United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R02-92/176
September 1992
PB93-963820
&EPA Superfund
Record of Decision
Ellis Property, NJ
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NOTICE
The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement, but adds no further applicable information to
the content of the document All supplemental material is, however, contained in the administrative record
for this site.
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50272-101
REPORT DOCUMENTATION i. REPORT NO. 2.
PAGE EPA/ROD/R02-92/176
4. True and Subtitle
SUPERFUND RECORD OF DECISION
Ellis Property, NJ
First Remedial Action - Final
7. Author(«)
9. Performing Organization Name and Address
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient's Accession No.
5. Report Date
09/30/92
&
& Performing Organization Rept No.
10. Pro|ect/Taak/WoitUnrlNo.
11. Contrsct(C) or Gr«nt(G) No.
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EPA/ROD/R02-92/176
Ellis Property, NJ
First Remedial Action - Final
stract (Continued)
various unknown liquids, some of which had corroded and were leaking into the onsite
soil. Soil sampling and analysis revealed contamination by hydrochloric acid, organic
compounds, metals, grease, and PCBs. In 1983 and 1989 removal actions were conducted by
EPA and the state that addressed the sources of contamination, the proper identification
of wastes in drums; and removal of the drums, waste, contaminated soil, sludge, and.
debris offsite for appropriate disposal. This ROD addresses a final remedy for the
remaining contaminated soil and ground water at the site. The primary contaminants of
concern affecting the soil and ground water are VOCs, including PCE and TCE; other
organics, including PCBs; and metals, including arsenic, chromium, and lead.
The selected remedial action for this site includes excavating -all contaminated soil, and
treating metal-contaminated soil onsite or offsite using stabilization if necessary,
prior to offsite disposal in a landfill; transporting organic- or PCB-contaminated soil
offsite for treatment by incineration; backfilling the excavated area with clean fill;
collecting ground water using interceptor trenches or extraction wells, and treating the
water onsite using precipitation and ultrafiltration to remove metals, followed by air
stripping to remove VOCs, with reinjection of the treated water onsite; treating air
emissions if necessary; using engineering controls to mitigate any affected wetlands; and
monitoring ground water. The estimated present worth cost for this remedial action is
$6,653,000, which includes an annual OSM cost of $188,200 for years 0-1; $365,000 for the
ground water remediation for years 1-3; and $283,000 for years 4-30.
PERFORMANCE STANDARDS OR GOALS:
hemical-specific soil and ground water clean-up goals are established based on the
levels specified in New Jersey's Proposed Cleanup Standards for Contaminated Sites
(February 1992). Surface soil clean-up standards include arsenic 20 mg/kg; lead
100 mg/kg; benzene 3 mg/kg; PCE 9 mg/kg; TCE 23 mg/kg(s); and PCBs 0.45 mg/kg. The
clean-up standards for sub-surface soil include arsenic 20 mg/kg; lead 1 mg/kg; PCE
1 mg/kg; TCE 1 mg/kg; and PCBs 100 mg/kg . Ground water clean-up standards include
arsenic 8 ug/1; chromium 100 ug/1; PCE 1 ug/1; TCE 1 ug/1; toluene 1,000 ug/1; and lead
100 ug/1.
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ROD FACT SHEET
Site name: Ellis Property
Site location: Sharp Road, Evesham Township, Burlington County,
New Jersey
HRS score: 34.62
ROD
Date signed: September 30, 1992
Selected remedy: Excavation and off-site treatment/disposal of
contaminated soil; extraction and treatment of contaminated ground
water.
SOIL
Capital cost: $560,000
0 & M cost: $188,200"
Present-worth cost: $739,000
GROUND WATER
$1,340,000
$365,000b/$283,000c
$5,914,000
* One year only
b Years 1-3
c Years 4-30
LEAD
New Jersey Department of Environmental Protection and Energy
Primary EPA Contact: Richard Ho, (212) 264-9543
Secondary EPA Contact: Charles Tenerella, (212) 264-9382
Main PRP(s): Irving Ellis, telephone unknown
WASTE
Waste type: Drum washings and leaks or spills.
Waste origin: Drum storage and washing operation.
Estimated waste quantity: Soil—760 cubic yards; ground water-
unknown .
Contaminated medium: Soil and ground water.
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DECLARATION STATEMENT
RECORD OF DECISION
ELLIS PROPERTY
SITE NAME AND LOCATION
Ellis Property
Evesham and Medford Townships, Burlington County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Ellis Property Site (the Site), which was chosen in
accordance with the requirements of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980,
as amended by the Superfund Amendments and Reauthorization Act of
1986, and to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan. This decision
document explains the factual and legal basis for selecting the
remedy for the Site.
The New Jersey Department of Environmental Protection and Energy
concurs with the selected remedy. The information supporting
this remedial action decision is contained in the administrative
record for the Site.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the
Site, if not addressed by implementing the response action
selected in this Record of Decision, may present an imminent and
substantial threat to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
This is the first and only planned operable unit for the Ellis
Property Site. The selected remedy addresses the remediation of
contaminated soil on the Site and ground water in the underlying
aquifer.
The major components of the selected remedy include the
following:
Excavation of contaminated soil and treatment/disposal
at an approved off-site facility?
• Extraction of contaminated ground water from the
shallow aquifer underlying the Site;
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-2-
Treatment of contaminated ground water in a facility to
be constructed on the Site;
• Disposal of the treated ground water by reinjection;
and
• Implementation of an environmental monitoring program
to ensure the effectiveness of the remedy.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. The selected remedy
utilizes permanent solutions and. alternative treatment (or
resource recovery) technologies to the maximum extent
practicable, and it satisfies the statutory preference for
remedies that employ treatment that reduce toxicity, mobility or
volume as their principal element.
Because the selected remedy will not result in hazardous
substances remaining on the Site above health-based levels, a
five-year review pursuant to Section 121(c) of the Comprehensive
Environmental Response, Compensation and Liability Act, as
amended, is not required. However, pursuant to Office of Solid
Waste and Emergency Response Directive 9355.7-02, a review will
be conducted at least every five years after initiation of the
selected remedial action because cleanup levels will require five
or more years to attain. The purpose of the reviews is to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
^'"'Co'nstantine Sidamon-Eristpff/ Dat
Regional Administrator j£^/
^—
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DECISION SUMMARY
RECORD OF DECISION
Ellis Property
Evesham and Medford Townships, Burlington County, New Jersey
United States Environmental Protection Agency
Region II
New York, New York
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TABLE OF CONTENTS
PAGE
SITE NAME, LOCATION AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
HIGHLIGHTS OF COMMUNITY PARTICIPATION 5
SCOPE AND ROLE OF RESPONSE ACTION 5
SUMMARY OF SITE CHARACTERISTICS 6
SUMMARY OF SITE RISKS 8
DESCRIPTION OF REMEDIAL ALTERNATIVES 14
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 19
SELECTED REMEDY 26
STATUTORY DETERMINATIONS 27
DOCUMENTATION OF SIGNIFICANT CHANGES 31
APPENDICES
APPENDIX I. FIGURES
APPENDIX II. TABLES
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SITE NAME, LOCATION AND DESCRIPTION
The Ellis Property Site (the Site) is located in Burlington
County, east of Sharp Road and about 2,000 feet north of
Evesboro-Medford Road in Evesham Township, New Jersey (Figure l).
The Site is surrounded by farmland and wooded lots, and is less
than one mile from the nearest residential area. The property
was once used as a dairy farm and is designated as Block 14, Lot
4 on the Evesham Township tax map. It comprises approximately 36
acres of land; 24 acres are located in Evesham Township and the
remainder in Medford Township. Currently, there are no buildings
on site. At the present time, the Site is overgrown with grasses
and weeds.
Land in the area immediately surrounding the Site is primarily
agricultural. Cultivated fields bound the Site to the north and
south. Another field is found to the west, across Sharp Road.
Approximately 60 residences were identified within one mile of
the Site. This may be a low estimate because there are new
housing developments in the area, especially near Coxs Corner.
To the east of the Site lies a wetland area, classified by the
U.S. Fish and Wildlife Service (USFWS) as a palustrine ecological
system with scrub/shrub and emergent plant classes. Although the
wetlands receive surface water runoff from the Site, inundation
and saturation of the wetland area is probably caused by
discharge from the shallow ground-water table. Consequently,
periodic drying of the wetlands occurs when the elevation of the
ground-water table is reduced. The nearest free-flowing surface
water is Sharps Run, approximately one-quarter mile north of the
Site. Drainage from the wetlands eventually leads to Sharps Run.
Sharps Run flows east through Medford Township to the south-
western branch of Rancocas Creek, approximately six miles east of
the Site. The northeastern corner of the Site, which includes
part of the wetlands, lies in the 100-year floodplain.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
In 1968, Irving and Reba Ellis purchased the property and used
part of it as a drum storage and reconditioning (drum cleaning)
operation. Approximately four acres of the 36-acre tract were
involved with this operation. The reconditioning operation
ceased in 1978, after a fire damaged some of the buildings.
However, storage of drums at the Site continued into the 1980s.
initial Activities
In September 1980, the New Jersey Department of Environmental
Protection and Energy (NJDEPE) investigated the Site following an
anonymous complaint. The Site was reported to have been used as
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a drum recycling operation, where used drums and containers were
brought, rinsed or cleaned, and then resold. The Site consisted
of a two-story building, housing several washing tanks with
troughs, three sheds, a storage area, and a boiler (Figure 2).
The building contained 50 to 75 drums, many of which were full of
unknown liquids. The three sheds also contained various-sized
drums and chemical containers, many of which contained unknown
substances. The area near the sheds was devoid of plant growth.
About one hundred 55-gallon plastic drums were located adjacent
to the sheds. One of these drums contained a dark green liquid
with a pH of 1. The ground surrounding these drums was stained
red and green. A soil sample taken from a depth of two feet had
a pH of 2 and a bright green color. A natural swale and several
man-made ditches led into a wetland, located approximately 700
feet east of Sharp Road. The troughs inside the larger building
drained into one of these ditches. Sediments and surface water
runoff entered the wetlands from the drainage ways (Figure 3).
Hundreds of drums and containers were spread haphazardly around
the Site. Some of these drums were later found to contain oils,
grease, acids, and various organic compounds. There was evidence
of spills from past operations at the Site. Several drums were
corroded, with the contents leaking onto the ground. A soil
sample taken near a leaking drum was found to contain oil and
grease. Subsequent inspections by the NJDEPE indicated that
chemical spills onto the ground had occurred in several areas.
Soil sampling and analysis by the NJDEPE revealed the presence of
hydrochloric acid, heavy metals, and grease. Polychlorinated
biphenyls (PCBs) were detected in concentrations up to 23.1 parts
per million (ppm).
In April 1981, NJDEPE issued a Directive Letter to Mr. Ellis,
instructing him to remove and dispose of the drums and
contaminated soil from the Site. NJDEPE made numerous attempts
to persuade Mr. Ellis to accept responsibility for the
contamination on his property. In September 1982, the Evesham
Municipal Utilities Authority filed a civil action in the
Superior Court of New Jersey, Law Division, Burlington County
(Docket No. L 24308-82) against Irving and Reba Ellis for the
illegal storage of drums containing hazardous substances. In
December 1982, NJDEPE filed a Civil Action Complaint in the
Superior Court of New Jersey, Chancery Division, Burlington
County (Docket No. C 1679-82) due to Mr. Ellis's failure to
comply with the Directive Letter and the continued use of the
Site for the storage of drums. In January 1983, the Burlington
County Health Department and the NJDEPE conducted a survey of
potable wells within an approximate 1-mile radius of the Site to
determine if they were impacted by site contamination. The
survey found that ten potable wells were completed in the
Wenonah-Mount Laurel Aquifer, and that the Site had not impacted
potable water supplies in the area. On August 30, 1983, an order
was entered transferring the matter of NJDEPE v. Irving Ellis to
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the Law Division and consolidating it with the matter of Evesham
Municipal Utilities Authority v. Irving Ellis and Reba P. Ellis.
On February 10, 1983, an Order for Partial Summary Judgment was
entered in the Superior Court against Irving Ellis in the
consolidated cases in the amount of $49,084.98. The court also
ordered Mr. Ellis to pay $53,000 in penalties. On June 6, 1984,
in a Judgment Consent, the court ordered Mr. Ellis to pay the
Evesham Municipal Authority $4,000 and forbade him to store,
discharge, or spill hazardous substances at the Site.
The Site was included on the National Priorities List on
September 1, 1983. On October 19, 1984, the U.S. Environmental
Protection Agency (EPA) issued a General Notice 'Letter to
Mr. Irving Ellis, informing him of his potential liability under
the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), with respect
to the contamination at the Site. In May 1989, EPA initiated a
search for other potentially responsible parties.
Removal Actions
In March 1983, utilizing the New Jersey Spill Compensation Fund,
NJDEPE removed approximately one hundred drums containing acids
and disposed of them at an approved off-site facility.
Containerized solids and flammable liquids were also removed and
disposed of, along with contaminated soil and sludge. In the
acid spill area, the highly acidic surface soils were removed,
and lime was tilled into the soil to neutralize the acid. Soils
in the vicinity of the PCB disposal area were removed to a depth
of approximately two feet and disposed at an approved off-site
facility. The large building and sheds were demolished at that
time because they were structurally unsafe. Private wells were
also sampled and showed no contamination.
On-February 22, 1989, NJDEPE requested that EPA conduct a drum
removal action at the Site. On February 28, 1989, EPA conducted
a preliminary assessment of the Site. An Emergency Response
Cleanup Services (ERGS) contractor began site preparation, waste
sampling, and stabilization on May 15, 1989. On October 23,
1989, the ERGS contractor was re-mobilized to segregate, stage,
mark, and label a total of 218 drums containing hazardous waste
material for off-site disposal. In addition, approximately 400
empty drums were crushed for off-site disposal. Removal of the
drums was completed on April 17, 1990.
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Remedial Investigation/Feasibility Study
In a letter, dated October 19, 1984, EPA offered Mr. Irving Ellis
the opportunity to undertake, or finance, a Remedial Investiga-
tion and Feasibility Study (RI/FS) at the Site. Mr. Ellis
declined the offer. Consequently, the RI/FS was initiated by the
NJDEPE through a Cooperative Agreement with EPA. In November
1985, Roy F. Weston, Inc. (WESTON®) was selected to perform a
remedial investigation to characterize the geology and hydrology
at the Site, and to identify the contaminants in the ground
water, surface water, soils, and sediments.
Eighteen monitoring wells were installed at the"Site. Eight
wells were located in the shallow aquifer, three in the
intermediate aquifer, and seven in the deep aquifer. Soil
samples were taken at depths from 0 to 72 inches below ground
surface. Surface water and sediments were collected from the
drainage ways and the wetlands.
The RI identified contaminants in the ground water, surface
water, soils, and sediments. The results of the RI are discussed
later, under "Nature and Extent of Contamination." After
characterizing the contamination at the Site, WESTON performed a
feasibility study to identify and screen remedial technologies to
address the potential risks to the public and the environment
posed by the Site. The FS was based on information obtained
during the RI and was completed in April 1992.
The National Historic Preservation Act requires federal agencies
to examine the potential impacts of their actions to these
places. As part of the RI/FS activities, WESTON conducted a
Stage IA Cultural Resources Survey to identify whether any
cultural resources on, or eligible for inclusion on, the National
Register of Historic Places are located on, or near, the Site.
The survey concluded that relatively undisturbed areas within 300
feet of the wetlands have a high potential for the presence of
prehistoric archaeologic resources; areas between 300 and 1,000
feet from the wetlands have a moderate potential for prehistoric
archaeologic resources.
A field investigation was conducted on March 28, 1992 to
delineate jurisdictional wetlands on site. This investigation
was documented in the Wetland Delineation Report: Ellis Property
Superfund Site, prepared by the NJDEPE. The field investigation
defined the boundary of the wetlands adjacent to or on the Site
itself.
A search of the National Heritage database was conducted by
WESTON to identify endangered/threatened species or critical
habitat that may be impacted. The search revealed that
observations of eight rare vertebrate species within an
approximate 3-mile radius of the Site were recorded. Of the
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eight species observed, three have been classified as endangered
by the State of New Jersey; five are classified as threatened by
the State of New Jersey. These species are listed in Table 1A.
Table IB lists other endangered/threatened species occurring in
Burlington County. Although no sightings of these species have
been recorded in the immediate vicinity of the Site, they may
potentially use the Site as habitat.
The USFWS was contacted by EPA regarding the potential existence
of federally-listed and proposed endangered and threatened
species in the vicinity of the Site. The USFWS indicated that
occurrence of the threatened Helonius bullata (swamp pink) is
documented for the Rancocas Creek and several of its tributaries.
However, the presence of the swamp pink has not been recorded for
Sharps Run or the wetland.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI report, FS report, and the Proposed Plan for the Site were
released to the public for comment on May 1, 1992. These
documents were made available to the public in the administrative
record file at the Evesham Township Municipal Building and the
information repositories at the NJDEPE and EPA Docket Room in
Region II, New York. The notice of availability for the above-
referenced documents was published in the Burlington County Times
on May 1, 1992. The public comment period on these documents was
scheduled from May 1, 1992 to May 30, 1992, and subsequently
extended to June 15, 1992 upon request from the public.
On May 13, 1992, NJDEPE conducted a public meeting at the Evesham
Township Municipal Building to inform local officials and
interested citizens about the Superfund process, to discuss
proposed remedial activities at the Site, and to respond to
questions from area residents and other interested parties.
Responses to the comments received at the public meeting, as well
as written comments received during the public comment period,
are included in the Responsiveness Summary.
SCOPE AND ROLE OF RESPONSE ACTION
This response action addresses remediation of the contaminated
media at the Ellis Property Site. It includes remedial
alternatives to address contaminated soil and ground water, and
focuses on the protection of human health and the environment.
No other operable units are planned for the future.
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SUMMARY OF SITE CHARACTERISTICS
Site Geology and Hydrology
The Ellis Property is situated in the central portion of the
Atlantic Coastal Plain, which extends from the fall line located
west of the Delaware River to the Atlantic Ocean. The Coastal
Plain regionally slopes gently to the southeast. The topography
is generally flat in the area. The Site consists of silty sand
with clay lenses, and is underlain by the Hornerstown Sand
(shallow aquifer), which is comprised of silty sand and clay
lenses. Underlying the shallow aquifer is the Navesink Sand,
which is interbedded with glauconitic clay and sand. These two
formations, which function as a confining layer, are just above
the Wenonah-Mount Laurel Sand, a major source of potable water
for domestic wells in the vicinity of the Ellis Property Site.
The Magothy-Raritan aquifers, which underlie the Wenonah-Mount
Laurel Sand, are confined by clay formations which separate them
from less productive aquifers. The Magothy-Raritan aquifers are
a significant source of municipal water supply in the vicinity of
the Site.
Based on available information, the water quality in the deeper
aquifers do not appear to be impacted at present by the
contaminants in the shallow aquifer. A Burlington County Health
Department survey found no private wells near the Site located in
the shallow aquifer, although there are no restrictions on well
locations to prevent its use as a domestic water supply. The
shallow aquifer is not currently used as a source of public water
supply because of its low productivity; however, it is a
potential source of recharge for the underlying aquifers at the
Site. Ground water beneath the Site is located in the New Jersey
Coastal Plain Sole Source Aquifer, and is therefore, classified
as "Class II potable water" (i.e., drinking water).
Shallow ground-water flow at the Site is to the east or east-
northeast. Hydraulic conductivity values calculated for the
shallow aquifer ranged from 0.41 to 1.63 feet per day.
Sharps Run is a tributary of the south branch of the Rancocas
Creek. The NJDEPE has classified the south branch of the
Rancocas Creek, from Vincentown to the Delaware River, and its
tributaries as FW2-NT, non-trout producing general surface
waters.
Nature and Extent of Contamination
The scope of the RI at the Ellis Property Site included
investigations in all media that may be contaminated. The
predominant contaminants in the soil, ground water, surface
water, and sediments, and their respective range of
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concentrations are summarized in Table 2. Surface water,
sediments, and air quality were investigated and determined not
to be contaminant pathways of concern. Contaminated soil and
ground water represent the primary contaminant exposure pathways
at this Site.
The predominant soil contaminants and the respective range of
concentrations, in parts per million (ppm), detected at the Site
include: arsenic (1.4-31.8 ppm), lead (2.2-3,790 ppm), PCBs
(0.31-23.1), and bis (2-ethylhexyl) phthalate, a base
neutral/acid extractable (BNA) compound, (0.045-2.3 ppm).
Approximately 690 cubic yards (yd3) of soil are contaminated with
metals, 60 yd3 with PCBs, and 10 yd3 with BNA compounds. The
contamination appears to be the result of chemical spillage or
leakage onto the ground. Migration of soil contaminants is
likely due to surface soil erosion and surface water runoff,
predominantly towards the east.
Ground-water contamination appears to be limited to the shallow
aquifer. The predominant contaminants and the respective range
of concentrations, in parts per billion (ppb), detected at the
Site are: antimony (19-2,123 ppb), arsenic (15.8-91 ppb),
beryllium (1.55-10.2 ppb), 1,2-dichloroethene (1,2-DCE) (5-520
ppb), methylene chloride (6-52 ppb), nickel (10.9-147 ppb),
tetrachloroethene (PCE) (760-33,000 ppb), trichloroethene (TCE)
(11-24,000 ppb), 1,1,2-trichloroethane (3-14 ppb), total chromium
(12-404 ppb), and lead (4.3-71 ppb).
The concentrations of antimony, arsenic, beryllium, chromium,
1,2-DCE, methylene chloride, nickel, 1,1,2-trichloroethane, TCE,
and PCE exceed the drinking water Maximum Contaminant Levels
(MCLs). Lead exceeds the National Primary Drinking Water action
level. A comparison of the range of concentrations detected and
MCLs is shown in Table 3. Ground-water contamination also
appears to be the result of chemical spillage or discharge from
drum washing operations or leakage from stored drums. There were
no underground storage tanks at the Site.
TCE and PCE are nonpolar, halogenated compounds with low
solubilities in water. These compounds are more dense than
water. When introduced as a free product, they tend to sink and
form dense nonaqueous phase liquids (DNAPLs), with an
indeterminate portion going into solution. As shown in
Table 3-25 of the RI report, the highest concentration of TCE
(i.e., 24,000 ppb) was found in monitoring well MW-2. This
concentration is above the New Jersey drinking water MCL of
1 ppb. Lower TCE concentrations were observed in wells MW-5,
MW-6, and MW-7, located east and southeast of MW-2. All of these
wells were installed in the shallow aquifer. The clay/silt
layer, approximately 17 to 25 feet below ground surface, is
believed to act as a barrier to vertical TCE migration, since no
contamination has been found in the intermediate and deep
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8
monitoring wells. Boring logs indicate that this clay/silt layer
appears to slope in a southeasterly direction across the Site.
Therefore, TCE would be expected to migrate from well MW-2 toward
wells MW-6 and MW-7, if the clay layer is continuous. The
evidence seems to suggest the existence of a TCE source in the
vicinity of the lime-tilled area. The presence of PCE at 15,000
ppb and 33,000 ppb at MW-7 and its absence at other monitoring
wells indicates the potential existence of another suspected
source of DNAPLs. However, soil and ground-water sampling during
the RI did not reveal the existence of DNAPL sources. Additional
studies would be performed, and monitoring wells would be
installed, during the design phase, so that the contamination
plume and the possible existence of a DNAPL source can be
examined more fully.
SUMMARY OF SITE RISKS
WESTON conducted a baseline risk assessment to evaluate the
potential risks to human health and the environment associated
with the Site. The Baseline Risk Assessment focused on
contaminants in the ground water, surface water, soil, and
sediments that are likely to pose significant risks to human
health and the environment. The Baseline Risk Assessment report
consists of a Human Risk Assessment and an Ecological Risk
Assessment.
Human Risk Assessment
The Human Risk Assessment portion of the Baseline Risk Assessment
report identified several exposure pathways by which the public
may be exposed to contaminant releases at the Site under current
and future land-use conditions. Surface water, soil, and
sediment exposures were assessed under a potential present land-
use scenario. Ground-water exposure was not evaluated because
there are no residents on site, and based on available
information, the shallow ground water is not used as a source of
drinking water by residents within a 1-mile radius. Ground
water, surface water, soil, and sediment exposures were assessed
under a future land-use scenario. Reasonable maximum exposure
scenarios were used in assessing both the present and potential
future risks.
Currently, the Site is not securely fenced and is accessible by
foot. Under current land-use conditions, trespassers represent
the probable population exposed to site contamination. The most
likely trespasser is an adult hunter/recreational user.
Therefore, an adult trespasser was evaluated under the current
scenario. The trespasser was assumed to live off site and, on
the average, trespass on the Site one day/week, 52 weeks/year.
This was an estimate, considering hunting season durations, as
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well as other potential recreational activities at the Site by a
trespasser, which may be higher during wanner months and lower
during the colder months. The adult trespasser was considered to
be on site for three hours per exposure event and exposed to on-
site surface soils, surface water, and sediments. The exposure
duration was considered to be 30 years.
Unrestricted future land-use of the Site was assumed. Therefore,
a future residential land-use scenario was evaluated. Two age
groups were evaluated for the future resident—a child aged 1-6
years and an adult. The future resident was assumed to be on
site on a daily basis, year-round. Exposure to surface soils was
assumed to occur during outdoor activities such"as gardening,
yard work, and recreational activities, and indirectly through
ingestion of home-grown vegetables. A year-round exposure to
soils of 350 days/year was assumed. In addition, contact with
surface water and sediments in the wetlands was assumed to occur
during recreational activities, such as wading. Due to the
shallow depth of these surface waters, recreational activities
were assumed to be limited.
The exposure pathways of concern for current land-use include:
(1) incidental ingestion of, and dermal contact with, chemicals
in the soil and sediments, (2) inhalation of wind-blown dust, and
(3) dermal contact with surface water. The potential exposure
pathways of concern for future land-use include those for current
land-use as well as the following: (1) ingestion of chemicals in
ground water, (2) dermal contact with chemicals in ground water,
(3) inhalation of volatile organic chemicals in ground water
during showering or bathing, and (4) consumption of home-grown
fruits and vegetables. For both the current and future land-use
scenarios, a reasonable maximum exposure was evaluated.
Under current EPA guidelines, the likelihood of carcinogenic
(cancer-causing) and noncarcinogenic effects due to exposure to
site chemicals are considered separately. It was assumed that
the toxic effects of the site-related chemicals would be
additive. Thus, carcinogenic and noncarcinogenic risks
associated with exposures to individual compounds of concern were
summed to indicate the potential risks associated with mixtures
of potential carcinogens and noncarcinogens, respectively.
Noncarcinogenic risks were assessed using a hazard index (HI),
based on a comparison of expected contaminant intakes and safe
levels of intake (Reference Doses). Reference doses (RfDs) have
been developed by EPA for indicating the potential for adverse
health effects. RfDs, which are expressed in units of milligrams
per kilogram per day (mg/kg-day), are estimates of daily exposure
levels for humans which are thought to be safe over a lifetime
(including sensitive individuals). Estimated intakes of
chemicals from environmental media (e.g., the amount of a
chemical ingested from contaminated drinking water) are compared
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to the RfD to derive the hazard quotient for the contaminant in
the particular medium. The HI is obtained by adding the hazard
quotients for all compounds across all media that impact a
particular receptor population.
An HI greater than 1.0 indicates that the potential exists for
noncarcinogenic adverse health effects to occur as a result of
site-related exposures. The HI provides a useful reference point
for gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
Potential carcinogenic risks were evaluated using the cancer
slope factors developed by EPA for the contaminants of concern.
Cancer slope factors (SFs) have been developed by EPA's
Carcinogenic Risk Assessment Verification Endeavor for estimating
excess lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals. SFs, 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 generate an upper-bound
estimate of the excess lifetime cancer risk associated with
exposure to the compound at that intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated
from the SF. Use of this approach makes the underestimation of
the risk highly unlikely.
For known or suspected carcinogens, risk is represented in terms
of an individual's likelihood of developing cancer as a result of
exposure to a carcinogenic chemical present in the exposure
media. For example, a cancer risk level of 1 x 10"3 indicates
that an individual has a one in a thousand chance of developing
cancer during their lifetime. Or, such a risk may be interpreted
as representing one additional case of cancer in an exposed
population of one thousand people. EPA considers excess upper-
bound individual lifetime cancer risks of 1 x 10"4 to 1 x 10"6 to
be acceptable. This level represents that an individual has not
greater than a one in ten thousand to a one in a million
increased chance of developing cancer as a result of a site-
related exposure to a carcinogen over a 70-year lifetime under
specific exposure conditions at the Site. Generally, if the
lifetime excess cancer risk exceeds 1 x 10"4, the contamination is
of sufficient concern to consider a remedial action. If the
excess cancer risk falls between 1 x 10"1 and 1 x 10"6, the need
for a remedial action is evaluated on a site-specific basis.
Finally, where the calculated lifetime excess cancer risk is
below 1 x 10"6, no remedial action is generally required. .
The results of the Baseline Risk Assessment indicate that under
the current land-use scenario, noncarcinogenic health effects to
an adult trespasser are not likely, based on the potential
exposure pathways and routes evaluated. The HI for this scenario
was less than 1.0. Similarly, the estimated carcinogenic risk
was found be within EPA's acceptable cancer risk range.
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Therefore, carcinogenic and noncarcinogenic health effects from
exposure to soils, surface water, and sediments at the Site are
not likely, under current land-use conditions.
Under the future residential land-use scenario, carcinogenic and
noncarcinogenic health effects are likely, based on the potential
exposure pathways and routes evaluated for a future resident.
The carcinogenic risk was calculated to be 1.26 x 10"2 (1.26 in a
hundred), and was attributable to arsenic, a known human
carcinogen, and PCE-and TCE, which are probable human
carcinogens. The exposure pathways with the greatest
carcinogenic potential risk for the future resident are ingestion
of home-grown produce, ingestion of chemicals in" the ground
water, and non-ingestion uses of ground water (i.e., bathing).
The His for the future child and adult resident were calculated
to be 362 and 127, respectively. The exposure pathways with the
greatest potential noncarcinogenic risk for the future child
resident (the most sensitive receptor) are ingestion of home-
grown produce, incidental ingestion of soil, dermal contact with
soil, inhalation of windblown dust, ingestion of chemicals in the
ground water, and non-ingestion uses of ground water (i.e.,
bathing). Risk was attributable to several compounds, including
PCBs, chromium, and bis (2-ethylhexyl) phthalate.
There are no restrictions which prohibit the use of the shallow
aquifer as a source of potable water supply. Consequently, in
the worst case scenario, the risk assessment assumed that future
residents might use the shallow aquifer as an untreated source of
potable water.
Health risks associated with exposure to surface water and
sediments at the Site were evaluated for both the current and
future land-use scenarios. The pathways analyzed include
incidental ingestion of sediment in the wetlands and drainage
ways, and dermal contact with sediments and surface water in the
wetlands and drainage ways. In both the current and future land-
use scenarios, the carcinogenic health risk associated with these
pathways was found to range from 1 x 10'7 to 1 x 10'10, which does
not exceed the acceptable risk range of 1 x 10"4 to 1 x 10"6.
Similarly, noncarcinogenic His for both scenarios were found to
be substantially less than 1.0. Therefore, these pathways do not
pose significant health concerns.
Ecological Risk Assessment
The Ecological Risk Assessment (ERA) evaluated potential impacts
to the environment associated with the contaminants at the Site.
The assessment focused on the potential impacts of contaminants
of concern found in the soil, surface water, and sediments, to
terrestrial and aquatic flora and fauna that inhabit, or are
potential inhabitants, of the Site. The contaminants of concern
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included pesticides, PCBs, lead, cadmium, chromium, and organic
compounds. The ecological receptors that were considered are:
white-tailed deer, woodcock, red-tailed hawk, aquatic organisms,
and terrestrial plants.
The ERA indicated that contaminated soil posed a risk to white-
tailed deer and woodcock. The greatest risk to the white-tailed
deer was attributed to browse ingestion. The ingestion of soil
and earthworms posed the greatest risk to the woodcock.
The ERA indicated that the contaminated surface water and
sediments in the drainage ways do not pose an unacceptable risk
to aquatic life. The contaminated surface water and sediments in
the wetlands posed a marginal, but not unacceptable, risk to
aquatic life. The ERA showed that the contaminants at the Site
posed no unacceptable risks to the red-tailed hawk and
terrestrial plants.
Sediment contamination in the wetlands appears to be the result
of surface soil erosion from the Site. The remediation of soil
contamination at the Site would reduce further migration of soil
contaminants into the wetlands by eliminating the soil erosion
pathway. Remediating the soil contaminants would also reduce the
potential for soil contaminants to infiltrate the ground water
and discharge into the wetlands, through the high water table.
Uncertainties In Risk Assessment
The risk assessment process involves numerous conservative
assumptions, all of which contributed to uncertainty in the risk
evaluation. In general, sources of uncertainties associated with
the risk assessment include: environmental sampling and analysis,
exposure assessment, and toxicity assessment.
Uncertainties in environmental sampling arise in part from the
potentially uneven distribution of chemicals in the media
sampled.
Uncertainties in the exposure assessment are related to estimates
of how often an individual would actually come in contact with
the chemicals of concern, the period of time over which such
exposure would occur, and in the models used to estimate the
concentrations of the chemicals of concern at the point of
exposure.
Uncertainties in toxicological data occur in extrapolating both
from animals to humans and from high to low doses of exposure, as
well as from the difficulties in assessing the toxicity of a
mixture of chemicals. These uncertainties are addressed by
making conservative assumptions concerning risk and exposure
parameters throughout the assessment. As a result, the risk
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assessment provides upper-bound estimates of the risks to
populations near the Site, and is highly unlikely to under-
estimate actual risks related to the Site.
Conclusion
Based on the results of the Baseline Risk Assessment, NJDEPE and
EPA determined that the contaminated soil and ground water at the
Site pose an unacceptable risk to human health. In addition,
contaminated soil poses an unacceptable risk to the environment.
The contaminants in the surface water and sediments in the
drainage ways do not pose an unacceptable risk to human health or
the environment. The ERA indicated that the surface water and
sediments in the wetlands pose a marginal, but not unacceptable,
risk to aquatic life. NJDEPE and EPA determined that the
contaminants in the surface water and sediments in the wetlands
do not pose an unacceptable risk to the environment for the
following reasons. The potential for aquatic exposure to
contaminants in the surface water and sediments is low,
considering that there is seldom any standing surface water in
the wetlands. The surface water samples that were collected are
not believed to be representative of actual surface water. There
was little or no surface water in the wetlands during the RI
sampling events. Surface water was created by depressing a
beaker, or digging a hole, into the surface of the wetlands and
allowing water to fill the depression or hole. Samples were
taken with a bailer, which stirred up the sediments. Because
lead adheres to sediment particles, the presence of sediments in
the water samples resulted in artificially high concentrations of
lead. The calculated risks associated with the contaminated
sediments in the wetlands are not believed to be representative
of actual risks. The risks associated with the sediments were
formulated using overly conservative assumptions based on
toxicity values that are more applicable to saltwater systems.
However, these toxicity values are routinely used as a screening
mechanism and are not used to establish cleanup levels.
Exceedance of these toxicity values does not necessarily indicate
that an ecological risk exists at the Site.
A remedial action to address the wetlands is not necessary since
NJDEPE and EPA that the contaminants in the surface water and
sediments of the wetlands do not pose an unacceptable risk to
human health or the environment.
Actual or threatened releases of hazardous substances from this
Site, if not addressed by the selected alternative or one of the
other remedial measures considered, may present an imminent and
substantial endangerment to the public health, welfare, and the
environment through the continued migration of contaminants from
the Site.
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Remedial Action Objectives
Remedial action objectives are specific goals to protect human
health and the environment. These objectives are based on
available information and standards, such as applicable or
relevant and appropriate requirements (ARARs) and risk-based
levels established in the Baseline Risk Assessment.
Because the Baseline Risk Assessment established that the soil
and ground water at the Site poses an unacceptable risk to human
health and the environment, the following remedial action
objectives were established:
Soil
o Prevent contact with contaminated soil, which represents an
unacceptable risk, or reduce contaminant concentrations in
the soil below risk-based levels.
o Prevent further migration of soil contaminants into the
ground water.
o Prevent migration of contaminated soils off site.
Ground Water
o Prevent the migration of contaminated ground water off site.
o Prevent the migration of contaminated ground water into the
underlying aquifers.
o Return the aquifer to its designated use as a source of
drinking water by reducing contaminant concentrations in the
shallow ground water to drinking water quality.
DESCRIPTION OF REMEDIAL ALTERNATIVES
CERCLA requires that each selected site remedy be protective of
human health and the environment, comply with other statutory
laws, be cost-effective, and utilize permanent solutions,
alternative treatment technologies and resource recovery
alternatives to the maximum extent practicable. In addition, the
statute includes a preference for the use of treatment as a
principal element for the reduction of toxicity, mobility, or
volume of the hazardous substances.
This Record of Decision evaluates remedial alternatives for
addressing soil and ground-water contamination at the Ellis
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Property Site. Since NJDEPE and EPA determined that the surface
water and sediment contamination in the wetlands and drainage
ways do not pose an unacceptable risk to human health or the
environment, remedial alternatives for the surface water and
sediments are not warranted.
The estimated capital cost, operation and maintenance (O&M)
costs, and net present worth costs of each alternative discussed
below are provided for comparison. The estimated implementation
time reflects only the time required to construct or implement
the remedy, and does not include the time required to design the
remedy, negotiate with the responsible parties, or procure
contracts for design and construction.
Soil Alternatives
The FS considered the following general response actions for the
contaminated soil at the Ellis Property Site: no action,
institutional controls, excavation with treatment and disposal,
and capping. Those alternatives which passed the screening
process are summarized below.
Alternative SS-3, which consists of excavation of surface soils,
on-site treatment, and on-site disposal, was analyzed in the FS.
It did not pass the screening process because the relatively
small volume of contaminated soil did not justify the
construction of an on-site treatment system; therefore, this
alternative is not included below.
Alternative SS-1; NO ACTION
Estimated Capital Cost: 0
Estimated Annual O&M Cost: $42,000
Estimated Net Present Worth Cost: $117,000 .
Estimated Implementation Time Frame: None
CERCLA requires that a "No Action" alternative be evaluated at
every site to establish a baseline for comparison to the other
alternatives. Under this alternative, EPA and NJDEPE would take
no further action at the Site. Current site contaminants would
be left in place, and no changes in levels of these contaminants
would be expected except for those resulting from natural
attenuation, biodegradation, or weathering. Access to the Site
would be unrestricted, allowing trespassers and wildlife to be
exposed to the contaminants.
Because this alternative would result in contaminants remaining
on site, CERCLA requires that the Site be reviewed at least every
five years. If justified by the review, remedial actions would
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be evaluated at that time to address the contamination. The cost
estimates above include the cost to perform this review.
Alternative SS-2: INSTITUTIONAL CONTROLS
Estimated Capital Cost: $40,000
Estimated Annual O&M Cost: $25,000
Estimated Net Present Worth Cost: $110,000
Estimated Implementation Time: 6 months
Under this alternative, measures would be taken to reduce the
potential risks to public health and the environment. This would
include the construction of a fence around the perimeter of the
Site and placement of warning signs to restrict access. Deeds
would be modified to restrict site development. These measures
are aimed at reducing potential contact with the contaminated
soil. Current levels of contaminants would remain at the Site.
As in the No Action alternative above, the Site would be reviewed
at least every five years. The cost estimates above include the
cost to perform this review.
Alternative SS-4; EXCAVATION AND OFF-SITE TREATMENT/DISPOSAL
Estimated Capital Cost: $560,000
Estimated Annual O&M Cost: $188,200 (1 year only)
Estimated Net Present Worth Cost: $739,000
Estimated Implementation Time: 1 year
Alternative SS-4 would include excavation of contaminated soil,
and treatment/disposal at an approved off-site facility, i.e,
landfill and/or hazardous waste incinerator. It is anticipated
that soil contaminated with PCBs and/or organic compounds would
be treated at an incinerator, while soil contaminated with heavy
metals would be disposed at a landfill. An incinerator would not
be effective in destroying heavy metals. The concentrations of
PCBs and SNA compounds currently present in the soil would permit
disposal in a landfill. However some stabilization for the
metal-contaminated soils may be required on site or off site,
prior to disposal. The need for stabilization would be
determined during the design phase. The excavated area would be
back-filled with clean fill. Under this alternative, soil
contaminants would be remediated to EPA's risk-based levels. The
soil is primarily contaminated with heavy metals (approximately
690' yd3) . The amount of soil contaminated with PCBs and BNA
compounds was estimated to be 60 yd3 and 10 yd3, respectively.
The O&M and net present worth costs include the cost of treatment
or stabilization of the soils prior to disposal.
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Alternative SS-5; CAPPING OF SURFACE SOILS
Estimated Capital Cost: $630,000
Estimated Annual O&M Cost: $100,800
Estimated Net Present Worth Cost: $2,180,000
Estimated Implementation Time: 2 years
Under Alternative SS-5, contaminated surface soils above risk-
based cleanup levels would be covered with an impermeable multi-
layer cap. This would prevent exposure to the contaminants, and
prevent migration of contaminants off site and into the ground
water through infiltration. The cap would be designed to meet
Federal and State of New Jersey requirements for hazardous waste
disposal facilities. The design of a multi-layered cap, to
satisfy these requirements, would consist of an upper vegetative
layer underlain by a drainage layer over a low permeability
layer. The low. permeability layer would be designed to minimize
infiltration of water into the contaminated soil below. The
drainage layer would consist of sand, which would decrease the
amount and residence time of water contacting the low
permeability layer, thereby minimizing water infiltration. The
drainage layer would be sloped to an exit toe drain, which would
allow the water to be expelled. The upper vegetative cover would
consist of about two feet of topsoil. The topsoil would be
capable of providing long-term vegetative support and would be
graded to a uniform slope between 3 and 5 percent. The
vegetation would be chosen to minimize erosion and promote
drainage off the cap.
As in the No Action alternative above, the Site would be reviewed
at least every five years because contaminants would remain on
site. The cost estimates above include the cost to perform this
review.
Ground-Water Alternatives
The following general response actions were considered in the FS
for contaminated ground water: no action, institutional controls,
and extraction and treatment. Below are summaries of the ground-
water alternatives.
Alternative GW-1; NO ACTION
Estimated Capital Cost: $30,000
Estimated Annual O&M Cost: $61,000
Estimated Net Present Worth Cost: $200,000
Estimated Implementation Time: None
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CERCLA requires that a "No Action" alternative be evaluated at
every site to establish a baseline for comparison to the other
alternatives. Under this alternative, EPA and NJDEPE would take
no further action at the Site. Current ground-water contaminants
would remain, and no changes in levels of these contaminants
would be expected except those resulting from natural
attenuation, migration, or biodegradation. Access to the shallow
ground water at the Site would be unrestricted, allowing
potential exposure to the contaminants. This alternative would
not prevent the potential migration of contaminants off site or
into the deeper aquifers.
Because this alternative would result in contaminants remaining
on site, CERCLA requires that the Site be reviewed at least every
five years. If justified by the review, remedial actions would
be evaluated at that time to address the contamination. The
above cost estimates include the cost to perform this review.
Alternative GW-2: INSTITUTIONAL CONTROLS
Estimated Capital Cost: $74,000
Estimated Annual O&M Cost: $180,000
Estimated Net Present Worth Cost: $575,000
Estimated Implementation Time: 6 months
Alternative GW-2 would include the implementation of deed and
well restrictions to reduce the potential for exposure to ground-
water contaminants. These restrictions may completely ban the
installation of wells in a particular area, or they may establish
well siting or construction specifications and the minimum depth
to which wells must be installed. Current site contaminants
would remain, and no changes in levels of these contaminants
would be expected except those resulting from natural
attenuation, migration, or biodegradation.
As in the No Action alternative above, the Site would be reviewed
every five years. The cost estimates above include the cost to
perform this review.
Alternative GW-3; EXTRACTION AND TREATMENT OF CONTAMINATED
GROUND WATER
Estimated Capital Cost: $1,340,000
Estimated Annual O&M Cost: $365,000 years 1-3; $283,000 years 4-30
Estimated Net Present Worth Cost: $5,914,000
Estimated Implementation Time: 30 years
Under this alternative, an interceptor trench and/or extraction
wells would be installed to collect shallow ground water. The
exact number and precise location of the extraction wells and the
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optimum pumping rate would be determined during design. The
design of the treatment system would be based upon additional
tests and investigations to be conducted during the remedial
design phase. The contaminated ground water would be pumped to
an on-site treatment system that would remove metals by
precipitation and ultrafiltration, and remove volatile organic
compounds (VOCs) by air stripping. The ground water would be
treated to meet Federal and New Jersey Safe Drinking Water
Standards. The treated ground water would be reinjected.
Ground-water monitoring would be performed during and following
active remediation. Further treatment of the air stream may be
required to comply with New Jersey's Air Pollution Control
Regulations for VOC and toxic emissions.
The installation of an interceptor trench and extraction wells
may affect the natural flow of ground water and-surface water to
the wetlands. The ground-water extraction system may affect the
hydrology of the wetlands. To the maximum extent practicable,
the interceptor trench and extraction wells would be placed in
locations that avoid or minimize any impacts. If it is
determined during design that hydrological impacts to the
wetlands are significant, ground water from the clean aquifer
below the shallow aquifer would be pumped and discharged into a
nearby swale that drains into the wetlands to minimize any
hydrological impacts.
It is anticipated that half as many monitoring well samples would
be required in years 4 through 30 than in the first 3 years
because the contaminant concentrations would be expected to
decline through the extraction and treatment of the ground water.
This is reflected in the annual O&M costs for this alternative.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the National Oil and Hazardous Substances
Pollution Contingency Plan, a detailed analysis of each remedial
alternative was performed with respect to each of the nine
criteria. This section discusses and compares the performance of
the remedial alternatives under consideration against these
criteria. These criteria were developed to address the
requirements of Section 121 of CERCLA to ensure all important
considerations are factored into remedy selection decisions.
All selected remedies must at least satisfy the Threshold
Criteria. The selected remedy should provide the best trade-offs
among the Primary Balancing Criteria. The Modifying Criteria are
evaluated following the public comment period.
Threshold Criteria
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1. Overall protection of human health and the environment
addresses whether or not a remedy provides adequate
protection and describes how risks posed through each
exposure pathway (based on a reasonable maximum exposure
scenario) are eliminated, reduced, or controlled through
treatment, engineering controls, or institutional controls.
2. Compliance with ARARs addresses whether or not a remedy
would meet all of the applicable or relevant and appropriate
requirements of Federal and State environmental statutes and
requirements and/or provide grounds for invoking a waiver.
Primary Balancing Criteria
3. Long-term effectiveness and permanence refers to the
magnitude of residual risk and the ability of a remedy to
maintain reliable protection of human health and the
environment over time, once remedial objectives have been
met.
4. Reduction of toxicity. mobility or volume through treatment
addresses the statutory preference for selecting remedial
actions that employ treatment technologies that permanently
and significantly reduce toxicity, mobility or volume of the
hazardous substances as a principal element.
5. Short-term effectiveness addresses the period of time needed
to achieve protection and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation period, until the remedial
objectives are achieved.
6. Imp1ementabi1ity is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
alternative.
7. Cost includes estimated capital and operation and
maintenance costs, and the present-worth costs.
Modifying Criteria
8. State acceptance indicates whether, based on its review of
the RI/FS and the Proposed Plan, the State supports,
opposes, and/or has identified any reservations regarding
the preferred alternative.
9. Community acceptance refers to the community's comments on
the alternatives described in the Proposed Plan, and the RI
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and FS reports. Responses to public comments are addressed
in the Responsiveness Summary of this ROD.
A comparative analysis of the remedial alternatives based upon
the aforementioned evaluation criteria follows.
Overall Protection of Human Health and the Environment
Risks to human health and the environment would not be eliminated
through Alternative GW-1, No Action, because it would not address
contaminants in the ground water, which pose an unacceptable
risk. In addition, ground-water degradation would continue
because migration of contaminants would not be controlled.
Alternative GW-2, Institutional Controls, would reduce the
potential for on-site contact through the placement of deed
restrictions. However, it would not prevent the migration of
contaminants off site or into the deeper aquifers, allowing
ground-water degradation to continue. Therefore, Alternative
GW-2 would not be protective of human health and the environment.
Since Alternatives GW-1 and GW-2 would not be protective of human
health and the environment, they will not be discussed further.
Alternative GW-3, Extraction and Treatment of Ground Water, would
protect human health by reducing contaminant concentrations in
the ground water to acceptable levels, and by preventing further
migration. If it is determined during design that the extraction
of contaminated ground water will adversely affect the hydrology
of the wetlands, engineering controls would be designed to
mitigate the hydrological impacts to the wetlands. Therefore,
Alternative GW-3 would be protective of human health and the
environment.
Risks to human health and the environment would not be eliminated
through Alternative SS-1, No Action, because it would not address
the contaminants in the soil, which pose an unacceptable risk.
In addition, ground-water degradation due to the uncontrolled
infiltration of soil contaminants would continue.
Alternative SS-2, Institutional Controls, would reduce the
potential for on-site contact through deed restrictions and the
installation of a fence around the Site. However, it would not
provide protection of human health and the environment because it
would not control off-site migration or infiltration of
contaminants. Since Alternatives SS-1 and SS-2 would not be
protective of human health and the environment, they will not be
discussed further.
Alternative SS-4, Excavation and Off-Site Treatment/Disposal,
would remove contaminants from the 'soil and prevent further
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migration of contaminants into the ground water, thereby
protecting human health and the environment.
Alternative SS-5, Capping, would reduce the potential for contact
with the contaminated soil, thereby reducing the risk posed by
the direct contact exposure pathway. In addition, deed
restrictions would need to be placed on the property to restrict
future land-use, and thereby reduce potential contact with the
contaminated soils.
Compliance with ARARs
There are several categories of ARARs: action-specific, chemical-
specific, and location-specific. Action-specific ARARs are
technology or activity-specific requirements or limitations
related to various activities of the project. Chemical-specific
ARARs are usually numerical values which establish the amount or
concentration of a chemical that may be found in, or discharged
to, the ambient environment. Location-specific ARARs are
restrictions placed on the concentrations of hazardous substances
or the conduct of activities solely because they occur in a
special location.
Action-Specific ARARs
Action-specific ARARs affecting Alternative SS-4 include Land
Disposal Restrictions (LDR), Resource Conservation and Recovery
Act (RCRA), and Toxic Substances Control Act (TSCA) requirements
for treatment and disposal of hazardous substances.
Under Alternative SS-4, stabilization of the excavated soils
would comply with LDR, which requires contaminated materials to
be treated to meet standards before placement in a landfill.
RCRA mandates that owners and/or operators of incinerators
receiving hazardous wastes must have operating permits and meet
specified treatment standards. Alternative SS-4 would comply
with this ARAR by sending excavated soils for treatment at an
approved facility that meets these requirements. PCB-
contaminated soils would be treated at an approved facility that
meets TSCA standards for incinerators.
Under Alternative SS-5, the multi-layer cap would be designed,
constructed, and installed to meet RCRA and New Jersey
requirements for performance and operating standards.
Chemical-Specific ARARs
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Because ground water at the Site is classified as Class II (i.e.,
drinking water), the following are considered relevant and
appropriate requirements: National Primary Drinking Water
Standards and New Jersey Safe Drinking Water Act Maximum
Contaminant Levels for Hazardous Contaminants, and/or New Jersey
Ground Water Quality Standards.
Alternative GW-3 would comply with ARARs. Ground water would be
treated to meet ARARs prior to reinjection. VOC emissions from
the air stripper would comply with New Jersey's "Control and
Prohibition of Air Pollution by Volatile Organic Substances" and
"Control and Prohibition of Air Pollution by Toxic Substances."
Since there are no ARARs for soil cleanup, contaminated soils
would be remediated to site-specific risk-based levels.
Alternative SS-5 does not include any treatment or disposal, and
would not attain risk-based soil cleanup levels because
contaminant concentrations would not be reduced. Alternative
SS-4, Excavation and Off-Site Treatment/Disposal, would remove
soil contaminants that are above EPA's risk-based levels and
eliminate the risks associated with exposure.
Location-Specific ARARs
Location-specific ARARs affecting the remedial action include the
Safe Drinking Water Act, National Historic Preservation Act,
Endangered Species Act, and the Wetlands Act of 1970.
Long-Term Effectiveness and Permanence
Alternative GW-3, Extraction and Treatment of Ground Water, would
be effective in treating the contamination in the shallow ground
water. However, Alternative GW-3, in and of itself, would not
attain the drinking water MCLs in the long term because soil
contaminants would continue to infiltrate into the ground water.
When paired with the appropriate source control alternative, it
would attain MCLs more effectively. Treatment residuals, such as
dewatered sludge, would be transported off site for disposal at
an approved facility. Therefore, no long-term risks would be
posed by these treatment residuals. Treated effluent would be
monitored to ensure that it meets applicable discharge criteria.
Alternative SS-5, Capping, would involve engineering controls to
minimize leachate production and soil contact via installation of
a multi-layer cap. Long-term maintenance and monitoring of the
cap would be required to ensure its effectiveness.
Alternative SS-4, Excavation and Off-Site Treatment/Disposal,
would remove soil contaminants to levels protective of human
health and the environment. The risks posed by the contaminated
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soils would be reduced. The threat of further ground-water
degradation would be reduced by controlling the infiltration of
soil contaminants. This alternative would provide long-term
effectiveness and permanence.
Reduction in Toxicity. Mobility or Volume
Under Alternative SS-4, it is anticipated that soils contaminated
with PCBs/organic compounds would be treated at an approved off-
site incinerator, while soils contaminated with heavy metals
would be disposed of at a landfill. Toxicity, mobility, and
volume of contaminants would be reduced by treatment of the
excavated soil at an approved off-site incinerator. Mobility of
the heavy metals would be reduced by stabilization of the soil
prior to disposal. However, the disposal of contaminated soil at
an approved landfill without stabilization would not reduce the
toxicity, mobility or volume of the contaminants.
Alternative SS-5, Capping, would reduce the mobility of
contaminants. This alternative would not involve active
treatment for the contaminated soil. The toxicity and volume of
the soil contaminants would remain at current levels for an
extended period of time. The volume of contaminants could
increase if the cap fails or if future ground-water table
fluctuations bring it into contact with contaminated soil.
Alternative GW-3, Extraction and Treatment of Ground Water, would
reduce mobility and volume of the contaminants because it would
reduce ground-water contamination and control migration. The
treatment system would remove contaminants from the extracted
ground water, thereby reducing their mobility and volume.
Short-Term Effectiveness
Risks to workers and nearby residents from airborne contaminants
would be minimized during the implementation of Alternative SS-4
or SS-5 through the use of appropriate engineering controls and a
comprehensive health and safety plan.
Appropriate levels of protection for workers would be specified
in the health and safety plan to avoid direct contact with
contaminated soils and ground water during construction
activities called for in Alternative GW-3.
The suspected presence of DNAPLs at the Site, which is
characterized by the high concentrations of PCE and TCE in the
shallow ground water, may have an influence on the time frame
required or ability to fully achieve cleanup levels.
Alternatives SS-4 and SS-5 would take approximately 1 and 2
years, respectively, to implement. The implementation period for
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25
Alternative GW-2 is estimated to be 6 months, while Alternative
GW-3 is approximately 30 years.
Implementability
Under Alternative SS-4, excavation would involve conventional and
readily implementable construction methods. Acceptance by an
approved treatment/disposal facility is not expected to pose a
problem due to the small quantity of contaminated soil that would
be sent off site.
Impermeable multi-layer caps, as described in Alternative SS-5,
are a proven technology, involve readily available materials, and
could be readily implemented.
Alternative GW-3 would include the installation of an interceptor
trench, ground-water extraction wells, a ground-water collection/
piping system, precipitation process equipment, an ultra-
filtration unit, an air stripping tower, and associated piping
and instrumentation. There is sufficient property on site to
construct and install this equipment. Construction and
installation of these components can be accomplished using common
techniques and readily available equipment.
Interceptor trenches and extraction wells are proven technologies
for extracting ground water. The extraction wells would be
placed near potential source areas to enhance removal of the
contaminants and reduce migration. Precipitation and ultra-
filtration processes are proven technologies for the removal of
heavy metals found in ground water, and have often been used to
reduce the levels of metals in wastewater. Air stripping of VOCs
is a proven technology. All the process units required for the
treatment system are readily available, transportable to the
Site, and easily installed. Sludge generated during treatment .
would require transportation to an approved facility on a
periodic basis.
Cost
Estimated capital costs, annual O&M costs, and the total present
worth of all the remedial alternatives are summarized in
Tables 4A and 4B. Present worth costs are based on a 30-year
period and a discount rate of 5 percent.
Alternative GW-3, Extraction and Treatment of Contaminated Ground
Water, is the most expensive, with a present worth cost of
$5,914,000.
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26
The estimated present worth cost of Alternative SS-4 is $739,000.
The most costly alternative is Alternative SS-5, with a present
worth cost of $2,180,000.
State Acceptance
The New Jersey Department of Environmental Protection and Energy
concurs with the preferred alternatives.
Community Acceptance
Community acceptance was evaluated after the close of the public
comment period. Written comments received during the public
comment period, as well as verbal comments during the public
meeting on May 13, 1992, were evaluated. The response to those
comments are addressed in the Responsiveness Summary.
Comments received during the public comment period indicated that
the local residents were in favor of the preferred alternatives
for the remediation of ground-water and soil contamination (i.e.,
GW-3 and SS-4). However, some local residents were dissatisfied
with the Proposed Plan and the preferred remedial alternatives
with respect to sediments. They believe that the Proposed Plan
should have included remedial alternatives to address sediment
contamination, particularly in the wetlands.
SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the
detailed analysis of the alternatives, and public comments, the
NJDEPE and EPA have determined that Alternatives SS-4 and
GW-3 constitute the remedy that is protective of human health and
the environment, will maintain protection over time, and that
will minimize untreated waste.
The soil and ground-water cleanup levels for the Ellis Property
Site are listed in Tables 5 and 6. NJDEPE has requested that
soil and ground-water contamination at the Site be remediated to
the levels specified in its Proposed Cleanup Standards for
Contaminated Sites (February 1992), shown in Tables 7A and 7B.
These proposed standards are not recognized as ARARs under
Section 121(d) of CERCLA because they are not yet promulgated.
However, EPA has determined that further remediation of the soil
and ground water at the Site to the levels requested by the
NJDEPE, does not conflict, or is not inconsistent, with the
selected remedy. The NJDEPE has agreed to fund the incremental
costs associated with this additional cleanup.
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27
The major components of the selected remedy include the
following:
Excavation of contaminated soil and treatment/disposal
at an approved off-site facility;
Extraction of contaminated ground water from the
shallow aquifer underlying the Site;
Treatment of the contaminated ground water in a
facility to be constructed on site;
Disposal of the treated ground water on the Site by
reinjection; and
• Implementation of an environmental monitoring program
to ensure the effectiveness of the remedy.
The goal of this remedial action is to restore the ground water
to its beneficial use, in this case, a source of drinking water.
However, EPA recognizes that the selected remedy may not achieve
this goal because of the technical difficulties associated with
achieving ground-water cleanup levels. It may become apparent,
during implementation or operation of the ground-water
extraction/treatment system, that contaminant levels have ceased
to decline and are remaining constant at levels higher than the
remediation goal. In such a case, the systems' performance
standards and/or the remedy may be reevaluated. Performance
monitoring of the ground-water extraction and treatment system
will be implemented. The data collected would be used to suggest
system adjustments or modifications to provide more effective or
efficient attainment of cleanup levels. Such adjustments or
modifications may include: increasing or decreasing the
extraction rate, initiating a pulsed pumping schedule, installing
additional extraction wells (or drains), or ceasing extraction at
wells where cleanup levels have been achieved. Monitoring data
will be used to assess the effectiveness of the modifications
implemented and may be used to re-assess the time frame required
to achieve cleanup levels.
While a DNAPL source was not observed during the RI, further
investigations will be conducted during the design phase to
locate, or determine, the existence of such a source. If a DNAPL
source is found, it will be addressed in the ground-water
extraction and treatment system design.
Because the ground-water extraction system may adversely impact
the wetlands, a wetlands assessment will be conducted during the
design phase to evaluate the potential effects due to the
extraction and discharge of ground water. Adverse impacts to the
wetlands will be mitigated through engineering controls to the
maximum extent practicable.
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28
STATUTORY DETERMINATIONS
The remedy selected by EPA for ground-water and soil remediation
at the Site complies with the requirements of Section 121 of
CERCLA, as amended by SARA. The selected remedy is protective of
human health and the environment, complies with Federal and State
requirements that are applicable, or relevant and appropriate to
this action, and is cost-effective. The selected remedy utilizes
permanent solutions, and alternative treatment technologies or
resource recovery technologies, to the maximum extent
practicable. The statutory preference for treatment that reduces
toxicity, mobility or volume will be satisfied by the selected
remedy. The selected remedy provides the best balance of trade-
offs among the criteria. The following sections discuss how the
selected remedy meets these statutory requirements.
Protection of Human Health and the Environment
The selected remedy is protective of human health and the
environment, dealing effectively with the threats posed by the
contaminants which were identified.
The principal threat posed by the Site is the contaminated soils.
The pathways associated with this threat include the infiltration
of soil contaminants into the ground water and the potential
migration of contaminated ground water into the deeper aquifers.
By excavating the soil contaminants, and extracting and treating
the contaminated ground water, the threats to human health and
the environment will be reduced. Contaminants in the ground
water will be reduced to levels that are acceptable for drinking
water. The removal of soil contaminants will prevent further
degradation of the wetlands caused by surface soil erosion.
Compliance with ARARs
The selected remedy will comply with the substantive requirements
of the statutes and regulations listed in Table 8 to the extent
they are applicable or relevant and appropriate to the
remediation at this Site.
Action-Specific ARARs
Sludge produced by the ground-water treatment system and
excavated soils will be disposed in accordance with RCRA
requirements at RCRA-permitted facilities. The excavated soil
will be stabilized prior to disposal, if necessary. Sludge and
soil will be disposed at a facility that meets RCRA requirements.
PCB-contaminated soil will be treated at a facility that meets
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29
TSCA requirements. Federal and State Department of
Transportation requirements, including hazardous waste manifests,
will be met for transportation of sludge and excavated soil from
the Site to treatment/disposal facilities.
The air stripper will be designed to meet the New Jersey Air
Pollution Control Regulations for VOC and toxic emissions (NJAC
7:27-16 & 17). The ground-water treatment system will be
designed to treat the extracted ground water to MCLs prior to
reinjection.
Chemical-Specific ARARs
The contaminants of concern in the ground water will be
remediated to meet MCLs. The cleanup levels for the ground-water
contaminants are listed in Table 6. These levels represent the
concentrations which would be attained in the treated water
before reinjection. The discharge of treated ground water will
meet the levels specified in the New Jersey Ground Water Quality
Criteria (Table 9).
Emissions from the air stripper will be designed to comply with
the New Jersey Air Pollution Control Regulations for VOC and
toxic emissions (NJAC 7:27-16 & 17).
The cleanup levels for soils are provided in Table 5. The
selected remedy will reduce exposure risks posed by site soils to
the acceptable range of 10"" to 10"8 for carcinogens, and to an HI
less than 1.0 for noncarcinogens.
Location-Specific ARARs
The contaminated ground water, which is located in a sole source
aquifer, will be treated to meet Federal and State drinking water
MCLs.
To comply with the National Historic Preservation Act, a Stage IB
excavation survey will be conducted during the remedial design
phase. If cultural resources are found, a cultural resources
mitigation plan will be developed to reduce the impact to these
resources as much as possible.
In addition, a survey of the Site will be conducted during the
remedial design phase to confirm the presence or absence of swamp
pink and other threatened/endangered species. If threatened/
endangered species are found to inhabit the Site, impacts to the
species and its habitat will be minimized to the maximum extent
practicable.
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30
The substantive requirements of the Freshwater Wetlands Act (NJAC
7:7A-1.1 et sea.) will be met. The wetlands delineation will be
extended to include all areas that could be affected by the
installation of an interceptor trench and/or ground-water extrac-
tion wells.
To ensure that remedial action process equipment and buildings
are not constructed or installed in flood-prone areas, the
remedial design activities will include a 100-year and 500-year
floodplain delineation. The substantive requirements of
Executive Order 11988, Protection of Floodplains, and the New
Jersey Flood Hazard Area Control Act (NJSA 58:16A-50 et seq.)
will be met if the floodplain delineation shows-that facilities
would be located in areas subject to flooding.
Advisories. Guidance and Criteria To Be Considered
The shipment of hazardous wastes off site to a treatment/disposal
facility will be conducted in accordance with EPA's Office of
Solid Waste and Emergency Response Directive No. 9834.11,
"Revised Procedures for Planning and Implementing Off-site
Response Actions." The intent of this directive is to ensure
that facilities authorized to accept CERCLA-generateti waste are
in compliance with RCRA operating standards.
Cost-Effectiveness
Of the alternatives which most effectively address the threats
posed by site contamination, the selected remedy provides for
overall effectiveness in proportion to its cost. The estimated
total project cost is $6,653,000.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
Contaminants in the ground water will be removed and treated
before reinjection. Hazardous wastes generated by the treatment
process will be disposed of at an approved off-site facility.
This will significantly reduce the toxicity, mobility and volume
of the contaminants, and offers a permanent solution to the risks
posed by the contaminated ground water. The treatment of soils
contaminated with PCBs/organic compounds at an approved off-site
incinerator will significantly reduce the toxicity, volume and
mobility.
The disposal of heavy metals-contaminated soil at an approved
off-site landfill does not represent a permanent solution with
respect to the risks associated with the contaminants because
toxicity, volume or mobility would not be reduced. However,
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31
treatment of the soil by stabilization prior to disposal, if
required, would reduce the mobility of the contaminants. As
demonstrated in the FS, treatment of all the soil contaminants by
one single technology was not practicable. Furthermore, the cost
of constructing an on-site treatment system was not justified by
the small volume of metals-contaminated soil (690 yd3) .
Considering the relatively small volume of metals-contaminated
soil, EPA believes that the selected remedy represents the
maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost-effective manner.
Preference for Treatment as a Principal Element '
With respect to ground-water contamination, the selected remedy
satisfies the statutory preference for treatment as a principal
element. The selected remedy reduces levels of contaminants in
the ground water through treatment using precipitation and
ultrafiltration for metals and air stripping for VOCs, thereby
reducing the risk to human health.
The disposal of heavy metals-contaminated soil in an approved
off-site landfill without stabilization does not satisfy the
statutory preference for treatment. Due to the different types
of contaminants present in the soil, treatment of the soil by one
technology is not practicable. As shown in the FS, there was no
one single treatment technology that was effective for treating
organic compounds, PCBs, and heavy metals in soils; however,
contaminated soils will be stabilized prior to disposal, if
required. The selected remedy calls for the off-site treatment
of soil contaminated with PCBs and/or organic compounds, and
hence, satisfies the preference for treatment for this portion of
the remedy.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Ellis Property Site was released to the
public on May 1, 1992. The Proposed Plan identified the
preferred alternatives for ground-water and soil remediation.
EPA reviewed all written and verbal comments received during the
public comment period. Upon review of these comments, EPA
determined that no significant changes to the selected remedy, as
it was originally identified in the Proposed Plan, were
necessary.
-------
APPENDIX I
FIGURES
Figure 1 Ellis Property Site Location
Figure 2 Ellis Property Site Plan
Figure 3 Ellis Property Site Drainage
-------
FIGURE 1. ELLIS PROPERTY SITE LOCATION
MEDFORD
TOWNSHIP
EVESHAM
TOWNSHIP
-------
FIGURE 2. ELLIS PROPEHTY SITE PLAN
I. en • •*•»•«•», i
I T I Rubbto. \
tl I I AbandoiMd \
!. \ I Rettioerator
Metal Siding^
OM (South) Buddiog J
— Former Drum Waste Locations
— Former Building Location
Interim Remedial Action locatfc
Soil SlatMktaiion or Removal
in n < I
Mote. TMa drawing l» per Intermatton coNected
Jan. 22.1966 and Base Topographic Map
developed by ADR Associates
-------
FIGURE 3. ELLIS PROPERTY SITE DRAINAGE
11 !
!
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•
f~^ — v.
j —
; <
>
t
)
\ \
SXA
^ }
/ / >
) )
\ (
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i
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l
X
(
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y i-
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o ° ^>
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POORQUALITV
^ORIGINAL
-------
Table 1A
Table IB
APPENDIX II
TABLES
Endangered/Threatened Species Observed Within a
Three-Mile Radius of the Ellis Property Site.
Endangered/Threatened Species Occurring in
Burlington County, New Jersey.
Table 2
Table 3
Table 4A
Table 4B
Table 5
Table 6
Table 7A
Table 7B
Table 8
Predominant Contaminants and Range of
Concentrations Detected at the Ellis Property
Site.
Comparison of Predominant Ground-water
Contaminants Found at the Ellis Property Site With
Drinking Water Standards.
Summary of Remedial Alternative Costs for Soil.
Summary of Remedial Alternative Costs for Ground
Water.
EPA's Risk-based Soil Remediation Levels.
Ground-Water Remediation Levels for Predominant
Contaminants
NJDEPE's Proposed Soil Cleanup Standards for
Contaminated Sites (February 1992)
NJDEPE's Proposed Ground Water Cleanup Standards
for Contaminated Sites (February 1992)
Summary of Federal and State Applicable or
Relevant and Appropriate Requirements (ARARs) for
the Ellis Property Site.
Table 9
Ground Water Quality Criteria (NJAC 7:9-6)
-------
Table 1A. Endangered/Threatened Species Observed Within a Three-Nile
Radius of the Ellis Property Site
COMMON NAME SCIENTIFIC NAME CLASSIFICATION3
Upland piper Bartramia longicauda Endangered
Bog turtle Clemmys muhlenbergii Endangered
Pine Barrens treefrog HyTa andersonii Endangered
Grasshopper sparrow Ammodramus savannarum Threatened
American bittern Botaurus lentiginosus Threatened
Wood turtle Clemmys insculpta Threatened
Bobolink Dolichonyx orhyzovorus Threatened
Red-headed woodpecker Melanerpes erythrocephalus - Threatened
Classified by the State of New Jersey.
Table IB. Endangered/Threatened Species Occurring in
Burlington County, New Jersey
COMMON NAME SCIENTIFIC NAME CLASSIFICATION9
Cooper's hawk Accipiter cooper??' Endangered
Corn snake Elaphe guttata Endangered
Northern harrier Circus cyaneus Endangered
Pied-billed grebe Podilymbus podiceps Endangered
Tiger salamander Ambystoma tigrinum Endangered
Timber rattlesnake Crotalus horridus Endangered
Vesper sparrow Pooecetes gramineus Endangered
Barred owl Strix van'a Threatened
Black rail Laterallus jamaicensis Threatened
Brook trout Salvelinus fontinalis Threatened
Great blue heron Ardea herodias Threatened
Mud salamander Pseudotriton montanus Threatened
Osprey Pandion haliaetus Threatened
Pine snake Pituophis melanoleucus Threatened
Classified by the State of New Jersey.
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Table 2. Predominant Site Contaminants and Range of Concentration Detected at the Ellis Property Site
CONTAMINANT
Antimony
Arsenic
Beryllium
Bis (2-ethylhexyl) phthalate
Chromium
1,2-Dichloroethene
Lead
Methyl ene Chloride
Nickel
Polychlorinated biphenyls (PCBs)
Tetrachloroethene (PCE)
1,1,2-Trichloroethane
Trichloroethene (TCE)
SOIL
(in ppm)
4.5-8.9
1.4-31.8
0.2-1.7
0.045-2.3
11.8-493
ND
2.2-3,790
0.002-0.12
1.26-19.1
0.31-23.1
0.0009-0.0085
ND
0.001-0.19
GROUND
MATER
(in ppb)
19-2,123.3
15.8-91
1.55-10.2
1-5
12-404
5-520
4.3-71
6-52
10.9-147
ND
760-33,000
3-14
11-24,000
WETLANDS
SEDIMENT
(in ppm)
ND
ND
ND
ND
23.6-108
0.008-0.53
53.8-204
0.14-0.91
ND
ND
ND
ND
0.048-5.4
SURFACE
WATER
(in ppb)
ND
ND
ND
ND
7.3-139
2-9
4-633
12-17
ND
ND
ND
ND
3-290
DRAINAGE WAYS
SEDIMENT
(in ppm)
ND
3.5-7.3
0.7-2.4
0.13-0.56
15.2-267
ND
7.8-263
0.037-0.083
5.3-27
0.017-0.21
ND
ND
ND
SURFACE
WATER
(in ppb)
ND
1.2-7.3
ND
ND
6-59
ND
3.8-86.9
ND
6.4-9
ND
ND
ND
ND
ppb = Parts per billion
ppm = Parts per million
ND = Not detected
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Table 3. Comparison of Predominant Ground Water Contaminants Found
at the Ellis Property Site With Drinking Water Standards3
CONTAMINANT
Antimony
Arsenic
Beryllium
Chromium
1,2-Dichloroethene
Lead
Methylene Chloride
Nickel
Trichloroethene
Tetrachloroethene
FREQUENCY
OF
OCCURRENCE6
1/4
4/4
4/4
6/6
4/7
5/6
7/7
4/4
5/7
1/7
RANGE OF
CONCENTRATION .
parts per billion
19 - 2,123.3
15.8 - 91
1.55 - 10.2
24.2 - 404
5 - 520
5 - 71
6 - 52
10.9 - 147
11 - 24,000
15000 - 33,000
DRINKING
WATER STANDARD
parts per billion
6f
50C
4f
50C
10d
15e
5f
100f
ld
ld
a Includes ground water sampling results taken by NJDEPE on November 14, 1991.
b Number of sampling locations at which the contaminant was detected compared
with the total number of sampling locations.
c National Primary Drinking Water Regulations, Maximum Contaminant Levels,
40 CFR Part 141.
d New Jersey Safe Drinking Water Act, Maximum Contaminant Levels,
NJAC 7:10-16.
e National Primary Drinking Water Regulations, Action Level for Lead, 40 CFR
Part 141.
National Primary Drinking Water Regulations, Maximum Contaminant Levels,
40 CFR Part 141 (promulgated July 17, 1992).
-------
Table 4A. Summary of Remedial Alternative Costs for Soil3
Alternative SS-1:
NO ACTION
Estimated Capital Cost: $ 0
Estimated Annual Operation & Maintenance (O&M) Cost: $ 42,000
Estimated Net Present Worth Cost: $117,000
Estimated Implementation Time Frame: None
Alternative SS-2: INSTITUTIONAL CONTROLS
Estimated Capital Cost:
Estimated Annual O&M Cost:
Estimated Net Present Worth Cost:
Estimated Implementation Time Frame:
$ 40,000
$ 25,000
$110,000
6 months
Alternative SS-4: EXCAVATION AND OFF-SITE TREATMENT/DISPOSAL
Estimated Capital Cost:
Estimated Annual O&M Cost:
Estimated Net Present Worth Cost:
Estimated Implementation Time Frame:
$560,000
$188,200
$739,000
1 year
Alternative ss-5: CAPPING OF SURFACE SOILS
Estimated Capital Cost:
Estimated Annual O&M Cost:
Estimated Net Present Worth Cost:
Estimated Implementation Time Frame:.
$630,000
$100,800
$2,180,000
2 years
Alternative SS-3, Excavation and on-site treatment, is not
included because it did not pass the screening process.
One year only.
-------
Table 4B. Summary of Remedial Alternative Costs
for Ground Water
Alternative GW-l: NO ACTION
Estimated Capital Cost: $ 30,000
Estimated Annual O&M Cost: $ 61,000
Estimated Net Present Worth Cost: $ 200,000
Estimated Implementation Time Frame: None
Alternative GW-2: INSTITUTIONAL CONTROLS
Estimated Capital Cost: $ 74,000
Estimated Annual O&M Cost: $ 180,000
Estimated Net Present Worth Cost: $ 575,000
Estimated Implementation Time Frame: 6 months
Alternative GW-3: EXTRACTION AND TREATMENT OF CONTAMINATED
GROUND WATER
Estimated Capital Cost: $1,340,000
Estimated Annual O&M Cost:
years 1-3 $ 365,000
years 4-30 $ 283,000
Estimated Net Present Worth Cost: $5,914,000
Estimated Implementation Time Frame: 30 years
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Table 5. EPA's Risk-Based Soil Remediation Levels
CHEMICAL
Arsenic
Bis (2-ethylhexyl) phthalate
Chromium
Lead
Polychlorinated Biphenyls (PCBs)
REMEDIATION LEVEL
in parts per million
(ppm)
20
46
945
500
1
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Table 6. Ground-Water Remediation Levels for Contaminants of Concern at the El 11s Property Site
CONTAMINANT
Antimony
Arsenic
Barium
Beryl 1 i urn
Cadmium
Chromium (total)
Copper
Cyanide
1,1 Dichloroethene
1,2 Dichloroethene
Lead
Methylene Chloride
Nickel
Selenium
Silver
1 , 1 ,2-Trichl oroethane
Tetrachloroethene (PCE)
Trichloroethene (TCE)
NATIONAL PRIMARY
DRINKING WATER
REGULATIONS MCLa
(ppb)
6
50
1000
4
10
50
1300d
200
7e
f o $J> £^ * vf>$' ' ^ V'-i?
'f ', '•• '', % ''"•*' / *•. f 4$&S, " £ i " jit ,
15d
5
100
100
50
3e
flSl^Mp^?^^ % ;
NEW JERSEY SAFE
DRINKING WATER
ACT PRIMARY MCLb
(ppb)
, '""/-, ^'^illPB **
'^V,,%^^Y';S:|
-$\: y&^ffi'. .-*
- 'VV/**:V' 7^$%V
-'-:': 'i-^t'^51^
'r/l^^j^f^-{f
- -:^Mif"^^ '•
' yj5ff;*. *^Wv-
2
10
^^;;^4-v;-"^^
. <> •
1 j 'l!
i
i
i
NEW JERSEY GROUND
WATER QUALITY
CRITERIA6
(ppb)
50
1000
10
50
?' •-• "*», -rir "*]-. '.
200
;; ' ' '-^i4Ji^
«^J' '.- J§.Sii'S ?
50
t^:;';' ; ->Sp^M ',
*?'.^}*"t.."f3f kNi
£^fl:;i^CflS^f^V.'
|^:^;;'s :/^fSl^J^
*fe' ^ ''A.^H^ VJ
l;!:!^:R,^i^^S|x/J
REMEDIATION
LEVEL
(ppb)
6
50
1000
4
10
50
1300d
200
2
10
15d
5
100
100
50
5
1
1
MCL = Maximum contaminant level.
ppb = Parts per billion.
Ill = No standard for this specific contaminant.
B:: 40 CFR Part 141.
b NJAC 7:10-16.8.
c NJAC 7:9-6.6; for ground water classified as GW-2.
d Action level established in 40 CFR 141. 8(c).
e Maximum contaminant level goal, 40 CFR 141.50(b).
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Table 7A. NJDEPE Proposed Residential Soil Cleanup Levels for Contaminated Sites
for Contaminants of Concern at the Ellis Property Site
CONTAMINANT
Acenaphthene
Acetone
Antimony
Arsenic (Total)
Barium
Benzene
Benzo (a) anthracene
Benzo (a) pyrene
Benzo (b) fluoranthene
Benzo (g,h,i) perytene
Benzo (k) fluoranthene
Beryllium
Bis (2-ethylhexyl) phthalate
Butylbenzyl phthalates
Cadmium
Chlorobenzene
Chrysene
Copper
4,4'-DDD
4,4'-DDE
4,4'-DDT
Dibenzo (a,h) anthracene
Di-n-butyl phthalate
Endrin
Fluoranthene
Indeno (1,2,3-cd) pyrene
Lead (Total)
Methoxychlor
Mercury (Total)
Methylene chloride
Nickel (soluble salts)
n-Nrtrosodiphenytamine
Phenol
Polychlorinated biphenyls (PCBs)
Pyrene
Selenium (Total)
Silver
Tetrachloroethene
Toluene
1,1,1 -Trichloroethane
Trichloroethene
Vanadium
Zinc
SURFACE SOIL (ppm)
3,400
1,000
14
20
600
3
0.66
0.66
0.66
0.66
0.66
2 ,
49
10,000
1
37
0.66
600
3
2
2
0.66
5,700
17
2,300
0.66
100
280
14
49
250
140
10,000
0.45
1,700
1
40
9
1,000
210
23
380
1,500
SUBSURFACE SOIL (ppm)
100
50
1
500
100
500
500
500
100
100
1
500
100
100
100
500
100
50
500
500
500
10
100
50
100
500
1
500
50
1
ppm = parts per million.
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Table 7B. NJDEPE Proposed Ground-Water Cleanup Levels for
Contaminated Sites for Contaminants of Concern at the Ellis Property Site
CONTAMINANT
Antimony
Arsenic (Total)
Barium
Beryllium
Bis (2-ethylhexyl) phthalate
Butyl benzyl phthalates
Cadmium
Chloroform
Chromium (Total)
1,1-Dichloroethene
1,2-Diehloroethene (cis)
1,2-Dichloroethene (trans)
Di ethyl phthalate
Di-n-butyl phthalate
2,4-Dinitrotoluene
Fluoranthene
Lead (Total)
Methyl ene chloride *
Nickel (soluble salts)
Pentachlorophenol
Pyrene
Selenium (Total)
Silver
Tetrachloroethene
Toluene
1 , 1 , 2-Tri chl oroethane
Trichloroethene
Zinc
CLEANUP LEVEL
(parts per billion)
20
8
2000
20
30
WO
4
6
100
2
10
100
5000
900
100
300
100
3
100
1
200
50
20
1
1000
3
1
5000
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Table 9. Ground Water Quality Criteria for Contaminants of
Concern at the Ellis Property Site
CONTAMINANT
Arsenic and compounds
Barium
Cadmium and compounds
Chromium (hexavalent) and
compounds
Lead and compounds
Selenium and compounds
Silver and compounds
STANDARD for GW-2 (ppb)
50
1000
100
50
50
10
50
Source: New Jersey Ground Water Quality Criteria (NJAC 7:9-6.6)
ppb = parts per billion.
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Table 8. Summary of Federal and State Applicable or Relevant and Appropriate
Requirements (ARARs) for the Ellis Property Site
FEDERAL ARARs
Safe Drinking Water Act--
National Drinking Water Regulations
Resource Conservation and Recovery Act (RCRA)--
Land Disposal Restrictions
RCRA Standards for Owners & Operators of
Hazardous Waste Treatment, Storage, and Disposal
Facilities
Toxic Substances Control Act--
Polychlorinated Biphenyls (PCBs) Manufacturing,
Processing, Distribution in Commerce, and Use
Prohibition
Protection of Wetlands
Floodplain Management
Endangered Species Act
Fish and Wildlife Coordination Act
National Historic Preservation Act
Department of Transportation Regulations
STATE ARARs
New Jersey Safe Drinking Water Act
New Jersey Water Pollution Control Regulations--
Ground Water Standards
New Jersey Water Pollution Control Regulations--
Surface Water Quality Standards
New Jersey Air Pollution Control Regulations
Flood Hazard Area Control Act
Flood Hazard Area Regulations
New Jersey Requirements for Ground Water
Monitoring
New Jersey Pollution Discharge Elimination System
New Jersey Fresh Water Wetlands Protection Act
New Jersey Hazardous Waste Regulations
Endangered and Non-Game Species Act
CITATION
40 CFR Part 141
40 CFR 268, Subpart D
40 CFR Part 264
40 CFR Part 761
Executive Order 11990
Executive Order 11988
16 USC 1531 et seq.
16 USC 661 et seq.
16 USC 470 et seo;.
49 CFR 178 et seq.
CITATION
NJAC 7:10 et sec;.
NJAC 7:9-6 et seq.
NJAC 7:9-4 et seq.
NJAC 7:27 et seq.
NJSA 58:16A-50 et seq.
NJAC 7:13 et seq.
NJAC 7:26-9 et seq.
NJAC 7:14A et seq.
NJSA 13:96-1 et seo;.
NJAC 7:26 et seo\
NJSA 23:2A-1 et seq.
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