public health and
the environment and will be addressed during the Operable Unit
One Remedial Action. After review of site records and waste
analysis, Resource Conservation and Recovery Act (RCRA) listed
wastes were not identified.

An estimated 22,000 cubic yards of residually contaminated soil
may exist on-site following the Operable Unit One Remedial
Action.

The primary source contaminants are largely chlorinated aliphatic
organic compounds (1,2-dichloroethane, tetrachloroethene, 1,1,1-
trichloroethane, methylene chloride, trichloroethene, carbon tet-
rachloride, 1,1-dichloroethane, chloroform) and aromatic hydro-
carbons (benzene, ethylbenzene, naphthalene, xylenes, toluene) as
well as lead, barium, copper and chromium.

The ground water contaminant plume originating from Area A
continues to migrate. The Operable Unit Two Feasibility Study
ground water sampling conducted in January, 1989 indicated that
this contaminant plume was approximately 760 feet long, 600 feet
wide, and 30 feet deep.

Summary of sit* Risks

The Operable Unit Two Feasibility Study concluded that actual or
threatened releases of hazardous substances from this site, if
not addressed by the preferred alternative or one of the other
active measures considered, may present an imminent and substan-
tial endangerment to public health, welfare, or the environment.

Human Health Risks

During the Remedial Investigation, an analysis was conducted to
estimate the health or environmental problems that could result
if the soil contamination and the ground water at the Ewan
Property site were not cleaned up. This analysis is commonly
referred to as a baseline risk assessment. In conducting this
assessment, the focus was on the health effects that could result
from direct exposure to the contaminants due to the soil coming
into contact with the skin, or from direct ingestion of the soil
by a child playing in the area, or by direct ingestion of the
ground water. The Remedial Investigation contains the complete
risk analysis for the Ewan Property site.
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10

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

Reference doses have been developed by EPA for indicating the
potential adverse health effects from exposure to chemicals
exhibiting noncarcinogenic effects. Reference doses, which are
expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking
water) can be compared to the reference dose. Reference doses
are derived from human epidemiological studies or animal studies
to which uncertainty factors have been applied (e.g., to account
for the use of animal data to predict effects on humans). These
uncertainty factors help ensure that the reference doses will not
underestimate the potential for adverse noncarcinogenic effects
to occur.

Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., IxlO*6 or 1E-6). An excess lifetime cancer risk of IxlO'6
indicates that, as a plausible upper bound, an individual has a
one in one million chance of developing cancer as a result of
site-related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at a site.

Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as a hazard quotient
(or the ratio of the estimated intake derived from the contam-
inant's reference dose). By adding the hazard quotients for all
contaminants within a medium or across all media to which a given
population may reasonably be exposed, the Hazard Index can be
generated. The Hazard Index provides a useful reference point
for gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
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11

The major public health risk posed by the Evan Property is the
potential ingestion of contaminated ground water. The ground
water on-site is contaminated with toluene, methylene chloride,
ethylbenzene, chromium, lead, and arsenic. EPA's sampling of the
ground water at the site found that the organic contamination
ranged from non-detectable concentrations to 5300 parts per bil-
lion. Inorganic contaminant concentrations ranged from 1 part
per billion to 1800 parts per billion. This concentration level
is associated with an excess lifetime cancer risk of 10 . This
means that if no cleanup action is taken by EPA, one additional
person per one thousand would have a chance of contracting cancer
as a result of exposure to the contaminated ground water. The
total Hazard Index for ingestion of the on-site contaminated
ground water is 1.9, where Hazard Index values below 1.0 are con-
sidered as no significant noncarcinogenic risks. At the present
time, no one uses the contaminated ground water for drinking or
other purposes. This risk analysis was performed to evaluate
potential site risks associated with potential domestic use of
the ground water.

Environmental Health Risks

The environmental risk present at the Evan Property site is the
continued degradation of ground water in the New Jersey Pinelands
(an especially sensitive ecosystem). EPA proposes to remediate
soil contamination and ground water contamination to levels which
will restore this valued natural resource.

EPA's sampling of the lesser contaminated soils shows that
without remediation the contaminant concentrations present will
allow continued leaching into the ground water, resulting in
concentrations in the ground water above cleanup goals. The
Operable Unit Two Feasibility Study contains a complete analysis
of soil remedial action goals to prevent ground water
degradation.

Description of Remedial Alternatives

The alternatives analyzed for Operable Unit Two are presented
below. These alternatives are numbered to correspond with those
in the Operable Unit Two Feasibility Study report.

Numerous remedial technologies were initially screened on the
basis of effectiveness, implementability, and cost. Following
the remedial technology screening, eight remedial alternatives
for Operable Unit Two were retained for consideration.
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12

The alternatives for the ground water cleanup were the following:

• Alternative 1G: No Action with Administrative Controls.

• Alternative 4G: Collection and Ten Year Treatment with
Reverse Osmosis and On-Site Reinjection of
Ground Water.

• Alternative 4Ga: Collection and Ten Year Treatment with On-
Site Reinjection of Ground Water.

• Alternative 4Gb: Collection and Three Year Treatment with On-
site Reinjection of Ground Water.

The alternatives for the soil cleanup were the following:

• Alternative IS: No Action with Administrative Controls.

• Alternative 3S: Excavation Followed by Solvent Extraction/
Solidification.

• Alternative 4S: Excavation Followed by Solvent Extraction/
Soil Washing.

• Alternative 55: Off-site Incineration of Less Contaminated
Soils.

Ground Water Remedial Alternatives

The NJDEP has determined that the site, which includes the
contaminated groundwater plume, is located within the Central
Pine Barrens portion of the New Jersey Pinelands. As a result of
ground water sampling in 1989, plume dimensions are estimated to
be 760 feet long by 600 feet wide by 30 feet deep. The "Draft
Guidelines for Ground Water Classification under the EPA Ground
Water Protection Strategy" identifies the on-site Cohansey Sand
aquifer as IIA because this is a potential drinking water source.
The ground water remedial alternatives were conceptually designed
to remediate the contaminated ground water plume.
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13
Alternative 1G:
No Action With Administrative Controls

Estimated Capital Cost: $0
Estimated Annual Operation and
Maintenance (O&M) Costs: $0
Estimated Present Worth: $0
Estimated Time to Implement: None

The National Contingency Plan requires that the "No Action"
alternative be evaluated at every site to establish a baseline
for comparison. Under this alternative, EPA would take no fur-
ther action at the site to prevent exposure to ground water con-
tamination. Instead, the contaminated ground water plume would
be allowed to continue to migrate off.-site. EPA has predicted
that the nearest ground water user (approximately 2000 feet down
gradient of the site) will be impacted in approximately 22 years.
Administrative controls would have to be enacted to prevent use
of the contaminated ground water.

Alternative 4G:
Collection and Ten Year Treatment With Reverse Osmosis and
On-Site Reinjection of Ground Water

Estimated Capital Cost: $11,000,000
Estimated Annual O&M Costs: $ 4,100,000
Estimated Present Worth: $42,300,000
Estimated Time to Implement: 10 years

This alternative utilizes an on-site ground water treatment
system. Contaminated ground water would be removed from the
aquifer by on-site extraction wells. The water would then be
passed through a succession of treatment steps which could
include the following processes:

• Chemical precipitation for metals and solids removal,

• Sedimentation to further remove metals and solids,
*ii
• Air stripping and activated sludge, ultraviolet light or
ozone addition to destroy or alter organic materials,

• Filtration to remove solids,

• Activated carbon adsorption to collect remaining organic
compounds,

• Reverse osmosis to remove residual solids and biochemical
oxygen demand
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14

The ground water will be reinjected within the contaminated
ground water plume following treatment. The remedial goal of
this alternative is to attain the Maximum Contaminant Levels
(MCLs) established pursuant to the Federal Safe Drinking Water
Act, and the State of New Jersey Safe Drinking Water Act; and New
Jersey Administrative Code Title 7, Chapter 9, Subchapter 6,
Section 6, Subsection (a) (N.J.A.C. 7:9-6.6(a)) criteria in the
treated effluent. The MCLs were developed to protect human
health and the N.J.A.C. 7:9-6.6 (a) criteria were developed to
protect the ground water in the Central Pine Barrens region of
the New Jersey Pinelands.

The ten year time term is an estimation used for costing pur-
poses. The objective of this alternative is to attain the pre-
viously discussed regulatory goal. I

Alternative 4Ga:
Collection and Ten Year Treatment With On-Site Reinfection
of Ground Water

Estimated Capital Cost: $ 6,700/000
Estimated Annual O&M Costs: $ 1,910,000
Estimated Present Worth: $21,400,000
Estimated Time to Implement: 10 years

This alternative is identical to Alternative 4G, except that
Reverse Osmosis is not included. The final remedial goal is to
attain the published N.J.A.C. 7:9-6.6(a) criteria, and the MCLs
established pursuant to the Federal Safe Drinking Water Act and
State Safe Drinking Water Act in the ground water at the end of
the remediation. The N.J.A.C. 7:9-6.6(a) standards were devel-
oped to protect the ground water in the Central Pine Barrens
region of the New Jersey Pinelands. The Federal and State Safe
Drinking Act MCLs were developed to provide protection of drink-
ing water supplies.
i
The treatment process to remove metals will cause an increase in
the level of total dissolved solids (TDS) in the effluent above
the standard established in N.J.A.C. 7:9-6.6(a). However, this
higher level of TDS is expected to be present only while the
metals precipitation unit is in operation. After treatment to
remove metals has been completed and the operation of the pre-
cipitation unit has been reduced or ceased, the concentration of
TDS in the aquifer is expected to revert to low levels consistent
with natural ground water conditions.

The ten year term is an estimation used for costing purposes.
The objective of this alternative is to attain the previously
discussed regulatory goal.
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15
Alternative 4Gb:
Collection and Three Year Treatment With On-Site Reinfection
of Ground Water

Estimated Capital Cost: $ 6,700,000
Estimated Annual O&M Costs: $ 1,910,000
Estimated Present Worth: $11,900,000
Estimated Time to Implement: 3 years

This remedial alternative is operationally identical to
Alternative 4Ga. The final remedial goal of the ground water
remedy is to attain the MCLs established pursuant to the Federal
and State Safe Drinking Water Acts.

The objective of this alternative is to attain the previously
discussed regulatory goal. :.

soil Remedial Alternatives

The goal of the soil remediation and redeposition alternatives
will be to maintain the ground water remedial goals. This will
be accomplished by removing the soil contaminants to concen-
trations which will not permit a leachate to pollute the ground
water above the specified ground water remedial objectives.

Alternative IS:
No Action With Administration Controls

Estimated Capital Cost: $0
Estimated Annual;O&M Costs: $0
Estimated Present Worth: $0
Estimated Time to Implement None

As stated in the No Action alternative for ground water above,
the no action alternative is evaluated as a baseline for com-
parison. Under this alternative, no further action would be
taken to clean up the residual soil at the site. Instead, ad-
ministrative controls would be instituted to prevent contact with
the contaminated soils.
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16

Alternative 3S:
Excavation Followed bv Solvent Extraction/Solidification

Estimated Capital Cost: $15,400,000
Estimated Annual O&M Costs: $ 43,200
Estimated Present Worth: $15,800,000
Estimated Time to Implement: 2 years

EPA conducted treatability studies for both solvent extraction
and solidification. The solvent extraction process readily
removed most organic contaminants in the soil. Inorganic con-
taminants which were not removed from the soil became leachable.
The results of the solidification tests indicated that semi-
volatile and inorganic contaminants would continue to leach at
rates which would cause the site ground water to remain con-
taminated above the Operable Unit Two remedial goals.

This remedial alternative proposes to excavate approximately
22,000 cubic yards of contaminated soils and treat them on-site
by extracting organic contaminants in the soil using solvent
extraction, and then chemically to stabilize any remaining soil
contaminants through solidification. The solvent used for
solvent extraction can be recycled for a time. After the solvent
has become unusable, it would be sent off-site for treatment
and/or disposal. It is expected that the solvent extraction
process will reduce the organic contamination in the soil to
concentrations which will not permit degradation of the ground
water.

Some soil contaminants, such as inorganics which will not ex-
tract easily from soil, may remain after solvent extraction.
Further .studies would have to indicate the degree to which the
soil would have to be solidified to bind these contaminants into
the soil matrix so they can not leach into the ground water. The
treated soil may qualify as clean fill as defined by the State
Solid Waste regulations.

Once the soil is treated to the cleanup goals, it will be
redeposiUed on-site as clean fill. The site would then be
regraded and revegetated.
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17
Alternative 4S:
Excavation Followed bv Solvent Extraction/Soil Washing

Estimated Capital Cost: $13,850,000
Estimated Annual O&M Costs: $ 0
Estimated Present Worth: $13,850,000
Estimated Time to Implement: 2 years

Under this remedial alternative, the contaminated soil will be
excavated and treated on-site. This process involves placing the
soil into a mobile soil washer and removing soil contaminants by
solvent extraction. EPA's treatability study results for soil
extraction indicate that organic contaminants can be readily
removed from the soil. The spent solvent will then be sent off-
site for treatment and disposal.

Following solvent extraction, the soils will be rinsed with water
to remove inorganic contaminants. The treatability study results
indicate that further refinement of this technology can achieve
the remedial goals. Spent wash water will be treated in the on-
site ground water treatment system.

It is expected that the treatment of the soil under this alter-
native will result in soil that meets the definition of clean
fill under the New Jersey Solid Waste Regulations. After at-
taining the cleanup goals, the soil will be redeposited on-site
as clean fill. Furthermore, any leachate which may occur from
water percolation through the soils will not deteriorate ground
water quality above N.J.A.C. 7:9-6.6(a) criteria, or MCLs under
the Federal and State Safe Drinking Water Acts. Following the
soil remediation, the site will be regraded and revegetated.

Alternative 55:
Off-Site Incineration of Less Contaminated Soils

Estimated Capital Cost: $67,700,000
Estimated Annual O&M Costs: $ 0
Estimated Present Worth: $67,700,000
Estimated Time to Implement: 2 years

Under this alternative, the 22,000 cubic yards of contaminated
soil would be excavated, transported and treated in an off-site
incinerator. The thermal destruction process would address the
organic contaminants in the soil. The excavation process would
remove the contaminated soil from the site, requiring no long-
term management controls. The off-site incinerator would comply
with technical standards for incinerators. The resulting ash
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18

would be properly handled and disposed of by the operators of the
incinerator. The facility, which must be permitted under the
Resource Conservation and Recovery Act, must also be in compli-
ance with the Superfund off-site policy before waste could be
transported there.

summary of the Comparative Analysis of Alternative*

In accordance with the National Contingency Plan, a detailed
analysis of each remedial alternative is conducted with respect
to each of nine detailed evaluation criteria. All selected
remedies must at least attain the Threshold Criteria. The
selected remedy should provide the best trade-offs among the
Primary Balancing Criteria. The Modifying Criteria were
evaluated following the public comment period.

Threshold Criteria

• Overall Protectiveness of Human Health and the Environment -
This criterion evaluates the adequacy of protection that the
remedy provides while describing how risks are eliminated,
reduced or controlled through treatment, engineering con-
trols, and/or institutional controls.

• Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) - This criterion addresses whether a
remedy will meet all of the applicable or relevant and
appropriate requirements of other Federal and State environ-
mental statutes and/or provide grounds for invoking a
waiver.

Primary Balancing Criteria

• Reduction of Toxicity, Mobility or Volume (TMV) - This
criterion addresses the anticipated treatment performance of
the remedy.

• Short-Term Effectiveness - This criterion addresses the
period of time required to achieve remedial goals and the
risks to human health and the environment during the
remedial action.

• Long-Term Effectiveness and Permanence - This criterion
evaluates the magnitude of residual risk and the ability of
the remedy to maintain reliable protection of human health
and the environment over time once remedial goals have been
attained.
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19

• Implementability - This criterion examines the technical and
administrative feasibility of executing a remedy, including
the availability of materials and services needed to imple-
ment the chosen solution.

• Cost - This criterion includes the capital and operation and
maintenance costs of the remedy.

Modifying Criteria

• State Acceptance - This criterion indicates whether, based
on its review of the Operable Unit Two Feasibility Study and
Operable Unit Two Proposed Plan, the State of New Jersey
concurs with, opposes, or has no comment on the preferred
alternative.
r,

• Community Acceptance - This criterion evaluates the reaction
of the public to the remedial alternatives and EPA's
Proposed Plan. Comments received during the public comment
period and EPA's responses to those comments are summarized
in the Responsiveness Summary attached to this document.

Ground Water Remedial Alternative*

The ground water remedial alternatives were evaluated to deter-
mine their effectiveness in remediating the site ground water
contaminant plume. The ground water contaminant plume origin-
ating from Area A continues to migrate. This plume is contained
within the Cohansey Sand aquifer. The Cohansey Sand is a water
table aquifer on-site. As presented in various geological re-
ferences and confirmed during the Remedial Investigation, exposed
portions of the Cohansey Sand geologic unit are recharge areas
for the aquifer. As a result of the 1989 ground water sampling,
plume dimensions are estimated to be 760 feet long by 600 feet
wide by 30 feet deep.

Analysis

overall Protection. All of the alternatives, with the exception
of the "No Action" alternative, would provide adequate protection
of human health by eliminating, reducing or controlling risk
through treatment of the ground water. The preferred
alternative, 46a, would attempt to remediate the ground water to
the more stringent standards that have been developed for the
protection of the Central Pine Barrens' unique ecosystem.
Alternative 46 involves adding a treatment unit to achieve
additional guidelines proposed by the NJDEP.

Because the "No Action" alternative is not protective of human
health and the environment, it is not considered further in this
analysis as an option for this site.
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20

Compliance with ARAR*. The applicable or relevant and appropri-
ate requirements under Federal and State environmental laws for -
ground water at the site are contained in N.J.A.C. 7:9-6.6(a)
(standards for the ground water of the Central Pine Barrens
Region of the New Jersey Pinelands) and the NCLs under the
Federal and State Safe Drinking Water Acts (Table 1). Alter-
native 4Gb would attain MCLs but would not meet the requirements
of N.J.A.C. 7:9-6.6(a).

Alternative 4Ga would meet all of the ARAR standards, although
the concentration of TOS would be temporarily elevated by the
metals removal treatment process. The increased level of TDS
would be a short-term condition that would not violate the ARAR,
as the TDS level is expected to return to an acceptable concen-
tration when the cleanup is completed. Further, since the plume
would be contained during the remedial action, the TDS levels
would not escape the extraction/treatment/reinjection system. It
is anticipated that the N.J.A.C. 7:9-6.6(a) criteria and the MCLs
under the Federal and State Safe Drinking Water Acts would be
attained within the plume prior to the completion of the Operable
Unit Two Remedial Action.

Alternative 4G would meet all of the ARARs and would utilize
additional treatment, reverse osmosis, to prevent the concen-
tration of TDS in the effluent from temporarily exceeding the
relevant N.J.A.C. 7:9-6.6(a) standard. Alternative 4G would also
attain a list of additional goals proposed by NJDEP.

Long-tern Effectiveness and Permanence. Alternatives 4G, 4Ga and
4Gb for ground water would reach and maintain acceptable ground
water cleanup levels. These alternatives were developed to at-
tain different levels of ground water cleanup. Alternative 4Ga,
the preferred alternative, is designed to reach the cleanup goals
at the end of the remedial action. The success of all of these
alternatives depends upon the removal of the originating source,
the contaminated soil. Since the contaminants would be removed,
rather than controlled, this represents a permanent remedy.

Reduction of Toxicity, Mobility or Volume of Contaminants. The
three ground water treatment alternatives would reduce the tox-
ic ity and volume of contaminated ground water through the use of
treatment technologies that remove contaminants from the ground
water. Alternative 4G would treat the site ground water con-
taminants to the remedial goals at the point of discharge.
Alternative 4Ga would attain the remedial goals in the ground
water plume at the end of the remedial action. Alternative 4Gb
will attain Federal and State Safe Drinking Water Acts MCLs in
the ground water plume at the end of the remedial action. The
remedial objectives are protective of human health and the
environment.
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TABLE \

around water Remedial Objectives
for the Operable Unit Tiro Remediation of the
Evan Property
Contaminants Goals (ug/11 Source

Aldrin/Dieldrin 0.003 l
Ammonia 50 1
Arsenic 50 3
Barium 1000 l
Benzene 1 2
Benzidine 0.1 l
Biological Oxygen Demand 3 1
Cadmium 10 l
Carbon tetrachloride 2 2
Chlordane 0.5 . 2
Chlorobenzene 4 2
Chloride 10,000 l
Chromium 50 l
Coliform Bacteria 40 CFR 141
Color 1 NTU 3
Copper 50 1
Corrosivity Non-Corrosive 3
Cyanide 200 l
DOT and metabolites 0.001 1
m-dichlorobenzene 600 1
p-dichlorobenzene 75 3
o-dichlorobenzene 600 3
1,2-dichloroethane 2 2
1,1-dichloroethylene 2 2
trans-l,2-dichloroethylene 10 2
2,4-dichlorophenoxyacetic acid 100 3
Ethylbenzene 700 3
Endrin 0.004 1
Fluoride 40 CFR 141
Foaming Agents 50 3
Gross alpha activity 15 pCi/14 3
Hydrogen sulfide 50 3
Iron 300 3
Lead 50 3
Lindane 4 3
Manganese 50 3
Mercury 2 3
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TABLE 1 (continued!

Ground Water Remedial objectives
for the operable Unit Two Raaediation of the
Evan Property (continued)

Contaminant Goals rucr/ll Source
Methoxychlor 100 3
Methylene chloride 2 2
Nickel 13.4 2
Nitrate-nitrogen 2000 i
Odor 3 3
Threshold
Odor
<. Number
pH : 4.2-5.8 1
Phenols 300 1
Polychlorinated biphenyls 0.001 l
Phosphate 700 1
Radionuclides 40 CFR 141
Radium 5 3
Selenium 10 3
Silver 50 3
Sodium 10 1
Strontium 8 pCi/14 3
Sulfate 15,000 1
2,4,5-TP Silvex 10 3
Tetrachloroethylene 12
Toluene 2000 3
Total Dissolved Solids 100 1
Toxaphene 5 3
Trichlorobenzene 8 2
Trichloroethylene 1 2
Trihalomethanes 100 3
Tritium 20 nCi/15 3
Turbidity 40 CFR 141
1,1,1-trichloroethane 26 2
Vinyl chloride 2 3
Xylenes 44 2
Zinc 5000 3

1). N.J.A.C. 7:9-6.6(a).
2). N.J.A.C. 7:10-5, N.J.A.C. 7:10-7, A-280.
3). 40 CFR 141, 40 CFR 143.
4). Picocuries per liter.
5). Nanocuries per liter.
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23

Short-tern Effectiveness. A short-term increase in the level of
total dissolved solids in the treated effluent is expected from
the metals treatment system of Alternative 4Ga. However,
Alternative 4Ga is expected to attain the ground water cleanup
goals by the end of the remedial action. Alternative 4Gb will
not attain the N.J.A.C. 7:9-6.6(a) total dissolved solids stan-
ard. Total dissolved solids are not associated with health risks
and any short-term impacts on the environment during the remed-
iation can be mitigated through proper monitoring and engine-
ering.

Alternative 4G utilizes an additional treatment unit to reduce
the concentration of TDS in the effluent to the N.J.A.C. 7:9-
6.6(a) standard.

Implementability. Alternatives 4G, 4Ga and 4Gb are expected to
be technically and administratively feasible. The alternatives
utilize water treatment equipment that is readily available,
reliable and are proven technologies.

Cost. Alternative 4Ga would be protective of public health and
the environment, and would attain all ARARs in the long-term at a
significantly lower cost than Alternative 4G. Alternative 4Gb is
the least expensive remedy. However, it cannot attain the
remedial goals. Table 2 provides a summary of the present worth
costs associated with the ground water remedies.

State Acceptance. The NJDEP was directly involved in the plan-
ning and oversight of the Remedial Investigation and Feasibility
Study. The State has accepted the remedy selected in this Record
of Decision, but has not concurred with the remedial goals for
cleanup of the ground water. For example, the State would prefer
that the selected treatment process be operated for a consider-
ably longer period of time. This opinion is expressed in corres-
pondence from the State to EPA, which is included in the
Administrative Record for the Ewan Property site.

Community Acceptance. The objective of the community relations
activities was to inform the public about the work being per-
formed at this site and to seek input from the public on the
remedy. Issues raised during the public comment period and at
the public meeting are addressed in the Responsiveness Summary
section of this ROD.
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TABU 2

Summary of Present Worth Costa for
Operable Unit Two Ground water Remedies
of the Evan Property

Alternative Total Present Worth Costs*

1G - No Action With Administrative 0
Controls

4G - Collection and Ten Year 42,300,000
Treatment With Reverse
Osmosis and On-Site
Reinjection of Ground Water

4Ga - Collection and Ten Year • 21,400,000
Treatment With On-Site •.
Reinjection of Ground Water

4Gb - Collection and Three Year 11,900,000
Treatment With On-Site
Reinjection of Ground Water

* Total present worth costs are estimates.
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25
Soil Alternatives

The soil remedial alternatives evaluated the treatment of the
estimated 22,000 cubic yards of contaminated soil which will
remain on-site following the implementation of the Operable Unit
One Remedial Action.

Analysis

Overall Protection. All of the soil treatment alternatives could
provide adequate protection of human health and the environment,
(if implemented in conjunction with a remedial action for ground
water) by eliminating, reducing or controlling risk through
treatment or engineering controls. The preferred alternative
would remove the contaminants from the soil through solvent ex-
traction and soil washing to levels which would be protective of
human health and the environment.

Similar to the analysis for the ground water alternatives, the
"No Action1* alternative for the soil will not be further con-
sidered in this analysis since it is not protective of human
health and the environment.

Compliance with ARARs. All of the alternatives could meet the
applicable or relevant and appropriate requirements of Federal
and State environmental laws. Treatability studies for the
preferred alternative demonstrated that treating the soils
through solvent extraction and soil washing would reduce the
contaminants in the soil to levels acceptable for redeposition at
the site.

Long-term Effectiveness and Permanence. All of the active
alternatives are considered effective and permanent. The pre-
ferred alternative, 4S, would remove the contaminants from the
soil so that it can be redeposited on-site without further
action. While Alternative 3S would remove most of the con-
taminants from the soil through solvent extraction, some of the
contaminants would remain. These contaminants would be stabil-
ized through the solidification process, which would bind the
inorganic contaminants to the solid material. Alternative 5S
would remove and treat all waste in a permitted, off-site in-
cinerator.
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26

Reduction of Toxicity, Mobility or Volume of the Contaminants.
All of the active alternatives would reduce the toxicity, nob-
ility or volume of the contaminants through treatment or stab-
ilization processes. Alternative 3S would remove organic soil
contaminants by solvent extraction. The mobility of the re-
maining inorganic contaminants could be retarded by extensive
solidification. Alternative 4S would remove all of the soil
contaminants by solvent extraction and soil washing. Alternative
5S would remove the soil from the site.

Short-term Effectiveness. Each soil treatment alternative is
expected to require two years of remedial activity to achieve the
site cleanup goals. All of the active treatment alternatives
include excavation. There are some minor short-term risks of
exposure of volatile organics during /the excavation, but these
can be mitigated through proper monitoring and engineering.
Alternative 5S, Off-site Incineration, requires the transporta-
tion of the 22,000 cubic yards of contaminated soil from the
site. There are also some minor short-term risks to the com-
munity associated with the transportation of contaminated soils
to the incineration facility. These risks can also be mitigated.

Implementability. All of the alternatives are considered imp-
lementable. Treatability studies for the preferred alternative,
Solvent Extraction/Soil Washing, have shown that the cleanup
goals for the soils can be attained, allowing the soil to be
redeposited on-site.

cost. The present-worth cost of the preferred alternative is
estimated at $13,850,000. The highest cost alternative is
Alternative 5S, Off-site Incineration, at $67,700,000. Table 3
provides a summary of the present worth costs of the soil remed-
ies.

Community Acceptance. The objective of the community relations
activities was to inform the public about the work being per-
formed at this site and to seek input from the public on the
remedy. Issues raised during the public comment period; and at
the public meeting are addressed in the Responsiveness' Summary
section of this ROD.
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TABLE 3

Summary of Present Worth Coats for
Operable Unit Two soil Remedies
of the Evan Property

Alternative Total Present Worth Costs*

IS - No Action With Administrative 0
Controls

3S - Excavation Followed by ' 15,800,000
Solvent Extraction/
Solidification

4S - Excavation Followed by 13,850,000
Solvent Extraction/
Soil Washing i.

5S - Off-Site Incineration of 67,700,000
Less Contaminated Soils
Total present worth costs are estimates.
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28

Selected Remedy

The selected alternative for cleanup of the ground water at the
Ewan Property site is Alternative 4Ga - Collection and Ten Year
Treatment with On-Site Reinjection of Ground Water. This alter-
native was chosen because the site, which includes the contamin-
ated ground water plume, is defined by NJOEP as being in the
Central Pine Barrens Region of the New Jersey Pinelands. The
cleanup goals for this action are the published N.J.A.C. 7:9-
6.6(a) criteria and MCLs established pursuant to the Federal and
State Safe Drinking Water Acts. N.J.A.C. 7:9-6.6(a) was devel-
oped to preserve and restore the conditions of the Central Pine
Barrens ground water. The MCLs of the Federal and State Safe
Drinking Water Acts were developed to protect public health. The
ground water contaminant plume will be contained by the extrac-
tion/treatment/ reinjection system. It is the goal of this ground
water remedy to attain N.J.A.C. 7:9-6.6(a) criteria, Federal
MCLs, and State MCLs within the contaminated portion of the
Cohansey Sand aquifer prior to the completion of the Operable
Unit Two Remedial Action. This alternative also complies with the
EPA Ground Water Protection Strategy.

The selected alternative for cleanup of contaminated soil at the
Ewan Property is Alternative 4S - Excavation Followed by Solvent
Extraction/Soil Washing. This alternative would be applied to
the estimated 22,000 cubic yards of contaminated soil remaining
after the Operable Unit One Remedial Action. The contaminated
soil would be treated to concentrations that would achieve the
ground water remedial goals.

A detailed cost analysis of the selected remedies is presented in
Table 4 and Table 5.

Several Pre-Design Studies will have to be conducted as part of
the Operable Unit Two Remedial Design. These studies should in-
clude:

• A wetlands assessment to delineate the nearby wetlands,
identify impacts to the wetlands and procedures to reduce
any impacts,

• An emissions study to fulfill NJDEP permit equivalency re-
quirements and to develop contingency plans to reduce the
possibility of potential impacts on nearby residents caused
by the operation of the selected remedies,

• Conduct further treatability studies to optimize operations
for the selected remedy,
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TABLE 4

Coat Summary of Operable unit Two
selected Alternative for around Water Remediation

Alternative 4Oa*
Collection and Ten Year Treatment with On-8ite
Reinjaction of Ground Watar

Capital Coata Batimatad Coats

Construction (Equipment, piping, instrumentation, $6,623454
foundations, structural, electrical)

Administrative Contingency $456,790

General Contingency $913,580

Engineering Contingency $685.185
$6,623,454

Operation and Maintenance (Energy, maintenance, $1,903,980
chemicals, operators,
carbon, ultraviolet or
ozone generation)

Total operation and Maintenance Through Ten Years $19,039,800

Total Present Worth (with 5% annual discount rate) $21,328,000
Costs reflect the more expensive physical waste water
treatment processes rather than the less expensive
biological treatment processes.
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Cost Summary of Operable unit Two
Selected Alternative for Soil Remediation
Alternative 48
Excavation Followed by solvent Extraction/
Soil Washing

Capital Costs Estimated Coats
Excavation (22,000 cubic yards) $50,600
Soil Extraction/Soil Washing $6,803,600
Reclamation $297,635
Health and Safety • $960,948
Labor, Materials, Subcontractor $714,932
Indirect costs and profit $907,811
Administrative Contingency $973,553
General Contingency $1,947,105
Engineering Contingency $1.168.263
Total Cost $13,824,447
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31

• Conduct further studies to refine the site specific remedial
soil objectives (soil goals will not deteriorate ground
water beneath the site above ground water remedial
objectives).

Perimeter monitoring will be conducted from the completion of
Operable Unit One to the completion of Operable Unit Two. This
monitoring program will minimize the potential of off-site im-
pacts. Contingency plans will be developed to maintain protec-
tion of human health and the environment.

Following completion of the remedial actions, all areas affected
by both operable units will be recontcured, restored and reveget-
ated to their original conditions.

Statutory Determinations

EPA's selection of Alternatives 4Ga and 4S comply with the re-
requirements of Section 121 of CERCLA as amended by SARA. Both
alternatives are protective of human health and the environment.
Together, they would achieve substantial risk reduction through
treatment of the principal threat remaining at the site (i.e.,
contaminated ground water and residual contaminated soil). Al-
ternative 4Ga is expected to meet the cleanup goals for the pre-
servation of the Central Pine Barrens. Alternative 4S reduces
the risk associated with the contaminated soils through a tech-
nology that has been shown to be technically feasible for this
site. Implementation of Alternative 4S would remove the remain-
ing source of ground water contamination present in the on-site
soils.

The ARARs identified for the ground water remediation are those
published in N.J.A.C. 7:9-6.6(a) and the MCLs under both the
Federal and State Safe Drinking Water Acts. The point of compli-
ance for this ground water remedy is immediately beneath the
site. Alternative 4Ga is anticipated to achieve these concentra-
tions by the end of the remedial action. After completion of
Alternative 4S, the soil will not leach contaminants into the
ground water above the specified ARAR levels.

EPA has planned to thermally destroy spent solvents produced
during the implementation of Alternative 4S. This disposal
procedure will comply with the RCRA Land Disposal Restrictions
(LDRs). This remediation will comply with all applicable RCRA
requirements.

If the source waste is determined to be RCRA regulated waste,
then all remedial activities will comply with all applicable RCRA
regulations.
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32

In any event, all off-site activities will comply with the joint
RCRA/CERCLA Off-Site Policy.

EPA will conduct a permit equivalency process to fulfill the
requirements of the promulgated NJDEP air pollution regulations.

All portions of the site affected by both operable unit remedial
actions will be restored, recontoured, and revegetated to their
original conditions. The site restoration will be in compliance
with the Wetlands Protection Act and the Farmland Preservation
Act.

Alternative 46a is considered cost-effective since it will
achieve the ground water goals at approximately half the cost of
Alternative 46. Treatability study results for Alternative 4S
indicate that it is feasible. This alternative was the least
expensive treatment option for soil remediation.

The Alternative 4Ga and Alternative 4S provide permanent
solutions to the contamination problems of the ground water and
soil. Contamination in both media will be addressed by on-site
treatment or off-site disposal. The treatments specified for
Alternative 4Ga and Alternative 4S will significantly reduce
toxicity, mobility, and/or volume of the contaminants found in
the Ewan Property ground water and soil, respectively.
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RESPONSIVENESS SUMMARY

RECORD OF DECISION

EWAN PROPERTY (OPERABLE UNIT TWO)

Overview

The United States Environmental Protection Agency (EPA) held a
public comment period from August 7, 1989 through September 11,
1989 for interested parties to comment on EPA's Operable Unit Two
Feasibility Study (FS) and Operable Unit Two Proposed Remedial
Action Plan of the Ewan Property Site.

To encourage public involvement during the public comment period,
EPA held a public meeting on August 17, 1989 at the Indian Mills
Public School in Indian Mills, New Jersey to describe the remedial
alternatives and present EPA's proposed remedial alternatives for
Operable Unit Two.

A responsiveness summary is required under the Superfund program
for the purpose of providing EPA and the public with a summary of
the interested parties' comments and concerns about the site, as
raised during the public meeting and public comment period, and
EPA's responses to those concerns. All comments summarized in this
document were factored into EPA's final decision for selection of
the remedial alternatives for cleanup.

This Responsiveness Summary contains the following appendices:

• Appendix A - Public Comment

• Attachment A.I - Public Notice

• Attachment A.2 - August 17, 1989 Public Meeting
Attendance Sheet

• Attachment A.3 - Notice of Public Comment Period
Extension

• Appendix B - New Jersey Department of Environmental Protection

• Attachment B.I - New Jersey Department of Environmental
Protection Comments

• Attachment B.2 - United States Environmental Protection
Agency Responses
-------
• Appendix C - Chrysler Motors Corporation

• Attachment C.I - Chrysler Motors Corporation Comments

• Attachment C.2 - United States Environmental Protection
Agency Responses

Comments from the nearby residents were presented during the public
meeting. No written comments from the residents were furnished to
EPA.

Background on Community Involvement

Residents reported to the Burlington County Health Department and
NJDEP that buried drums were located at the Ewan Property site.
Subsequently, residents held numerous meetings, signed petitions,
and wrote letters to Federal, State and local officials requesting
cleanup of the site. In February 1983, more than 100 residents
participated in a meeting to discuss the site and how to get a
government agency to clean-up the site. A petition with 92 sig-
natures was submitted by the Coalition Against Toxics to the New
Jersey congressional delegation requesting that the Ewan Property
site be cleaned up. The Shamong Township Board of Education also
requested help from EPA in developing an educational campaign for
area school children about the Ewan Property site.

The primary concerns citizens have raised about the site include:

• Decreases in property values that residents feel may occur as
a result of close proximity to tha Ewan Property site;

• Potential contamination of potable wells if the contaminated
groundwater spreads to the residential areas;

• Potential health risks associated with exposure to
contaminants in soils, groundwater, and materials leaking from
the buried drums;

• Potential disruption of the surrounding community during the
implementation phase of remediation;

• Responsibility for remediation of the site, i.e. financial and
statutory; and

• Perceived cleanup delays.

New Jersey Department of Environmental Protection (NJDEP) comments
pertaining to remedial goals are contained in Appendix B. The EPA
responses to the NJDEP comments ara also contained in Appendix B.
-------
2. consistency of Regulatory Application to Previous Mew Jersey
Pinelands Superfund Records of Decision

Chrysler also commented that application of N.J.A.C. 7:9-6.6(a)
to the Ewan Property ground water remediation would be incon-
sistent with previous EPA Region 2 signed Records of Decision.
EPA's review of the Chrysler comments indicates an apparent
confusion concerning the "GW1 standards" in the N.J.A.C.
7:9-6.6(a) regulation. According to Chrysler, the "GW1 standard"
would require remediation of the contaminated ground water to
"background" concentrations.

In the Operable Unit Two Proposed Plan (the first of EPA's two
decision documents for Operable Unit Two) EPA identified three
promulgated, quantitative, numerical .regulations as the goals for
the Operable Unit Two ground water remediation: the Federal Safe
Drinking Water Act (SWDA) Maximum Contaminant Levels (MCLs) con-
tained in 40 CFR Part 141 and 40 CFR Part 143; and the State of
New Jersey SWDA MCLs contained in N.J.A.C. 7:10-5, N.J.A.C.
7:10-7; and N.J.A.C. 9:7-6.6(a). EPA considers only these pro-
mulgated, quantitative, numerical portions of the Central Pine
Barrens criteria (see the N.J.A.C. 7:9-6.6(a) GW-l Criteria) as
applicable regulations. Although N.J.A.C. 7:9-6.6(a) contains
several non-numerical standards, EPA has selected the numerical
remedial goals for these substances from the MCL listings found
in the Federal SWDA and State SWDA. The NJDEP disagrees with
this selection. Attached is the NJDEP letter and the EPA
response.

Chrysler also stated that the Cooper Road Dump and Ciba-Geigy
Records of Decision did not advocate the use of any New Jersey
Pinelands related regulations as remedial goals. Since neither
site is located within the New Jersey Pinelands these regulations
are not applicable or relevant and appropriate to those sites.

Chrysler indicated that the Lang Property was determined to be
located in both the New Jersey Central Pine Barrens area and the
New Jersey Pinelands Preservation Area. Chrysler further claimed
that EPA did not use the "GW1 standards", but chose to use only
State and Federal standards in determining a remedy for the Lang
Property. The State standards referred to in the Lang Property
Record of Decision include the numerical portions of the Central
Pine Barrens criteria (see the N.J.A.C. 7:9-6.6(a) GW-l
Criteria). Furthermore, the Lang Property Record of Decision was
signed prior to the enactment of the Superfund Amendments and
Reauthorization Act (SARA). SARA requires the use of more strin-
gent applicable or relevant and appropriate State requirements.
Therefore, Chrysler's argument is irrelevant.
-------
The Ewan Property Proposed Plan cites the same ARARs that were
identified in the Lang Property Record of Decision, which in-
cludes the promulgated, quantitative, numerical Central Pine
Barrens criteria (see the N.J.A.C. 7:9-6.6(a) GW-1 Criteria).

3. Technical Feasibility of Proposed Alternative

EPA has determined that the remedial goals selected in the
Operable Unit Two Proposed Plan can be reached. The contrary
opinion presented by Chrysler's consultants was unsupported by
technical evidence.

Furthermore, Chrysler claimed NJDEP "conceded" the Ewan Property
ground water remediation may be unobtainable. NJDEP never
conceded that the ground water remediation was impossible. It
merely indicated that the Central Pine Barrens criteria (see the
N.J.A.C. 7:9-6.6(a) GW-1 Criteria) contain standards which may be
difficult to reach.

4. Analytical Detection Limits

Chrysler claimed that the detection limits required to recognize
the remedial goals do not exist. The Operable Unit Two
Feasibility Study activities (treatability studies and ground
water sampling) used published analytical methods. These an-
alytical methods had detection limits more sensitive than the
Contract Required Detection Limits used in the EPA Contract
Laboratory Program (see the attached NUS Corporation response).

5. Less Risk to Human Health and the Environment
•i
Chrysler alleged that excavation of the residual contaminated
soils would result in a discharge of volatile emissions.

Chrysler failed to recognize that EPA will implement site
monitoring and contingency plans should volatile emissions begin
to occur. These plans include engineering measures to insure the
protection of public health and the environment while Operable
Unit Two is in operation. Furthermore, similar soil excavations
conducted in Region 2 have not resulted in any significant
discharges of volatile organic contaminants.
-------
6. Soil Treatability Study

Chrysler has maintained that the treatability studies conducted
for the soils were an attempt to differentiate heavily contam-
inated materials from residually contaminated soils.

The only goal of the treatability studies was to determine the
remedial effectiveness of solidification and solvent washing in
removing contaminants from the Ewan Property soils. To make this
determination two types of soils were used in the studies; soils
which were heavily contaminated by source waste material, and
soils which were slightly contaminated.

EPA used the heavily contaminated soils to evaluate the effect-
iveness of the technologies in the studies on materials which
could potentially be missed in the Operable Unit One Remedial
Action. The slightly contaminated soils were used to determine
the effectiveness of the processes on soils which are anticipated
to be present at the conclusion of the Operable Unit One Remedial
Action.

EPA realizes that some refinements are required to optimize the
soil extraction procedure (see the attached NUS Corporation re-
sponse) . The Treatability Studies were conducted to provide pre-
liminary evidence concerning the remedial effectiveness of the
technology in question. The Operable Unit Two Record of Decision
will refer to the Pre-Remedial Design studies needed to identify
the specific process to be used in the implementation of solvent
extraction.

Furthermore, when EPA selects "On-Sitej Solvent Extraction
followed by Soil Washing", it is not-limited to the process used
in the Treatability Study. Although triethylamine was used in a
patented solvent extraction process, EPA will not limit the
Operable Unit Two Pre-Remedial Design studies to repeating the
Treatability Studies. The evidence provided by the solvent
extraction treatability study illustrated that the technology
could work at the Ewan Property and fulfill Superfund statutory
requirements.
-------
Comment:

A resident asked if the chemicals identified on site were
carcinogenic.

EPA Response:

Many compounds have been identified on site. Some such as
benzene, methylene chloride, and tetrachloroethene are con-
sidered to be carcinogenic. The Remedial Investigation report
contains the complete risk analysis, including toxicity pro-
files for the indicator compounds selected for the Ewan
Property site.

Comment: ';

Several residents inquired about EPA's contingency plans
during remediation. They asked if the community would be
involved during the development of any contingency plans.

EPA Response:

Contingency plans are developed by both EPA and contractors
involved in the remediation of the site. Local officials,
community groups, hospitals, and emergency units will be
contacted in the development of these plans.

Future Activities

Comment:

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

EPA Response:

Once a ROD is signed a des;ign contractor will be hired. The
remedial design phase of <;ach operable unit will precede the
remedial implementation phase. As yet a Record of Decision
(ROD) has not been signed for Operable Unit Two. However, the
remediation of Operable Unit One has an estimated duration of
1.5 years. The preferrec alternative for groundwater remed-
iation under Operable Unit Two has an estimated 10 year oper-
ation time, and the preferred alternative for soil under
Operable Unit Two has an estimated 2 year remediation time.
-------
Comment:

A resident asked if funds were available for residents and
community groups to hire a contractor to oversee or examine
what has been accomplished by EPA at the Ewan Property site.

EPA Response:

The Superfund law includes a program, known as the Technical
Assistance Grant (TAG) for community groups to hire con-
tractors for the purpose of review of the technical aspects
of a site. Often, these reviewers are called upon to explain
technical aspects of specific sites and the Superfund process.
EPA offered to provide information regarding TAGs.

Comment:

A resident asked whether monitoring of the residential well
at the Green Acres Park would be done by EPA as a precaution
during the design and implementation phases.

EPA Response:

Monitoring of residential wells is something that EPA will
consider during the design phase. Citizens were welcomed and
encouraged to share their ideas on the safest way to implement
the proposed remedial action.

Comment:

A resident inquired about whom to contact during remedial
design and implementation if residents have questions.

EPA Response:

Residents should contact the EPA Remedial Project Manager,
Craig De Biase, with any questions that they might have.

Remaining Concerns

Issues related to the implementation of the remedial action,
including fencing and truck traffic, will continue to b>e areas of
concern. The primary reason for continued concern is the potential
for disruption to the community during the remedial action phase.
-------
Appendix A
Public Comment
-------
Attachment A.I
THZ UMll'&U STATES EMV1ROMMKIRAL PROTBCTXOJI AO0CT
RIOIOU XI
AMKHMCXS
PKOPOSZD eUCXMOV ALTZRIOIT1VBS
FOR TBS
OPKRMU UNIT TWO R2KKDXAXXOM
OF THB
EHAN PROPERTY SUPCTFTJND SITE
SBAMOMO TOWH8HIP
BURLINGTON COUNTY, MEW JERSEY

The United scat** Environmental Protection Agency (EPA) has recently completed
the operable unit Two Feasibility Study for the Swan Property Superfund Sit*
in Burlington county, New Jersey. This Superfund study evaluated remedial
alternatives for the operable Unit Two cleanup at the Swan Property. EPA has
identified preferred remedies for the Operable Unit Two cleanup wnicn will
address soil and groundwater contamination. Before final selection of the
reoMdiee. EPA will consider all comment* on the Operaale Unit Two Feasibility
Study and Proposed Plan from August 7, 1989 to September 6, 1989. The final
decision document will include a sumary of significant public comment* ana
SPA response*.

EPA will hold an informational public meeting on August 17, 1989 at 8:00 p.m.
at the Indian Mills Public School on Medford-Indian Mills Road in Indian
Mills, New Jersey to discuss the Operable Unit Two Feasibility Study and the
preferred remedial alternatives for thefOperable Unit Two cleanup. The first
operable unit, which wae selected in the Record of Decision issued by EPA in
September 1988, addressed the remediation of the estimated SOO to 8000 buried
drums and heavily contaminated materials at the site. EPA selected Off-Site
Thermal Destruction and/or Treatment to remediate the buried drums ana
materials. The second operable unit will address residually contaminated
soils and contaminated groundwater.

The Operable Unit Two Feasibility study evaluated eight options for cleaning
up the lesser contaminated soils and contaminated groundwater. For soils,
these remedial alternatives werei

1) No Action with Administrative Controls
2) Excavation and On-Site Solvent Extraction Followed by On-Site
Solidification
3) Cxeavation and On-Site Solvent Extraction Followed by On-Site Soil
Washing
4) Excavation and Off-Site Incineration

For groundwater, the remedial alternatives were:

S) No Action witli Administrative Controls
6) Collection and Ten year Treatment with Reverse Osmosis and On-Sit*
Re-tn^ection of Oroundwater
7, Collection and Ten xear Treatment with On-Site Re-injection of
Croundwater
S) Collection and Three (ear Treatment with On-Site Re-injection of
Groundwater
EPA's preferred soil remedial alternative for Operable Unit Two is On-Site
Solvent Extraction Followed by On-Site Soil washing. The preferred
groundwater remedial alternative is Collection and Ten Year Treatment with On-
Site Re-injeetion of croundwoter.

The Operable Unit Two Feasibility Study, the Proposed Plan, and other site
related document! are available at the following repository!

Mr. Lrna Beiahold
a&asnag Towasoip Clerk
Soaana? Township Municipal BuildJjtg
60 billow drove Road
Viaeeacawa, New Jersey 080*1

Written comments to the Operable Unit Two Feasibility Study and the Proposed
Plan should be sent to:

Craig OeBiase
Project Manager
U.J. Eaviroaawacal Protection Ageaev
2* Federal Plasa
Room 711
New York, New xork 10278

CoasMnte must oe submitted to the above address, postmarked on or before
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Attachment A.2
Saptrfnnd Up<
EPA Refion
5

20
NAME.
Ewan Property Site
Shimon* Township, New Jersey"
Aufmt 1989
TELEPHONE. AFFILIATION
-------
Superftmd Update-
Ewan Property Site
Shtmong Townihip, New Jersey
EPA Region 2-
Aogost 1989
2

6
9

12
i
13

18
SICNJN
NAME. AUURbSS, TELEPHONE, AFFILIATION
\
IfegAnSfe,

8
a
7
l/i

I
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Attachment A.3
United States
Environmental Protection Agency
77 * Ranirtn 9
^•v negion £.
26 Federal Plaza, NY, NY 10278
NEWS
89 (99) Timothy Smitil (212) 264-2515
FOR RELEASE: Tuesday, September S, 1989
EPA gXT^MPS PUBETg CQMMTTWP PgRIQD VP EWMT PBOPERfTV SITPgRFUND SITE
NEW YORK — Th« U.S. Environmental Protection Agency has extended
the public comment period on the Operable unit Two Feasibility
(FS) report, and the Operable unat TWO yroposea naii zur r.n« tw*u
Property Superfund site in Shamong Township, New Jersey until
September 11, 1989.

The extension was granted following a request for more time
to review and comment on the FS report, and Proposed Plan. EPA'a
proposed soil remedy is on-site solvent extraction followed
by on site ooil waching. Th«. proposed rpw*«Hal alternative for
the groundwater is collection and ten year treatment with on-site
reinjection of ground water. Copies of the FS report, the
Proposed Plan, and other site related documents can be reviewed
at the following information repository:

Shamong. Township Municipal Building
60 Willow Grove Road
Vincentown, New Jersey 08088
-rnors-
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.i.- .i os1 +e.'
-------
Appendix B
New Jersey Department of Environmental Protection
-------
Attachment B.I
State ot Jleto
DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF HAZARDOUS SITE MITIGATION
CN 413, Trenton, NJ. 08625-0413
(609) 984-2902
Fax # (609) 633-2360
Anthony J. Farro

SEP 1 I ,389
U.S. Environmental Protection Agency
Region 2
26 Federal Plaza, Room 711
New York, New York 10278

Attn: Mr. Craig De Blase,
Project Manager

Re: Ewan Property Superfund Site
Operable Unit Two

Dear Mr. De Blase:

In response to the U.S. Environmental Protection Agency's (USEFA)
solicitation for public comments on the cleanup methods described in the
"Proposed Plan for the Operable Unit Two Remediation for the Ewan Property
Superfund Site", dated August 1989, the N.J. Department of Environmental
Protection's (NJDEP) comments are presented herewith. Since the USEPA has
released this Proposed Plan under their own initiative and without prior
review by the NJDEP, our comments are lengthy and substantial.

Our foremost comment concerns the ground water cleanup goals described in
the Plan. First, note that reference to New Jersey ground water quality
standards that are intended to restore the pristine conditions of the
Central Pinelands should reference N.J.A.C 7:9r6.4 through 6.7 and not just
N.J.A.C 7:9-6.6. It is the NJDEP'a position'that the narratives found in
these and other sections do constitute Applicable or Relevant and
Appropriate Requirements (ARARS).

The reason we believe the above-noted standards are ARARs is based on our
understanding of section 121 of CERCLA. Subsection d of 121 specifies the
degree* of cleanup that must be achieved at NPL sites. Subsection 2 of d
states that If a hazardous substance, pollutant or contaminant remains on
site and there is a promulgated standard, requirement, criteria or
limitation under a state environmental law which is more stringent than the
federal standard, and that standard has been Identified to EPA, and it is
legally applicable or relevant or appropriate under the circumstances of the
release, then the remedial action shall attain such standards. 42 U.S.C.
Section 121(d)(2)(A)(11). Subsection (d)(2)(B) goes on to state that in
determining if water quality criteria are relevant and appropriate the
President must consider the "designated or potential use of this surface or
groundwater, the environmental media affected, the purposes for which such
criteria were developed, and the latest information available."

New Jersey is an Equal Opportunity Employer
-------
-2-
The State identified to EPA several months ago the ARARs for this site,
which is in the Central Pine Barrens. These ARARs Included N.J.A.C.7:9-6.4
through 6.7, including the narratives in those sections. They state that
there should be a non-degradation of waters in these Central Pine Barrens.
We believe that these regulations, which are duly promulaged according to
law, and have been consistently applied, must be part of any ARARs that are
used for this site according to the statutory criteria set out above.

A reading of the proposed National Oil and Hazardous Substances Pollution
Contingency Plan ("NCP"), dated December 21, 1988 (See 53 FR 51394 through
51520), confirms our opinion.

EPA proposed in December 1988 to place the discussion of ARARs in 40 CFR
section 300.400. The EPA's discussion of that proposal is relevant at two
places: Subpart E regarding EPA's approach for ground water remediation
under the Superfund program, and Subpart F, compliance with the applicable
or relevant or appropriate requirements of other laws. These discuss how
ARARs are to be selected. Subpart E, at page 51433, engages in a discussion
of EPA's approach for ground water remediation and notes that ground water
classification is site-specific for Superfund remediation and may be
superceded by other classification schemes promulaged by a state which are
ARARs.

In the more specific discussion in Subpart F, the preamble notes on page
51438 that state anti-degradation statues "would be a potential ARAR." On
page 51442 the preamble goes on to note that state water quality standards
can be narratives. Therefore, according to the preamble of the NCP,
specific numerical criteria as well as narrative standards are appropriately
considered as applicable regulations for the Ewan property site.

As we stated at the outset, there is no indication that the criteria we have
proposed for the ARARS from N.J.A.C. 7:9-6.4-6.7 are in any way outside of
the requirements set out in the statute for ARARs, since EPA has provided no
evidence that these are either inapplicable, inappropriate or irrelevant,
nor has EPA provided any evidence that the State has Inconsistently applied
the standards.
Attachments
HS227/al
Sincerely yours,
Director,
Hazardous Site Mitigation
-------
-3-
cc: Assistant Commissioner Burke
R. Engel, DAG
Director Farro, DHSM
Assistant Director MacDonald, DRA
D. Martin,. DRA
Assistant Director Putnam, DHSM
A. Charles, BEERA
L. Welkom, BGVPA
R. Yeates, DEQ
F. Cosollto, DEQ
S: Krietzman, DWR
B. Soboleski, BSM I
R. Collier, BSM I
M. Burlingame, BSM I
File: EWAN Property B8
-------
Appendix B.2

United States Environmental Protection Agency
Responses
-------
United States Environmental Protection Agency
Response to the Comments for the
Operable Unit Two Feasibility Study and
Operable Unit Two Proposed Plan
for the Ewan Property as presented by
the New Jersey Department of Environmental Protection

Although United States Environmental Protection Agency (EPA)
often requests that State agencies advise the Agency as to their
views concerning cleanup requirements which may be imposed under
state laws and regulations at sites, EPA is ultimately respons-
ible for selecting and determining the "applicable" and the
"relevant and appropriate requirements" ("ARARs") for cleanups of
different media at Superfund sites. (See 53 Fed.Reg. 51,441.)

The anti-degradation policy (ADP) which the New Jersey Department
of Environmental Protection (DEP) asserts should be used to
establish cleanup requirements for groundwater at the Site is
located within NJAC 7.9-6.4(h). That regulation states:

The Central Pine Barrens Area constitutes a unique and
particularly fragile ecosystem ... In light of the
vulnerable character of the area, the Department . . .
shall not, in the performance of its statutory duties,
approve anv activity which, alone or in combination
with any other activities, will cause degradation in
the existing groundwater quality . (emphasis added).

The Agency has concluded that the ADP, as stated in NJAC 7.9-
6.4(h) above, does not provide a basis for establishing
quantified target cleanup levels for groundwater contaminants at
the Ewan Site which can be required pursuant to CERCLA. The
reasons for this are as follows:

1. "Applicable" requirements, within the context of remediations
at Superfund sites, mean "those cleanup standards . . .
criteria, or limitations promulgated under Federal or State law
that specifically address a hazardous substance, pollutant,
contaminant, remedial action, location or other circumstance at a
CERCLA site." 53 Fed.Reg. 51,436.

Furthermore, to be "applicable", a requirement should meet the
following four prerequisites: (a) the party be subject to the
requirement's authority, (b) the activities be prohibited or
directed by the regulation, (c) the substances or places be
within the requirement's authority, and (d) the effective time
period for the regulation. (See 53 Fed.Reg. 51,436.)
-------
The Ewan Site is located within the "place", i.e., the Central
Pine Barrens region covered by the regulation (i.e., the ADP).
The proposed remedial action is also, at least arguably, within
the "effective time period" of the regulation.

However, the ADP in question does not address any specific
hazardous substance, pollutant or contaminant which exists at the
Site. It does not refer to or relate to Superfund cleanups, in
particular, or even any site cleanups, in general. The wording
of the ADP itself is prospective; it talks in terms of activities
which will cause degradation. The remedial action planned for
the Site will not cause degradation of groundwater at the site
and, therefore, it does not fall within the plain meaning of the
those activities regulated by the ADP ..provisions. It is,
therefore, not a regulated "activity" .within the meaning of the
ADP.

The ADP, therefore, fails to meet the prerequisites for an
"applicable" requirement for CERCLA groundwater remediation at
the Ewan Site.

2. "Relevant and appropriate" requirements, within the context
of Superfund site remediations, mean "those cleanup standards . .
. criteria or limitations promulgated under Federal or State law
that, while not "applicable" . . . address problems or situations
sufficiently similar to those encountered at the CERCLA site that
their use is well suited to the particular site." 53 Fed. Reg.
51,'"6. The determination of whether an alleged "requirement" is
rfciii-. -rt and appropriate is a two-step process. The requirement
must .••• determined to be both relevant and, even if relevant,
appropriate for use at a particular site.

First, "relevance" is determined by comparing the action,
location or chemicals covered by the requirement with related
conditions at the site, release or potential remedy; a
requirement is relevant if the requirement generally pertains to
these conditions. (£e_g 53 Fed.Reg. 51,436.) As noted above, the
ADP, by its own wording, is prospective. It refers to activities
which "will cause degradation". CERCLA remedial actions, such as
that proposed for this site, are aimed at remediating pre-
existing contamination not causing some future degradation.
Therefore, the ADP is :.iot "relevant" to setting target cleanup
levels in groundwater at the Ewan site.

Only those requirements which are both relevant and appropriate
must be complied with. (See 53 Fed.Reg. 51,436.) Since the ADP
is neither applicable nor relevant for establishing target
cleanup levels for groundwater cleanup at the Ewan site, it does
not constitute an ARAR under Section 121(d)(2) of CERCLA for
-------
remediation of groundwater at this site. This view is supported
by EPA guidance which states that at a CERCLA site, a State
ground water antidegradation law would not require cleanup to the
aquifer's original quality. (See ARARs Q's & A's, OERR 9234.2-
01FS, May 1989.)
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Appendix C
Chrysler Motors Corporation
-------
HOGAN & HARTSON

COLUMBIA SQUARE

555 THIRTEENTH STREET NW

WASHINGTON, DC 20004-tlOO

202/637-5600

DAVID J. HAYES

OIUfCT OIAL 2Ot/MT-M13
Attachment C.I
•TW ROCKLEDOE DRIVE

MTMESOA. MARYLAND 2O817

3O1/493-0030

m SOUTH CALVERT STREET

BALTIMORE, MARYLAND 21202

301/8S»-3700

•300 QREENSaORO DRIVE

MCLEAN, VIRQINIA 22102

7O3/84a-2MO
September 11, 1989
VIA TELECOPY AND FEDERAL EXPRESS

James P. Rooney, Esq.
Office of Regional Counsel
U.S. Environmental Protection Agency
26 Federal Plaza
New York, NY 10278

Craig DeBiase
Project Manager
U.S. Environmental Protection Agency
26 Federal Plaza
New York, NY 10278

Re: Ewan Property/Shamona Township

Dear Messrs. Rooney and DeBiase:

Enclosed are- the comments of the Chrysler Motors
Corporation on the Feasibility Study (FS) for Operable Unit Two
for the above-captioned site. They were prepared with the
technical assistance of Hart Environmental Management Corporation
and Goldberg-Zoino & Associates.

Through this letter, Chrysler is filing the enclosed
comments today, the deadline for public comments on the FS. In
addition to the copy that is being supplied via facsimile,
another copy is being sent to you via Federal Express.
Sincerely,
David J. Hayes
DJH/sw

cc: William C. Achinger
Lynn Y. Buhl, Esq.

6075H
"HOOANOCft \MASHINOTON". TCLEX! 24MTO (MCA}, M2TS7 (WU)> FACSIMILE* 20a/837-S*K3. EA«VUNK« 8277*734
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COMMENTS ON THE FEASIBILITY STUDY
FOR OPERABLE UNIT TWO
EWAN PROPERTY SITE
SHAMQNG TOWNSHIP
Comments submitted by:

Chrysler Motors Corporation
September 11, 1989
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TABLE OF CONTENT^

PAGE
I. EXECUTIVE SUMMARY 1
A. Groundwater/Soil Cleanup Standards 1
B. Remedy Selection 3
II. THE FEASIBILITY STUDY IMPROPERLY IDENTIFIES
NEW JERSEY'S CLASS GW1 GROUNDWATER STANDARD
AS AN ARAR FOR THE EWAN PROPERTY SITE 6
A. Background «. 7
1. The Class GW1 standard 7
2. The Pine Barrens . 7
3. ARARS 8
B. The Class GWl Standard is not an
ARAR for the Ewan Property Site 9
1. The Class GWl Standard is Not
•Applicable" to the Ewan
Property Site 9
2. The Class GWl Standard is Not
•Relevant and Appropriate" 11
C. Even if the Class GWl Standard
Qualified as an ARAR, SARA'S
Waiver Principles Would Clearly
Apply in This Case , 16
1. The Class GWl Standard Has
Not Been Consistently Applied 16
2. Application of the Class GWl
Standard May Result in Greater
Risk to Health and the
Environment 18

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PAGE

III. THE REMEDY SELECTED BY THE FS IS NOT
SUPPORTED BY ADEQUATE DATA 20

A. The Existing Data Base Does Not
Support EPA's Attempt to Distinguish
Between "Heavily Contaminated* and
•Less Contaminated" Soils 20

B. The Existing Data Base Does Not
Support the FS's Evaluation of
the Extent and Nature of Soil
Contamination 21
*,
C. The FS's Soil Remediation Screening
Process Improperly Excluded
Cost-Effective Combinations of
Technologies 24

D. The Predesign Work Scheduled in
Connection With the Implementation
of Operable Unit One Will Provide
the Data Needed to Identify a
Preferred Alternative for
Operable Unit Two 28

E. There Are Serious Issues Related
to the FS's Preferred Soil Remediation
Alternative That Have Not Been
Addressed 30

F. The FS's Recommended Groundwater
Pumping Scheme Is Not Supported
by Sufficient Data 32

IV. CONCLUSION 35
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I. EXECUTIVE SUMMARY
These comments submitted by Chrysler Motors
Corporation identify several major flaws in the Feasibility
Study ("FS") for Operable Unit Two of the Ewan site that must
prompt fundamental revisions in the FS before the Agency can
adopt a Record of Decision ("ROD") for Operable Unit Two. In
addition to these major flaws/ the comments also identify
several additional deficiencies that must be addressed prior to
adoption of a ROD for the Second Unit.
A. Groundwater/Soil Cleanup Standards
The FS has proposed improper and unauthorized cleanup
standards for Operable Unit Two. As explained at length below,
the FS identifies a non-degradation groundwater cleanup
standard (the "GW1" standard) and an extremely stringent soil
cleanup standard that has been derived from the groundwater
standard. The proposed CERCLA cleanup standard is based on the
State of New Jersey's classification system for the Central
Pine Barrens (also known as the Pinelands Preservation Area).
The proposed standard is neither applicable nor
appropriate to CERCLA sites in general, or to the Ewan site in
particular. As an initial matter, the Ewan site is not in the
Central Pine Barrens and the groundwater standard simply does
not apply to the site. Moreover, even if the site were located
within the boundaries of the Central Pine Barrens, the standard
nonetheless would not apply. EPA explicitly has determined
-------
that the GW1 standard is not applicable to the Tabernacle Drum
Site, a CERCLA site that is located within the Central Pine
Barrens. EPA has reached a similar conclusion for the Lang
CERCLA Site, another site that is within the Central Pine
Barrens.
EPA's prior determinations that the GWl standard does
not apply to CERCLA sites that are within the Central Pine
t,
Barrens applies with all the more force to sites, such as Ewan,
which are outside the boundaries of the Central Pine Barrens.
Indeed, EPA has confirmed on several occasions that the
Pinelands standard does not apply to CERCLA sites that are
located outside the Preservation Area including, for example,
the Ciba-Geigy Chemical Corporation Site and the Cooper Road
Dump. The rationale for EPA's prior rejection of the GWl
standard is equally applicable to the Ewan site. EPA
previously rejected the GWl standard as an ARAR because, among
other failings/ it is a non-numerical and non-quantitative
standard that does not identify specific concentration limits
for contaminants.
All of these key defects make the GWl standard, and
the soil cleanup standard derived from it, inapplicable and
inappropriate for the Ewan site. If EPA were to adopt such
standards in a ROD for Operable Unit Two, it would be
promulgating legally unenforceable cleanup standards that are
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not consistent with statutory requirements set forth in
Section 121 of the Superfund Amendments and Reauthorization Act.
B. Remedy Selection
Serious flaws in EPA's remedy selection process have
resulted in the selection of inappropriate remedial measures
for the Ewan Site. First, the FS confirms that there is no
valid technical basis for distinguishing between "heavily
contaminated soil" and "less heavily contaminated soil" at the
Ewan Site. Despite the FS's inability to characterize
so-called "heavily contaminated soil" and "less heavily
contaminated soil," and despite its inability to identify a
meaningful distinction between these arbitrary categories, the
FS exacerbates the flaws of Operable Unit One by relying
heavily on these artificial categories when analyzing potential
remedial alternatives. Second, EPA's assessment of the extent
and nature of soil contamination is based on flawed, unreliable
interpolations from widely-spaced data. Because the volume and
distribution patterns of volatile organic compounds and metals
have a significant impact on the selection of treatment
technologies, relying on inadequate data has caused EPA to
«.
overlook several promising remediation alternatives.
Even in the absence of these difficulties, the FS does
not include a sound legal or technical basis for identifying a
*-^
preferred remedial alternative for the Ewan Site. More

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specifically/ there are several serious problems associated
with the proposed solvent extraction/soil washing remedy that
the FS has either ignored or addressed inadequately including,
in particular, the remedy's ability (or inability) to
accomplish the FS's remediation goals. The proposed remedy
•
also presents potential concerns related to the release of
volatiles during excavation that EPA has not addressed. In
addition, the solvent proposed for use in extraction at the
Ewan Site, triethylamina (TEA), has not been demonstrated to be
effective, and its use creates serious odor problems that the
FS has failed entirely to address. More generally, EPA has
admitted that the TEA solvent extraction method is an unproven,
experimental technology that may not be appropriate for CERCLA
actions.
The FS's proposed groundwater pumping remedy is
similarly flawed. EPA does not have sufficient data on either
the age of the groundwater contamination or aquifer properties
to develop a pumping scheme. Also, EPA relied on an overly
simplistic method of estimating the required number of wells
for the pumping remedy. As a result, EPA has no reliable basis
for evaluating either the costs/ or the effectiveness, of the
groundwater remedy — two essential elements of the remedy
selection process. Moreover, in light of EPA's need to revise
the groundwater cleanup standard that is applied to this site,
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the Agency must reevaluate the need for, and appropriateness
of, the groundwater treatment system proposed in the FS.
In relying on an inadequate data base and failing to
fully analyze all relevant alternatives, EPA has violated the
statutory mandate of CE5CLA, as well as its own guidelines for
*
screening potential remedies. These guidelines require, at a
minimum, that EPA evaluate the relative effectiveness,
implementability, and cost of the possible remedies.
Because many of the deficiencies in the data base and
in the evaluation of proposed remedies can be cured through
further analysis and data collection, as will occur during the
predesign phase of the Operable Unit One action, it is
imperative that EPA await the availability of the forthcoming
comprehensive site characterization data before issuing the
ROD. EPA and Chrysler already have encountered difficulty in
developing a Statement of Work for the initial phase of a
cleanup (Operable Unit One) because the available data base is
extremely limited. These difficulties will be compounded if
EPA prematurely adopts a ROD for Unit Two. Indeed, it is
Chrysler's strong view that issuance of a ROD for Unit Two on
the current data base, without consideration of the forthcoming
comprehensive site characterization, would be legally and
technically flawed.
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II. THE FEASIBILITY STUDY IMPROPERLY IDENTIFIES NEW
JERSEY'S CLASS GW1 GROUNDWATER STANDARD AS AN ARAR FOR
TflE EWAN PROPERTY SITE

In the FS for Operable Unit Two, EPA identifies the

Class GW1 groundwater standard applicable to the Pinelands

Preservation Area (the Central Pine Barrens) as a
•

location-specific ARAR for the Swan Property Site. This

decision in turn affects several aspects of the selected

remedy, which are pegged to compliance with the Class GWl

standard including, in particular, the cleanup standard

proposed for contaminated soils. I/ The proposed GW1 standard,

however, is not a proper ARAR for the Ewan site, for the

reasons set forth below. Accordingly, the FS and the selected

remedy must be reezamined to select an appropriate ARAR and to

tailor the selected remedy accordingly.
I/ Both "Contaminated Soil Clean-up Goals" and "Contaminated
Groundwater Clean-up Goals" are derived in part from the
Class GW1 standard. Sfifl FS at 2-18, 2-23 (soil clean-up goal
of preventing degradation of groundwater based on Class GWl);
FS at 2-23, B-22 (soil clean-up goal of protecting against
health effects from contamination of ground water based on
Class GWl); FS at 2-32 (groundwater clean-up to background or
non-detect based on Class GWl).

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A. Background
1. The Class GW1 Standard
The FS selects Class GWl as the appropriate
groundwater standard for the Ewan Property Site because Class
GWl is the standard that applies to the Central Pine Barrens.
•
FS at 2-10. New Jersey classifies Class GWl groundwater as
water "suitable for potable water supply, agricultural water
supply/ continual replenishment of surface waters to maintain
the existing quantity and high quality of the surface waters in
the Central Pine Barrens and other reasonable uses.*
N.J.A.C. 7:9-6.5(f). In general terms, Class GWl groundwater
is subject to a non-degradation standard, with the cleanup
standards associated with such groundwater being either
background levels or non-detection levels. See Memorandum of
June 8 from Kevin Psarianos, Bureau of Site Management, NJDEP.
As such, this standard establishes a goal of groundwater purity
that is extremely difficult, if not impossible, to achieve.
2. The Pine Barrens
The Pine Barrens region of New Jersey is a
sensitive ecological system which the State is committed to
preserving. The State has established a Pinelands Commission/
which "bears ultimate responsibility for implementing and
enforcing the provisions of the Pinelands Protection Act and
[the Pinelands Management] Plan." N.J.A.C. § 7:50-1.1; see
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N.J.S.A. § 13:18A-4. The Pinelands Commission has
divided the lands in the overall Pinelands Region into two
primary areas: the Pinelands Preservation Area (i.e.. the
Central Pine Barrens), which is the most ecologically important
and sensitive area, and the Pinelands Protection Area, a less
•
sensitive region which lies outside the Preservation Area.
N.J.S.A. § 13:18A-11. The Pinelands Commission has determined
that the Ewan Property site is not Ideated within the Pinelands
Preservation Area, but instead lies in the Pinelands Protection
Area. FS at 1-12.

3. ARARs
Section 121(d)(4> of CERCLA requires that a ,
selected remedy attain "a level or standard of control for
[hazardous substances] which at least attains [any] legally
applicable or relevant and appropriate standard, requirement,
criteria, or limitation." 42 U.S.C. § 9621(d)(4). Pursuant to
this statutory mandate, the FS identifies numerous standards
which may be applicable or relevant and appropriate
requirements ("ARARs") for the Ewan Property site, including
federal and state Safe Drinking Water Standards, as well as the
groundwater protection standards set forth in N.J.A.C. 7:9-6.6
(l^fiju, the Class GWl standard). As the summary accompanying
the FS explains, the latter standards "were codified to
maintain natural conditions of the Central Pine Barrens

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groundwater," and the remedy selected to meet these standards
•would attempt to remediate the groundwater to the more
stringent standards that have been developed for the protection
of the Central Pine Barrens' unique ecosystem." FS Summary at
12.
B. The Class GW1 Standard is not an ARAB for the
%wan Property Site
'.
1. The Class GW1 Standard is Not "Applicable'
to the Ewan Property Site
Applicable requirements "may be identified on a
site-specific basis by determining whether the jurisdictional
prerequisites of a requirement fully address the circumstances
at the site or the proposed remedial activity." 53 Fed. Reg.
51394, 51436 (Dec. 21, 1988) (Proposed National Pollution
Contingency Plan ("NCP")). EPA states that a typical
jurisdictional prerequisite is that "[t]he substances or places
[be] within the authority of the requirement." IdL (emphasis
added).
The FS applies the Class GW1 groundwater standard to
the Ewan Property site because those standards apply to the
Central Pine Barrens Region. The FS summary asserts that "the
site ... is defined by N.J.D.E.P. as being in the Central
Pine Barrens Region of the New Jersey Pinelands." FS Summary
at 12. In fact, however/ the FS itself.concedes that
"[allthough the site is located near the border between the

' - 9 -
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Pinelands Preservation and Protection Areas, the Ewan Property
is located within the Pinelands Protection Area." — not within
the Preservation area. FS at 1-12 (emphasis added). Moreover,
as noted above, the authoritative agency for determining
Pinelands status, the Pinelands Commission, has determined that
•
the site lies outside the Pinelands Preservation Area, and lies
instead in the less-sensitive Pinelands Protection Area. Id.
at 2-11. Accordingly, the stringent Class GW1 standard, which
•was developed to preserve and restore the pristine conditions
of the Central Pine Barrens Region of the New Jersey
Pinelands," FS Summary at 8 (emphasis added), does not apply to
the Ewan Site, because that site is not within the region
covered by that standard.
In addition to being outside the relevant area, EPA
has recognized that the non-specific nature of the Pinelands
groundwater standard makes it inapplicable to CERCLA cleanups.
In a letter from EPA's Remedial Action Branch Chief regarding
the cleanup of the Tabernacle Drum Site, a site located within
the Central Pine Barrens, EPA clearly stated that "we do not
believe that the non-degradation standard [of the Pinelands
Comprehensive Management Plan] is an applicable requirement."
Letter from John S. Frisco to William F. Harrison, Assistant
Director of the Pinelands Commission (May 11, 1988) ("Frisco
Letter"). The Frisco letter also noted that "it is EPA's
policy to only consider numerical or quantitative standards in
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establishing cleanup goals for Superfund Sites,* and since the
Pinelands standard "does not identify specific concentration
limits" for contaminants, EPA would not utilize the standard in
determining appropriate cleanup levels. Id. Similarly, in
EPA's Responsiveness Summary to the draft Feasibility Study for
•
the Lang CERCLA Site, also located "within the Central Pine
Barrens Water Quality Critical Area and the Pinelands
Preservation Area," EPA Record of Decision, Lang Property Site,
at 1 (Sept. 29, 1986) (emphasis added), EPA explained that
•background levels [the standard recommended by the Pinelands
Commission] do not provide well-defined criteria to measure
whether an area has been cleaned of contamination." Final
Responsiveness Summary to the Draft Feasibility Study Report,
Lang Property Site, at 9. Accordingly, EPA elected to "rel[y]
on State and Federal Standards to determine whether water
quality is acceptable." Id.

2. The Class GW1 Standard is Not "Relevant and
Appropriate" •
In EPA's own terms, the primary task for determining
whether a standard is relevant and appropriate/ and thus
eligible to serve as a location-specific ARAR, is whether the
CERCLA site in question "is sufficiently similar to the
location upon which the requirement is based." 53 Fed. Reg. at
51436. Determining whether a requirement is both relevant and
appropriate, according to EPA's proposed NCP, is a two-step
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process. First/ it is necessary to compare the location
covered by the requirement and the "related conditions of the
site"; a requirement is relevant "if the requirement generally
pertains to these conditions." 1£L. Next, the comparison "is
further refined by focusing on fche nature of the substances/
the characteristics of the site/ the circumstances of the
release/ and the proposed remedial action; the requirement is
appropriate if/ based on such comparison/ its use is
well-suited to the particular site." Id.
While the FS is not clear on this point, EPA
apparently has determined that the Class GW1 standard developed
for the Central Pine Barrens also is relevant and appropriate
for the Ewan Property Site/ which lies outside the Central Pine
Barrens/ because the two areas are sufficiently similar. This
is not/ however/ the case. The Agency charged with protecting
the Pinelands/ the Pinelands Commission/ had an opportunity to
classify the Ewan Property Site as within the Central Pine
Barrens Region, but explicitly chose not to do so. A Summary
of the Pinelands Plan (Feb. 6, 1981) at 5. The Comrrission's
action reflects the State's decision that the area which
includes the Ewan Property Site is not sufficiently similar to
the Central Pine Barrens Region to merit equal protectiveness.
Accordingly, EPA's attempt to apply the Central Pine Barrens'
groundwater standards represents a fundamental legal flaw in
the FS.
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Moreover, the GW1 standard is not "appropriate" as
applied in this case. According to the FS, the rationale for
applying the GW1 classification outside of the Central Pine
Barrens is a concern that contaminants from the Ewan Property
Site will migrate to the more ecologically sensitive region.
The record provides absolutely no support for such a concern.
Only a limited groundwater plume is associated with the Ewan
site, and there is no evidence whatsoever that migration of
contaminants to the Central Pine Barrens area represents a
i,
realistic concern. To the contrary, the FS elsewhere
acknowledges that the Ewan contamination is highly localized
and amenable to local remedial efforts.
The cleanup standards for soil and groundwater set by
the FS are also not "well suited to the particular site" as
required by EPA's appropriateness criteria, see 53 Fed. Reg. at
51436, because they are simply not feasible. 2/ The soil
cleanup goals identified in the FS are extremely low, and it is
not clear whether the currently proposed remedial alternative,
or any other remedial alternative, can accomplish these goals.
Chrysler engaged the services of two technical consultants
to review the FS and provide technical comments. The
consultants, whose comments are incorporated into this
feasibility discussion as well as into Part III below, are Hart
Environmental Management Corporation, and Goldberg-Zoino &
Associates.
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As noted below at page 28, the solvent extraction/soil washing
bench-top treatability testing performed on Ewan soil samples
indicated that the proposed goals were not met, see Appendix E
to the FS at E-18; moreover, as also noted below, solvent
extraction/soil washing remains an unproven, experimental
technology. Nonetheless, EPA has identified the solvent
extraction/soil washing technique as the preferred remedial
alternative for residually-contaminated soils for the Ewan Site.
EPA's proposed groundwater cleanup goals may also be
technologically infeasible, and therefore inappropriate, for
the Ewan Site. A June 7, 1988 NJDEP Memorandum concedes that
the planned Ewan cleanup may not achieve the recommended
groundwater standard, noting that "[i]f the . . . cleanup
objectives are found by the contractor to be technologically
unachievable then the cleanup objectives may be set based upon
BAT (Best Available Technology)." See Attachment E to Appendix
B of the FS.
The groundwater cleanup goals are also inappropriate
because they, may not be measurable. It may be difficult for
laboratories to determine whether the groundwater cleanup goals
are met, due to the laboratories' inability to reach detection
limits as low as the proposed cleanup goals. A comparison of
EPA's listed contract-required detection limits (CROLs), &&&
Attachment B to Appendix B of the FS, with the proposed Ewan
groundwater cleanup goals, see FS at 2-34, illustrates this
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difficulty. Technical consultants working on Chrysler's behalf
contacted two laboratories participating in EPA's Contract
Laboratory Program (CLP) to inquire about their ability to
reach detection limits at or below the proposed groundwater
cleanup goals for the Ewan Site. Both of the CLP laboratories,
ERCO and E3I, were skeptical about their ability, or that of
other CLP laboratories/ to meet the detection limits identified
t,
in the FS for a number of contaminants.
Both the soil and groundwater cleanup goals are thus
technically infeasible, and must be reevaluated. EPA's own
guidelines note that "technical factors," including
"detection/quantification limits for contaminants, technical
limitations to restoration, [and] the ability to monitor and
control movement of contaminants," are among the "pertinent
factors for modifying the remediation goals within the
acceptable risk range." 53 Fed. Reg. at 51426. Review of
these technical factors indicates that EPA should indeed
consider modification of the FS's proposed soil and groundwater
cleanup goals. To formulate technologically achievable, and
therefore more appropriate, cleanup standards, additional
treatability testing and laboratory studies are needed.
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C. Even if the Class GW1 Standard Qualified as an
ARAR, SARA's Waiver Principles Would Clearly
Apply in This Case
Section 121(d)(4) of CERCLA provides for waiver of
ARARs under certain specified conditions. While the Class GW1
standard is not an ARAR for the reasons set forth above, even
•
if the standard were eligible for ARAR status, at least two of
the statutory criteria for waiver would apply in this case.
1. The Class GW1 Standard Has Not Been
Consistently Applied . •
Section 121(d)(4)(E) provides that waiver is
appropriate when "the State has not consistently applied (or
demonstrated the intention to consistently apply) the standard,
requirement, criteria, or limitation in similar circumstances
and other remedial actions within the State."
42 U.S.C. § 9621(d)(4)(E). In its proposed NCP, EPA noted that
State standards should not be applied "where there is evidence
that the State does not intend to apply them elsewhere."
53 Fed. Reg. at 51440. According to the proposed NCP, "EPA
envisions using this waiver* when State requirements "[have]
never [been] applied because of a lack of applicability in past
situations,* or when State standards "have been variably
applied or inconsistently enforced." IdL.
To evaluate the appropriateness of granting a waiver
of a State requirement due to inconsistent application, EPA's
Interim Guidance on Compliance with ARARs recommends evaluating
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the application of the requirement to similar sites or response
circumstances, or examining the proportion of cases in which
the requirement was not applied out of the total number of
actions in which it could have been applied. 52 Fed. Reg.
32498 (Aug. 27, 1987). In addition, an intention to
*
consistently apply a State standard may be evaluated through
such materials as site remedial planning documents. Id.
Applying these waiver guidelines to the Pinelands GW1
standard, it is clear that the standard has not been applied
consistently. For example, at the Tabernacle Drum Dump Site,
located "in the northern region of the New Jersey Pine
Barrens," EPA Record of Decision, Tabernacle Drum Dump, at 5
(June 30, 1988), the Pinelands groundwater standard was not
used as an ARAR. The NJDEP Memorandum identified above
confirms that the Pinelands groundwater standard was not
applied to the Tabernacle Site. See Attachment E to Appendix B
of the FS. In addition, the above-referenced letter from the
New Jersey Remedial Action Branch Chief regarding the
Tabernacle Site states that the Branch "dotes] not believe that
the non-degradation standard [of the Pinelands Comprehensive
Management Plan] is an applicable requirement." Frisco Letter,
at 2.
EPA has not only failed to apply the Pinelands
groundwater standard within the Pinelands Preservation Area,
which presumably is the area of greatest concern for which the
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standard would be most appropriate, but it also has recently
declined to apply the standard to nearby sites located outside
the Preservation Area. See EPA Record of Decision, Ciba-Geigy
Chemical Corporation Site (April 24, 1989); EPA Record of
Decision, Cooper Road Dump (Segt. 30, 1987).
Thus, the FS's attempt to apply the GW1 standard
appears to have been formulated solely for this case. When
confronted with other Superfund sites located near the
Pinelands Preservation Area, EPA never applied, or expressed an
intention to apply, the GW1 standard. Instead, EPA explicitly
stated that the Pinelands standard is nflt an applicable
requirement. Hence, even if the class GW1 standard were to
qualify as an ARAR (which it does not), waiver of the standard
in this case would be fully appropriate.

2. Application of the Class GW1 Standard May
Result in Greater Risk to Health and the
Environment
Section 121(d)(4)(B) provides that an ARAR may be
waived when compliance with it at a particular facility would
result in greater risk to human health and the environment than
alternative options. As is discussed in Part III of these
comments, the remedy that EPA has selected to satisfy the
stringent Class GW1 standard at the Ewan Property site presents
unnecessary environmental risks, by allowing discharges of
volatile organics through extensive excavation of less heavily

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contaminated soils. The massive excavation process, needed in
order to utilize the solvent extraction portion of the soil
remedy, will release volatiles to the air that otherwise would
not be released in an uncontrolled manner. Thus, the very
techniques used to reach the nearly-impossible cleanup
standards for the Central Pine Barrens may have the ironic
result of increasing public exposure^to hazardous materials.
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III. THE REMEDY SELECTED BY THE FS IS NOT SUPPORTED BY
ADEQUATE DATA
A. The Existing Data Base Does Not Support EPA's
Attempt to Distinguish Between "Heavily
Contaminated" and "Less Contaminated* Soils
As Chrysler noted in its comments on Operable Unit
One, there is no sound basis far distinguishing between
"heavily contaminated soils* and "less heavily contaminated
soils." The FS for Operable Unit Two compounds the flaws of
Operable Unit One by perpetuating this arbitrary distinction.
The Agency's own treatability studies demonstrate that
EPA's attempt to draw a line between soil types is unsound and
unworkable. In attempting to collect a composite sample of
heavily contaminated materials for treatment evaluation, the FS
relied on samples from an area previously classified as heavily
contaminated only to find that the soil sample was much more
diluted than expected; indeed, the sample met the cleanup goals
identified in the ROD for Operable Unit One for all but one
parameter (phenol). In light of EPA's own difficulties in
differentiating between contaminated soils, Chrysler believes
that the Agency should reassess its approach to soil
contamination and limit the Operable Unit One
remedy — incineration — to drums and their contents.
The results of the treatability study lend further
support to this approach. The study found that the solvent
extraction/soil washing remedy, which the FS selected for use

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on the less contaminated soils, was as effective against
•heavily contaminated soils." Thus, if the FS's own analysis
of the solvent extraction/soil washing method is correct, soils
currently slated for incineration as part of Operable Unit One
could be treated as part of Operable Unit Two while still
•
protecting public health and the environment. An additional
advantage to such an approach is that the unit cost of solvent
extraction/soil washing is significantly lower than that for
incineration, thereby satisfying CERCLA's cost-effectiveness
requirement. Sflfl 42 U.S.C. 9621(a). Together with EPA's
inability to distinguish between heavily contaminated and less
heavily contaminated soils, the Agency's evaluation of the
solvent extraction/soil washing remedy suggests that the most
effective and efficient approach to the site's soil
contamination problem is to treat all of the soil together and
reserve incineration for drums and their contents.

B. The Existing Data Base Does Not Support the FS's
Evaluation of the Extent and Nature of Soil
Contamination
The FS's selection of an appropriate remedy is based
in part on the Agency's assessment of the extent and nature of
soil contamination at the site. That assessment, however, is
based on flawed assumptions and interpolations from
widely-spaced data which, to the extent they are useful at all,
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suggest that the FS's selected remedy is not well-suited to the
conditions at the Ewan site.
Based on soil-gas screening, geophysical surveys and
soil samples from a limited number of test pits and soil
borings, the FS concludes that there are 22,000 cubic yards of
•
"residually contaminated soil* requiring remediation as part of
Operable Unit Two.
There is virtually no data that supports such a
conclusion. First, while soil-gas screening and geophysical
surveys provide useful "first cut" information on possible
locations of areas of past waste disposal and contamination,
they cannot serve as a substitute for detailed investigations
into the nature and extent of the contamination. Although the
FS suggests that such investigations may be underway, the
results of these investigations were not provided to Chrysler.
A second key difficulty is that the number of soil explorations
undertaken to confirm the presence of contaminated
materials — eight test pits and thirteen soil borings — is
insufficient considering that the area of potential concern
covers nine acres. It is inconceivable that the kind of
thorough assessment of site conditions necessary for the
development of a ROD could be made on the basis of twenty-one
widely-spaced soil explorations, almost half of which failed to
detect contamination levels in excess of proposed cleanup
goals. In addition, of the site explorations which detected
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significant contamination levels, the contamination was found
either in surficial or in deeper soils, but not both. Thus,
the FS's assumption that both layers of soil would always need
to be treated is not consistent with the data. Finally, the
FS's assumption of an average depth of excavation of eight feet
below ground surface, approximately two feet below the average
water table in this area of the site, is not supported by the
laboratory data collected to date. As a result, EPA has
included "soil" in its estimate that is at or below the
groundwater table, and it also has assumed - without support —
that all levels of soil are contaminated.
In addition to failing to adequately assess the volume
of contaminated soil, the limited data collected during the RI
fail to provide an accurate picture of the identity and
distribution of the soil contaminants — an essential element
of the remedial selection piocess. Of the eight test pits
excavated in Area A, volatiles were detected in only four.
Contaminant concentrations were found to exceed proposed soil
cleanup goals in only three of the eight test pits. In
addition, of thirteen soil borings installed in Area A,
contaminant concentrations Above proposed soil cleanup goals
were observed in only eight of the borings; only six borings
had levels of one or more metals in excess of the proposed soil
cleanup goals. Volatile organics were detected in excess of
proposed soil cleanup goals in three of the same borings, and
- 23 -
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in surficial soil samples only rrom three other borings.
Semi-volatile organics were observed in only two of the
thirteen borings.
These data indicate that the site is characterized by
smaller, localized areas of contamination, due to past waste
burial in pits and trenches, rather than the 22,000 cubic yards
of contamination estimated by the FS. Moreover, the data
t,
indicate that volatile organics are the most widely distributed
class of compounds on the site, while metals and semi-volatile
organics have been detected above proposed soil cleanup goals
in only a limited number of locations. As a result of EPA's
failure to assess the implications of this data, the Agency has
identified an inappropirate remedial alternative as its
•preferred alternative," and has failed to consider
combinations of proven technologies that appear to be
well-suited to the Ewan Site's contamination pattern*

C. The FS's Soil Remediation Screening Process
Improperly Excluded Cost-Effective Combinations
of Technologies
The evaluation process conducted to screen the various
remedial alternatives for the Ewan Site failed to satisfy
CERCLA's statutory requirements, or EPA's own screening
guidelines, and it would be highly improper for EPA to issue a
ROD, which constitutes a final decision regarding the
appropriate remedy, based upon this insufficient evaluation.

- 24 -
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Section 121 of CERCLA requires that certain factors be
considered in the remedy-selection process. For example, the
potential threat to health and the environment associated with
the proposed remedy, as well as its long-term maintenance
costs, must be considered. Sfifij 42 U.S.C § 9621(b)(l). The
guidelines contained in EPA's proposed NCP, which are based on
the statute, state that the remedy screening process involves
':
"a preliminary evaluation of the relative effectiveness,
implementability, and cost of the alternatives." 53 Fed. Reg.
at 51427. The purpose of the screening process is to "ensurEe]
that the number and the types of alternatives carried forward
matches the nature and complexity of the site problems," id. at
51428, since "EPA believes that it often will be the case that
the most appropriate solution for a site will involve a
combination of methods of achieving protection of human health
and the environment." id. at 51423.
It is clear that the full range of treatment options
was not considered in the FS, as the statutory and agency
guidelines require. As described above/ EPA relied upon an
erroneous conclusion — that substantial volwnes of soil are
contaminated with several classes of contaminants — to select
the solvent extraction/soil washing treatment alternative.
Because the limited data indicate that the site is in fact
characterized by smaller pockets of unevenly distributed
contaminants, and because the differing distribution patterns
- 25 -
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of volatiles and metals should have a significant impact on the
identification and evaluation of treatment technologies, other
treatment alternatives are available and need to be considered
as part of the FS process.
One technology alternative eliminated from
•
consideration by EPA but requiring further study is in-situ
soil vapor extraction, also known as vacuum extraction or soil
venting, which is well suited to the remediation of
volatiles-contaminated, unsaturated-zone soils. Although the
FS acknowledged that this treatment technology "is generally
useful in reducing organic contamination, particularly
volatiles," FS at 2-43, its use for the Ewan Site was rejected
because EPA believed it might not affect inorganic, and in some
cases semi-volatile, contamination, thus requiring the use of
additional technologies to address this contamination. Id.
EPA also noted that environmental and process control of
in-situ reaction processes is much more difficult than
above-ground processes, id.
EPA's reservations notwithstanding, the soil vapor
extraction option has several advantages which the FS has
completely overlooked. First, trench-based vapor extraction
systems have been used to successfully remediate
unsaturated-zone soil under shallow water table conditions. In
addition, this approach is extremely cost-effective; cleanup to
detection limit levels has been demonstrated at costs ranging
- 26 -
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from $20 to $50 per cubic yard for large sites. Also, because
vapor extraction eliminates the release of volatiles associated
with soil remediation technologies requiring excavation, it may
be more protective of public health and the environment.
Moreover, vapor extraction is a demonstrated technology which
*
is widely used for remediating the type of granular soil
present at the Ewan Property Site.
*.
It is possible, as the FS asserts, that vapor
extraction may not fully address inorganic or semi-volatile
contamination. However, this technology could still be
effectively utilized in combination with other treatment
options; as noted above, EPA "believes that it often will be
the case that the most appropriate solution for a site will
involve a combination of methods." 53 Fed. Reg. at 51423.
Accordingly, smaller volumes of soil contaminated with
semi-volatiles and metals could be remediated using several
methods, none of which were considered in the FS. For
instance, the soil could be treated on-site via a
microencapsulation-based solidification method, such as the
service offered by HAZCOM, Inc. and hailed by EPA.
EPA/540/A5-89/001, May 1989.
Remarkably, the FS failed completely to discuss or
analyze possible combinations of different cost-effective
treatment technologies including, for example, the use of
in-situ soil vapor extraction to address volatiles and
- 27 -
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supplemental additional approaches to treat semi-volatiles and
metals. Relying on an extraordinarily sparse data base, the FS
adopted an extraordinarily simplistic approach when screening
remedial alternatives, with tens of millions of dollars at
stake, and with the need to identify a workable and effective
remedy, EPA should not endorse this short-cut approach —
especially when much more comprehensive data will soon become
available which is directly relevant to the remedy selection
process.
D. The Predesign Work Scheduled in Connection With
the Implementation of Operable Unit One Will
Provide the Data Needed to Identify a Preferred
Alternative for Operable Unit Two
The proposed pre-design study incorporates numerous
elements specifically designed to provide a more comprehensive
understanding of the composition and extent of contamination at
the Ewan site. The five most critical elements of the proposed
pre-design study in this respect are: (1) a supplemental
geophysical study; (2) a soil gas analysis; (3) a soil
sampling/test pit program; (4) an incineration study; and
(5) aquifer testing for dewatering excavation. All of these
analyses will provide extensive data that will assist EPA in
identifying an appropriate remedy for Operable Unit Two.
The supplemental geophysical study will further
.^
delineate the extent of buried drums and provide a basis for
•»
evaluating the need to implement dewatering of the excavation.
- 28 -
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The study will also be useful in identifying areas which should
be directly investigated in the soil sampling/test pit program.
The soil gas analysis will delineate areas of source
contaminants and more closely define shallow groundwater
contamination. The data compiled from this analysis will be
*
useful in further defining excavation limits and clarifying the
distribution of volatile contaminants across the site.
».
The proposed pre-design study also envisions a program
of soil sampling in conjunction with extensive test pitting
which will collect visual and analytical data for source
characterization and help in further defining limits of
contamination/ developing a more accurate estimate of the
number of drums and evaluating the need for dewatering of the
excavation.
The incineration study wii:i help differentiate between
wastes appropriate for thermal destruction and wastes that are
more suitable for other treatment tochnologies.
Finally, the pre-design study provides for limited
aquifer testing to collect the required design parameters
associated with the implementation of a temporary dewatering
system for use during waste excavation activities. This
undertaking will provide invaluable information that can be
used in subsequent predesign.
Clearly/ the proposed pre-design study will collect
extensive data relating to the characterization of the site,
- 29 -
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including waste descriptions/ disposal characteristics/
subsurface conditions, dewatering requirements/ and visual
analysis. In light of the fact that this critical information
will be available in the near future/ there is simply no
justification for formulating a, remedy for Operable Unit Two
without it.
E. There Are Serious Issues Related to the FS's
Preferred Soil Remediation Alternative That Have
Been Addressed
EPA's preferred remedial alternative for
residually-contaminated soil (the solvent extraction/soil
washing technique) involves the on-site excavation and
treatment of soil/ followed by soil rinsing/ and the off-site
incineration of spent solvent. Despite EPA's assertion that
"treatability studies for the preferred alternative/ Solvent
Extraction/Soil Washing/ have shown that the cleanup goals for
the soils can be attained/" FS Summary at IS/ it is by no means
certain that EPA's chosen remediation alternative can
accomplish the soil cleanup goals proposed in the FS. In fact/
the solvent extraction/soil washing bench-top treatability
testing performed on Ewan Property Site soil samples indicated
that the proposed cleanup goals were not met. Sfifl Appendix E
to FS at E-18. In particular/ the testing indicated that
metals would not be substantially removed through solvent
extraction/soil washing. Id.
- 30 -
-------
In addition to questions regarding overall
effectiveness, EPA's chosen soil remediation technique raises
other issues of concern. For example, in selecting the solvent
extraction/soil remediation alternative, EPA did not adequately
examine the potential dangers resulting from the release of
volatiles associated with excavation. The FS merely notes that
"[a]ir monitoring may be necessary during the excavation." FS
at 2-80. Such excavation-related releases have the potential
to pose a threat to human health and the environment, and their
impact must be fully considered before a final remedy choice is
made.
Another issue raised by the choice of the solvent
extraction/soil remediation alternative is EPA's proposal that
the solvent triethylamine (TEA) be used for extraction at the
Ewan Site, even though there are serious drawbacks to the use
of TEA. First, the removal efficiency of TEA is doubtful.
During the bench-scale treatability testing, extraction with
TEA did not substantially reduce volatile and semi-volatile
organic compounds beyond that achieved with water, id.
Moreover, tlie use of TEA solvent extraction technology is still
somewhat experimental. TEA solvent extraction has not yet been
demonstrated in full scale applications for the treatment of
contaminated soil; EPA's own Hazardous Waste Engineering
Research Laboratory acknowledges that treatment of contaminated
soil vi;i solvent extraction "is still considered an emerging
- 31 -
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technology requiring further development and refinement."
Conversation with Ed Bates, U.S. Environmental Protection
Agency, Aug. 31, 1989.
Yet another problem presented by the use of TEA is its
very low odor threshold. The inevitable release of even minor
amounts of TEA during soil excavation and processing will
create a serious nuisance to on-site workers and nearby
residences. In addition, low levels of residual TEA are likely
to remain in the treated soil that will be backfilled on the
site.
The FS failed to address anv of these serious
deficiencies at the same time that it stated its preference for
use of the solvent extraction/soil washing technique for soil
remediation. Further analysis, including consideration of
other remedial alternatives, is essential before a final
decision can be reached regarding the most appropriate means of
meeting soil cleanup goals.

F. The FS's Recommended Groundwater Pumping Scheme
la Not Supported by Sufficient Data ^
The proposed groundwater remedy is not backed by
sufficient data with respect to either the age of the
groundwater contamination or aquifer properties. These issues
must be addressed before an appropriate remedy can be developed,
At the present time, there is no firm basis for
determining when the groundwater contamination originated. The
- 32 -
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observed contamination may have originated when the drums were
first buried more than thirteen years ago; conversely, the
observed contamination could be the result of recent drum
deterioration in which case the groundwater plume would be
relatively young. This uncertainty/ in conjunction with the
lack of information on the vertical distribution of groundwater
contaminations and uncertainties in transportation rates, makes
it impossible to determine the optimum locations for extraction
wells.
The FS is similarly deficient with respect to data
related to aquifer properties. The estimate of the aquifer's
transmissivity was based on small scale, short duration, field
tests. Chrysler's technical consultants reviewed these test
results in conjunction with a mass balance calculation (areal
recharge versus ambient groundwater flow) and determined that
the minimum volume of groundwater which needs to be pumped may
be greater than that indicated in the FS. In addition, the FS
did not include direct measurements of organic carbon. This
omission is critical because the pumping duration required by
the FS was based on a simplistic analytical model used by EPA's
consultant which is very sensitive to the percentage of "organic
carbon present in the aquifer. Consequently, both the pumping
rate and the pumping duration are no more than educated guesses.
The FS also used an overly simplistic method to
estimate the number of required wells. It did not consider the
- 33 -
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potential inefficiency generally associated with pumping at
higher rates. (The capture zone of withdrawal wells increases
with increased pumping rates. Thus, at larger pumping rates
more uncontaminated groundwater is generally withdrawn than
with pumping at a lower rate; albeit for longer durations.)
Additionally/ computer analyses of the proposed scheme
indicates that the withdrawal/injection, presented in the FS,
may not create a hydraulically isolated zone.
These flaws in the FS clearly demonstrate that more
data is necessary before the proposed remedy can be properly
evaluated. The logical approach is to use information obtained
during the drum removal process, in conjunction with monitoring
and pump testing, to develop the required data base. Visual
observations made during drum removal should provide an insight
into the age of the .groundwater contamination. (Open or
crushed drums and heavy contaminated soils versus rusted drums
in generally clean soils.) These data, together with
additional information on aquifer properties, will allow for a
far more detailed evaluation of the required size of the
withdrawal system. Once such information is developed, studies
can be undertaken to evaluate the costs and benefits of using
various pumping rates and pumping durations.
- 34 -
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IV. CONCLUSION
The FS for Operable Unit Two for the Ewan Property
Site* is seriously deficient. The cleanup standards proposed
by the FS are improper and inapplicable to the Ewan Site, and
thus violate the statutory requirements of Section 121 of
CERCLA. in addition, EPA has failed to comply with the
relevant remedy selection requirements and, as a result, has
proposed inappropriate remedial alternatives. A ROD issued at
this time would be based on inadequate data, improper
standards, and non-compliance with CERCLA's statutory mandate.
Therefore, EPA should await additional information and further
analysis, as will be forthcoming in the predesign work for the
site, before issuing the ROD for the Ewan Site.
4102g/0887o
- 35 -
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Appendix C.2

United states Environmental Protection Agency
Responses
-------
United States Environmental Protection Agency
Response to the Comments for the
Operable Unit Two Feasibility study and
Operable Unit Two Proposed Plan
for the Evan Property as presented by
Chrysler Motors Corporation

1. Evan Property Site Location

Chrysler Motors Corporation (Chrysler) alleged that the remedial
objectives for the Operable Unit Two remediation at the Evan
Property were unsubstantiated. The United States Environmental
Protection Agency's (EPA) review of these comments indicates that
Chrysler has misunderstood the site location and the applicabil-
ity of the regulations supporting the Operable Unit Two remedial
goals. ';

The New Jersey Pinelands area is regulated by both the New Jersey
Pinelands Commission (NJPC) and the New Jersey Department of
Environmental Protection (NJDEP).

NJPC, in accordance with the New Jersey Pinelands Comprehensive
Management Plan, divides the New Jersey Pinelands into ten
specific areas: Preservation Area, Forest Areas, Agricultural
Production Areas, Special Agricultural Production Areas, Rural
Development Areas, Regional Growth Areas, Pinelands Towns,
Military and Federal Installation Areas, Pinelands Villages, and
areas within the Pinelands National Reserve but outside the State
designated Pinelands Area.

NJDEP identifies a portion of the New Jersey Pinelands as the
Central Pine Barrens Area. The Central Pine Barrens Area is
defined by drainage basins located within southern New Jersey
Pinelands. The defined region of the Central Pine Barrens is
described in the New Jersey Administrative Code, Title 7, Chapter
9, Subchapter 6, Section 7, Subsection (c) (N.J.A.C. 7:9-6.7(c)):

The Central Pint* Barrens Area (The Boundary of the
Central Pine Barrens is further clarified by the
Official Map wh:ich is available for review at the New
Jersey Department of Environmental Protection, Division
of Water Resources or appropriate county planning
board, board of health, or municipality.) boundaries
will underlie the following surface water drainages;

1. Mullica River Watershed: . . .
-------
2. Cedar Creek (Lacey Township and tri-
butaries upstream of Route 9, (head of
tide) surrounded by the northern ridge-
line; and the southern ridgeline west of
the Garden State Parkway and the south-
ern ridgeline (between the Garden State
Parkway and Route 9) as defined by Lacey
Road, Manchester Avenue, and Haines
Road.

3. All fresh waters west of the Garden
State Parkway bounded by the Mullica and
Cedar Creek (Lacey Township) watersheds.

4. Toms River Watershed: . . .

5. Rancocas Creek Watershed: . . .

6. The Central Pine Barrens boundary
underlies the surface Water drainages in
the following State and National Park,
Forests, and Fish and Wildlife lands:
• • #

Chrysler believes that the New Jersey Pinelands Preservation Area
and New Jersey Central Pine Barrens have the same boundaries.
This is incorrect. A review of the New Jersey Pinelands
Comprehensive Management Plan indicates which areas of the New
Jersey Pinelands are classified as the New Jersey Pinelands
Preservation Area. Application of the previously quoted N.J.A.C.
7:9-6.7(c) to a reliable map of New Jersey, or review of the pre-
viously mentioned NJDEP Official Map, indicates the area known as
the New Jersey Central Pine Barrens. Further comparison of these
two areas illustrates that there is some overlap but not a con-
tinuous overlay.

Chrysler was correct in stating that the Ewan Property is located
outside of the New Jersey Pinelands Preservation Area. In fact,
NJPC has determined that the Ewan Property is presently located
within an Agricultural Production Area and Rural Development
Area. However, as determined by NJDEP and N.J.A.C. 7:9-6.7(c),
the Ewan Property is located within the boundary of the Central
Pine Barrens.
-------
2. Consistency of Regulatory Application to Previous New Jersey
Finalands superfund Records of Decision

In the Operable Unit Two Proposed Plan (the first of EPA's two
decision documents for Operable Unit .Two) EPA identified three
promulgated, quantitative, numerical regulations as the goals for
the Operable Unit Two ground water remediation: the Federal Safe
Drinking Water Act (SWDA) Maximum Contaminant Levels (MCLs) con-
tained in 40 CFR Part 141 and 40 CFR Part 143; and the State of
New Jersey SWDA MCLs contained in N.J.A.C. 7:10-5, N.J.A.C.
7:10-7; and N.J.A.C. 9:7-6.6(a). EPA considers only these pro-
mulgated, quantitative, numerical portions of the Central Pine
Barrens criteria rsee the N.J.A.C. 7:9-6.6(a) GW-1 Criteria) as
applicable regulations. Although N.J.A.C. 7:9-6.6(a) contains
several non-numerical standards, EPA has selected the numerical
remedial goals for these substances from either the of MCL list-
ings found in the Federal and State SWDA. The NJDEP disagrees
with this selection. Attached is the NJDEP letter and the EPA
response.

Chrysler indicated that the Lang Property was determined to be
located in both the New Jersey Central Pine Barrens area and the
New Jersey Pinelands Preservation Area. Chrysler further claimed
that EPA did not use the "GW1 standards", but chose to use only
State and Federal standards in determining a remedy for the Lang
Property. The State standards referred to in the Lang Property
Record of Decision include the numerical portions of the Central
Pine Barrens criteria (see the N.J.A.C. 7:9-6.6(a) GW-1
Criteria). Furthermore, the Lang Property Record of Decision was
signed prior to the enactment of the Superfund Amendments and
Reauthorization Act (SARA). SARA requires the use of more strin-
gent applicable or relevant and appropriate State requirements.
Therefore, Chrysler's argument is irrelevant.
-------
The Evan Property Proposed Plan cites the same ARARs that were
identified in the Lang Property Record of Decision, which in-
cludes the promulgated, quantitative, numerical Central Pine
Barrens criteria (see the N.J.A.C. 7:9-6.6(a) GW-l Criteria).

3. Technical Feasibility of Proposed Alternative

Furthermore, Chrysler claimed NJDEP "conceded" the Ewan Property
ground water remediation may be unobtainable. NJDEP never
conceded that the ground water remediation was impossible. It
merely indicated that the Central Pine Barrens criteria (see the
N.J.A.C. 7:9-6.6(a) GW-l Criteria) contain standards which may be
difficult to reach.

4. Analytical Detection Limits

5. Less Risk to Human Health and the Environment

Chrysler alleged that excavation of the residual contaminated
soils would result in a discharge of volatile emissions.

However, Chrysler failed to recognize that EPA will implement
site monitoring and contingency plans should volatile emissions
begin to occur. These plans include engineering measures to in-
sure the protection of public health and the environment while
Operable Unit Two is in operation. Furthermore, similar soil
excavations conducted in Region 2 have not resulted in any sig-
nificant discharges of volatile organic contaminants.
-------
6. Soil Tr«atability study

Chrysler has maintained that the treatability studies conducted
for the soils were an attempt to differentiate heavily contam-
inated materials from residually contaminated soils.

EPA used the heavily contaminated soi,ls to evaluate the effect-
iveness of the technologies in the studies on materials which
could potentially be missed in the Operable Unit One Remedial
Action. The slightly contaminated soils were used to determine
the effectiveness of the processes on soils which are anticipated
to be present at the conclusion of the Operable Unit One Remedial
Action.

Furthermore, when EPA selects the process of On-Site Solvent
Extraction followed by Soil Washing, decision it is not limited
to the process used in the Treatability Study. Although tri-
ethylamine was used in a patented solvent extraction process, EPA
will not limit the Operable Unit Two Pre-Remedial Design studies
to repeating the Treatability Studies. The evidence provided by
the solvent extraction treatability study illustrated that the
technology could work at the Ewan Property and fulfill Superfund
statutory requirements.
-------
7. Remedial summary

At present, Operable Unit One is a full year behind schedule due
to protracted negotiations with Chrysler. Delaying a remedial
decision on Operable Unit Two would slow down the site remed-
iation further. These delays would permit the ground water con-
taminated plume to continue to migrate. EPA believes that there
is enough data available to make a decision at the present time.

Water Remedy Selection
EPA believes that the ground water remediation should to begin
immediately following the source waste treatment. Therefore, the
design of the ground water system should begin as soon as poss-
ible. Delay of the ground water remedial design would allow the
contaminated ground water plume to continue to migrate. EPA
believes the advantages of treating the plume at an early stage
are:

• Reduced likelihood of human ingest ion of contaminated ground
water;

• Earlier treatment of presently deteriorated portion of New
Jersey Pinelands natural resources;

• Construction and operation of a smaller treatment plant;

• Earlier completion of the site remediation; and

• Increased cost-effectiveness.

EPA believes that the remedial objectives for both soil and
ground water are feasible (see the attached NUS Corporation re-
sponse) and that remedial designs and actions can be developed to
meet these goals. EPA maintains that an applicable ground water
remedial goal for the Ewan Property is contained in N.J.A.C.
7:9-6. 6(a). Contrary to Chrysler's conclusion, N.J.A.C.
7: 9-6. 6 (a) contains numerical and quantitative standards for
thirty of thirty-six listed pollutants and chemical substances.
Other promulgated regulations which directly relate to remed-
iation of the Ewan Property ground water (and the EPA Ground
Water Protection Strategy) are the Federal SWDA MCLs and the
State of New Jersey SWDA MCLs (see the Operable Unit Two Proposed
Plan for the Ewan Property) .
-------
Soils Remedy Selection

Chrysler has stated that the volume and distribution patterns of
the volatile organic compounds and metals will affect remedial
technology selection. The waste disposal practices at the Ewan
Property involved random placement of wastes within trenches.
Therefore, since each drum may contain different waste, no dis-
cernable waste patterns can be identified.

Chrysler has also stated that the solvent extraction method is an
unproven technology. The EPA March 1988 Record of Decision
Update identifies the selection of solvent extraction for two
other Superfund sites: Palmetto Wood and Davis Liquid Waste.
Furthermore, a solvent extraction process is already being used
in the cleanup of the General Refining Superfund site (see the
attached NUS Corporation response).
-------
IMUS
CORPORATION

WAST* MANAOBMBNT 8BBVICBB OROUP

>ARK WEST TWO
IFF MINE ROAD
PirrsetJRGH. PA 1327S-1O71
|4i si 7sa-ioea
September 20, 1989
NUSP/89-0827
Mr. Craig DeBiase
Remedial Project Manager
U S Environmental Protection Agency
Region II
26 Federal Plaza
New York, New York 10278

Subject: REM III PROGRAM - EPA CONTRACT NO. 68-01-7250
' EWAN PROPERTY SITE, NEW JERSEY
RESPONSE TO CHRYSLER MOTOR COMMENTS OF
SEPTEMBER 11. 1989

Dear Mr. DeBiase:

Attached are the REM III responses to Chrysler Motor
comments Executive Summary Section B, Section II item B.2,
and Section III items A, B, C, E, and F. These comments
were contained in the letter dated September 11, 1989, from
David J. Hayes to James P. Rooney, Esq. and you.

If you need further assistance, do not hesitate to call.

Very truly yours, ,
Debra M Wroblewski
Site Manager
DMW:vlp

Attachment

cc: G Latulippe
D Knapp
File: W A No. 130-2LA5
Daily
-------
Chrysler Motors Corporation
Final Operable Unit Two Feasibility Study
Comments of September 11, 1989
Section I ** Executive Summary

B. Remedy Selection

Response Paragraph No. 1:

The materials to be considered as part of Operable Unit One
are the drums and their contents and the heavily
contaminated materials (not soils) associated with the
drums. The drums and their contents are obviously more
readily identifiable. The purpose 0f adding "the heavily
contaminated materials associated with the drums" was to
prevent material that has leaked from or is unintentionally
released from the drums from being left at the site until
Operable- Unit Two activities are initiated. This material
would be considered a primary source of contamination in
that it is a concentrated waste potentially in direct
contact with the water table. The residually contaminated
soil would be considered a secondary source of
contamination, in that contaminants leach more slowly from
it into the groundwater.

Response Paragraph No. 2:

The alternative includes the use of a solvent followed by
water. Triethylamine (TEA) was the solvent used for
discussion and costing purposes in the Feasibility Study
(FS). Also, during excavation there is a potential for air
emissions, as stated in the FS. Contingency plans, etc.
will need to be prepared during the Remedial Design (RD)
phase. TEA' functioned well during our treatability studies
and odors are only a problem if there is a leak in the
system. TEA will be discussed further in response to
comment Section III Item E.

Response Paragraph No. 3:

The pumping sceneries presented in the FS were developed to
access the general implementability and effectivness of a
groundwater collection system that utilizes extraction
wells. As indicated in the FS, many pumping, systems are
considered viable and may be used during the Remedial
Action (RA) . The system to be used will be developed
during the RD phase. other groundwater collection systems
(i.e., trenches) were eliminated from consideration.
-1-
-------
As with the response to Paragraph 2, the system is not
"required" to be implemented exactly as we have outlined in
the FjS. We selected pumping of the groundwater as the
technology to be used at the site. The simplistic method
of estimating the number of wells is for feasibility study
purposes, not for design purposes. We feel that our system
meets the FS guideline for developing costs that are plus
50% minus 30% (OSWER 9355.3-01).

Response Paragraph No. 4 and No. 5:

There is the potential at this site for a variety of
contaminants to be associated with each drum. The
alternative that is recommended by EPA is considered to
provide the best overall remediation of contaminants at the
site. The Remedial Investigation/Feasibility Study (RI/FS)
guidance documents states "For those situations in which
numerous waste management options are appropriate and
developed, the assembled alternatives may need to be
refined and screened to reduce the number of altrenatives
that will be analyzed in detail". (OSWER 9355.3-01).

Further details are provided in responses made to comments
within Section III.

Section II Item B.2 pages 13-15:

The soil cleanup goals are low because they are protective
of the groundwater. The goals for semi-volatile organics
were met after solvent extraction with triethylamine
(TEA). Despite significant volatile organic reductions
(99.998%) some of the goals were not attained. Minor
adjustments to the process (increased temperature, etc.)
should result in lower concentrations. It is anticipated,
based on the results of the ASTM leaching procedure
conducted on the TEA-treated samples, that inorganic
concentrations can be reduced to low levels (See FS, page
E-19). Solvent extraction followed by a rinsing step (as
shown in Figure 3-9, page 3-27) should reduce the
concentrations of both inorganics and organics to very low
levels. Refinement of the treatment process will be
necessary during the remedial design stage.

The groundwater treatment systems outlined in the
feasibility study are anticipated to attain very low
contaminant concentrations in the aquifer and are
representative of the best available technologies. The
methods that can be used to measure these low
concentrations include EPA method 524.1 and 524.2. EPA or
the State may have a preference for either of these
methods. We used method 524.2 through Revet Environmental
and Analytical Laboratory (through the Contract Laboratory

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Program) for the supplemental groundwater sampling
activities (see FS at page 1-41). The goals are,
therefore, measurable.

Section III The Remedy Selected bv the FS is not Supported
by Adequate Data.

A. The Existing Data Base does not Support EPA's Attempt
to Distinguish between "Heavily Contaminated" and Less
Contaminated" Soils.

Response Item A:

As stated in the response to Paragraph No. 1 of the
Executive Summary, the terminology is "heavily contaminated
materials" and "residually contaminated soils". The
commentors' use of the phrases "heavily contaminated soils"
and "less heavily contaminated soils" is not correct. The
treatability study evaluated the range of contaminated
"soils" (i.e., a discrete worst case and a composite
average). The composite sample was obtained from areas of
known soil contamination that were not considered to be
"heavily contaminated materials". These soil samples were
collected in an effort to examine a range of situations
that may be encountered during Operable Unit Two.

The TEA was effective for remediating the discrete worst
case soil sample, not heavily contaminated materials.
These worst case soils are included as part of Operable
Unit Two. The fact that the worst case soils were
effectively treated allows for a contingency factor if some
of the heavily contaminated materials are are
unintentionally left on the soils at the site after the
Operable Unit One activities.

B. The Existing Data Base does not support the FS' s
Evaluation of the Extent and Nature of Soil
Contamination.

Response Item B:

Our estimates are very conservative for both soil and
groundwater volumes. The FS does not require 22,000 cubic
yards of residually contaminated soil to be treated. The
22,000 cubic yards is an estimate, EPA could require only
soil that exceeds cleanup goals to be treated.

The potential areas of concern is not nine acres; study
Area A is nine acres in size. During the RI the affected
area was estimated, conservatively, to cover an area of
approximately four acres. The affected area is within
Area A. Based on geophysical surveys, soil gas screening,

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and both mobile laboratory and Contract Laboratory Program
(CLP) sample results, a focused area of approximately two
acres (within the affected area) is considered to require
remediation. See FS Section 2.1.2 and Appendix C. As
stated above, the estimate of 22,000 cubic yards is a
conservative estimate.

We agree that the site is characterized by localized areas
of contamination (see Figure 2-1 in the FS) . Seven
Igcalized areas that are anticipated to need remediation
are currently considered. It is anticipated that these
localized areas will be further subdivided, during the
design and implementation phases based on information
obtained from Operable Unit One activities.

C. The FS's Soil Remediation Screening Process Improperly
Excluded Cost-Effective Combinations of Technologies.

Response Item C:

I-n situ vacuum extraction is a technology tou remove
volatile (Henry's Law constant >3xlO atm-m /mole)
organic compounds (VOCs) from soil (EPA/540/2-88/004). See
the attached listing of Henry's Law constants for the
organic contaminants detected at the Evan Property Site
(Table 1). As can be seen, vapor extraction is potentially
not effective for many of the organic compounds found at
this site because their Henry's Law. Constants are
significantly less than 3x10 at m-m /mole. Because
the trenches will have been excavated as part of Operable
Unit One, preferential flow patterns and, therefore,
inconsistant removal rates are anticipated. Modeling such
conditions would also be very difficult.

The commentors ignore the fact that site specific
treatability study results are available for solvent
extraction and recommend the use of microencapsulation.
Microencapulation, specifically HAZCON's process, is a
solidification/stabilization technology that mixes
hazardous waste, cement, water and and additive called
Chloranan. The additive is claimed to encapsulate organic
molecules so that they do not retard or inhibit
solidification. HAZCON's process was demonstrated at a
site in Douglassville, Pennsylvania. One of the major
conclusions is that TCLP results for semi-volatiles (and
oil and grease) were essentially the same for treated and
untreated samples. Also, high volume increases accompany
the treatment process. (Handout at the Third International
Conference on New Frontiers for Hazardous Waste Management,
Site Demonstration and Evaluation Branch,
September 7, 1989.) The results of the SITE program's
demonstration prove that the process is not effective -for

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TABLE 1
PROPOSED CLEANUP GOALS FOR SOIL AND HENRY'S LAW CONSTANT
EWAN PROPERTY SITE, SHAMONG TOWNSHIP, NEW JERSEY
Chemical
toluene
Methylene Chloride
Phenol
Trichloroethylene
Tetrachloroethylene
Ethylbenzene
Xylenes (total)
Acenaphthene
Di-n-butyl Phthalate
Butyl Benzyl Phthalate
4,4-DDE
4,4-000
4, 4 -DDT
Heptachlor Epoxide
Pentachlorophenol
Diethyl Phthalate
Di-n-octyl Phthalate
Bis(2-Ethylhaxyl)
Phthalate
Anthracene
Benzo( a) anthracene
Benzo(k) f luoranthene
Chrysene
Fluoranthene
Maximum
Concentration
Detected
(ug/kg)
570,000
77,000
77,000
8,100
24,000
20,000
77,000
9,700
2,500
27,000
50
170
17
ND
ND
ND
1,400
28,000
1,800
ND
ND
ND
2,300
Soil Cleanup
GoalU)
(wg/kg)
5.0
5.0
330
s 5.0
5.0
5.0
5.0
330
330
330
440
77
16
8
2,650
330
102,344
102,344
330
330
330
330
330
Henry's Law
Constant
atm-m3/mole
6.66 x 10-3
2.03 x 10-3
4.54 x 10-7
9.1 x 10-3
1.53 x 10-2
6.6 x 10-3
4.33 x 10-3
9.1 x 10-5
2.8 x 10-7
8.3 x 10-6
6.8 x 10-5
2.2 x 10-8
1.5 x 10-5
3.S x I0"t
2.8 x 10-6
1.2 x 10-6
1.7 x 10-5
3.0 x 10-7
8.6 x 10-5
1.0 x 10-6
3.87 x 10-5
1.05 x 10-6
6.5 x 10-6
-------
TABLE 1
PROPOSED CLEANUP GOALS FOR SOIL AND HENRY'S LAW CONSTANT
EWAN PROPERTY SITE, SHAMONG TOWNSHIP, NEW JERSEY
PAGE TWO
Chemical
Fluorene
Phenanthrene
Pyrene
2-Butanone
2-Hexanone
2 -Methyl Naphthalene
4-Methyl-2-pentanone
Acetone
Dibenzofutan
2,4-Dimethyl Phenol
4-Methylphenol
Benzene
1,2-Dichlo roe thane
1 , 1 , 1-Tr ichloroe thane
Carbon Tetrachloride
1,1-Dichloroethene
Chloroform
Hapthalene
1 , 1-Dichloroethane
Tetrachloroethene
tran«-l , 2-Dichloroethene
Maximum
Concentration
Detected
(ug/kg)
2,100
77,000
MO
44,000
11
440,000
97,000
110,000
2,000
NO
ND
NO
ND
ND
ND
ND
ND
NO
ND
24,000
ND
Soil Cleanup
Goald)
(ug/kg)
330
330
380
10
10
330
10
10
330
330
330
5.0
5.0
5.0
5.0.
5.0
5.0
330
5.0
5.0
5.0
Henry's Law
Constant
atm-mVmole
6.4 x 10-5
2.26 x 10-4
5.1 x 10-6
2.08 x 10-5
7.52 x 10-6
6.02 x 10-4
4.16 x 10-5
3.4 x 10-5
HA
1.7 x 10-5
2.37 x 10-7
5.5 x 10-3
9.14 x 10-4
3.0 x 10-2
2.3 x 10-2
1.9 x 10-1
2.8 x 10-3
4.6 x 10-4
4.26 x 10-3
1.53 X 10-2
6.7 x 10-2
ND Not detected at concentrations higher than contract
required detection levels.
No goal currently established.
U) Basis for cleanup goals is described in Appendix B.
NA Not readily available.
-------
organics. Since protection of the groundwater at this site
is a major concern, the fact that semi-volatile organics
leach at essentially the same rate before and after
treatment is a major concern. In fact, in the abstract
from the paper that the commentors reference
(EPA/540/A5-89/001) on HAZCON's process if it states
11 ... the process does not immobilize volatile or
semivolatile organics in most instances..." and that
"...the microstructure indicates a potential for
degradation over the long term...". This process, as if
currently exists, should not be considered for use at this
site.

As with alternative 3S in the FS, there is a large volume
increase and the pH of the mass would remain high,
potentially causing detrimental effects to the sensitive
Pinelands ecosystem. As stated on page 2-1 of the FS, the
overall goal of the site remediation is to clean up the
site to its orginal condition prior to disposal, thus
enabling unrestricted use of the area. Placing a solid
mass back onto the site would not attain this goal. Our
treatability studies for stabilization evaluated lime,
flyash, and a lime/flyash mixture in an effort to stabilize
the inorganics without creating a solid mass. The
treatability studies produced negative results.

Several major comparisons are:

o The use of microencapsulation for organics is not
proven effective. Conversely, positive site-specific
treatability study results were obtained for solvent
extraction.

o With in-situ vacuum extraction followed by
microencapsulation, semi-volatile organic compounds
and inorganic compounds would remain at the site.
Conversely, with Alternative 4S volatile and
semi-volatile organics and metals are removed from the
site.

o A solid mass of substantially more volume would be
placed back on site after microencapsulation.
Conversely, with Alternative 4S the treated loose soil
would be placed back on site and there would be no
volume increase.

o With microencapsulation long-term monitoring would be
required. With Alternative 4S the contamination is
removed and there is no potential for further
contaminants to leach into the groundwater, therefore,
no long-term maintenance is expected.
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In conclusion, as part of our treatability studies the
combination of devolatilization followed by stabilization
was evaluated. The devolatilization step was conducted
under a vacuum (30 mmHg Absolute) at elevated temperatures
(130 C) . The elevated temperature was used in an attempt
to remove volatile and semi-volatile organics. Excellent
volatile organics removal was documented. Semi-volatile
organics concentrations were not effectively reduced, even
when subjected to elevated temperatures. Since a solid
mass was not desired, cement was not tested. Lime, flyash,
and a lime/flyash mixture were tested. This combination of
different cost-effective treatment technologies was' not
effective as tested.

E. There Are Serious Issues Related to the FS's Preferred
Soil Remediation Alternative . That Have Not Been
Addressed. •.

.Response Item E:

The results shown on page E-18 are after the solvent
extraction only. The rinsing stage did not occur. See
page E-19. The use of TEA increases the solubility of
inorganic compounds suggesting the potential benefits of
subsequent water washes. The ASTM Leachate results shown
on page E-18 support this point for rinsing following
extraction with TEA. Since hexane and water had no
significant removal of metals and since their solubility
was not increased making them easier to remove, we selected
the use of TEA followed by water rinsing as part of
Alternative 4S.

The most significant potential for volatile releases is
anticipated to occur during Operable Unit One. It is
assumed that during excavation of the drums volatile
emissions .will be controlled. Costs for controlling
volatile emissions were also included for Operable Unit Two
activities, however, details (foam, portable structures,
etc.) is left until the design stage.

The commentors again assume that the FS requires them to
use TEA; this is not true. However, responses to the four
specific comments about the use of TEA are provided.

o* Based on the treatability studies that we conducted,
TEA provided the best removal efficiencies for
volatile and semi-volatile compounds.

Removal Efficiencies
Parameters TEA Water Hexane

Semi-volatiles 99.8% 96% 98.7%
Volatiles 99.998% 99.993% 99.97%
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As can be seen the removal efficiency for TEA is
slightly better than water or hexane. However, the
commentors overlook one very significant point. The
process used for TEA increased the solubility of
inorganics enabling then to be rinsed from the soils.
This is not true for the processes that used water or
hexane. For these later two processes, inorganics
would remain in the soil requiring further treatment.

The commentors state that TEA solvent extraction is
somewhat experimental and that an EPA representative
stated that it is an emerging technology requiring
further development and refinement. A definition of
terms problem exists here. The EPA representative
means that the patented B.E.S.T process (that uses
TEA) is an innovative technology-developed, but not in
widespread use. The use of the term emerging
technology is unfortunate and not correct here.
Emerging means that the technology has not progressed
beyond tthe laboratory stage of development. This is
not the case with the B.E.S.T. process.

The B.E.S.T. process dates back to the mid 1970's
Resources Conservation Company (RCC) built the first
truck mounted pilot B.E.S.T. unit in 1975. This unit
was operated at numerous sites and the data generated
at these sites was used to refine the slurry handling,
continuous extraction, and solvent recovery/recycle
operations of the process. In 1984, RCC built the
second generation B.E.S.T. pilot unit to develop the
data necessary to design a full scale commercial
B.E.S.T. unit for treating RCRA listed petroleum
refining oily sludges. Data from this pilot unit was
used to design the commercial scale B.E.S.T. unit.

The full scale B.E.S.T. unit was used at the General
Refining Superfund site to treat 3700 yd of acidic
oily sludges. At this site, soils were slurried and
treated with this unit. Currently, RCC is operating a
third generation pilot unit to develop the data
necessary to configure a B.E.S.T. unit specifically
for treating contaminated soils.

The process that is used by RCC is designed so that no
TEA will be released into the air as air emissions.
The only time an odor should be detected is if there
is a leak in the system. It a worker, or nearby
resident, were to detect the odor of TEA this would
indicate that the system is not operating properly.

Low levels (<200 ppm) of residual TEA may be left in
the treated soil (EPA-600/2-82-001a). This amount of
TEA is biodegradable in 11 hours by Aerobacter, a

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common soil bacteria. After treatment the material
may be staged for a period before it is backfilled
into the excavated areas. The TEA remaining in the
treated soils is ionically bound and not volatile and
as such does not cause an odor problem.

F. The FS's Recommended Groundwater Pumping Scheme is not
Supported bv Sufficient Data.

Response Item F:

The commentor again wrongly assumes that the pumping
schemes developed in the FS are required to be constructed
as described. Many viable pumping schemes may be
considered in more detail during the design stage. The
pumping schemes developed in the FS are used to support, the
fact that extraction wells, and not some other type of
collection system (i.e., trenches), are implementable and
effective at the site.
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